UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C.  20549
FORM 10-Q
(Mark One)
xQUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the quarterly period ended Sept. 30, 2017
2019 or
¨TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
Commission File Number: 001-3280
Public Service Company of Colorado
001-0328084-0296600
(Commission File Number)(I.R.S. Employer Identification No.)
(Exact name of registrant as specified in its charter)
(Registrant, State of Incorporation or Organization, Address of Principal Executive Officers and Telephone Number)
Public Service Company of Colorado
Colorado
1800 Larimer, Suite 1100
DenverColorado80202
303571-7511
Securities registered pursuant to Section 12(b) of the Act:
Title of each class 84-0296600
(State or other jurisdiction of incorporation or organization)Trading Symbol (I.R.S. Employer Identification No.)Name of each exchange on which registered
N/A 
1800 Larimer, Suite 1100N/A 
Denver, Colorado80202
(Address of principal executive offices)(Zip Code)N/A
(303) 571-7511
(Registrant’s telephone number, including area code)

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. xYes¨ No

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 andof Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files). xYes¨ No

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting company or an emerging growth company.  See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.
Large accelerated filer¨
 
Accelerated filer¨
Non-accelerated filerSmaller reporting company
   
Non-accelerated filer x
Smaller reporting company ¨
(Do not check if smaller reporting company)
Emerging growth company¨
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ¨

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). ¨ Yes x No

Indicate the number of shares outstanding of each of the issuer’s classes of common stock, as of the latest practicable date.
Class Outstanding at Oct. 27, 201725, 2019
Common Stock, $0.01 par value 100 shares


Public Service Company of Colorado meets the conditions set forth in General Instruction H (1) H(1)(a) and (b) of Form 10-Q and is therefore filing this Form 10-Q with the reduced disclosure format specified in General Instruction H (2)H(2) to such Form 10-Q.

     





TABLE OF CONTENTS

PART I — FINANCIAL INFORMATION
 
Item l —
Item 2 —
Item 4 —
   
PART II — OTHER INFORMATION
 
Item 1 —
Item 1A —
Item 6 —
   

  
Certifications Pursuant to Section 3021
Certifications Pursuant to Section 9061
Statement Pursuant to Private Litigation1

This Form 10-Q is filed by Public Service Company of Colorado a Colorado corporation (PSCo). PSCo is a wholly owned subsidiary of Xcel Energy Inc. Xcel Energy Inc. wholly owns the following subsidiaries: Northern States Power Company, a Minnesota corporation (NSP-Minnesota); Northern States Power Company, a Wisconsin corporation (NSP-Wisconsin); PSCo; and Southwestern Public Service Company, a New Mexico corporation (SPS). NSP-Minnesota, NSP-Wisconsin, PSCo and SPS are also referred to collectively as utility subsidiaries. Additional information on Xcel Energy Inc. and its subsidiaries (collectively, Xcel Energy) is available onin various filings with the SEC. This report should be read in its entirety.



ABBREVIATIONS AND INDUSTRY TERMS
Xcel Energy Inc.’s Subsidiaries and Affiliates (current and former)
NSP-MinnesotaNorthern States Power Company, a Minnesota corporation
NSP-WisconsinNorthern States Power Company, a Wisconsin corporation
PSCoPublic Service Company of Colorado
SPSSouthwestern Public Service Company
Utility subsidiariesNSP-Minnesota, NSP-Wisconsin, PSCo and SPS
WYCOWYCO Development, LLC
Xcel EnergyXcel Energy Inc. and subsidiaries
Federal and State Regulatory Agencies
CECColorado Energy Consumers
CPUCColorado Public Utilities Commission
EPAUnited States Environmental Protection Agency
FEAFederal Executive Agencies
FERCFederal Energy Regulatory Commission
IRSInternal Revenue Service
OCCOffice of Consumer Counsel
SECSecurities and Exchange Commission
Electric, Purchased Gas and Resource Adjustment Clauses
DSMDemand side management
Other
ACEAffordable Clean Energy
AFUDCAllowance for funds used during construction
ASCFASB Accounting Standards Codification
ASUFASB Accounting Standards Update
C&ICommercial and Industrial
CCRCoal combustion residual
CCR RuleFinal rule (40 CFR 257.50 - 257.107) published by the EPA regulating the management, storage and disposal of CCRs as a nonhazardous waste
CEOChief executive officer
CFOChief financial officer
CIGColorado Interstate Gas Company, LLC
DRCDevelopment Recovery Company
ETREffective tax rate
FASBFinancial Accounting Standards Board
GAAPGenerally accepted accounting principles
IPPIndependent power producing entity
MDLMulti district litigation
MGPManufactured gas plant
NOLNet operating loss
O&MOperating and maintenance
PPAPower purchase agreement
PTCProduction tax credit
ROEReturn on equity
ROURight-of-use
Measurements
MWMegawatts
Forward-Looking Statements
Except for the historical statements contained in this report, the matters discussed herein are forward-looking statements that are subject to certain risks, uncertainties and Exchange Commission (SEC).assumptions. Such forward-looking statements, assumptions and other statements are intended to be identified in this document by the words “anticipate,” “believe,” “could,” “estimate,” “expect,” “intend,” “may,” “objective,” “outlook,” “plan,” “project,” “possible,” “potential,” “should,” “will,” “would” and similar expressions. Actual results may vary materially. Forward-looking statements speak only as of the date they are made, and we expressly disclaim any obligation to update any forward-looking information. The following factors, in addition to those discussed elsewhere in this Quarterly Report on Form 10-Q and in other securities filings (including PSCo’s Annual Report on Form 10-K for the fiscal year ended Dec. 31, 2018 and subsequent securities filings), could cause actual results to differ materially from management expectations as suggested by such forward-looking information: changes in environmental laws and regulations; climate change and other weather natural disaster and resource depletion, including compliance with any accompanying legislative and regulatory changes; ability to recover costs from customers; reductions in our credit ratings and the cost of maintaining certain contractual relationships; general economic conditions, including inflation rates, monetary fluctuations and their impact on capital expenditures and the ability of PSCo and its subsidiaries to obtain financing on favorable terms; availability or cost of capital; our customers’ and counterparties’ ability to pay their debts to us; assumptions and costs relating to funding our employee benefit plans and health care benefits; tax laws; operational safety; successful long-term operational planning; commodity risks associated with energy markets and production; rising energy prices; costs of potential regulatory penalties; effects of geopolitical events, including war and acts of terrorism; cyber security threats and data security breaches; fuel costs; and employee work force and third party contractor factors.


PART I — FINANCIAL INFORMATION

Item 1FINANCIAL STATEMENTS

PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF INCOME (UNAUDITED)
(amounts in thousands)millions)
Three Months Ended Sept. 30 Nine Months Ended Sept. 30Three Months Ended Sept. 30 Nine Months Ended Sept. 30
2017 2016 2017 20162019 2018 2019 2018
Operating revenues              
Electric$877,604
 $897,516
 $2,318,912
 $2,337,547
$880.7
 $894.8
 $2,314.8
 $2,309.3
Natural gas142,389
 152,763
 691,302
 659,738
153.9
 157.2
 830.7
 707.8
Steam and other10,300
 8,898
 31,529
 29,585
9.7
 8.7
 31.8
 28.7
Total operating revenues1,030,293
 1,059,177
 3,041,743
 3,026,870
1,044.3
 1,060.7
 3,177.3
 3,045.8
              
Operating expenses 
  
     
  
    
Electric fuel and purchased power288,997
 318,624
 857,346
 890,509
284.7
 288.6
 829.5
 841.7
Cost of natural gas sold and transported37,243
 42,379
 303,903
 270,182
34.3
 32.3
 376.7
 282.1
Cost of sales — steam and other4,098
 3,664
 11,991
 10,874
3.5
 3.3
 11.9
 10.9
Operating and maintenance expenses173,905
 191,011
 547,413
 570,343
198.4
 201.4
 597.9
 573.5
Demand side management expenses34,520
 31,015
 92,552
 88,094
36.6
 39.4
 100.9
 105.3
Depreciation and amortization118,289
 111,803
 350,796
 330,593
153.5
 168.0
 448.6
 406.1
Taxes (other than income taxes)47,213
 45,076
 146,481
 146,851
49.0
 50.8
 154.8
 153.2
Total operating expenses704,265
 743,572
 2,310,482
 2,307,446
760.0
 783.8
 2,520.3
 2,372.8
              
Operating income326,028
 315,605
 731,261
 719,424
284.3
 276.9
 657.0
 673.0
              
Other income, net1,536
 544
 7,085
 1,837
1.4
 1.3
 1.9
 2.4
Allowance for funds used during construction — equity8,642
 5,343
 19,591
 13,714
3.8
 16.4
 12.9
 40.9
              
Interest charges and financing costs 
  
     
  
    
Interest charges — includes other financing costs of $1,605, $1,271, $4,669 and
$4,735, respectively
49,097
 46,664
 141,403
 138,982
Interest charges — includes other financing costs of $1.6, $1.7, $4.9 and $4.9, respectively59.2
 53.2
 176.3
 154.3
Allowance for funds used during construction — debt(3,266) (1,995) (7,610) (5,222)(2.2) (6.4) (7.0) (16.1)
Total interest charges and financing costs45,831
 44,669
 133,793
 133,760
57.0
 46.8
 169.3
 138.2
              
Income before income taxes290,375
 276,823
 624,144
 601,215
232.5
 247.8
 502.5
 578.1
Income taxes104,298
 103,216
 225,934
 224,390
28.0
 40.7
 57.7
 115.0
Net income$186,077
 $173,607
 $398,210
 $376,825
$204.5
 $207.1
 $444.8
 $463.1
 
See Notes to Consolidated Financial Statements

PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (UNAUDITED)
(amounts in thousands)millions)
 Three Months Ended Sept. 30 Nine Months Ended Sept. 30 Three Months Ended Sept. 30 Nine Months Ended Sept. 30
 2017 2016 2017 2016 2019 2018 2019 2018
Net income $186,077
 $173,607
 $398,210
 $376,825
 $204.5
 $207.1
 $444.8
 $463.1
                
Other comprehensive income (loss)      
  
Other comprehensive income      
  
                
Pension and retiree medical benefits:                
Amortization of losses (gains) included in net periodic benefit cost,
net of tax of $1, $0, $3 and $(134), respectively
 1
 
 3
 (217)
Net pension and retiree medical losses arising during the period, net of tax of $0, $(0.1), $0 and $(0.1), respectively 
 (0.2) 
 (0.2)
Amortization of losses included in net periodic benefit cost, net of tax of $0, $0.1, $0 and $0.1, respectively 
 0.2
 
 0.2
         
 
 
 
Derivative instruments:      
  
     ��
  
Net fair value increase, net of tax of $0, $(1), $0, and $1, respectively
 
 (1) 
 1
Reclassification of losses to net income, net of tax of $150, $162, $455, and $486, respectively 257
 266
 753
 792
Reclassification of losses to net income, net of tax of $0.1, $0.1, $0.3 and $0.3, respectively 0.3
 0.3
 0.9
 0.9
                
Other comprehensive income 258
 265
 756
 576
 0.3
 0.3
 0.9
 0.9
Comprehensive income $186,335
 $173,872
 $398,966
 $377,401
 $204.8
 $207.4
 $445.7
 $464.0


See Notes to Consolidated Financial Statements



PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS (UNAUDITED)
(amounts in thousands)millions)
Nine Months Ended Sept. 30Nine Months Ended Sept. 30
2017 20162019 2018
Operating activities      
Net income$398,210
 $376,825
$444.8
 $463.1
Adjustments to reconcile net income to cash provided by operating activities: 
  
 
  
Depreciation and amortization353,653
 332,383
452.2
 409.8
Demand side management program amortization672
 1,802
Deferred income taxes223,121
 202,599
24.1
 66.6
Amortization of investment tax credits(2,102) (2,104)(1.9) (2.1)
Allowance for equity funds used during construction(19,591) (13,714)(12.9) (40.9)
Net realized and unrealized hedging and derivative transactions907
 (1,801)64.5
 (9.9)
Other(11) (388)
Changes in operating assets and liabilities: 
  
 
  
Accounts receivable4,431
 27,080
13.1
 (0.7)
Accrued unbilled revenues74,918
 70,498
84.8
 60.1
Inventories(250) (11,712)(15.1) 13.6
Prepayments and other11,717
 52,526
(12.4) 12.6
Accounts payable(53,706) (20,164)(96.0) 25.3
Net regulatory assets and liabilities(28,594) (31,152)72.3
 (23.6)
Other current liabilities(40,789) (59,596)(66.3) (87.7)
Pension and other employee benefit obligations(16,691) (13,080)(44.4) (29.0)
Change in other noncurrent assets(1,149) (1,422)
Change in other noncurrent liabilities(1,916) (15,433)
Other, net(72.4) (19.8)
Net cash provided by operating activities902,830
 893,147
834.4
 837.4
      
Investing activities 
  
 
  
Utility capital/construction expenditures(995,680) (802,051)(1,098.6) (1,190.7)
Proceeds from insurance recoveries
 608
Allowance for equity funds used during construction19,591
 13,714
Investments in utility money pool arrangement(659,000) (437,000)(397.0) (578.0)
Repayments from utility money pool arrangement609,000
 437,000
397.0
 575.0
Other, net(657) (1,460)
Net cash used in investing activities(1,026,746) (789,189)(1,098.6) (1,193.7)
      
Financing activities 
  
 
  
Repayments of short-term borrowings, net(129,000) (14,000)(307.0) 
Borrowings under utility money pool arrangement40,000
 357,000
58.0
 526.0
Repayments under utility money pool arrangement(40,000) (306,000)(58.0) (526.0)
Proceeds from issuance of long-term debt393,795
 244,527
928.6
 691.4
Repayments of long-term debt
 (129,500)(400.0) (300.0)
Capital contributions from parent158,080
 1,571
632.7
 246.8
Dividends paid to parent(245,291) (253,796)(295.4) (271.9)
Other(110) 
Net cash provided by (used in) financing activities177,474
 (100,198)
Other, net
 (0.1)
Net cash provided by financing activities558.9
 366.2
      
Net change in cash and cash equivalents53,558
 3,760
294.7
 9.9
Cash and cash equivalents at beginning of period5,926
 3,585
33.4
 7.5
Cash and cash equivalents at end of period$59,484
 $7,345
$328.1
 $17.4
      
Supplemental disclosure of cash flow information: 
  
 
  
Cash paid for interest (net of amounts capitalized)$(145,461) $(149,786)$(173.4) $(145.3)
Cash (paid) received for income taxes, net(7,752) 32,388
Supplemental disclosure of non-cash investing transactions: 
  
Property, plant and equipment additions in accounts payable$133,933
 $84,417
Cash paid for income taxes, net(43.7) (86.4)
Supplemental disclosure of non-cash investing and financing transactions: 
  
Accrued property, plant and equipment additions$228.5
 $135.0
Inventory transfers to property, plant and equipment24.4
 29.8
Operating lease right-of-use assets653.8
 
Allowance for equity funds used during construction12.9
 40.9


See Notes to Consolidated Financial Statements

PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED BALANCE SHEETS (UNAUDITED)
(amounts in thousands,millions, except share and per share data)
Sept. 30, 2017 Dec. 31, 2016Sept. 30, 2019 Dec. 31, 2018
Assets      
Current assets      
Cash and cash equivalents$59,484
 $5,926
$328.1
 $33.4
Accounts receivable, net299,367
 304,900
294.2
 310.3
Accounts receivable from affiliates13,386
 9,421
13.6
 80.8
Investments in utility money pool arrangement50,000
 
Accrued unbilled revenues222,160
 297,078
228.8
 313.5
Inventories205,640
 202,220
188.1
 197.4
Regulatory assets81,021
 103,783
70.5
 120.6
Derivative instruments3,681
 10,934
10.0
 42.6
Prepayments and other24,193
 34,559
39.3
 23.8
Total current assets958,932
 968,821
1,172.6
 1,122.4
      
Property, plant and equipment, net13,550,488
 12,849,799
15,786.4
 15,120.0
      
Other assets 
  
 
  
Regulatory assets972,876
 958,429
1,063.3
 1,010.7
Derivative instruments861
 3,398
0.7
 1.2
Operating lease right-of-use assets594.4
 
Other27,636
 25,637
248.9
 37.2
Total other assets1,001,373
 987,464
1,907.3
 1,049.1
Total assets$15,510,793
 $14,806,084
$18,866.3
 $17,291.5
      
Liabilities and Equity 
  
 
  
Current liabilities 
  
 
  
Current portion of long-term debt$305,437
 $5,270
$
 $406.2
Short-term debt
 129,000

 307.0
Accounts payable399,402
 376,186
514.0
 503.4
Accounts payable to affiliates32,179
 98,797
44.5
 46.0
Regulatory liabilities61,224
 101,110
116.5
 67.3
Taxes accrued138,924
 171,862
159.7
 202.0
Accrued interest33,430
 48,619
36.0
 43.2
Dividends payable to parent88,588
 74,208
97.3
 91.5
Derivative instruments6,049
 6,788
11.7
 34.6
Other79,265
 73,022
179.5
 101.5
Total current liabilities1,144,498
 1,084,862
1,159.2
 1,802.7
      
Deferred credits and other liabilities 
  
 
  
Deferred income taxes3,122,909
 2,889,129
1,772.0
 1,719.3
Deferred investment tax credits28,559
 30,661
23.5
 25.3
Regulatory liabilities493,674
 512,933
2,022.3
 2,021.5
Asset retirement obligations298,740
 289,563
350.1
 338.7
Derivative instruments4,255
 7,828
54.8
 0.6
Customer advances159,012
 162,742
172.8
 168.1
Pension and employee benefit obligations269,156
 285,774
230.5
 275.3
Operating lease liabilities539.5
 
Other59,909
 62,201
152.0
 50.4
Total deferred credits and other liabilities4,436,214
 4,240,831
5,317.5
 4,599.2
      
Commitments and contingencies

 



 

Capitalization 
  
 
  
Long-term debt4,303,229
 4,210,936
5,384.0
 4,591.4
Common stock — 100 shares authorized at $0.01 par value; 100 shares
outstanding at Sept. 30, 2017 and Dec. 31, 2016, respectively

 
Common stock — 100 shares authorized at $0.01 par value; 100 shares
outstanding at Sept. 30, 2019 and Dec. 31, 2018, respectively

 
Additional paid in capital3,851,318
 3,633,216
4,903.3
 4,340.5
Retained earnings1,797,778
 1,659,239
2,126.9
 1,983.2
Accumulated other comprehensive loss(22,244) (23,000)(24.6) (25.5)
Total common stockholder’s equity5,626,852
 5,269,455
7,005.6
 6,298.2
Total liabilities and equity$15,510,793
 $14,806,084
$18,866.3
 $17,291.5


See Notes to Consolidated Financial Statements

PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF COMMON STOCKHOLDER’S EQUITY (UNAUDITED)
(amounts in millions, except share data)
 Common Stock Issued Retained Earnings Accumulated
Other
Comprehensive
Loss
 Total
Common
Stockholder’s
Equity
 Shares Par Value Additional Paid In Capital   
Three Months Ended Sept. 30, 2019 and 2018          
Balance at June 30, 2018100
 $
 $4,273.1
 $1,882.6
 $(26.1) $6,129.6
Net income      207.1
   207.1
Other comprehensive income        0.3
 0.3
Dividends declared to parent      (103.5)   (103.5)
Contribution of capital by parent    5.3
     5.3
Balance at Sept. 30, 2018100
 $
 $4,278.4
 $1,986.2
 $(25.8) $6,238.8
            
Balance at June 30, 2019100
 $
 $4,618.3
 $2,019.7
 $(24.9) $6,613.1
Net income      204.5
   204.5
Other comprehensive income        0.3
 0.3
Dividends declared to parent      (97.3)   (97.3)
Contribution of capital by parent    285.0
     285.0
Balance at Sept. 30, 2019100
 $
 $4,903.3
 $2,126.9
 $(24.6) $7,005.6
            
See Notes to Consolidated Financial Statements

PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF COMMON STOCKHOLDER’S EQUITY (UNAUDITED)
(amounts in millions, except share data)

 Common Stock Issued Retained Earnings Accumulated
Other
Comprehensive
Loss
 Total
Common
Stockholder’s
Equity
 Shares Par Value Additional Paid In Capital   
Nine Months Ended Sept. 30, 2019 and 2018          
Balance at Dec. 31, 2017100
 $
 $4,032.8
 $1,822.2
 $(26.7) $5,828.3
Net income      463.1
   463.1
Other comprehensive income        0.9
 0.9
Dividends declared to parent      (299.1)   (299.1)
Contribution of capital by parent    245.6
     245.6
Balance at Sept. 30, 2018100
 $
 $4,278.4
 $1,986.2
 $(25.8) $6,238.8
            
Balance at Dec. 31, 2018100
 $
 $4,340.5
 $1,983.2
 $(25.5) $6,298.2
Net income      444.8
   444.8
Other comprehensive income        0.9
 0.9
Dividends declared to parent      (301.1)   (301.1)
Contribution of capital by parent    562.8
     562.8
Balance at Sept. 30, 2019100
 $
 $4,903.3
 $2,126.9
 $(24.6) $7,005.6
            
See Notes to Consolidated Financial Statements


PUBLIC SERVICE CO. OF COLORADO AND SUBSIDIARIES
Notes to Consolidated Financial Statements (UNAUDITED)

In the opinion of management, the accompanying unaudited consolidated financial statements contain all adjustments necessary to present fairly, in accordance with accounting principles generally accepted in the United States of America (GAAP),U.S. GAAP, the financial position of PSCo and its subsidiaries as of Sept. 30, 20172019 and Dec. 31, 2016;2018; the results of its operations, including the components of net income and comprehensive income, and changes in stockholders’ equity for the three and nine months ended Sept. 30, 20172019 and 2016;2018; and its cash flows for the nine months ended Sept. 30, 20172019 and 2016.2018. All adjustments are of a normal, recurring nature, except as otherwise disclosed. Management has also evaluated the impact of events occurring after Sept. 30, 20172019 up to the date of issuance of these consolidated financial statements. These statements contain all necessary adjustments and disclosures resulting from that evaluation. The Dec. 31, 20162018 balance sheet information has been derived from the audited 20162018 consolidated financial statements included in the PSCo Annual Report on Form 10-K for the year ended Dec. 31, 2016.2018. These notes to the consolidated financial statements have been prepared pursuant to the rules and regulations of the SEC for Quarterly Reports on Form 10-Q. Certain information and note disclosures normally included in financial statements prepared in accordance with GAAP on an annual basis have been condensed or omitted pursuant to such rules and regulations. For further information, refer to the consolidated financial statements and notes thereto, included in the PSCo Annual Report on Form 10-K for the year ended Dec. 31, 2016,2018, filed with the SEC on Feb. 24, 2017.22, 2019. Due to the seasonality of PSCo’s electric and natural gas sales, interim results are not necessarily an appropriate base from which to project annual results.

1.Summary of Significant Accounting Policies

The significant accounting policies set forth in Note 1 to the consolidated financial statements in the PSCo Annual Report on Form 10-K for the year ended Dec. 31, 2016,2018, appropriately represent, in all material respects, the current status of accounting policies and are incorporated herein by reference.

2.Accounting Pronouncements

Recently Issued

Credit Losses In 2016, the FASB issued Financial Instruments - Credit Losses, Topic 326 (ASC Topic 326), which changes how entities account for losses on receivables and certain other assets. The guidance requires use of a current expected credit loss model, which may result in earlier recognition of credit losses than under previous accounting standards. ASC Topic 326 is effective for interim and annual periods beginning on or after Dec. 15, 2019, and will be applied on a modified-retrospective approach through a cumulative-effect adjustment to retained earnings as of Jan. 1, 2020. PSCo expects the impact of adoption of the new standard to include first-time recognition of expected credit losses (i.e., bad debt expense) on unbilled revenues, with the initial allowance established at Jan. 1, 2020 charged to retained earnings.
Revenue RecognitionRecently Adopted
Leases In May 2014,2016, the Financial Accounting Standards Board (FASB)FASB issued Revenue from Contracts with Customers, Leases, Topic 606 (Accounting Standards Update (ASU) No. 2014-09)842(ASC Topic 842), which provides new accounting and disclosure guidance for leasing activities, most significantly requiring that operating leases be recognized on the balance sheet. PSCo adopted the guidance on Jan. 1, 2019 utilizing the package of transition practical expedients provided by the new standard, including carrying forward prior conclusions on whether agreements existing before the adoption date contain leases and whether existing leases are operating or finance leases; ASC Topic 842 refers to capital leases as finance leases.
Specifically for land easement contracts, PSCo has elected the practical expedient provided by ASU No. 2018-01 Leases: Land Easement Practical Expedient for Transition to Topic 842, and as a new framework forresult, only those easement contracts entered on or after Jan. 1, 2019 will be evaluated to determine if lease treatment is appropriate.
PSCo also utilized the recognition of revenue. PSCo expects its adoption will primarily result in increased disclosures regarding revenue related to arrangements with customers, as well as separate presentation of alternative revenue programs. PSCo currently expectstransition practical expedient offered by ASU No. 2018-11 Leases: Targeted Improvements to implement the standard on a modified retrospective basis, which requires application to contracts with customers effective Jan. 1, 2018, with the cumulative impact on contracts not yet completed as of Dec. 31, 2017 recognized as an adjustment to the opening balance of retained earnings.

Classification and Measurement of Financial Instruments — In January 2016, the FASB issued Recognition and Measurement of Financial Assets and Financial Liabilities, Subtopic 825-10 (ASU No. 2016-01), which eliminates the available-for-sale classification for marketable equity securities and also replaces the cost method of accounting for non-marketable equity securities withprospective basis. As a model for recognizing impairments and observable price changes. Under the new standard, other than when the consolidation or equity method of accounting is utilized, changesresult, reporting periods in the fair value of equity securities are to be recognized in earnings. This guidance will be effective for interim and annual reporting periodsconsolidated financial statements beginning after Dec. 15, 2017. PSCo expects that the overall impacts of the Jan. 1, 2018 adoption will not be material.

Leases —In February 2016, the FASB issued Leases, Topic 842 (ASU No. 2016-02), which for lessees requires balance sheet recognition of right-of-use assets and lease liabilities for most leases. This guidance will be effective for interim and annual reporting periods beginning after Dec. 15, 2018. PSCo has not yet fully determined the impacts of implementation. However, adoption is expected to occur on Jan. 1, 2019 utilizingreflect the practical expedients provided by the standard. As such, agreements enteredimplementation of ASC Topic 842, while prior to Jan. 1, 2017 that are currently considered leases are expectedperiods continue to be recognizedreported in accordance with Leases, Topic 840 (ASC Topic 840). Other than first-time recognition of operating leases on theits consolidated balance sheet, including contracts for usethe implementation of office space, equipment and natural gas storage assets, as well as certain purchased power agreements (PPAs) for natural gas-fueled generating facilities. PSCo expects that similar agreements entered after Dec. 31, 2016 will generally qualify as leases under the new standard, but hasASC Topic 842 did not yet completed its evaluationhave a significant impact on PSCo’s consolidated financial statements. Adoption resulted in recognition of certain other contracts, including arrangements for the secondary use of assets, such as land easements.



Presentation of Net Periodic Benefit Cost —In March 2017, the FASB issued Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost, Topic 715 (ASU No. 2017-07), which establishes that only the service cost element of pension cost may be presented as a componentapproximately $0.7 billion of operating income in the income statement. Also under the guidance, only the service cost component of pension cost is eligible for capitalization. PSCo expects that as a result of application of accounting principles for rate regulated entities, a similar amount of pension cost, including non-service components, will be recognized consistent with the current ratemaking treatmentlease ROU assets and that the impacts of adoption will be limitedcurrent/noncurrent operating lease liabilities. See Note 9 to changes in classification of non-service costs in the consolidated statement of income. This guidance will be effectivefinancial statements for interim and annual reporting periods beginning after Dec. 15, 2017.

leasing disclosures.
3.Selected Balance Sheet Data
(Millions of Dollars) Sept. 30, 2019 Dec. 31, 2018
Accounts receivable, net    
Accounts receivable $315.1
 $330.8
Less allowance for bad debts (20.9) (20.5)
Accounts receivable, net $294.2
 $310.3
(Thousands of Dollars) Sept. 30, 2017 Dec. 31, 2016
Accounts receivable, net    
Accounts receivable $319,051
 $324,512
Less allowance for bad debts (19,684) (19,612)
  $299,367
 $304,900

(Millions of Dollars) Sept. 30, 2019 Dec. 31, 2018
Inventories    
Materials and supplies $61.8
 $61.9
Fuel 75.3
 69.5
Natural gas 51.0
 66.0
Total inventories $188.1
 $197.4
(Thousands of Dollars) Sept. 30, 2017 Dec. 31, 2016
Inventories    
Materials and supplies $69,051
 $66,161
Fuel 56,247
 66,429
Natural gas 80,342
 69,630
  $205,640
 $202,220

(Millions of Dollars) Sept. 30, 2019 Dec. 31, 2018
Property, plant and equipment, net    
Electric plant $14,070.5
 $13,604.5
Natural gas plant 4,526.5
 4,387.6
Common and other property 1,070.2
 1,023.7
Plant to be retired (a)
 275.5
 321.9
Construction work in progress 928.8
 573.3
Total property, plant and equipment 20,871.5
 19,911.0
Less accumulated depreciation (5,085.1) (4,791.0)
Property, plant and equipment, net $15,786.4
 $15,120.0
(Thousands of Dollars) Sept. 30, 2017 Dec. 31, 2016
Property, plant and equipment, net    
Electric plant $12,542,171
 $12,304,436
Natural gas plant 3,904,223
 3,710,772
Common and other property 943,117
 919,955
Plant to be retired (a)
 11,412
 31,839
Construction work in progress 874,399
 484,340
Total property, plant and equipment 18,275,322
 17,451,342
Less accumulated depreciation (4,724,834) (4,601,543)
  $13,550,488
 $12,849,799


(a) 
In 2018, the third quarterCPUC approved early retirement of 2017, PSCo early retired Valmont Unit 5PSCo’s Comanche Units 1 and converted Cherokee Unit 4 from a coal-fueled generating facility to natural gas.2 in approximately 2022 and 2025, respectively. PSCo also expects Craig Unit 1 to be retired early retired in approximately 2025. Amounts are presented net of accumulated depreciation.

4.Income Taxes

Except to the extent noted below, Note 7 to the consolidated financial statements included in PSCo’s Annual Report on Form 10-K for the year ended Dec. 31, 2016 appropriately represents, in all material respects, the current status of other income tax matters, and are incorporated herein by reference.

Federal Audits PSCo is a member of the Xcel Energy affiliated group that files a consolidated federal income tax return. The statute of limitations applicable to Xcel Energy’s 2009 through 2011 and 2012 through 2013 federal income tax returns, following extensions, expires in June 2018 and October 2018, respectively.

In 2012, the Internal Revenue Service (IRS) commenced an examination of tax years 2010 and 2011, including a 2009 carryback claim. The IRS proposed an adjustment to the federal tax loss carryback claims that would result in $14 million of income tax expense for the 2009 through 2011 claims, and the 2013 through 2015 claims. In the fourth quarter of 2015, the IRS forwarded the issue to the Office of Appeals (Appeals). In the third quarter of 2017, Xcel Energy and Appeals reached an agreement and the benefit related to the agreed upon portions was recognized. PSCo did not accrue any income tax benefit related to this adjustment.


In the third quarter of 2015, the IRS commenced an examination of tax years 2012 and 2013. In the third quarter of 2017, the IRS concluded the audit of tax years 2012 and 2013 and proposed an adjustment that would impact Xcel Energy’s net operating loss (NOL) and effective tax rate (ETR). After evaluating the proposed adjustment Xcel Energy filed a protest with the IRS. Xcel Energy anticipates the issue will be forwarded to Appeals. As of Sept. 30, 2017, Xcel Energy has recognized its best estimate of income tax expense that will result from a final resolution of this issue; however, the outcome and timing of a resolution is unknown.

State Audits — PSCo is a member of the Xcel Energy affiliated group that files consolidated state income tax returns. As of Sept. 30, 2017, PSCo’s earliest open tax year that is subject to examination by state taxing authorities under applicable statutes of limitations is 2009. There are currently no state income tax audits in progress.

Unrecognized Benefits The unrecognized tax benefit balance includes permanent tax positions, which if recognized would affect the annual ETR. In addition, the unrecognized tax benefit balance includes temporary tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility. A change in the period of deductibility would not affect the ETR but would accelerate the payment of cash to the taxing authority to an earlier period.

A reconciliation of the amount of unrecognized tax benefit is as follows:
(Millions of Dollars) Sept. 30, 2017 Dec. 31, 2016
Unrecognized tax benefit — Permanent tax positions $3.7
 $2.9
Unrecognized tax benefit — Temporary tax positions 6.2
 16.8
Total unrecognized tax benefit $9.9
 $19.7

The unrecognized tax benefit amounts were reduced by the tax benefits associated with NOL and tax credit carryforwards. The amounts of tax benefits associated with NOL and tax credit carryforwards are as follows:
(Millions of Dollars) Sept. 30, 2017 Dec. 31, 2016
NOL and tax credit carryforwards $(3.9) $(5.8)

It is reasonably possible that PSCo’s amount of unrecognized tax benefits could significantly change in the next 12 months as the IRS Appeals progresses and the IRS and state audits resume. As the IRS Appeals progresses, it is reasonably possible that the amount of unrecognized tax benefit could decrease up to approximately $3 million.

The payable for interest related to unrecognized tax benefits is partially offset by the interest benefit associated with NOL and tax credit carryforwards. A reconciliation of the beginning and ending amount of the payable for interest related to unrecognized tax benefits are as follows:

(Millions of Dollars) Sept. 30, 2017 Dec. 31, 2016
Payable for interest related to unrecognized tax benefits at beginning of period $(1.1) $(0.4)
Interest income (expense) related to unrecognized tax benefits recorded during the period 0.9
 (0.7)
Payable for interest related to unrecognized tax benefits at end of period $(0.2) $(1.1)

No amounts were accrued for penalties related to unrecognized tax benefits as of Sept. 30, 2017 or Dec. 31, 2016.

5.Rate Matters

Except to the extent noted below, the circumstances set forth in Note 11 to the consolidated financial statements included in PSCo’s Annual Report on Form 10-K for the year ended Dec. 31, 2016 and in Note 5 to PSCo’s Quarterly Report on Form 10-Q for the quarterly periods ended March 31, 2017 and June 30, 2017, appropriately represent, in all material respects, the current status of other rate matters, and are incorporated herein by reference.


Pending Regulatory Proceedings — Colorado Public Utilities Commission (CPUC)

Colorado 2017 Multi-Year Electric Rate Case — In October 2017, PSCo filed a multi-year request with the CPUC seeking to increase electric rates approximately $245 million over four years. The request, summarized below, is based on forecast test years (FTY) ending Dec. 31, a 10.0 percent return on equity (ROE) and an equity ratio of 55.25 percent.
Revenue Request (Millions of Dollars) 2018 2019 2020 2021 Total
Revenue request $74.6
 $74.9
 $59.7
 $35.7
 $244.9
Clean Air Clean Jobs Act (CACJA) revenue conversion to base rates (a)
 90.4
 
 
 
 90.4
Transmission Cost Adjustment (TCA) revenue conversion to base rates (a)
 42.7
 
 
 
 42.7
  Total (b)
 $207.7
 $74.9
 $59.7
 $35.7
 $378.0
           
Expected year-end rate base (billions of dollars) (b)
 $6.8
 $7.1
 $7.3
 $7.4
  
(a)
The roll-in of each of the TCA and CACJA rider revenues into base rates will not have an impact on total customer bills or total revenue as these costs are already being recovered through a rider. Transmission investments for 2019 through 2021 will be recovered through the TCA rider.

(b)
This base rate request does not include the impacts associated with the renewable energy standard adjustment and retail electric commodity adjustment for the Rush Creek wind investments or any impacts of the proposed Colorado Energy Plan.

Final rates are expected to be effective in June 2018. PSCo also proposed a stay-out provision and earnings test through 2021.

Colorado 2017 Multi-Year Natural Gas Rate Case — In June 2017, PSCo filed a multi-year request with the CPUC seeking to increase retail natural gas rates approximately $139 million over three years. The request, detailed below, is based on FTYs, a 10.0 percent ROE and an equity ratio of 55.25 percent.
Revenue Request (Millions of Dollars) 2018 2019 2020 Total
Revenue request $63.2
 $32.9
 $42.9
 $139.0
Pipeline System Integrity Adjustment (PSIA) revenue conversion to base rates (a)
 
 93.9
 
 93.9
Total $63.2
 $126.8
 $42.9
 $232.9
         
Expected year-end rate base (billions of dollars) (b)
 $1.5
 $2.3
 $2.4
  
(a)
The roll-in of PSIA rider revenue into base rates will not have an impact on customer bills or total revenue as these costs are already being recovered through the rider. PSCo plans to request new PSIA rates for 2018 in November 2017. The recovery of incremental PSIA related investments in 2019 and 2020 are included in the base rate request.

(b)
The additional rate base in 2019 predominantly reflects the roll-in of capital associated with the PSIA rider.

In October 2017, several parties filed answer testimony. The CPUC Staff (Staff) and the Office of Consumer Counsel (OCC), recommended a single 2016 historic test year (HTY), based on an average 13-month rate base, and opposed a multi-year plan (MYP). The Staff and OCC recommended an equity capital structure of 48.73 percent and 51.2 percent, respectively. Both the Staff and the OCC recommended the existing PSIA rider expire with the 2018 rates rolled into base rates beginning Jan. 1, 2019. Planned investments in 2019 and 2020 would be recoverable through base rates, subject to a future rate case.

The following represents adjustments to PSCo’s filed request made by Staff and OCC for 2018:
(Millions of Dollars) Staff OCC
Filed 2018 new revenue request $63.2
 $63.2
Impact of the change in test year 4.4
 4.4
PSCo’s filed 2016 HTY $67.6
 $67.6
     
Recommended adjustments:    
ROE (9.0 percent) (13.5) (13.5)
Capital structure and cost of debt (10.2) (7.5)
Change in amortization period (5.4) 
Prepaid pension and retiree medical assets (5.2) 
Change from 2016 year end to average rate base (4.8) (4.8)
Other, net (5.0) (5.5)
Total adjustments $(44.1) $(31.3)
     
Total recommended rate increase $23.5
 $36.3

The next steps in the procedural schedule are as follows:

Rebuttal testimony — Nov. 3, 2017;
Intervenor sur-rebuttal testimony — Nov. 15, 2017;
Hearings — Dec. 11 - 15 and 18 - 19, 2017; and
Statements of position — Jan. 19, 2018.

Interim rates, subject to refund, are expected to be effective Jan. 1, 2018. A final decision by the CPUC is anticipated in March 2018.

Annual Electric Earnings Test — PSCo must share with customers earnings that exceed the authorized ROE of 9.83 percent for 2015 through 2017, as part of an annual earnings test. The current estimate of the 2017 earnings test, based on annual forecasted information, did not result in the recognition of a liability as of Sept. 30, 2017.

6.Commitments and Contingencies

Except to the extent noted below and in Note 5 above, the circumstances set forth in Notes 11 and 12 to the consolidated financial statements included in PSCo’s Annual Report on Form 10-K for the year ended Dec. 31, 2016 and in Notes 5 and 6 to the
consolidated financial statements included in PSCo’s Quarterly Report on Form 10-Q for the quarterly periods ended March
31, 2017 and June 30, 2017, appropriately represent, in all material respects, the current status of commitments and contingent liabilities and are incorporated herein by reference. The following include commitments, contingencies and unresolved contingencies that are material to PSCo’s financial position.

PPAs

Under certain PPAs, PSCo purchases power from independent power producing entities that own natural gas fueled power plants for which PSCo is required to reimburse natural gas fuel costs, or to participate in tolling arrangements under which PSCo procures the natural gas required to produce the energy that it purchases. These specific PPAs create a variable interest in the associated independent power producing entity.

PSCo had approximately 1,571 megawatts (MW) of capacity under long-term PPAs as of Sept. 30, 2017 and Dec. 31, 2016, with entities that have been determined to be variable interest entities. PSCo has concluded that these entities are not required to be consolidated in its consolidated financial statements because it does not have the power to direct the activities that most significantly impact the entities’ economic performance. These agreements have expiration dates through 2032.


Environmental Contingencies

Manufactured Gas Plant (MGP) Sites — PSCo is currently involved in investigating and/or remediating MGP sites. PSCo has identified three sites where former MGP disposal activities have or may have resulted in site contamination and are under current investigation and/or remediation. At some or all of these sites, there may be parties that have responsibility for some portion of any remediation. PSCo anticipates that the majority of the investigation or remediation at these sites will continue through at least 2018. PSCo had accrued $3.3 million and $1.7 million and for these sites as of Sept. 30, 2017 and Dec. 31, 2016, respectively. There may be insurance recovery and/or recovery from other potentially responsible parties to offset any costs incurred. PSCo anticipates that any significant amounts incurred will be recovered from customers.

Environmental Requirements

Water and Waste
Federal Clean Water Act (CWA) Waters of the United States Rule In 2015, the EPA and the U.S. Army Corps of Engineers (Corps) published a final rule that significantly expanded the types of water bodies regulated under the CWA and broadened the scope of waters subject to federal jurisdiction. In October 2015, the U.S. Court of Appeals for the Sixth Circuit issued a nationwide stay of the final rule and subsequently ruled that it, rather than the federal district courts, had jurisdiction over challenges to the rule.  In January 2017, the U.S. Supreme Court agreed to resolve the dispute as to which court should hear challenges to the rule. A ruling is expected in the first quarter of 2018.

In February 2017, President Trump issued an executive order requiring the EPA and the Corps to review and revise the final rule. On June 27, 2017, the agencies issued a proposed rule that rescinds the 2015 final rule and reinstates the prior 1986 definition of “Water of the U.S.” The agencies are also undertaking a rulemaking to develop a new definition of “Waters of the U.S.”

Federal CWA Effluent Limitations Guidelines (ELG) In 2015, the EPA issued a final ELG rule for power plants that use coal, natural gas, oil or nuclear materials as fuel and discharge treated effluent to surface waters as well as utility-owned landfills that receive coal combustion residuals. In September 2017, the EPA delayed the compliance date for flue gas desulfurization wastewater and bottom ash transport water until November 2020 while the agency conducts a rulemaking process to potentially revise the effluent limitations and pretreatment standards for these waste streams.

Air
Greenhouse Gas (GHG) Emission Standard for Existing Sources (Clean Power Plan or CPP) — In 2015, the EPA issued its final rule for existing power plants.  Among other things, the rule requires that state plans include enforceable measures to ensure emissions from existing power plants achieve the EPA’s state-specific interim (2022-2029) and final (2030 and thereafter) emission performance targets. 

The CPP was challenged by multiple parties in the D.C. Circuit Court.  In February 2016, the U.S. Supreme Court issued an order staying the final CPP rule. In September 2016, the D.C. Circuit Court heard oral arguments in the consolidated challenges to the CPP. The stay will remain in effect until the D.C. Circuit Court reaches its decision and the U.S. Supreme Court either declines to review the lower court’s decision or reaches a decision of its own.

In March 2017, President Trump signed an executive order requiring the EPA Administrator to review the CPP rule and if appropriate, publish proposed rules suspending, revising or rescinding it. Accordingly, the EPA has requested that the D.C. Circuit Court hold the litigation in abeyance until the EPA completes its work under the executive order. The D.C. Circuit granted the EPA’s request and is holding the litigation in abeyance while considering briefs by the parties on whether the court should remand the challenges to the EPA rather than holding them in abeyance, determining whether and how the court continues or ends the stay that currently applies to the CPP.

In October 2017, the EPA published a proposed rule to repeal the CPP, based on an analysis that the CPP exceeds the EPA’s statutory authority under the Clean Air Act (CAA). The EPA will take public comment on the proposal for 60 days. The EPA stated it has not yet determined whether it will promulgate a new rule to regulate GHG emissions from existing electric generating units.


Revisions to the National Ambient Air Quality Standard (NAAQS) for Ozone — In 2015, the EPA revised the NAAQS for ozone by lowering the eight-hour standard from 75 parts per billion (ppb) to 70 ppb. The Denver Metropolitan Area is currently not meeting the prior ozone standard and will therefore not meet the new, more stringent standard, however PSCo’s scheduled retirement of coal fired plants in Denver that began in 2011 and was completed in August 2017, should help in any plan to mitigate non-attainment. In August 2017, the EPA withdrew its prior decision delaying designations of nonattainment areas under the 2015 ozone NAAQS to October 2018. The CAA requires areas to be designated within two years after a revision to the NAAQS but allows a one year extension if the EPA has insufficient information on which to base a decision. The EPA is now re-assessing to what extent it has sufficient information to make designations in October 2017 and whether in some cases an extension is still necessary.

Legal Contingencies

PSCo is involved in various litigation matters that are being defended and handled in the ordinary course of business. The assessment of whether a loss is probable or is a reasonable possibility, and whether the loss or a range of loss is estimable, often involves a series of complex judgments about future events. Management maintains accruals for such losses that are probable of being incurred and subject to reasonable estimation. Management is sometimes unable to estimate an amount or range of a reasonably possible loss in certain situations, including but not limited to when (1) the damages sought are indeterminate, (2) the proceedings are in the early stages, or (3) the matters involve novel or unsettled legal theories. In such cases, there is considerable uncertainty regarding the timing or ultimate resolution of such matters, including a possible eventual loss. For current proceedings not specifically reported herein, management does not anticipate that the ultimate liabilities, if any, arising from such current proceedings would have a material effect on PSCo’s financial statements. Unless otherwise required by GAAP, legal fees are expensed as incurred.

Employment, Tort and Commercial Litigation

Line Extension Disputes — In December 2015, Development Recovery Company (DRC) filed a lawsuit in Denver State Court, stating PSCo failed to award proper allowances and refunds for line extensions to new developments pursuant to the terms of electric and gas service agreements entered into by PSCo and various developers. The dispute involves claims by over fifty developers. In May 2016, the district court granted PSCo’s motion to dismiss the lawsuit, concluding that jurisdiction over this dispute resides with the CPUC. In June 2016, DRC appealed the district court’s dismissal of the lawsuit, and the Colorado Court of Appeals affirmed the lower court decision in favor of PSCo. In July 2017, DRC filed a petition to appeal the decision with the Colorado Supreme Court. It is uncertain whether the Colorado Supreme Court will grant the petition. DRC also brought a proceeding before the CPUC as assignee on behalf of two developers, Ryland Homes and Richmond Homes of Colorado.  In March 2016, the administrative law judge (ALJ) issued an order rejecting DRC’s claims for additional allowances and refunds.  In June 2016, the ALJ’s determination was approved by the CPUC.  DRC did not file a request for reconsideration before the CPUC contesting the decision, but filed an appeal in the Denver District Court in August 2016.  In July 2017, a stipulation to dismiss this lawsuit with prejudice was filed on behalf of all parties and granted by the Denver District Court.
PSCo has concluded that a loss is remote with respect to this matter as the service agreements were developed to implement CPUC approved tariffs and PSCo has complied with the tariff provisions. Also, if a loss were sustained, PSCo believes it would be allowed to recover these costs through traditional regulatory mechanisms. The amount or range in dispute is presently unknown and no accrual has been recorded for this matter.

7.Borrowings and Other Financing Instruments

Short-Term Borrowings

PSCo meets its short-term liquidity requirements primarily through the issuance of commercial paper and borrowings under its credit facility and the money pool.
Money Pool — Xcel Energy Inc. and its utility subsidiaries have established a money pool arrangement that allows for short-term investments in and borrowings between the utility subsidiaries. Xcel Energy Inc. may make investments in the utility subsidiaries at market-based interest rates; however, the money pool arrangement does not allow the utility subsidiaries to make investments in Xcel Energy Inc. Money pool borrowings for PSCo were as follows:
(Amounts in Millions, Except Interest Rates) Three Months Ended Sept. 30, 2019 Year Ended Dec. 31, 2018
Borrowing limit $250
 $250
Amount outstanding at period end 
 
Average amount outstanding 23
 25
Maximum amount outstanding 50
 156
Weighted average interest rate, computed on a daily basis 2.29% 1.93%
Weighted average interest rate at period end N/A
 N/A

(Amounts in Millions, Except Interest Rates) Three Months Ended Sept. 30, 2017 Year Ended Dec. 31, 2016
Borrowing limit $250
 $250
Amount outstanding at period end 
 
Average amount outstanding 
 21
Maximum amount outstanding 
 141
Weighted average interest rate, computed on a daily basis N/A
 0.73%
Weighted average interest rate at period end N/A
 N/A

Commercial Paper PSCo meets its short-term liquidity requirements primarily through the issuance of commercial paper and borrowings under its credit facility and the money pool. Commercial paper outstanding for PSCo was as follows:
(Amounts in Millions, Except Interest Rates) Three Months Ended Sept. 30, 2019 Year Ended Dec. 31, 2018
Borrowing limit $700
 $700
Amount outstanding at period end 
 307
Average amount outstanding 129
 55
Maximum amount outstanding 379
 309
Weighted average interest rate, computed on a daily basis 2.52% 2.28%
Weighted average interest rate at period end N/A
 2.95

(Amounts in Millions, Except Interest Rates) Three Months Ended Sept. 30, 2017 Year Ended Dec. 31, 2016
Borrowing limit $700
 $700
Amount outstanding at period end 
 129
Average amount outstanding 
 24
Maximum amount outstanding 
 154
Weighted average interest rate, computed on a daily basis N/A
 0.70%
Weighted average interest rate at period end N/A
 0.95

Letters of Credit PSCo uses letters of credit, generally with terms of one year, to provide financial guarantees for certain operating obligations. At Sept. 30, 2017 and Dec. 31, 2016, thereThere were $4$9 million and $3$10 million respectively of letters of credit outstanding under the credit facility.facility at Sept. 30, 2019 and Dec. 31, 2018, respectively. The contract amounts of these letters of credit approximate their fair value and are subject to fees.

Credit Facility — In order to use its commercial paper program to fulfill short-term funding needs, PSCo must have a revolving credit facility in place at least equal to the amount of its commercial paper borrowing limit and cannot issue commercial paper in an aggregate amount exceeding available capacity under this credit facility. The credit facility provides short-term financing in the form of notes payable to banks, letters of credit and back-up support for commercial paper borrowings.

Amended Credit Agreement In June 2019, PSCo entered into an amended five-year credit agreement with a syndicate of banks. The amended credit agreements have substantially the same terms and conditions as the prior credit agreements with the exception of the maturity, which was extended from June 2021 to June 2024.
PSCo has the right to request an extension of the revolving credit facility termination date for 2 additional one year periods. All extension requests are subject to majority bank group approval.

At Sept. 30, 2017,2019, PSCo had the following committed credit facility available (in millions of dollars):
Credit Facility (a)
Credit Facility (a)
 
Drawn (b)
 Available
Credit Facility (a)
 
Outstanding (b)
 Available
$700
 $4
 $696
700
 $9
 $691

(a)    This credit facility expires in June 2021.2024.
(b)    Includes outstanding commercial paper and letters of credit.

All credit facility bank borrowings, outstanding letters of credit and outstanding commercial paper reduce the available capacity under the credit facility. PSCo had no0 direct advances on the credit facility outstanding at Sept. 30, 20172019 and Dec. 31, 2016.2018.

Long-Term Borrowings

In June 2017,During the nine months ended Sept. 30, 2019, PSCo issued $400the following:
$400 million of 4.05% first mortgage bonds due Sept. 15, 2049.
$550 million of 3.20% first mortgage green bonds due March 1, 2050.
5.Revenues
Revenue is classified by the type of 3.80 percent first mortgage bonds due June 15, 2047.goods/services rendered and market/customer type. PSCo’s operating revenues consists of the following:
  Three Months Ended Sept. 30, 2019
(Millions of Dollars) Electric Natural Gas All Other Total
Major revenue types        
Revenue from contracts with customers:        
Residential $315.3
 $94.1
 $3.1
 $412.5
C&I 452.4
 32.9
 5.5
 490.8
Other 11.8
 
 
 11.8
Total retail 779.5
 127.0
 8.6
 915.1
Wholesale 40.3
 
 
 40.3
Transmission 16.4
 
 
 16.4
Other 8.3
 21.4
 
 29.7
Total revenue from contracts with customers 844.5
 148.4
 8.6
 1,001.5
Alternative revenue and other 36.2
 5.5
 1.1
 42.8
Total revenues $880.7
 $153.9
 $9.7
 $1,044.3
  Three Months Ended Sept. 30, 2018
(Millions of Dollars) Electric Natural Gas All Other Total
Major revenue types        
Revenue from contracts with customers:        
Residential $315.7
 $84.4
 $2.7
 $402.8
C&I 458.5
 29.1
 4.9
 492.5
Other 11.8
 
 
 11.8
Total retail 786.0
 113.5
 7.6
 907.1
Wholesale 41.2
 
 
 41.2
Transmission 16.3
 
 
 16.3
Other 10.6
 18.4
 
 29.0
Total revenue from contracts with customers 854.1
 131.9
 7.6
 993.6
Alternative revenue and other 40.7
 25.3
 1.1
 67.1
Total revenues $894.8
 $157.2
 $8.7
 $1,060.7

  Nine Months Ended Sept. 30, 2019
(Millions of Dollars) Electric Natural Gas All Other Total
Major revenue types        
Revenue from contracts with customers:        
Residential $771.9
 $535.6
 $8.4
 $1,315.9
C&I 1,204.7
 202.6
 20.0
 1,427.3
Other 36.1
 
 
 36.1
Total retail 2,012.7
 738.2
 28.4
 2,779.3
Wholesale 126.7
 
 
 126.7
Transmission 41.4
 
 
 41.4
Other 26.4
 76.3
 
 102.7
Total revenue from contracts with customers 2,207.2
 814.5
 28.4
 3,050.1
Alternative revenue and other 107.6
 16.2
 3.4
 127.2
Total revenues $2,314.8
 $830.7
 $31.8
 $3,177.3
  Nine Months Ended Sept. 30, 2018
(Millions of Dollars) Electric Natural Gas All Other Total
Major revenue types        
Revenue from contracts with customers:        
Residential $766.1
 $416.2
 $7.9
 $1,190.2
C&I 1,185.4
 154.0
 17.4
 1,356.8
Other 35.4
 
 0.1
 35.5
Total retail 1,986.9
 570.2
 25.4
 2,582.5
Wholesale 125.3
 
 
 125.3
Transmission 41.7
 
 
 41.7
Other 44.1
 62.1
 
 106.2
Total revenue from contracts with customers 2,198.0
 632.3
 25.4
 2,855.7
Alternative revenue and other 111.3
 75.5
 3.3
 190.1
Total revenues $2,309.3
 $707.8
 $28.7
 $3,045.8

8.6.Income Taxes
Note 8 to the consolidated financial statements included in PSCo’s Annual Report on Form 10-K for the year ended Dec. 31, 2018 represents, in all material respects, the current status of other income tax matters except to the extent noted below, and are incorporated herein by reference.
The following table reconciles the difference between the statutory rate and the ETR:
  Nine Months Ended Sept. 30
  2019 2018
Federal statutory rate 21.0 % 21.0 %
State tax (net of federal tax effect) 3.7
 3.7
Decreases in tax from: 
 
Wind PTCs (7.7) 
Plant regulatory differences (a)
 (3.6) (3.1)
Other tax credits and tax credit and NOL allowances (net) (1.3) (0.7)
Other (net) (0.6) (1.0)
Effective income tax rate 11.5 % 19.9 %

(a)
Regulatory differences for income tax primarily relate to the credit of excess deferred taxes to customers through the average rate assumption method and the timing of regulatory decisions regarding the return of excess deferred taxes. Income tax benefits associated with the credit of excess deferred credits are offset by corresponding revenue reductions and additional prepaid pension asset amortization.
Federal Audits PSCO is a member of the Xcel Energy affiliated group that files a consolidated federal income tax return. Statute of limitations applicable to Xcel Energy’s federal income tax returns expire as follows:
Tax Year(s)Expiration
2009 - 2013June 2020
2014 - 2016September 2020

In 2015, the IRS commenced an examination of tax years 2012 and 2013. In 2017, the IRS concluded the audit of tax years 2012 and 2013 and proposed an adjustment that would impact Xcel Energy’s NOL and ETR. Xcel Energy filed a protest with the IRS. As of Sept. 30, 2019, the case has been forwarded to Office of Appeals and Xcel Energy has recognized its best estimate of income tax expense that will result from a final resolution of this issue; however, the outcome and timing of a resolution is unknown.
In 2018, the IRS began an audit of tax years 2014 - 2016. As of Sept. 30, 2019 0 adjustments have been proposed.
State Audits — PSCo is a member of the Xcel Energy affiliated group that files consolidated state income tax returns. As of Sept. 30, 2019, PSCo’s earliest open tax year subject to examination by state taxing authorities under applicable statutes of limitations is 2009. There are currently no state income tax audits in progress.
Unrecognized Benefits — Unrecognized tax benefit balance includes permanent tax positions, which if recognized would affect the annual ETR. In addition, the unrecognized tax benefit balance includes temporary tax positions for which ultimate deductibility is highly certain, but for which there is uncertainty about the timing of such deductibility. A change in the period of deductibility would not affect the ETR but would accelerate the payment to the taxing authority to an earlier period.
Unrecognized tax benefits — permanent vs temporary:
(Millions of Dollars) Sept. 30, 2019 Dec. 31, 2018
Unrecognized tax benefit — Permanent tax positions $7.0
 $5.4
Unrecognized tax benefit — Temporary tax positions 4.7
 4.9
Total unrecognized tax benefit $11.7
 $10.3


Unrecognized tax benefits were reduced by tax benefits associated with NOL and tax credit carryforwards:
(Millions of Dollars) Sept. 30, 2019 Dec. 31, 2018
NOL and tax credit carryforwards $(8.3) $(5.6)

Net deferred tax liability associated with the unrecognized tax benefit amounts and related NOLs and tax credits carryforwards were $4.9 million and $2.0 million for Sept. 30, 2019 and Dec. 31, 2018, respectively.
As the IRS Appeals and federal audit progresses, it is reasonably possible that the amount of unrecognized tax benefit could decrease up to approximately $8.7 million in the next 12 months.
Payables for interest related to unrecognized tax benefits were not material and 0 amounts were accrued for penalties related to unrecognized tax benefits as of Sept. 30, 2019 or Dec. 31, 2018.
7.Fair Value of Financial Assets and Liabilities

Fair Value Measurements

The accounting guidance for fair value measurements and disclosures provides a single definition of fair value, hierarchical framework for measuring assets and liabilities and requires certain disclosuresdisclosure about assets and liabilities measured at fair value. A hierarchical framework for disclosing the observability of the inputs utilized in measuring assets and liabilities at fair value is established by this guidance. The three levels in the hierarchy are as follows:

Level 1 Quoted prices are available in active markets for identical assets or liabilities as of the reporting date. The types of assets and liabilities included in Level 1 are highly liquid and actively traded instruments with quoted prices.

Level 2 Pricing inputs are other than quoted prices in active markets, but are either directly or indirectly observable as of the reporting date. The types of assets and liabilities included in Level 2 are typically either comparable to actively traded securities or contracts, or priced with models using highly observable inputs.

Level 3 Significant inputs to pricing have little or no observability as of the reporting date. The types of assets and liabilities included in Level 3 are those valued with models requiring significant management judgment or estimation.


Specific valuation methods include the following:include:

Cash equivalents — The fair values of cash equivalents are generally based on cost plus accrued interest; money market funds are measured using quoted net asset value (NAV).value.

Interest rate derivatives— The fair values of interest rate derivatives are based on broker quotes that utilize current market interest rate forecasts.

Commodity derivatives— The methods used to measure the fair value of commodity derivative forwards and options generally utilize observable forward prices and volatilities, as well as observable pricing adjustments for specific delivery locations, and are generally assigned a Level 2 classification. When contractual settlements relate to delivery locations for which pricing is relatively unobservable, or extend to periods beyond those readily observable on active exchanges or quoted by brokers, the significance of the use of less observable forecasts of long-term forward prices and volatilitiesinputs on a valuation is evaluated, and may result in Level 3 classification.

Derivative Instruments Fair Value Measurements

PSCo enters into derivative instruments, including forward contracts, futures, swaps and options, for trading purposes and to manage risk in connection with changes in interest rates, utility commodity prices and vehicle fuel prices.

Interest Rate Derivatives PSCo enters into various instruments that effectively fix the interest payments on certain floating rate debt obligations or effectively fix the yield or price on a specified benchmark interest rate for an anticipated debt issuance for a specific period. These derivative instruments are generally designated as cash flow hedges for accounting purposes.

At Sept. 30, 2017,2019, accumulated other comprehensive lossesloss related to interest rate derivatives included $1.0$1.2 million of net losses expected to be reclassified into earnings during the next 12 months as the related hedged interest rate transactions impact earnings, including forecasted amounts for unsettled hedges, as applicable.

Wholesale and Commodity Trading Risk PSCo conducts various wholesale and commodity trading activities, including the purchase and sale of electric capacity, energy, energy-related instruments and natural gas relatedgas-related instruments, including derivatives. PSCo’s risk management policy allows managementPSCo is allowed to conduct these activities within guidelines and limitations as approved by its risk management committee, which is made upcomprised of management personnel not directly involved in the activities governed by this policy.

Commodity Derivatives PSCo enters into derivative instruments to manage variability of future cash flows from changes in commodity prices in its electric and natural gas operations, as well as for trading purposes. This could include the purchase or sale of energy or energy-related products, natural gas to generate electric energy, natural gas for resale, and vehicle fuel.

PSCo entersmay enter into derivative instruments that mitigate commodity price risk on behalf of electric and natural gas customers but may not be designated as qualifying hedging transactions. Changes in the fair value of non-trading commodity derivative instruments are recorded inas other comprehensive income or deferred as a regulatory asset or liability. The classification as a regulatory asset or liability is based on commission approved regulatory recovery mechanisms.
As of Sept. 30, 2019, PSCo recorded immaterial amounts to income related to the ineffectiveness ofhad 0 commodity contracts designated as cash flow hedges for the three and nine months ended Sept. 30, 2017 and 2016.hedges.

Additionally, PSCo also enters into commodity derivative instruments for trading purposes not directly related to commodity price risks associated with serving its electric and natural gas customers. Changes in the fair value of these commodity derivatives are recorded in electric operating revenues, net of amounts credited to customers under margin-sharing mechanisms.

The following table details the grossGross notional amounts of commodity forwards and options at Sept. 30, 2017 and Dec. 31, 2016:options:
(Amounts in Thousands) (a)(b)
 Sept. 30, 2017 Dec. 31, 2016
(Amounts in Millions) (a)(b)
 Sept. 30, 2019 Dec. 31, 2018
Megawatt hours of electricity 13,967
 6,283
 15.5
 24.4
Million British thermal units of natural gas 14,807
 42,203
 58.8
 48.4
(a) 
Amounts are not reflective of net positions in the underlying commodities.
(b) 
Notional amounts for options are included on a gross basis, but are weighted for the probability of exercise.


Consideration of Credit Risk and Concentrations — PSCo continuously monitors the creditworthiness of the counterparties to its interest rate derivatives and commodity derivative contracts prior to settlement, and assesses each counterparty’s ability to perform on the transactions set forth in the contracts. The following tables detail the impact of derivative activity duringcredit risk was immaterial to the three months ended Sept. 30, 2017fair value of unsettled commodity derivatives presented in the consolidated balance sheets. PSCo’s most significant concentrations of credit risk with particular entities or industries are contracts with counterparties to its wholesale, trading and 2016, on accumulated other comprehensive loss, regulatory assets and liabilities, and income:
non-trading commodity activities.
  Three Months Ended Sept. 30, 2017 
  
Pre-Tax Fair Value
Losses Recognized
During the Period in:
 
Pre-Tax Losses
Reclassified into Income
During the Period from:
   
(Thousands of Dollars) 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
(Assets) and
Liabilities
 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
Assets and
(Liabilities)
 
Pre-Tax Losses
Recognized
During the Period
in Income
 
Derivatives designated as cash flow hedges           
Interest rate $
 $
 $407
(a) 
$
 $
 
Total $
 $
 $407
 $
 $
 
Other derivative instruments           
Commodity trading $
 $
 $
 $
 $(211)
(c) 
Natural gas commodity 
 (1,635) 
 
 
 
Total $
 $(1,635) $
 $
 $(211) 
            
  Nine Months Ended Sept. 30, 2017 
  
Pre-Tax Fair Value
Losses Recognized
During the Period in:
 
Pre-Tax Losses
Reclassified into Income
During the Period from:
 
Pre-Tax Losses
Recognized
During the Period
in Income
 
(Thousands of Dollars) 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
(Assets) and
Liabilities
 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
Assets and
(Liabilities)
  
Derivatives designated as cash flow hedges           
Interest rate $
 $
 $1,208
(a) 
$
 $
 
Total $
 $
 $1,208
 $
 $
 
Other derivative instruments  
         
Commodity trading $
 $
 $
 $
 $(23)
(c) 
Natural gas commodity 
 (8,643) 
 282
(d) 
(2,990)
(d) 
Total $
 $(8,643) $
 $282
 $(3,013) 
            
            
  Three Months Ended Sept. 30, 2016 
  
Pre-Tax Fair Value
Losses Recognized
During the Period in:
 
Pre-Tax Losses
Reclassified into Income
During the Period from:
   
(Thousands of Dollars) 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
(Assets) and
Liabilities
 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
Assets and
(Liabilities)
 
Pre-Tax Gains
Recognized
During the Period
in Income
 
Derivatives designated as cash flow hedges           
Interest rate $
 $
 $407
(a) 
$
 $
 
Vehicle fuel and other commodity (2) 
 21
(b) 

 
 
Total $(2) $
 $428
 $
 $
 
Other derivative instruments           
Commodity trading $
 $
 $
 $
 $(28)
(c) 
Natural gas commodity 
 (4,848) 
 

(6)
(d) 
Total $
 $(4,848) $
 $
 $(34) 

At Sept. 30, 2019, 6 of PSCo’s 10 most significant counterparties for these activities, comprising $124.6 million or 74% of this credit exposure, had investment grade credit ratings from S&P Global Ratings, Moody’s Investor Services or Fitch Ratings. NaN of the 10 most significant counterparties, comprising $14.9 million or 9% of this credit exposure, were not rated by these external agencies, but based on PSCo’s internal analysis, had credit quality consistent with investment grade. NaN of these significant counterparties, comprising $8.0 million or 5% of this credit exposure, had credit quality less than investment grade, based on external analysis. NaN of these significant counterparties are independent system operators, municipal or cooperative electric entities, or other utilities.
Impact of derivative activity:
  Pre-Tax Fair Value Losses Recognized During the Period in:
(Millions of Dollars) Accumulated Other
Comprehensive Loss
 Regulatory (Assets) and Liabilities
Three Months Ended Sept. 30, 2019    
Other derivative instruments    
Natural gas commodity $
 $(2.2)
Total $
 $(2.2)
     
Nine Months Ended Sept. 30, 2019    
Other derivative instruments    
Natural gas commodity $
 $(3.7)
Total $
 $(3.7)
     
Three Months Ended Sept. 30, 2018    
Other derivative instruments    
Natural gas commodity $
 $(1.2)
Total $
 $(1.2)
     
Nine Months Ended Sept. 30, 2018    
Other derivative instruments    
Natural gas commodity $
 $(1.6)
Total $
 $(1.6)
            
  Nine Months Ended Sept. 30, 2016 
  
Pre-Tax Fair Value
Gains (Losses) Recognized
During the Period in:
 
Pre-Tax Losses
Reclassified into Income
During the Period from:
   
(Thousands of Dollars) 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
(Assets) and
Liabilities
 
Accumulated
Other
Comprehensive
Loss
 
Regulatory
Assets and
(Liabilities)
 
Pre-Tax Gains (Losses)
Recognized
During the Period
in Income
 
Derivatives designated as cash flow hedges           
Interest rate $
 $
 $1,211
(a) 
$
 $
 
Vehicle fuel and other commodity 2
 
 67
(b) 

 
 
Total $2
 $
 $1,278
 $
 $
 
Other derivative instruments           
Commodity trading $
 $
 $
 $
 $200
(c) 
Natural gas commodity 
 (1,172) 
 7,736
(d) 
(3,242)
(d) 
Total $
 $(1,172) $
 $7,736
 $(3,042) 

  Pre-Tax (Gains) Losses
Reclassified into Income
During the Period from:
 
Pre-Tax Gains
(Losses) Recognized
During the Period in Income
 
(Millions of Dollars) Accumulated
Other
Comprehensive Loss
 Regulatory
Assets and (Liabilities)
  
Three Months Ended Sept. 30, 2019       
Derivatives designated as cash flow hedges       
Interest rate $0.4
(a) 
$
 $
 
Total $0.4
 $
 $
 
Other derivative instruments       
Commodity trading $
 $
 $0.6
(b) 
Total $
 $
 $0.6
 
        
Nine Months Ended Sept. 30, 2019       
Derivatives designated as cash flow hedges       
Interest rate $1.2
(a) 
$
 $
 
Total $1.2
 $
 $
 
Other derivative instruments       
Commodity trading $
 $
 $5.3
(b) 
Natural gas commodity 
 (1.3)
(c) 
(2.1)
(c) 
Total $
 $(1.3) $3.2
 
        
Three Months Ended Sept. 30, 2018       
Derivatives designated as cash flow hedges       
Interest rate $0.4
(a) 
$
 $
 
Total $0.4
 $
 $
 
Other derivative instruments       
Commodity trading $
 $
 $2.0
(b) 
Total $
 $
 $2.0
 
        
Nine Months Ended Sept. 30, 2018       
Derivatives designated as cash flow hedges       
Interest rate $1.2
(a) 
$
 $
 
Total $1.2
 $
 $
 
Other derivative instruments       
Commodity trading $
 $
 $2.7
(b) 
Natural gas commodity 
 2.7
(c) 
(1.6)
(c) 
Total $
 $2.7
 $1.1
 

(a) 
RecordedAmounts are recorded to interest charges.
(b) 
Recorded to operating and maintenance (O&M) expenses.
(c)
Amounts are recorded to electric operating revenues. Portions of these gains and losses are subject to sharing with electric customers through margin-sharing mechanisms and deducted from gross revenue as appropriate.
(d)(c) 
CertainAmounts for both the three and nine months ended Sept. 30, 2019 included 0 settlement gain or losses on derivatives are utilizedentered to mitigate natural gas price risk for electric generation and are recorded to electric fuel and purchased power, subject to cost-recovery mechanisms and reclassified to a regulatory asset, as appropriate. Amounts for the three and nine months ended Sept. 30, 20172018 included no0 such settlement gains or losses and $0.9$1.2 million of such settlement gains,losses, respectively. AmountsRemaining derivative settlement losses for the three and nine months ended Sept. 30, 2016 included no settlement gains or losses. The remaining derivative settlement gains2019 and losses for the nine months ended Sept. 30, 2017 and 20162018 relate to natural gas operations and are recorded to cost of natural gas sold and transported. These gains and losses are subject to cost-recovery mechanisms and reclassified out of income to a regulatory asset or liability, as appropriate.

PSCo had no0 derivative instruments designated as fair value hedges during the three and nine months ended Sept. 30, 20172019 and 2016. Therefore, no gains or losses from fair value hedges or related hedged transactions were recognized for these periods.2018.

Consideration of Credit Risk and Concentrations — PSCo continuously monitors the creditworthiness of the counterparties to its interest rate derivatives and commodity derivative contracts prior to settlement, and assesses each counterparty’s ability to perform on the transactions set forth in the contracts. Given this assessment, as well as an assessment of the impact of PSCo’s own credit risk when determining the fair value of derivative liabilities, the impact of credit risk was immaterial to the fair value of unsettled commodity derivatives presented in the consolidated balance sheets.

PSCo employs additional credit risk control mechanisms when appropriate, such as letters of credit, parental guarantees, standardized master netting agreements and termination provisions that allow for offsetting of positive and negative exposures. Credit exposure is monitored and, when necessary, the activity with a specific counterparty is limited until credit enhancement is provided.

PSCo’s most significant concentrations of credit risk with particular entities or industries are contracts with counterparties to its wholesale, trading and non-trading commodity activities. At Sept. 30, 2017, five of PSCo’s 10 most significant counterparties for these activities, comprising $4.5 million or 10 percent of this credit exposure, had investment grade credit ratings from Standard & Poor’s, Moody’s or Fitch Ratings. Four of the 10 most significant counterparties, comprising $17.3 million or 39 percent of this credit exposure, were not rated by these external agencies, but based on PSCo’s internal analysis, had credit quality consistent with investment grade. The one remaining significant counterparty, comprising $8.1 million or 18 percent of this credit exposure, had credit quality less than investment grade, based on ratings from external analysis. Nine of these significant counterparties are municipal or cooperative electric entities, or other utilities.


Credit Related Contingent FeaturesContract provisions for derivative instruments that PSCo enters into, including those accounted for as normal purchase-normal sale contracts and therefore not reflected on the consolidated balance sheet,sheets, may require the posting of collateral or settlement of the contracts for various reasons, including if PSCo’s credit ratings are downgraded below its investment grade credit rating by any of the major credit rating agencies, or for cross-default contractual provisions that could result in the settlement of such contracts if there was a failure under other financing arrangements related to payment terms or other covenants. At Sept. 30, 20172019 and Dec. 31, 2016,2018, there were no0 derivative instruments in a material liability position with such underlying contract provisions.provisions, with 0 offsetting positions or posted collateral.

Certain derivative instruments are also subject to contract provisions that contain adequate assurance clauses. These provisions allow counterparties to seek performance assurance, including cash collateral, in the event that PSCo’s ability to fulfill its contractual obligations is reasonably expected to be impaired. PSCo had no0 collateral posted related to adequate assurance clauses in derivative contracts as of Sept. 30, 20172019 and Dec. 31, 2016.2018.

Recurring Fair Value MeasurementsThe following table presents, for each of the fair value hierarchy levels, PSCo’s assets and liabilities measured at fair value on a recurring basis at Sept. 30, 2017:basis:
  Sept. 30, 2019 Dec. 31, 2018
  Fair Value Fair Value
Total
 
Netting (a)
   Fair Value Fair Value
Total
 
Netting (a)
  
(Millions of Dollars) Level 1 Level 2 Level 3   Total Level 1 Level 2 Level 3   Total
Current derivative assets                        
Other derivative instruments:                        
Commodity trading $1.4
 $13.6
 $0.2
 $15.2
 $(10.0) $5.2
 $2.3
 $65.0
 $0.1
 $67.4
 $(28.2) $39.2
Natural gas commodity 
 4.8
 
 4.8
 
 4.8
 
 3.4
 
 3.4
 
 3.4
Total current derivative assets $1.4
 $18.4
 $0.2
 $20.0
 $(10.0) $10.0
 $2.3
 $68.4
 $0.1
 $70.8
 $(28.2) $42.6
Noncurrent derivative assets                        
Other derivative instruments:                        
Commodity trading $0.5
 $5.7
 $0.1
 $6.3
 $(5.6) $0.7
 $
 $1.6
 $
 $1.6
 $(0.4) $1.2
Total noncurrent derivative assets $0.5
 $5.7
 $0.1
 $6.3
 $(5.6) $0.7
 $
 $1.6
 $
 $1.6
 $(0.4) $1.2
 Sept. 30, 2017 Sept. 30, 2019 Dec. 31, 2018
 Fair Value 
Fair Value
Total
 
Counterparty
Netting (b)
   Fair Value Fair Value
Total
 
Netting (a)
   Fair Value Fair Value
Total
 
Netting (a)
  
(Thousands of Dollars) Level 1 Level 2 Level 3 Total
Current derivative assets            
Other derivative instruments:            
Commodity trading $116
 $3,238
 $5
 $3,359
 $(2,652) $707
Natural gas commodity 
 1,394
 
 1,394
 (135) 1,259
Total current derivative assets $116
 $4,632
 $5
 $4,753
 $(2,787) 1,966
PPAs (a)
           1,715
Current derivative instruments           $3,681
Noncurrent derivative assets            
Other derivative instruments:            
Commodity trading $
 $511
 $
 $511
 $(109) $402
Total noncurrent derivative assets $
 $511
 $
 $511
 $(109) 402
PPAs (a)
           459
Noncurrent derivative instruments           $861
(Millions of Dollars) Level 1 Level 2 Level 3 Fair Value
Total
 
Netting (a)
 Total Level 1 Level 2 Level 3 Fair Value
Total
 
Netting (a)
 Total
Current derivative liabilities                            
Other derivative instruments:                                    
Commodity trading $144
 $3,104
 $3
 $3,251
 $(3,188) $63
 $1.4
 $19.1
 $0.1
 $20.6
 $(13.3) $7.3
 $2.4
 $64.2
 $
 $66.6
 $(34.7) $31.9
Natural gas commodity 
 962
 
 962
 (135) 827
 
 4.4
 
 4.4
 
 4.4
 
 
 
 
 
 
Total current derivative liabilities $144
 $4,066
 $3
 $4,213
 $(3,323) 890
 $1.4
 $23.5
 $0.1
 $25.0
 $(13.3) 11.7
 $2.4
 $64.2
 $
 $66.6
 $(34.7) 31.9
PPAs (a)
           5,159
PPAs (b)
           
           2.7
Current derivative instruments           $6,049
           $11.7
           $34.6
Noncurrent derivative liabilities                                    
Other derivative instruments:                                    
Commodity trading $
 $406
 $
 $406
 $(109) $297
 $0.4
 $60.0
 $
 $60.4
 $(5.6) $54.8
 $
 $1.1
 $
 $1.1
 $(0.5) $0.6
Total noncurrent derivative liabilities $
 $406
 $
 $406
 $(109) 297
 $0.4
 $60.0
 $
 $60.4
 $(5.6) $54.8
 $
 $1.1
 $
 $1.1
 $(0.5) $0.6
PPAs (a)
           3,958
Noncurrent derivative instruments           $4,255
(a) 
During 2006, PSCo qualified these contracts under the normal purchase exception. Based onthis qualification, the contracts are no longer adjusted to fair value and the previous carrying value of these contracts will be amortized over the remaining contract lives along with the offsetting regulatory assets and liabilities.
(b)
PSCo nets derivative instruments and related collateral in its consolidated balance sheet when supported by a legally enforceable master netting agreement, and all derivative instruments and related collateral amounts were subject to master netting agreements at Sept. 30, 2017.2019 and Dec. 31, 2018. At both Sept. 30, 2017,2019 and Dec. 31, 2018, derivative assets and liabilities include no0 obligations to return cash collateralcollateral. At Sept. 30, 2019 and Dec. 31, 2018, derivative assets and liabilities include the rights to reclaim cash collateral of $0.5 million.$3.2 million and $6.5 million, respectively. The counterparty netting amounts presented exclude settlement receivables and payables and non-derivative amounts that may be subject to the same master netting agreements.


The following table presents, for each of the fair value hierarchy levels, PSCo’s assets and liabilities measured at fair value on a recurring basis at Dec. 31, 2016:
  Dec. 31, 2016
  Fair Value 
Fair Value
Total
 
Counterparty
Netting (b)
  
(Thousands of Dollars) Level 1 Level 2 Level 3   Total
Current derivative assets            
Other derivative instruments:            
Commodity trading $1,124
 $5,453
 $
 $6,577
 $(5,137) $1,440
Natural gas commodity 
 7,778
 
 7,778
 
 7,778
Total current derivative assets $1,124
 $13,231
 $
 $14,355
 $(5,137) 9,218
PPAs (a)
           1,716
Current derivative instruments           $10,934
Noncurrent derivative assets            
Other derivative instruments:    
    
  
  
Natural gas commodity $
 $1,652
 $
 $1,652
 $
 $1,652
Total noncurrent derivative assets $
 $1,652
 $
 $1,652
 $
 1,652
PPAs (a)
           1,746
Noncurrent derivative instruments           $3,398
Current derivative liabilities            
Other derivative instruments:            
Commodity trading $1,386
 $5,357
 $22
 $6,765
 $(5,137) $1,628
Total current derivative liabilities $1,386
 $5,357
 $22
 $6,765
 $(5,137) 1,628
PPAs (a)
           5,160
Current derivative instruments           $6,788
Noncurrent derivative liabilities            
PPAs (a)
           $7,828
Noncurrent derivative instruments           $7,828

(a)(b) 
During 2006, PSCo qualified these contracts under the normal purchase exception. Based onthis qualification, the contracts are no longer adjusted to fair value and the previous carrying value of these contracts will be amortized over the remaining contract lives along with the offsetting regulatory assets and liabilities.
(b)
PSCo nets derivative instruments and related collateral in its consolidated balance sheet when supported by a legally enforceable master netting agreement, and all derivative instruments and related collateral amounts were subject to master netting agreements at Dec. 31, 2016. At Dec. 31, 2016, derivative assets and liabilities include no obligations to return cash collateral or rights to reclaim cash collateral. The counterparty netting amounts presented exclude settlement receivables and payables and non-derivative amounts that may be subject to the same master netting agreements.

There were immaterial gains$0.5 million and $1.5 million of losses recognized in earnings for Level 3 commodity trading derivatives in the three and nine months ended Sept. 30, 20172019, respectively. There were immaterial gains and 2016.losses recognized in earnings for Level 3 commodity trading derivatives in both the three and nine months ended Sept. 30, 2018.

PSCo recognizes transfers between fair value hierarchy levels as of the beginning of each period. There were no0 transfers of amounts between levels for derivative instruments for the three and nine months ended Sept. 30, 20172019 and 2016.2018.

Fair Value of Long-Term Debt

As of Sept. 30, 2017 and Dec. 31, 2016, otherOther financial instruments for which the carrying amount did not equal fair value were as follows:value:
  Sept. 30, 2019 Dec. 31, 2018
(Millions of Dollars) 
Carrying
Amount
 Fair Value 
Carrying
Amount
 Fair Value
Long-term debt, including current portion $5,384.0
 $6,139.2
 $4,997.6
 $5,123.2

  Sept. 30, 2017 Dec. 31, 2016
(Thousands of Dollars) 
Carrying
Amount
 Fair Value 
Carrying
Amount
 Fair Value
Long-term debt, including current portion $4,608,666
 $4,958,850
 $4,216,206
 $4,491,570

The fairFair value of PSCo’s long-term debt is estimated based on recent trades and observable spreads from benchmark interest rates for similar securities. The fairFair value estimates are based on information available to management as of Sept. 30, 20172019 and Dec. 31, 2016,2018, and given the observability of the inputs, to these estimates, the fair values presented for long-term debt have beenwere assigned aas Level 2.

8.Benefit Plans and Other Postretirement Benefits
Components of Net Periodic Benefit Cost (Credit)

  Three Months Ended Sept. 30
  2019 2018 2019 2018
(Millions of Dollars) Pension Benefits Postretirement Health
Care Benefits
Service cost $6.4
 $7.3
 $0.1
 $0.2
Interest cost (a)
 12.9
 11.8
 3.9
 3.8
Expected return on plan assets (a)
 (17.1) (17.1) (4.7) (5.7)
Amortization of prior service credit (a)
 (0.8) (0.9) (1.3) (1.6)
Amortization of net loss (a)
 6.3
 7.8
 0.7
 1.0
Net periodic benefit cost (credit) 7.7
 8.9
 (1.3) (2.3)
Credits (costs) not recognized due to the effects of regulation 0.8
 (4.1) 0.4
 1.4
Net benefit cost (credit) recognized for financial reporting $8.5
 $4.8
 $(0.9) $(0.9)
  Nine Months Ended Sept. 30
  2019 2018 2019 2018
(Millions of Dollars) Pension Benefits Postretirement Health
Care Benefits
Service cost $19.2
 $21.8
 $0.4
 $0.5
Interest cost (a)
 38.7
 35.5
 11.7
 11.2
Expected return on plan assets (a)
 (51.4) (51.4) (14.2) (17.0)
Amortization of prior service credit (a)
 (2.5) (2.5) (4.1) (4.7)
Amortization of net loss (a)
 19.1
 23.4
 2.2
 3.1
Net periodic benefit cost (credit) 23.1
 26.8
 (4.0) (6.9)
Credits (costs) not recognized due to the effects of regulation 4.4
 (1.7) 0.9
 1.4
Net benefit cost (credit) recognized for financial reporting $27.5
 $25.1
 $(3.1) $(5.5)

(a)
The components of net periodic cost other than the service cost component are included in the line item “other income, net” in the consolidated statement of income or capitalized on the consolidated balance sheet as a regulatory asset.
In January 2019, contributions of $150.0 million were made across 4 of Xcel Energy’s pension plans, of which $43.0 million was attributable to PSCo. In July 2019, Xcel Energy made a $4.0 million contribution to the Xcel Energy Inc. Non-Bargaining Pension Plan (South), of which $2.7 million was attributable to PSCo. Xcel Energy does not expect additional pension contributions during 2019.
9.Other Income, NetCommitments and Contingencies

The following include commitments, contingencies and unresolved contingencies that are material to PSCo’s financial position.
Other income, net consisted
Legal
PSCo is involved in various litigation matters in the ordinary course of business. The assessment of whether a loss is probable or is a reasonable possibility, and whether the loss or a range of loss is estimable, often involves a series of complex judgments about future events. Management maintains accruals for losses probable of being incurred and subject to reasonable estimation.
Management is sometimes unable to estimate an amount or range of a reasonably possible loss in certain situations, including but not limited to, when (1) the damages sought are indeterminate, (2) the proceedings are in the early stages, or (3) the matters involve novel or unsettled legal theories. In such cases, there is considerable uncertainty regarding the timing or ultimate resolution of such matters, including a possible eventual loss. For current proceedings not specifically reported herein, management does not anticipate that the ultimate liabilities, if any, would have a material effect on PSCo’s financial statements. Unless otherwise required by GAAP, legal fees are expensed as incurred.
Gas Trading Litigation e prime is a wholly owned subsidiary of Xcel Energy. e prime was in the business of natural gas trading and marketing but has not engaged in natural gas trading or marketing activities since 2003.  Multiple lawsuits seeking monetary damages were commenced against e prime and its affiliates, including Xcel Energy, between 2003 and 2009 alleging fraud and anticompetitive activities in conspiring to restrain the trade of natural gas and manipulate natural gas prices. Cases were all consolidated in the U.S. District Court in Nevada.
NaN cases remain active which include an MDL matter consisting of a Colorado purported class (Breckenridge) and a Wisconsin purported class (Arandell Corp.).
Breckenridge/Colorado — In February 2019, the MDL panel remanded Breckenridge back to the U.S. District Court in Colorado.
Arandell Corp. — In February 2019, the case was remanded back to the U.S. District Court in Wisconsin.
Xcel Energy has concluded that a loss is remote for both remaining lawsuits.
Line Extension Disputes — In December 2015, the DRC filed a lawsuit seeking monetary damages in the Denver District Court, stating PSCo failed to award proper allowances and refunds for line extensions to new developments pursuant to the terms of electric and gas service agreements. The dispute involves claims by over 50 developers. In February 2018, the Colorado Supreme Court denied DRC’s petition to appeal the Denver District Court’s dismissal of the following:lawsuit, effectively terminating this litigation. However, in January 2018, DRC filed a new lawsuit in Boulder County District Court, asserting a single claim that PSCo was required to file its line extension agreements with the CPUC but failed to do so.
This claim is similar to the arguments previously raised by DRC. PSCo filed a motion to dismiss this claim, which was granted in May 2018. DRC subsequently filed an appeal to the Colorado Court of Appeals. It is uncertain when a decision will be rendered.
PSCo has concluded that a loss is remote with respect to both of these matters as the service agreements were developed to implement CPUC approved tariffs and PSCo has complied with the tariff provisions. If a loss were sustained, PSCo believes it would be allowed to recover costs through traditional regulatory mechanisms. Amount or range in dispute is presently unknown and 0 accrual has been recorded for this matter.

Environmental
MGP, Landfill or Disposal Sites — PSCo is cooperating with the City of Denver on an environmental investigation of the Rice Yards Site in Denver, Colorado, which had various historic industrial uses by multiple parties, including railroad, maintenance shop, scrap metal yard, and MGP operations.
The area is being redeveloped into residential and commercial mixed uses, and PSCo is in discussions with the current property owner regarding legal claims related to the Rice Yards Site.
In addition, PSCo is currently investigating or remediating 2 other MGP, landfill or other disposal sites across its service territories.
PSCo has recognized its best estimate of costs/liabilities that will result from final resolution of these issues, however, the outcome and timing is unknown.  In addition, there may be insurance recovery and/or recovery from other potentially responsible parties, offsetting a portion of the costs incurred.
Environmental Requirements — Water and Waste
Coal Ash RegulationPSCo’s operations are subject to federal and state laws that impose requirements for handling, storage, treatment and disposal of solid waste.
Under the CCR Rule, utilities are required to complete groundwater sampling around their CCR landfills and surface impoundments. By the end of 2019, only 6 of PSCo’s regulated ash units are expected to be in operation. PSCo is conducting groundwater sampling and where appropriate, initiating the assessment of corrective measures and evaluating whether corrective action is required at any CCR landfills or surface impoundments.
Until PSCo completes its assessment, it is uncertain what impact, if any, there will be on the operations, financial condition or cash flows.
Leases
PSCo evaluates contracts that may contain leases, including PPAs and arrangements for the use of office space and other facilities, vehicles and equipment. Under ASC Topic 842, adopted by PSCo on Jan. 1, 2019, a contract contains a lease if it conveys the exclusive right to control the use of a specific asset. A contract determined to contain a lease is evaluated further to determine if the arrangement is a finance lease.
ROU assets represent PSCo's rights to use leased assets. Starting in 2019, the present value of future operating lease payments is recognized in other current liabilities and noncurrent operating lease liabilities. These amounts, adjusted for any prepayments or incentives, are recognized as operating lease ROU assets.
Most of PSCo’s leases do not contain a readily determinable discount rate. Therefore, the present value of future lease payments is calculated using the estimated incremental borrowing rate (weighted-average of 4.1%). PSCo has elected to utilize the practical expedient under which non-lease components, such as asset maintenance costs included in payments, are not deducted from minimum lease payments for the purposes of lease accounting and disclosure.
Leases with an initial term of 12 months or less are classified as short-term leases and are not recognized on the consolidated balance sheet.
Operating lease ROU assets:
(Millions of Dollars) Sept. 30, 2019
PPAs $585.1
Other 68.7
Gross operating lease ROU assets 653.8
Accumulated amortization (59.4)
Net operating lease ROU assets $594.4

In 2019, ROU assets for finance leases are included in other noncurrent assets, and the present value of future finance lease payments is included in other current liabilities and other noncurrent liabilities. Prior to 2019, finance leases were included in property, plant and equipment, the current portion of long-term debt and long-term debt.
PSCo’s most significant finance lease activities are related to WYCO, a joint venture with CIG, to develop and lease natural gas pipeline, storage and compression facilities. Xcel Energy Inc. has a 50% ownership interest in WYCO. WYCO leases its facilities to CIG, and CIG operates the facilities, providing natural gas storage and transportation services to PSCo under separate service agreements.
PSCo accounts for its Totem natural gas storage service and Front Range pipeline arrangements with CIG and WYCO, respectively, as finance leases.
Finance lease ROU assets:
(Millions of Dollars) Sept. 30, 2019
Gas storage facilities $200.5
Gas pipeline 20.7
Gross finance lease ROU assets 221.2
Accumulated amortization (80.8)
Net finance lease ROU assets $140.4

Components of lease expense:
 Three Months Ended Sept. 30 Nine Months Ended Sept. 30
(Thousands of Dollars)2017 2016 2017 2016
Interest income$1,422
 $162
 $2,406
 $451
Other nonoperating income193
 511
 4,940
 1,594
Insurance policy expense(79) (129) (261) (205)
Other nonoperating expense
 
 
 (3)
Other income, net$1,536
 $544
 $7,085
 $1,837
(Millions of Dollars) Three Months Ended Sept. 30, 2019 Nine Months Ended Sept. 30, 2019
Operating leases    
PPA capacity payments $24.6
 $73.6
Other operating leases (a)
 4.3
 11.5
Total operating lease expense (b)
 $28.9
 $85.1
     
Finance leases    
Amortization of ROU assets $1.6
 $4.6
Interest expense on lease liability 4.7
 14.2
Total finance lease expense $6.3
 $18.8
(a)
Includes short-term lease expense of $0.3 million for the three months ended Sept. 30, 2019 and $1.0 million for the nine months ended Sept. 30, 2019.
(b)
PPA capacity payments are included in electric fuel and purchased power on the consolidated statements of income. Expense for other operating leases is included in O&M expense and electric fuel and purchased power.

Future commitments under operating and finance leases as of Sept. 30, 2019:
(Millions of Dollars) 
PPA (a) (b)
Operating
Leases
 
Other Operating
Leases
 
Total
Operating
Leases
 Finance Leases
2019 $23.9
 $3.3
 $27.2
 $6.2
2020 95.9
 13.2
 109.1
 24.8
2021 96.4
 12.6
 109.0
 23.6
2022 82.6
 11.6
 94.2
 20.5
2023 70.0
 10.9
 80.9
 20.3
Thereafter 288.6
 29.2
 317.8
 419.8
Total minimum obligation 657.4
 80.8
 738.2
 515.2
Interest component of obligation (100.6) (13.1) (113.7) (374.8)
Present value of minimum obligation $556.8
 $67.7
 624.5
 140.4
Less current portion     (85.0) (6.7)
Noncurrent operating and finance lease liabilities     $539.5
 $133.7
         
Weighted-average remaining lease term in years     8.1
 38.9
(a)
Amounts do not include PPAs accounted for as executory contracts and/or contingent payments, such as energy payments on renewable PPAs.
(b)
PPA operating leases contractually expire at various dates through 2032.
Future commitments under operating and finance leases as of Dec. 31, 2018:
(Millions of Dollars) 
PPA (a) (b)
Operating
Leases
 
Other Operating
Leases
 
Total
Operating
Leases
 Finance Leases
2019 $95.5
 $10.8
 $106.3
 $24.9
2020 95.9
 10.7
 106.6
 24.8
2021 96.4
 9.5
 105.9
 23.6
2022 82.6
 8.4
 91.0
 20.5
2023 70.0
 8.1
 78.1
 20.3
Thereafter 288.6
 53.4
 342.0
 420.4
Total minimum obligation 

 

 

 534.5
Interest component of obligation       (389.5)
Present value of minimum obligation     $145.0
(a)
Amounts do not include PPAs accounted for as executory contracts and/or contingent payments, such as energy payments on renewable PPAs.
(b)
PPA operating leases contractually expire at various dates through 2032.
Variable Interest Entities
Under certain PPAs, PSCo purchases power from IPPs and is required to reimburse the IPPs for fuel costs, or to participate in tolling arrangements under which PSCo procures the natural gas required to produce the energy that it purchases. These specific PPAs create a variable interest in the associated IPP.
PSCo had approximately 1,442 MW and 1,571 MW of capacity under long-term PPAs as of Sept. 30, 2019 and Dec. 31, 2018, respectively, with entities that have been determined to be VIEs. PSCo concluded that these entities are not required to be consolidated in its financial statements because it does not have the power to direct the activities that significantly impact the entities’ economic performance. These agreements have various expiration dates through 2032.
10.Other Comprehensive Income (Loss)
Changes in accumulated other comprehensive loss, net of tax, for the three and nine months ended Sept. 30, 2019 and 2018:
  Three Months Ended Sept. 30, 2019 Three Months Ended Sept. 30, 2018
(Millions of Dollars) 
Gains and Losses
on Cash Flow Hedges
 
Defined Benefit Pension and
Postretirement Items
 Total 
Gains and Losses
on Cash Flow Hedges
 
Defined Benefit Pension and
Postretirement Items
 Total
Accumulated other comprehensive loss at July 1 $(24.7) $(0.2) $(24.9) $(25.8) $(0.3) $(26.1)
Other comprehensive loss before reclassifications (net of taxes of $0, $0, $0 and $(0.1), respectively) 
 
 
 
 (0.2) (0.2)
Losses reclassified from net accumulated other comprehensive loss:       
 
 

Interest rate derivatives (net of taxes of $0.1, $0, $0.1 and $0, respectively) (a)
 0.3
 
 0.3
 0.3
 
 0.3
Amortization of net actuarial loss (net of taxes of $0, $0, $0 and $0.1, respectively) 
 
 
 
 0.2
 0.2
Net current period other comprehensive income 0.3
 
 0.3
 0.3
 
 0.3
Accumulated other comprehensive loss at Sept. 30 $(24.4) $(0.2) $(24.6) $(25.5) $(0.3) $(25.8)


  Nine Months Ended Sept. 30, 2019 Nine Months Ended Sept. 30, 2018
(Millions of Dollars) 
Gains and Losses
on Cash Flow Hedges
 
Defined Benefit Pension and
Postretirement Items
 Total 
Gains and Losses
on Cash Flow Hedges
 
Defined Benefit Pension and
Postretirement Items
 Total
Accumulated other comprehensive loss at Jan. 1 $(25.3) $(0.2) $(25.5) $(26.4) $(0.3) $(26.7)
Other comprehensive loss before reclassifications (net of taxes of $0, $0, $0 and $(0.1), respectively 
 
 
 
 (0.2) (0.2)
Losses reclassified from net accumulated other comprehensive loss:       

 

 

Interest rate derivatives (net of taxes of $0.3, $0, $0.3 and $0, respectively) (a)
 0.9
 
 0.9
 0.9
 
 0.9
Amortization of net actuarial loss (net of taxes of $0, $0, $0 and $0.1, respectively) 
 
 
 
 0.2
 0.2
Net current period other comprehensive income 0.9
 
 0.9
 0.9
 
 0.9
Accumulated other comprehensive loss at Sept. 30 $(24.4) $(0.2) $(24.6) $(25.5) $(0.3) $(25.8)

(a)
Included in interest charges.
11.Segment Information

Operating results from the regulated electric utility and regulated natural gas utility are each separately and regularly reviewed by PSCo’s chief operating decision maker. PSCo evaluates performance based on profit or loss generated from the product or service provided. These segments are managed separately because the revenue streams are dependent upon regulated rate recovery, which is separately determined for each segment.

PSCo has the following reportable segments: regulated electric utility, regulated natural gas utility and all other.

PSCo’s regulated electric utility segment generates, transmits and distributes electricity primarily in portions of Colorado. In addition, this segment includes sales for resale and provides wholesale transmission service to various entities in the United States. Regulated electric utility also includes PSCo’s commodity trading operations.
PSCo’s regulated natural gas utility segment transports, stores and distributes natural gas primarily in portions of Colorado.
Revenues from operating segments not included above are below the necessary quantitative thresholds and are therefore included in the all other category. Those primarily include steam revenue, appliance repair services and nonutility real estate activities.

Regulated Electric - The regulated electric utility segment generates electricity which is transmitted and distributed in Colorado. This segment includes sales for resale and provides wholesale transmission service to various entities in the United States. Regulated electric utility also includes PSCo’s wholesale commodity and trading operations.
Regulated Natural Gas - The regulated natural gas utility segment transports, stores and distributes natural gas in portions of Colorado.
All Other - Revenues from operating segments not included above are below the necessary quantitative thresholds are included in the all other category. Those primarily include steam revenue, appliance repair services and nonutility real estate activities.
Asset and capital expenditure information is not provided for PSCo’s reportable segments because assegments. As an integrated electric and natural gas utility, PSCo operates significant assets that are not dedicated to a specific business segment, and reportingsegment. Reporting assets and capital expenditures by business segment would require arbitrary and potentially misleading allocations which may not necessarily reflect the assets that would be required for the operation of the business segments on a stand-alone basis.

To report income from operations for regulated electric and regulated natural gas utility segments, the majority of costs are directly assigned to each segment. However, someCertain costs, such as common depreciation, common O&M expenses and interest expense are allocated based on cost causation allocators. Aallocators across each segment. In addition, a general allocator is used for certain general and administrative expenses, including office supplies, rent, property insurance and general advertising.
(Thousands of Dollars) Regulated Electric Regulated Natural Gas All Other Reconciling Eliminations Consolidated Total
Three Months Ended Sept. 30, 2017          
Operating revenues (a)(b)
 $877,604
 $142,389
 $10,300
 $
 $1,030,293
Intersegment revenues 47
 222
 
 (269) 
Total revenues $877,651
 $142,611
 $10,300
 $(269) $1,030,293
Net income $178,648
 $5,815
 $1,614
 $
 $186,077

(Thousands of Dollars) Regulated Electric Regulated Natural Gas All Other Reconciling Eliminations Consolidated Total
Three Months Ended Sept. 30, 2016          
Operating revenues (a)(b)
 $897,516
 $152,763
 $8,898
 $
 $1,059,177
Intersegment revenues 54
 6
 
 (60) 
Total revenues $897,570
 $152,769
 $8,898
 $(60) $1,059,177
Net income (loss) $168,328
 $4,918
 $361
 $
 $173,607
(a)    Operating revenues include $0 and $2 million of affiliate electric revenue for the three months ended Sept. 30, 2017 and 2016.
(b)    Operating revenues include $1 million of other affiliate revenue for the three months ended Sept. 30, 2017 and 2016.
(Thousands of Dollars) Regulated Electric Regulated Natural Gas All Other Reconciling Eliminations Consolidated Total
Nine Months Ended Sept. 30, 2017          
Operating revenues (a)(b)
 $2,318,912
 $691,302
 $31,529
 $
 $3,041,743
Intersegment revenues 206
 318
 
 (524) 
Total revenues $2,319,118
 $691,620
 $31,529
 $(524) $3,041,743
Net income $342,195
 $53,133
 $2,882
 $
 $398,210
(Thousands of Dollars) Regulated Electric Regulated Natural Gas All Other Reconciling Eliminations Consolidated Total
Nine Months Ended Sept. 30, 2016          
Operating revenues (a)(b)
 $2,337,547
 $659,738
 $29,585
 $
 $3,026,870
Intersegment revenues 196
 84
 
 (280) 
Total revenues $2,337,743
 $659,822
 $29,585
 $(280) $3,026,870
Net income $320,192
 $53,883
 $2,750
 $
 $376,825
(a)    Operating revenues include $1 million and $7 million of affiliate electric revenue for the nine months ended Sept. 30, 2017 and 2016, respectively.
(b)    Operating revenues include $3 million of other affiliate revenue for the nine months ended Sept. 30, 2017 and 2016.

11.Benefit Plans and Other Postretirement Benefits

Components of Net Periodic Benefit Cost (Credit)
         
  Three Months Ended Sept. 30
  2017 2016 2017 2016
(Thousands of Dollars) Pension Benefits 
Postretirement Health
Care Benefits
Service cost $6,820
 $6,487
 $192
 $192
Interest cost 12,639
 13,852
 4,191
 4,518
Expected return on plan assets (17,134) (17,692) (5,476) (5,575)
Amortization of prior service credit (803) (801) (1,562) (1,562)
Amortization of net loss 7,089
 6,692
 961
 483
Net periodic benefit cost (credit) 8,611
 8,538
 (1,694) (1,944)
Credits not recognized due to the effects of regulation 736
 682
 
 
Net benefit cost (credit) recognized for financial reporting $9,347
 $9,220
 $(1,694) $(1,944)

         
  Nine Months Ended Sept. 30
  2017 2016 2017 2016
(Thousands of Dollars) Pension Benefits Postretirement Health
Care Benefits
Service cost $20,460
 $19,445
 $576
 $576
Interest cost 37,919
 41,554
 12,573
 13,554
Expected return on plan assets (51,402) (53,076) (16,428) (16,725)
Amortization of prior service credit (2,409) (2,408) (4,686) (4,686)
Amortization of net loss 21,267
 20,078
 2,883
 1,449
Net periodic benefit cost (credit) 25,835
 25,593
 (5,082) (5,832)
Credits not recognized due to the effects of regulation 1,898
 1,947
 
 
Net benefit cost (credit) recognized for financial reporting $27,733
 $27,540
 $(5,082) $(5,832)

In January 2017, contributions of $150.0 million were made across four of Xcel Energy’s pension plans, of which $16.8 million was attributable to PSCo. Xcel Energy does not expect additional pension contributions during 2017.

12.Other Comprehensive Income (Loss)

Changes in accumulated other comprehensive loss, net of tax,PSCo’s segment information for the three and nine months ended Sept. 30, 2017 and 2016 were as follows:30:
  Three Months Ended Sept. 30, 2017
(Thousands of Dollars) Gains and Losses on Cash Flow Hedges Defined Benefit and Postretirement Items Total
Accumulated other comprehensive loss at July 1 $(22,284) $(218) $(22,502)
Losses reclassified from net accumulated other comprehensive loss 257
 1
 258
Net current period other comprehensive income 257
 1
 258
Accumulated other comprehensive loss at Sept. 30 $(22,027) $(217) $(22,244)
  Three Months Ended Sept. 30, 2016
(Thousands of Dollars) Gains and Losses on Cash Flow Hedges Defined Benefit and Postretirement Items Total
Accumulated other comprehensive loss at July 1 $(23,308) $(217) $(23,525)
Other comprehensive loss before reclassifications (1) 
 (1)
Losses reclassified from net accumulated other comprehensive loss 266
 
 266
Net current period other comprehensive income 265
 
 265
Accumulated other comprehensive loss at Sept. 30 $(23,043) $(217) $(23,260)
  Nine Months Ended Sept. 30, 2017
(Thousands of Dollars) Gains and Losses on Cash Flow Hedges Defined Benefit and Postretirement Items Total
Accumulated other comprehensive loss at Jan. 1 $(22,780) $(220) $(23,000)
Losses reclassified from net accumulated other comprehensive loss 753
 3
 756
Net current period other comprehensive income 753
 3
 756
Accumulated other comprehensive loss at Sept. 30 $(22,027) $(217) $(22,244)

  Nine Months Ended Sept. 30, 2016
(Thousands of Dollars) Gains and Losses on Cash Flow Hedges Defined Benefit and Postretirement Items Total
Accumulated other comprehensive loss at Jan. 1 $(23,836) $
 $(23,836)
Other comprehensive income (loss) before reclassifications 1
 (219) (218)
Losses reclassified from net accumulated other comprehensive loss 792
 2
 794
Net current period other comprehensive loss 793
 (217) 576
Accumulated other comprehensive loss at Sept. 30 $(23,043) $(217) $(23,260)

Reclassifications from accumulated other comprehensive loss for the three and nine months ended Sept. 30, 2017 and 2016 were as follows:
      
  Amounts Reclassified from Accumulated Other
Comprehensive Loss
 
(Thousands of Dollars) Three Months Ended Sept. 30, 2017 Three Months Ended Sept. 30, 2016 
Losses on cash flow hedges:  
   
Interest rate derivatives $407
(a) 
$407
(a) 
Vehicle fuel derivatives 
(b) 
21
(b) 
Total, pre-tax $407
 $428
 
Tax benefit (150) (162) 
Total, net of tax $257
 $266
 
Defined benefit pension and postretirement losses:     
Amortization of net loss $2
(c) 
$
(c) 
Total, pre-tax 2
 
 
Tax benefit (1) 
 
Total, net of tax 1
 
 
Total amounts reclassified, net of tax $258
 $266
 
  
Amounts Reclassified from Accumulated
Other Comprehensive Loss
 
(Thousands of Dollars) Nine Months Ended Sept. 30, 2017 Nine Months Ended Sept. 30, 2016 
Losses on cash flow hedges:     
Interest rate derivatives $1,208
(a) 
$1,211
(a) 
Vehicle fuel derivatives 
(b) 
67
(b) 
Total, pre-tax 1,208
 1,278
 
Tax benefit (455) (486) 
Total, net of tax $753
 $792
 
Defined benefit pension and postretirement losses:     
Amortization of net loss $6
(c) 
$
(c) 
Total, pre-tax 6
 
 
Tax benefit (3) 
 
Total, net of tax 3
 
 
Total amounts reclassified, net of tax $756
 $792
 
  Three Months Ended Sept. 30
(Millions of Dollars) 2019 2018
Regulated Electric    
Operating revenues $880.7
 $894.8
Intersegment revenues 0.1
 
Total revenue 880.8
 894.8
Net income 204.7
 191.7
Regulated Natural Gas    
Operating revenues $153.9
 $157.2
Intersegment revenues 0.1
 0.3
Total revenue 154.0
 157.5
Net income 0.7
 15.1
All Other    
Operating revenues (a)
 $9.7
 $8.7
Net (loss) income (0.9) 0.3
Consolidated Total    
Operating revenues (a)
 $1,044.5
 $1,061.0
Reconciling eliminations (0.2) (0.3)
Total revenue $1,044.3
 $1,060.7
Net income 204.5
 207.1
(a) 
Included in interest charges.Operating revenues include $1.1 million of other affiliate revenue for the three months ended Sept. 30, 2019 and 2018.

  Nine Months Ended Sept. 30
(Millions of Dollars) 2019 2018
Regulated Electric    
Operating revenues $2,314.8
 $2,309.3
Intersegment revenues 0.3
 0.2
Total revenue 2,315.1
 2,309.5
Net income 371.9
 373.3
Regulated Natural Gas    
Operating revenues $830.7
 $707.8
Intersegment revenues 0.2
 0.4
Total revenue 830.9
 708.2
Net income 77.5
 89.7
All Other    
Operating revenues (a)
 $31.8
 $28.7
Net (loss) income (4.6) 0.1
Consolidated Total    
Operating revenues (a)
 $3,177.8
 $3,046.4
Reconciling eliminations (0.5) (0.6)
Total revenue $3,177.3
 $3,045.8
Net income 444.8
 463.1

(b)(a) 
Included in O&M expenses.
(c)
Included inOperating revenues include $3.3 million of other affiliate revenue for the computation of net periodic pensionnine months ended Sept. 30, 2019 and postretirement benefit costs. See Note 11 for details regarding these benefit plans.2018.


Item 2 — MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

Discussion of financial condition and liquidity for PSCo is omitted per conditions set forth in general instructions H (1) H(1)(a) and (b) of Form 10-Q for wholly owned subsidiaries. It is replaced with management’s narrative analysis of the results of operations set forth in general instructions H (2) H(2)(a) of Form 10-Q for wholly owned subsidiaries (reduced disclosure format).

Non-GAAP Financial Review

Measures
The following discussion includes financial information prepared in accordance with GAAP, as well as certain non-GAAP financial measures such as electric margin, natural gas margin and ongoing earnings. Generally, a non-GAAP financial measure is a measure of a company’s financial performance, financial position or cash flows that excludes (or includes) amounts that are adjusted from measures calculated and presented in accordance with GAAP. PSCo’s management uses non-GAAP measures for financial planning and analysis, by management focuses on those factors that hadfor reporting of results, in determining performance-based compensation and communicating its earnings outlook to analysts and investors. Non-GAAP financial measures are intended to supplement investors’ understanding of our performance and should not be considered alternatives for financial measures presented in accordance with GAAP. These measures are discussed in more detail below and may not be comparable to other companies’ similarly titled non-GAAP financial measures.
Electric and Natural Gas Margins
Electric margin is presented as electric revenues less electric fuel and purchased power expenses. Natural gas margin is presented as natural gas revenues less the cost of natural gas sold and transported. Expenses incurred for electric fuel and purchased power and the cost of natural gas are generally recovered through various regulatory recovery mechanisms. As a material effect on PSCo’s financial condition, results of operations and cash flows during the periods presented, orresult, changes in these expenses are expected to have a material impactgenerally offset in the future. It should be read in conjunction with the accompanying unaudited consolidated financial statements and related notes to the consolidated financial statements. Due to the seasonality of PSCo’soperating revenues.
Management believes electric and natural gas sales, such interim results are not necessarily an appropriate base from whichmargins provide the most meaningful basis for evaluating our operations because they exclude the revenue impact of fluctuations in these expenses. These margins can be reconciled to project annual results.

Forward-Looking Statements

Except for the historical statements contained in this report, the matters discussed herein, are forward-looking statements that are subject to certain risks, uncertainties and assumptions. Such forward-looking statements are intended to be identified in this documentoperating income, a GAAP measure, by the words “anticipate,” “believe,” “estimate,” “expect,” “intend,” “may,” “objective,” “outlook,” “plan,” “project,” “possible,” “potential,” “should” and similar expressions. Actual results may vary materially. Forward-looking statements speak only as of the date they are made, and we expressly disclaim any obligation to update any forward-looking information. The following factors, in addition to those discussed elsewhere in this Quarterly Report on Form 10-Q and inincluding other securities filings (including PSCo’s Annual Report on Form 10-K for the fiscal year ended Dec. 31, 2016 and subsequent securities filings), could cause actual results to differ materially from management expectations as suggested by such forward-looking information: general economic conditions, including inflation rates, monetary fluctuations and their impact on capital expenditures and the ability of PSCo and its subsidiaries to obtain financing on favorable terms; business conditions in the energy industry; including the risk of a slow down in the U.S. economy or delay in growth, recovery, trade, fiscal, taxation and environmental policies in areas where PSCo has a financial interest; customer business conditions; actions of credit rating agencies; competitive factors including the extent and timing of the entry of additional competition in the markets served by PSCo and its subsidiaries; unusual weather; effects of geopolitical events, including war and acts of terrorism; cyber security threats and data security breaches; state, federal and foreign legislative and regulatory initiatives that affect cost and investment recovery, have an impact on rates or have an impact on asset operation or ownership or impose environmental compliance conditions; structures that affect the speed and degree to which competition enters the electric and natural gas markets; costs and other effects of legal and administrative proceedings, settlements, investigations and claims; financial or regulatory accounting policies imposed by regulatory bodies; outcomes of regulatory proceedings; availability oroperating revenues, cost of capital;sales-other, O&M expenses, conservation and employee work force factors.

DSM expenses, depreciation and amortization and taxes (other than income taxes).
Results of Operations

PSCo’s net income was approximately $398.2$444.8 million for 2017 year-to-date,the nine months ended Sept. 30, 2019 compared with approximately $376.8$463.1 million for the same period of 2016.prior year. The increase isdecrease in year-to-date earnings was driven by higher electric margin, lowerdepreciation, O&M, expensesinterest expense and lower ETR,AFUDC, which were partially offsetoffsets higher natural gas and electric margin. Changes in depreciation and AFUDC are primarily driven by increased depreciation expense.

the Rush Creek wind project that was placed in service in 2018.
Electric Revenues and Margin

Electric revenues and fuel and purchased power expenses are impacted by fluctuations in the price of natural gas and coal used in the generation of electricity. However, these price fluctuations have minimal impact on electric margin due to fuel recovery mechanisms that recover fuel expenses. The following table details theIn addition, electric customers receive a credit for PTCs that are generated in a particular period.
Electric revenues and margin:
 Nine Months Ended Sept. 30 Nine Months Ended Sept. 30
(Millions of Dollars) 2017 2016 2019 2018
Electric revenues $2,319
 $2,338
 $2,314.8
 $2,309.3
Electric fuel and purchased power (857) (891) (829.5) (841.7)
Electric margin $1,462
 $1,447
 $1,485.3
 $1,467.6


The following tables summarize the components of the changesChanges in electric revenues and electric margin for the nine months ended Sept. 30:

Electric Revenuesmargin:
(Millions of Dollars) 2017 vs. 2016
Fuel and purchased power cost recovery $(33)
Non-fuel riders 5
Trading 4
Earnings test 2
Other, net 3
Total decrease in electric revenues $(19)

Electric Margin
(Millions of Dollars) 2017 vs. 2016 2019 vs. 2018
Non-fuel riders $5
 $50.2
Trading 3
Earnings test 2
Finance leases (offset in interest expense and amortization) 16.4
Timing of tax reform regulatory decisions (offset in income tax and amortization) (19.7)
Conservation and DSM riders (offset in expense) (3.8)
Estimated impact of weather (2.6)
Wholesale transmission revenue (net) (2.4)
Sales decline (1.9)
Other, net 5
 (18.5)
Total increase in electric margin $15
 $17.7
Natural Gas Revenues and Margin

Total naturalNatural gas expense varies with changing sales and the cost of natural gas. However, fluctuations in the cost of natural gas hashave minimal impact on natural gas margin due to natural gas cost recovery mechanisms. The following table details natural
Natural gas revenues and margin:
  Nine Months Ended Sept. 30
(Millions of Dollars) 2019 2018
Natural gas revenues $830.7
 $707.8
Cost of natural gas sold and transported (376.7) (282.1)
Natural gas margin $454.0
 $425.7
  Nine Months Ended Sept. 30
(Millions of Dollars) 2017 2016
Natural gas revenues $691
 $660
Cost of natural gas sold and transported (304) (270)
Natural gas margin $387
 $390

The following tables summarize the components of the changes
Changes in natural gas revenues and natural gas margin for the nine months ended Sept. 30:

Natural Gas Revenuesmargin:
(Millions of Dollars) 2017 vs. 2016
Purchased natural gas adjustment clause recovery $33
Infrastructure and integrity rider 9
Retail rate decrease (5)
Estimated impact of weather (4)
Other, net (2)
Total increase in natural gas revenues $31


Natural Gas Margin
(Millions of Dollars) 2017 vs. 2016 2019 vs. 2018
Retail rate decrease $(5)
Estimated impact of weather (4) $8.5
Infrastructure and integrity rider 9
Infrastructure and integrity riders 8.5
Transport sales 4.6
Retail sales growth (excluding weather impact) 4.4
Retail rate increase 3.5
Other, net (3) (1.2)
Total decrease in natural gas margin $(3)
Total increase in natural gas margin $28.3
Non-Fuel Operating Expenses and Other Items

O&M Expenses O&M expenses decreased $22.9increased $24.4 million, or 4.0 percent,4.3%, for 2017 year-to-date. The decrease primarily reflects the nine months ended Sept. 30, 2019 compared with the prior year. Increase was driven by distribution costs, plant generation costs and gas operations. Distribution costs were higher due to storms, meters and vegetation management. Plant generation costs increased due to in-servicing the Rush Creek wind project and timing of planned maintenance and overhauls at various generation facilities, the timing of transmission line maintenance and the impact of costs associated with storm damage in 2016, as summarized in the table below:
(Millions of Dollars) 2017 vs. 2016
Plant generation costs $(13.1)
Electric distribution costs (8.0)
Transmission costs (3.1)
Employee benefits expense 3.2
Other, net (1.9)
  Total decrease in O&M expenses $(22.9)

DSM Program Expenses Demand side management (DSM) programoverhauls. Gas operation expenses increased $4.5 million, or 5.1 percent, for 2017 year-to-date. The increase was due to higher recovery rates. DSM expenses are generally recovered concurrently through riders and base rates. Timing of recovery may not correspond to the period in which costs were incurred.pipeline maintenance.

Depreciation and Amortization Depreciation and amortization expense increased $20.2$42.5 million, or 6.1 percent,10.5%, for 2017 year-to-date. The increasethe nine months ended Sept. 30, 2019 compared with the prior year. Increase was primarily attributable to electric and natural gas investmentsdriven by the in-servicing of the Rush Creek wind farm, as well as a new enterprise resource planning system.other capital investments, partially offset by accelerated amortization of the prepaid pension asset in the third quarter of 2018.

AFUDC, Equity and Debt Allowance for funds used during construction (AFUDC) increased $8.3 AFUDC decreased $37.1 million for 2017 year-to-date.  The increasethe nine months ended Sept. 30, 2019 compared with the prior year. Decrease was primarily due to an increasethe Rush Creek wind project being placed in-service in wind construction work in progress, particularly Rush Creek.2018.

Income Taxes Interest Charges Income tax expenseInterest charges increased $1.5$22.0 million, or 14.3%, for 2017 year-to-date. The increase in income tax expensethe nine months ended Sept. 30, 2019 compared with the prior year. Increase was primarily due to higher pretax earnings, partially offset by increased permanent plant-related adjustments (e.g., AFUDC-equity); a tax benefit for adjustments attributabledebt levels to the 2016 tax return filedfund capital investments, changes in the third quarter;short-term interest rates and aimplementation of lease accounting standard (offset in electric margin).
Income Taxes — Income tax expense decreased $57.3 million for state tax credit valuation allowances in 2016. Thethe nine months ended Sept. 30, 2019 compared with the prior year. Decrease was primarily driven by wind PTCs and lower pre-tax earnings. Wind PTCs are credited to customers (recorded as a reduction to revenue) and do not have a material impact on net income. ETR was 36.2 percent11.5% for 2017 year-to-date,the nine months ended Sept. 30, 2019 compared with 37.3 percent19.9% for the same period of 2016. The lower ETR in 2017 was primarilyprior year, largely due to the adjustmentsitems referenced above. See Note 6 to the consolidated financial statements.
Regulation
FERC and State Regulation The FERC has jurisdiction over rates for electric transmission service in interstate commerce and electricity sold at wholesale, hydro facility licensing, natural gas transportation, asset transactions and mergers, accounting practices and certain other activities of PSCo, including enforcement of North American Electric Reliability Corporation mandatory electric reliability standards. State and local agencies have jurisdiction over many of PSCo’s activities, including regulation of retail rates and environmental matters.
Xcel Energy, which includes PSCo, attempts to mitigate the risk of regulatory penalties through formal training on prohibited practices and a compliance function that reviews interaction with the markets under FERC and Commodity Futures Trading Commission jurisdictions.
Public campaigns are conducted to raise awareness of public safety issues of interacting with our electric systems.
While programs to comply with regulatory requirements are in place, there is no guarantee compliance programs or other measures will be sufficient to ensure against violations. Decisions by these regulators can significantly impact PSCo’s results of operations.
PSCo Colorado 2019 Electric Rate Case — In May 2019, PSCo filed a request with the CPUC seeking a net rate increase of approximately $158.3 million, or 5.7%. The filing also requests the transfer of $249.4 million of rider revenue to base rates, which will not impact overall customer bills as the revenue is currently being recovered through various riders. The request is based on a ROE of 10.35%, an equity ratio of 56.46%, a rate base of approximately $8.2 billion, a historic test year ended Dec. 31, 2018 (adjusted for 2019 capital investment) and incorporates the full impact of tax reform.
In October 2019, PSCo filed rebuttal testimony and revised its request seeking a net increase to retail electric base rate revenue of $108.3 million, reflecting a $353.3 million increase offset by $245.0 million of previously authorized costs (currently recovered through various rider mechanisms). The rebuttal includes certain forecasted plant additions through June 2019 based on a 13-month average rate base convention, a ROE of 10.20%, an equity ratio of 55.61% (based on a 13-month average equity ending Aug. 31, 2019) and inclusion of short-term debt in the capital structure and CWIP in rate base.
The procedural schedule is as follows:
Settlement deadline — Oct. 30, 2019
Evidentiary hearing — Nov. 4-13, 2019
A CPUC decision is anticipated in December 2019 with implementation of final rates on Jan. 1, 2020.
In September 2019, the CPUC Staff, FEA, OCC and CEC filed comprehensive answer testimony. Several other parties filed additional testimony.
Recommendations and the estimated impact on PSCo’s filed electric rate request as calculated by the filing parties, but with our estimate of the impact of their recommendations on riders are as follows:
(Millions of Dollars) Filed base revenue request 
Less: Previously authorized costs (existing riders) (b)
 Filed net change to revenue
PSCo $407.7
 $249.4
 $158.3
CPUC Staff (a)
 234.6
 226.9
 7.7
FEA 245.8
 238.9
 6.9
OCC (a)
 207.4
 216.3
 (8.9)
CEC (a)
 186.9
 213.0
 (26.1)
(a)
Staff, OCC and CEC have incorporated corrections to the filed case of ($4.3) million identified by PSCo.
(b)
Amounts derived from intervenors’ positions attributable to previously authorized costs (existing riders), impacted by proposed differences in weighted average cost of capital.

Recommended positions on PSCo’s filed electric rate request are as follows:
Position Staff FEA OCC CEC 
ROE 9.00% 9.20% 8.80% 8.90% 
Equity 55.57% 56.11% 54.60% 54.27% 
Test Year 2019 Current
(a) 
2018 Historic
(b) 
2018 Historic
(c) 
2018 Historic
(d) 
(a)
Incorporated 13-month average of proposed forecasted plant additions and rejected adjustments for wildfire mitigation improvements.
(b)
Incorporated year-end rate base and rejected proposed forecasted plant additions. Except for the transmission portion, the FEA supported portions of wildfire mitigation improvements and included 2019 distribution capital and O&M in its cost of service amount.
(c)
Incorporated proposed 13-month average rate base while rejecting the proposed forecasted plant additions including amounts requested for AGIS and wildfire mitigation improvements.
(d)
Rejected proposed forecasted plant additions and the majority of the adjustment for wildfire mitigation improvements.


Other Pending and Recently Concluded Regulatory Proceedings
MechanismUtility Service
Amount Requested
(in millions)
Filing
Date
ApprovalAdditional Information
CPUC
Rate CaseSteam$7
May
2019
ReceivedIn May 2019, PSCo filed an unopposed Settlement Agreement with CPUC Staff and the City of Denver. The settlement reflects a ROE of 9.67% for AFUDC purposes, an equity ratio of 56.04% and utilization of tax reform benefits. The CPUC approved the Settlement Agreement without modification on Sept. 5, 2019. The first stepped increase went into effect Oct. 1, 2019, with full rates effective Oct. 1, 2020.
Rate Case AppealNatural GasN/A
April
2019
PendingIn April 2019, PSCo filed an appeal seeking judicial review of the CPUC’s prior ruling regarding PSCo’s last natural gas rate case (approved in December 2018). Appeal requests review of the following: denial of a return on the prepaid pension and retiree medical assets; the use of a capital structure that is not based on the actual historical test year level; and the use of an average rate base methodology rather than a year-end rate base methodology. The District Court of Denver County has adopted a briefing schedule that will conclude in October 2019. Timeline on a final ruling is unknown.
Public Utility Regulation

Except to the extent noted below,in Regulation above, the circumstances set forth in Public Utility Regulation included in Item 1 of PSCo’s Annual Report on Form 10-K for the year ended Dec. 31, 20162018 and Public Utility Regulation included in Item 2 of PSCo’sPSCo's Quarterly Report on Form
10-Q for the quarterly periods ended March 31, 20172019 and June 30, 2017,2019, appropriately represent, in all material respects, the current status of public utility regulation and are incorporated herein by reference.

Rush Creek Wind Ownership Proposal — In 2016, the CPUC granted PSCo a Certificate of Public Convenience and Necessity (CPCN) to build, own and operate a 600 MW wind generation facility in Colorado at Rush Creek. The CPCN includes a hard cost-cap of $1.096 billion (including transmission costs) and a capital cost sharing mechanism between customers and PSCo of 82.5 percent to customers and 17.5 percent to PSCo for every $10 million the project comes in below the cost-cap.

All major contracts required to complete the project have been executed including the Vestas turbine supply and balance of plant agreements. Vestas production tax credit (PTC) components for safe harboring the facility have been fabricated and are currently being stored at Vestas facilities in Colorado. Construction of roads, collection systems, and foundations began in April 2017.


Colorado Energy Plan (CEP) — In May 2016, PSCo filed its 2016 Electric Resource Plan which included the estimated need for additional generation resources through 2024. In April 2017, the CPUC approved the modeling assumptions that will be used in the Request for Proposal (RFP) process. In August 2017, PSCo filed an updated capacity need with the CPUC of 450 MW.

In August 2017, PSCo, along with various other stakeholders, filed a stipulation agreement proposing the CEP. The major components include:

Early retirement of 660 MW of coal-fired generation at Comanche Units 1 (2022) and 2 (2025);
An RFP which could result in the addition of up to 1,000 MW of wind, 700 MW solar and 700 MW of natural gas and/or storage;
Utility ownership targets of 50 percent renewable generation resources and 75 percent of natural gas-fired, storage, or renewable with storage generation resources;
Accelerated depreciation for the early retirement of the two Comanche units and establishment of a regulatory asset to collect the incremental depreciation expense and related costs;
Reduction of the Renewable Energy Standard Adjustment rider, from two percent to one percent, subject to regulatory proceedings, effective beginning 2021 or 2022; and
Construction of a new transmission switching station to further the development of renewable generating resources.

In August 2017, PSCo issued an All-Source RFP. Bids are due on Nov. 28, 2017. PSCo anticipates filing its’ recommended portfolios in April 2018. The CPUC is expected to rule on the stipulation agreement in March 2018. A CPUC decision on the recommended portfolio is anticipated in the summer of 2018.

Approval of the CEP could increase the total capital investment up to $1.5 billion.

Advanced Grid Intelligence and Security — In July 2017, the CPUC approved PSCo’s CPCN for implementation of its advanced grid initiative. The project incorporates installing advanced meters, implementing hardware and software applications to allow the distribution system to operate at a lower voltage (integrated volt-var optimization) and installing communications infrastructure. These major projects are expected to improve customer experience, enhance grid reliability and enable the implementation of new and innovative programs and rate structures.

Environmental Matters
In June 2017,2019, the CPUC approved a settlement, which delayedEPA issued the advanced meter deployment from 2017-2021final ACE rule to 2019-2024.replace the Obama-era Clean Power Plan. The total capital costfinal ACE rule may require implementation of heat rate improvement projects at some of our coal-fired power plants. It is not known what the project included in the CPCN is approximately $537 million for 2017-2024. As a result of the settlement, approximately $120 million of capital investment was deferred to 2022-2024.

Decoupling Filing — In July 2016, PSCo filed a requestcosts associated with the CPUCfinal rule might be until state plans are developed to approve a partial decoupling mechanism, whichimplement the final regulation. PSCo believes the costs would adjust annual revenues based on changes in weather normalized average use per customer for the residential and small commercial classes. 

In July 2017, the CPUC issued a decision which approved the following key decisions regarding decoupling:

Effective Jan. 1, 2018 through December 2023 (subject to establishing new rates in the next electric rate case);
Applicable to the residential class and small commercial class;
Based on total class revenues (subject to establishing the base period in the next electric rate case);
Based on actual sales; and
Subject to a soft cap of 3 percent on any annual adjustment.

In August 2017, the CPUC denied PSCo’s request for reconsideration of the order.

Boulder, Colo. Municipalization — In 2011, in the City of Boulder, Colo. (Boulder), voters passed a ballot measure authorizing the formation of a municipal utility, subject to certain conditions. In 2014, the Boulder City Council passed an ordinance to establish an electric utility. PSCo challenged the formation of this utility. In 2016, the Colorado Court of Appeals preserved PSCo’s ability to do so. Subsequently, Boulder filed a Petition for Writ of Certiorari with the Colorado Supreme Court. In August 2017, the Colorado Supreme Court granted the petition to review the Colorado Court of Appeals decision.


In 2015, the Boulder District Court affirmed a prior CPUC decision that Boulder cannot serve customers outside its city limits. The District Court also ruled the CPUC has jurisdiction over the transfer of any facilities to Boulder and in determining how the systems are separated to preserve reliability, safety and effectiveness. Further, the Boulder District Court dismissed the condemnation action Boulder had filed, finding that the CPUC must give approval before Boulder files any future condemnation proceeding. Boulder does not have authorization to initiate a condemnation proceeding at this time.
Beginning in 2015, Boulder filed multiple separation applications, the most recent one being in May 2017. In June 2017, PSCo and other intervenors filed alternatives to Boulder’s separation plan and opposed certain sharing; contracting and financing aspects of the plan. 

In September 2017, the CPUC issued a written decision, agreeing with several key aspects of PSCo’s position, stating PSCo is not required to:

Finance Boulder’s municipalization efforts;
Design or construct future Boulder electric distribution facilities;
Enter into joint use of pole arrangements with Boulder; and
Use a third party to design and build facilities.

The CPUC provided conditional approval related to the transfer of some of the electrical distribution assets in Boulder, however subject to completion of certain items, including:

Filing an agreement between Boulder and PSCo providing permanent rights for PSCo to place and access facilities in Boulder needed to continue to serve its customers;
Filing a complete and accurate revised list of distribution assets to be transferred; and
Filing an agreement to address numerous aspects of payments from Boulder to PSCo for costs of Boulder’s municipalization efforts.

The CPUC requested those filings be made by Dec. 13, 2017. The CPUC has established a process whereby once those filings are made, additional hearings may be held.

At the end of 2017, several Boulder measures expire absent voter approvals, including the Utility Occupational Tax (UOT) which funds Boulder’s municipalization efforts. In response, Boulder has placed the following measures on the November 2017 ballot:

An extension and increase of the UOT for funding Boulder’s exploration of municipalization;
Requiring final voter approval prior to Boulder issuing debt to acquire assets and fund the start up of a local electric utility; and
Extending Boulder city council’s authority to hold non-public, executive sessions to discuss legal strategy related to municipalization, but not to discuss certain settlement options with PSCo.

Mountain West Transmission Group (MWTG) — PSCo, along with six other transmission owners from the Rocky Mountain region, have been considering creating and operating a joint transmission tariff to increase wholesale market efficiency and improve regional transmission planning.  In September 2017, the MWTG determined that membership in the Southwest Power Pool, Inc. (SPP) Regional Transmission Organization (RTO) would provide opportunities to reduce customer costs, and maximize resource and electric grid utilization. If participation with SPP proceeds, the MWTG utilities expect an economic benefit. In October 2017, the MWTG commenced negotiations with SPP through the SPP public stakeholder process.

SPP’s organizational group will address respective findings, objectives and next steps related to MWTG’s consideration of SPP membership. Should the MWTG decide to move forward, SPP would make filings with the FERC and PSCo would make filings with the CPUC and the FERC, in mid-2018. If approved, MWTG operations within the SPP RTO would not be expected to begin until late 2019, at the earliest. 


Summary of Recent Federal Regulatory Developments

FERC

The FERC has jurisdiction over rates for electric transmission service in interstate commerce and electricity sold at wholesale, hydro facility licensing, natural gas transportation, asset transactions and mergers, accounting practices and certain other activities of PSCo, including enforcement of North American Electric Reliability Corporation mandatory electric reliability standards. State and local agencies have jurisdiction over many of PSCo’s activities, including regulation of retail rates and environmental matters. See additional discussion in the summary of recent federal regulatory developments and public utility regulation sections of the PSCo Annual Report on Form 10-K for the year ended Dec. 31, 2016 and Quarterly Report on Form 10-Q for the quarterly periods ended
March 31, 2017 and June 30, 2017. In addition to the matters discussed below, see Note 5 to the consolidated financial statements for a discussion of other regulatory matters.

North American Electric Reliability Corporation (NERC) Supply Chain Standards — In September 2017, NERC filed supply chain cyber security reliability standards with the FERC. These standards consider the FERC’s directives to address supply chain cyber security risk management for industrial control system hardware, software, computing and network services associated with electric grid operations. The proposed reliability standards focus on security objectives including software integrity and authenticity, vendor remote access protections, information system planning and vendor risk management. It is uncertain when the FERC will take action to approve or remand the proposed reliability standards. If approved by the FERC, the proposed reliability standards will become effective on the first calendar quarter that is 18 months after the effective date of the approval. PSCo is in the process of developing plans in accordance with the requirements of the standards. The additional cost for compliance is anticipated to be recoverable through wholesale and retail rates.rates based on prior state commission practice.

Public Utility Regulatory Policies Act (PURPA) Enforcement Complaint Against CPUC In December 2016, Sustainable Power Group, LLC (sPower) petitioned the FERC to initiate an enforcement action in federal court against the CPUC under PURPA. The petition asserts that a December 2016 CPUC ruling, which indicated that a qualifying facility must be a successful bidder in a PSCo resource acquisition bidding process, violated PURPA and FERC rules. In January 2017, PSCo filed a motion to intervene and protest, arguing that the FERC should decline the petition. The CPUC filed a similar pleading. sPower has proposed to construct 800 MW of solar generation and 700 MW of wind generation in Colorado and seeks to require PSCo to contract for these resources under PURPA. If sPower were to prevail, PSCo’s ability to select generation resources through competitive bidding would be negatively affected. However, due to a lack of quorum at the FERC, the FERC did not act on that petition within the sixty days contemplated by PURPA. Subsequently sPower filed a complaint for declaratory and injunctive relief in the United States District Court for the District of Colorado (District Court) requesting that the court find the bidding requirement in the CPUC qualifying facility rules to be unlawful. PSCo intervened in that proceeding and the CPUC filed a motion to dismiss. In June 2017, the United States Magistrate Judge (Magistrate) issued a recommendation to the District Court that sPower’s complaint be dismissed because sPower failed to establish that it faced a substantial risk of harm. In October 2017, the District Court denied the CPUC’s motion to dismiss and instead allowed sPower to file an amended complaint. The case effectively starts over and PSCo is expected to intervene in the proceeding again. The timing of a resolution in this case is unclear.

Item 4 — CONTROLS AND PROCEDURES

Disclosure Controls and Procedures

PSCo maintains a set of disclosure controls and procedures designed to ensure that information required to be disclosed in reports that it files or submits under the Securities Exchange Act of 1934 is recorded, processed, summarized, and reported within the time periods specified in SEC rules and forms. In addition, the disclosure controls and procedures ensure that information required to be disclosed is accumulated and communicated to management, including the chief executive officer (CEO)CEO and chief financial officer (CFO),CFO, allowing timely decisions regarding required disclosure. As of Sept. 30, 2017,2019, based on an evaluation carried out under the supervision and with the participation of PSCo’s management, including the CEO and CFO, of the effectiveness of its disclosure controls and the procedures, the CEO and CFO have concluded that PSCo’s disclosure controls and procedures were effective.


Internal Control Over Financial Reporting

In 2016, PSCo implemented the general ledger modules of a new enterprise resource planning system to improve certain financial and related transaction processes. PSCo initiated deployment of work management systems modules and is continuing to implement additional modules including the conversion of existing work management systems to this same system during 2017. In connection with this ongoing implementation, PSCo is updating its internal control over financial reporting, as necessary, to accommodate modifications to its business processes and accounting systems. PSCo does not believe that this implementation will have an adverse effect on its internal control over financial reporting.

No changes in PSCo’s internal control over financial reporting occurred during the most recent fiscal quarter that materially affected, or are reasonably likely to materially affect, PSCo’s internal control over financial reporting.

Part II — OTHER INFORMATION

Item 1LEGAL PROCEEDINGS

Legal Proceedings
PSCo is involved in various litigation matters that are being defended and handled in the ordinary course of business. The assessment of whether a loss is probable or is a reasonable possibility, and whether the loss or a range of loss is estimable, often involves a series of complex judgments about future events. Management maintains accruals for such losses that are probable of being incurred and subject to reasonable estimation.
Management is sometimes unable to estimate an amount or range of a reasonably possible loss in certain situations, including but not limited to, when (1) the damages sought are indeterminate, (2) the proceedings are in the early stages, or (3) the matters involve novel or unsettled legal theories. In such cases, there is considerable uncertainty regarding the timing or ultimate resolution of such matters, including a possible eventual loss. For current proceedings not specifically reported herein, management does not anticipate that the ultimate liabilities, if any, would have a material effect on PSCo’s financial statements. Unless otherwise required by GAAP, legal fees are expensed as incurred.

Additional Information

See Note 69 to the consolidated financial statements for further discussion of legal claims and environmental proceedings. See Part I Item 2 and Note 5 to the consolidated financial statements for a discussion of proceedings involving utility rates and other regulatory matters.

further information.
Item 1A — RISK FACTORS

PSCo’s risk factors are documented in Item 1A of Part I of its Annual Report on Form 10-K for the year ended Dec. 31, 2016,2018, which is incorporated herein by reference. There have been no material changes from the risk factors previously disclosed in the Form 10-K.10-K.

Item 6 EXHIBITS
*Indicates incorporation by reference
+Executive Compensation Arrangements and Benefit Plans Covering Executive Officers and Directors
* Indicates incorporation by reference
+ Executive Compensation Arrangements and Benefit Plans Covering Executive Officers and Directors
Exhibit NumberDescriptionReport or Registration StatementSEC File or Registration NumberExhibit Reference
PSCo Form 10-Q for the quarter ended Sept. 30, 2017001-032803.01
PSCo Form 10-Q/A10-K for the quarteryear ended Sept. 30, 2013 (file no. 001-03280)).Dec. 31, 2018001-032803.02
PSCo Form 10-Q of Xcel Energy for the quarter ended Sept. 30, 2017 (file no. 001-03034)).8-K dated August 13, 2019001-32804.01
101.INSXBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.
101101.SCHThe following materials from PSCo’s Quarterly Report on Form 10-Q for the quarter ended Sept. 30, 2017 are formattedXBRL Schema
101.CALXBRL Calculation
101.DEFXBRL Definition
101.LABXBRL Label
101.PREXBRL Presentation
104Cover Page Interactive Data File (formatted as Inline XBRL and contained in XBRL (eXtensible Business Reporting Language):  (i) the Consolidated Statements of Income, (ii) the Consolidated Statements of Comprehensive Income (iii) the Consolidated Statements of Cash Flows, (iv) the Consolidated Balance Sheets, (v) Notes to Consolidated Financial Statements, and (vi) document and entity information.Exhibit 101)



SIGNATURES


Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.


  Public Service Company of Colorado
   
Oct. 27, 201725, 2019By:/s/ JEFFREY S. SAVAGE
  Jeffrey S. Savage
  Senior Vice President, Controller
  (Principal Accounting Officer)
   
  /s/ ROBERT C. FRENZEL
  Robert C. Frenzel
  Executive Vice President, Chief Financial Officer and Director
  (Principal Financial Officer)




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