xcel energy 6_26_07boasecilingjune2007

30
Sustainable Growth Sustainable Growth June 26, 2007 June 26, 2007 Bank of America Conference Bank of America Conference

Upload: finance26

Post on 16-Jan-2015

133 views

Category:

Economy & Finance


0 download

DESCRIPTION

 

TRANSCRIPT

Page 1: xcel energy  6_26_07BOASECilingJune2007

Sustainable GrowthSustainable Growth

June 26, 2007June 26, 2007Bank of America ConferenceBank of America Conference

Page 2: xcel energy  6_26_07BOASECilingJune2007

This material includes forwardThis material includes forward--looking statements that are subject to certain looking statements that are subject to certain risks, uncertainties and assumptions. Such forwardrisks, uncertainties and assumptions. Such forward--looking statements looking statements include projected earnings, cash flows, capital expenditures aninclude projected earnings, cash flows, capital expenditures and other d other statements and are identified in this document by the words statements and are identified in this document by the words ““anticipate,anticipate,””““estimate,estimate,”” ““expect,expect,”” ““projected,projected,”” ““objective,objective,”” ““outlook,outlook,”” ““possible,possible,””““potentialpotential”” and similar expressions. Actual results may vary materially. and similar expressions. Actual results may vary materially. Factors that could cause actual results to differ materially incFactors that could cause actual results to differ materially include, but are lude, but are not limited to: general economic conditions, including the availnot limited to: general economic conditions, including the availability of ability of credit, actions of rating agencies and their impact on capital ecredit, actions of rating agencies and their impact on capital expenditures; xpenditures; business conditions in the energy industry; competitive factors;business conditions in the energy industry; competitive factors; unusual unusual weather; effects of geopolitical events, including war and acts weather; effects of geopolitical events, including war and acts of terrorism; of terrorism; changes in federal or state legislation; regulation; costs and ochanges in federal or state legislation; regulation; costs and other effectsther effectsof legal administrative proceedings, settlements, investigationsof legal administrative proceedings, settlements, investigations and claims and claims including litigation related to companyincluding litigation related to company--owned life insurance (COLI); actions owned life insurance (COLI); actions of accounting regulatory bodies; the higher degree of risk assocof accounting regulatory bodies; the higher degree of risk associated with iated with Xcel EnergyXcel Energy’’s nonregulated businesses compared with Xcel Energys nonregulated businesses compared with Xcel Energy’’s s regulated business; and other risk factors listed from time to tregulated business; and other risk factors listed from time to time byime byXcel Energy in reports filed with the SEC, including Exhibit 99.Xcel Energy in reports filed with the SEC, including Exhibit 99.01 to01 toXcel EnergyXcel Energy’’s report on Form 10s report on Form 10--K for year 2006.K for year 2006.

Safe HarborSafe Harbor

Page 3: xcel energy  6_26_07BOASECilingJune2007

Investment Merits Investment Merits

* Represents expected average annual normalized EPS growth, excluding any impact from COLI program

** On May 23, 2007, Xcel Energy increased its quarterly dividend by 3.4%, which is equivalent to $0.92 per share annualized

* Represents expected average annual normalized EPS growth, excluding any impact from COLI program

** On May 23, 2007, Xcel Energy increased its quarterly dividend by 3.4%, which is equivalent to $0.92 per share annualized

Sustainable EPS growth of 5% – 7%*

Dividend growth of 2% – 4% per year**

Dividend yield 4%

Sustainable EPS growth of 5% – 7%*

Dividend growth of 2% – 4% per year**

Dividend yield 4%

Page 4: xcel energy  6_26_07BOASECilingJune2007

Strategy: Building the CoreStrategy: Building the Core

Get the rules right

Invest in fully regulated utility operations— Meet customers’ needs— Provide environmental leadership

Earn a reasonable return

Get the rules right

Invest in fully regulated utility operations— Meet customers’ needs— Provide environmental leadership

Earn a reasonable return

Page 5: xcel energy  6_26_07BOASECilingJune2007

Environmental LeadershipEnvironmental LeadershipNumber 1 utility wind provider— 1,300 MW on-line— 2,800 MW projected by year-end 2007Over 2,000 MW of conservation and DSM achievedOne of the largest U.S. solar photovoltaic projects Evaluating an IGCC with sequestrationReducing emissions and increasing efficiency— MERP— Comanche— Sherco Upgrade ProjectNuclear life extension and capacity increasesMember of Dow Jones Sustainability Index

Number 1 utility wind provider— 1,300 MW on-line— 2,800 MW projected by year-end 2007Over 2,000 MW of conservation and DSM achievedOne of the largest U.S. solar photovoltaic projects Evaluating an IGCC with sequestrationReducing emissions and increasing efficiency— MERP— Comanche— Sherco Upgrade ProjectNuclear life extension and capacity increasesMember of Dow Jones Sustainability Index

Page 6: xcel energy  6_26_07BOASECilingJune2007

Getting the Rules RightGetting the Rules Right

MERP – Forward recoveryComanche 3 – Forward CWIP through rate case filingTransmission – Forward recovery – MN, CO, ND & SD Environmental – Forward recovery – MN, ND & SDPurchased capacity cost adjustment – CORenewable investments – Forward recovery – COIGCC – Supportive legislation – CO

MERP – Forward recoveryComanche 3 – Forward CWIP through rate case filingTransmission – Forward recovery – MN, CO, ND & SD Environmental – Forward recovery – MN, ND & SDPurchased capacity cost adjustment – CORenewable investments – Forward recovery – COIGCC – Supportive legislation – CO

Page 7: xcel energy  6_26_07BOASECilingJune2007

Constructive RegulationConstructive Regulation2006 rate case outcomes2006 rate case outcomesDollars in millionsDollars in millions

Colorado Gas $34.5 $22.0 11.0% 10.5%Wisconsin Electric 53.1 43.4 11.9% 11.0%Wisconsin Gas 7.8 3.9 11.9% 11.0%Minnesota Electric 156 131/115* 11.0% 10.54%Colorado Electric 208 151 11.0% 10.50%

Colorado Gas $34.5 $22.0 11.0% 10.5%Wisconsin Electric 53.1 43.4 11.9% 11.0%Wisconsin Gas 7.8 3.9 11.9% 11.0%Minnesota Electric 156 131/115* 11.0% 10.54%Colorado Electric 208 151 11.0% 10.50%

Dollar IncreaseDollar Increase Return on EquityReturn on EquityRequested GrantedRequested Granted Requested GrantedRequested Granted

** $131 million for 2006 reduced to $115 million in 2007 for large $131 million for 2006 reduced to $115 million in 2007 for large customer customer coming oncoming on--line January 1, 2007 line January 1, 2007

Page 8: xcel energy  6_26_07BOASECilingJune2007

2007 Rate Cases2007 Rate Cases

Dollars in millionsDollars in millions

Colorado Gas $41.5 $32.3 11.0% 10.25%

North Dakota Gas $2.8 $2.2 11.3% 10.75%

Texas Electric* $48 $23 11.6% NA

Colorado Gas $41.5 $32.3 11.0% 10.25%

North Dakota Gas $2.8 $2.2 11.3% 10.75%

Texas Electric* $48 $23 11.6% NA

Dollar IncreaseDollar Increase Return on EquityReturn on EquityRequested GrantedRequested Granted Requested GrantedRequested Granted

** Settlement pending commission approvalSettlement pending commission approval

Page 9: xcel energy  6_26_07BOASECilingJune2007

Pending Rate CasesPending Rate CasesDollars in millions Dollars in millions

RevenueRevenue RequestedRequested InterimInterimJurisdictionJurisdiction RequestRequest ROEROE RatesRates DecisionDecision

Minnesota GasMinnesota Gas $16.8 $16.8 10.75%10.75% $15.9$15.9 Summer 2007Summer 2007

Wisconsin ElectricWisconsin Electric 67.467.4 11.0%11.0% NANA Winter 2007Winter 2007

Wisconsin GasWisconsin Gas 5.35.3 11.0%11.0% NANA Winter 2007Winter 2007

Note: Xcel Energy plans to file a New Mexico electric case in JuNote: Xcel Energy plans to file a New Mexico electric case in July 2007ly 2007

Page 10: xcel energy  6_26_07BOASECilingJune2007

Proposed COLI Settlement in PrincipleProposed COLI Settlement in PrincipleXcel Energy agrees to pay the IRS $64.4 million for full settlement of IRS claims for income tax, interest and penalties for 1993-2007Xcel Energy will surrender its COLI policies following written acceptance of the offer by the IRS The IRS permits Xcel Energy to surrender the COLI polices without incurring any tax liability The settlement eliminates a potential exposure of $583 million for income tax, interest and penaltiesThe settlement eliminates approximately 5 cents per share of annual earning contribution associated with the COLI programThe potential settlement requires final approval by the Xcel Energy Board of Directors, IRS and the Department of Justice Tax Division

Xcel Energy agrees to pay the IRS $64.4 million for full settlement of IRS claims for income tax, interest and penalties for 1993-2007Xcel Energy will surrender its COLI policies following written acceptance of the offer by the IRS The IRS permits Xcel Energy to surrender the COLI polices without incurring any tax liability The settlement eliminates a potential exposure of $583 million for income tax, interest and penaltiesThe settlement eliminates approximately 5 cents per share of annual earning contribution associated with the COLI programThe potential settlement requires final approval by the Xcel Energy Board of Directors, IRS and the Department of Justice Tax Division

Page 11: xcel energy  6_26_07BOASECilingJune2007

Significant Capital Investment PipelineSignificant Capital Investment Pipeline

Growing service territory

Environmental initiatives

Renewable portfolio standards

Growing service territoryGrowing service territory

Environmental initiativesEnvironmental initiatives

Renewable portfolio standardsRenewable portfolio standards

Capital investment will drive sustainable growthCapital investment will drive sustainable growth

Page 12: xcel energy  6_26_07BOASECilingJune2007

Capital Expenditure ForecastCapital Expenditure ForecastDollars in millionsDollars in millions Denotes enhanced recovery processDenotes enhanced recovery process

20072007 20082008 20092009 20102010 20112011Base & Other Cap ExBase & Other Cap Ex $ 955$ 955 $ 950$ 950 $ 950$ 950 $1,000$1,000 $ 965$ 965MERPMERP 275275 170170 3535 1010 00Comanche 3Comanche 3 345345 275275 5555 1515 00MN Wind TransmissionMN Wind Transmission 150150 2020 5050 1515 0 0 CapX 2020CapX 2020 55 2020 110110 240240 180180Sherco UpgradeSherco Upgrade 1010 6565 200200 245245 165165Wind GenerationWind Generation 5050 155155 00 00 00BART ProjectsBART Projects 00 55 4040 6565 4040Nuclear Nuclear

FuelFuel 9090 160160 145145 105105 165165Capacity & Life ExtCapacity & Life Ext 2020 8080 115115 155155 185185

TotalTotal $1,900$1,900 $1,900$1,900 $1,700$1,700 $1,850$1,850 $1,700$1,700

Page 13: xcel energy  6_26_07BOASECilingJune2007

Renewable Portfolio Standards (RPS) Renewable Portfolio Standards (RPS)

In 2007, a law was passed in Minnesotarequiring a 30% renewable standard by 2020

In 2007, a law was passed in Coloradorequiring a 20% renewable standard by 2020

In 2007, a law was passed in New Mexicorequiring a 20% renewable standard by 2020

In 2007, a law was passed in MinnesotaIn 2007, a law was passed in Minnesotarequiring a 30% renewable standard by 2020requiring a 30% renewable standard by 2020

In 2007, a law was passed in ColoradoIn 2007, a law was passed in Coloradorequiring a 20% renewable standard by 2020requiring a 20% renewable standard by 2020

In 2007, a law was passed in New MexicoIn 2007, a law was passed in New Mexicorequiring a 20% renewable standard by 2020requiring a 20% renewable standard by 2020

RPS creates investment opportunitiesRPS creates investment opportunitiesfor wind generation and transmission linesfor wind generation and transmission lines

Page 14: xcel energy  6_26_07BOASECilingJune2007

Wind DensityWind DensityHighHigh

LowLow

Source: National Renewable Energy LaboratorySource: National Renewable Energy Laboratory

Xcel Energy and Wind PotentialXcel Energy and Wind Potential

Xcel EnergyXcel EnergyStates ServedStates Served

Page 15: xcel energy  6_26_07BOASECilingJune2007

Projected Wind GenerationProjected Wind Generation

MWMWMW

1,3001,3001,300

2,8002,8002,800

6,0006,0006,000

200620062006 200720072007 202020202020

Page 16: xcel energy  6_26_07BOASECilingJune2007

Strong Operational PerformanceStrong Operational PerformanceNuclear Capacity FactorsNuclear Capacity Factors

20032003 20042004 20052005 20062006

System Reliability (SAIDI) - MinutesSystem Reliability (SAIDI) - Minutes

20032003 20052005 2006200620042004

10510581.481.4

99.599.579.279.2

92.392.3 91.291.2 90.490.4 92.892.8

OSHA Incident RateOSHA Incident Rate

20032003 20052005 2006200620042004

3.623.62 3.403.402.762.76 2.532.532.762.76

Residential SatisfactionResidential Satisfaction

88%88% 85%85%85%85%85%85%

20032003 20052005 2006200620042004

Page 17: xcel energy  6_26_07BOASECilingJune2007

2007 Earnings Guidance Range 2007 Earnings Guidance Range

Dollars per shareDollars per share

Regulated Utility $1.45 – $1.55Holding Company $(0.15)Continuing Operations $1.30 – $1.40

Disc Ops - PSRI earnings $0.03 – $0.05Disc Ops – COLI settlement $(0.13) Total Disc Ops – COLI $(0.10) – $(0.08)

Total Xcel Energy $1.20 – $1.32

Regulated Utility $1.45 – $1.55Holding Company $(0.15)Continuing Operations $1.30 – $1.40

Disc Ops - PSRI earnings $0.03 – $0.05Disc Ops – COLI settlement $(0.13) Total Disc Ops – COLI $(0.10) – $(0.08)

Total Xcel Energy $1.20 – $1.32

20072007

Page 18: xcel energy  6_26_07BOASECilingJune2007

Attractive Total ReturnAttractive Total ReturnSustainable 5% Sustainable 5% –– 7% earnings per share growth7% earnings per share growthDividend yield 4%Dividend yield 4%Dividend growth of 2% Dividend growth of 2% –– 4% per year4% per year

SummarySummaryLow risk, fully regulated and integrated utilityConstructive regulatory environment with enhanced recovery of major capital projectsPipeline of investment opportunitiesEnvironmental leader, well-positionedfor changing rules

Low risk, fully regulated and integrated utilityConstructive regulatory environment with enhanced recovery of major capital projectsPipeline of investment opportunitiesEnvironmental leader, well-positionedfor changing rules

Page 19: xcel energy  6_26_07BOASECilingJune2007

AppendixAppendix

Page 20: xcel energy  6_26_07BOASECilingJune2007

Delivering Competitively Priced EnergyDelivering Competitively Priced EnergySummer 2006 EEI Typical BillsSummer 2006 EEI Typical Bills

Milwaukee

Milwaukee

Milwaukee

0

3

6

9

12

15

18

21

0

3

6

9

12

15

18

21Cents per kWh (Retail)Cents per kWh (Retail)Cents per kWh (Retail)

7.017.017.01

Des Moines

Des Moines

Des Moines

Amarillo

Amarillo

Amarillo

Kansas City

Kansas City

Kansas City

Denver

Denver

Denver

Mpls/St. Paul

Mpls/St. Paul

Mpls/St. Paul

BostonBostonBoston

Chicago

Chicago

Chicago

Phoenix

Phoenix

Phoenix

Salt Lake City

Salt Lake City

Salt Lake City

St. Louis

St. Louis

St. Louis

MiamiMiamiMiami

New York

New York

New York

Washington DC

Washington DC

Washington DC

6.646.646.64 7.797.797.79

Page 21: xcel energy  6_26_07BOASECilingJune2007

Northern States Northern States Power CompanyPower Company--

MinnesotaMinnesota45% Net Income 45% Net Income

Public Service Public Service Company of Company of

ColoradoColorado40% Net Income40% Net Income

Southwestern Southwestern Public ServicePublic Service8% Net Income8% Net Income

Northern Northern States Power States Power

CompanyCompany--WisconsinWisconsin

7% Net Income7% Net Income

5th Largest Combination Electric and Gas Utility (based on customers)

5th Largest Combination Electric and Gas Utility (based on customers)

Traditional RegulationTraditional Regulation

2006 EPS $1.35 continuing operations2007 Dividend $0.92 per share annualized2006 EPS $1.35 continuing operations2007 Dividend $0.92 per share annualized

Page 22: xcel energy  6_26_07BOASECilingJune2007

CoalCoal 3535 8,1828,182Natural GasNatural Gas 5858 4,9874,987NuclearNuclear 33 1,6681,668HydroHydro 8383 508508OilOil 2424 460460RDFRDF 66 6767WindWind 3737 2727TotalTotal 15,89915,899

2006 OwnedGenerating Facilities

2006 OwnedGenerating Facilities

Unit TypeUnit Type UnitsUnits MWMW

Xcel Energy Supply SourcesXcel Energy Supply Sources

Nuclear12%

Nuclear12%

Coal **52%

Coal **52%

Gas & Oil27%

Gas & Oil27%

* Includes purchases** Low-sulfur western coal* Includes purchases** Low-sulfur western coal

Renewables9%

Renewables9%

2006Energy Supply Mix*

2006Energy Supply Mix*

Page 23: xcel energy  6_26_07BOASECilingJune2007

Senior Debt RatingsSenior Debt Ratings

SecuredSecured UnsecuredUnsecuredFitch Moody’s S&P Fitch Moody’s S&PFitch Moody’s S&P Fitch Moody’s S&P

Holding Co. BBB+ Baa1 BBB-NSPM A+ A2 A- A A3 BBB-NSPW A+ A2 A- A A3 BBB PSCo A- A3 A- BBB+ Baa1 BBB-SPS BBB+ Baa1 BBB

Holding Co. BBB+ Baa1 BBB-NSPM A+ A2 A- A A3 BBB-NSPW A+ A2 A- A A3 BBB PSCo A- A3 A- BBB+ Baa1 BBB-SPS BBB+ Baa1 BBB

Page 24: xcel energy  6_26_07BOASECilingJune2007

Debt MaturitiesDebt MaturitiesDebt Maturities

0

200

400

600

800

1,000

1,200

2007 2008 2009 2010 2011 2012 2013 2014 2015

XcelNSPMNSPWPSCoSPS

Dollars in millionsDollars in millions

PSCo$100M due 3/1/07 @ 7.11%PSCo$100M due 3/1/07 @ 7.11%

Xcel$230M due 11/1/07 @ 7.50%Xcel$230M due 11/1/07 @ 7.50%

Page 25: xcel energy  6_26_07BOASECilingJune2007

Texas Electric Rate Case SettlementTexas Electric Rate Case Settlement

Requested rate increase of $48 million

Unanimous settlement reached:— $23 million base rate increase— $27 million of 2004-2005 fuel expense disallowed;

reserve was established prior to 2007— Potential disallowance for the El Paso contract

capped at $6.3 million annually through 2008

Interim rate increase went into effect in April 2007 pending commission order

Commission decision expected in second quarter

Requested rate increase of $48 million

Unanimous settlement reached:— $23 million base rate increase— $27 million of 2004-2005 fuel expense disallowed;

reserve was established prior to 2007— Potential disallowance for the El Paso contract

capped at $6.3 million annually through 2008

Interim rate increase went into effect in April 2007 pending commission order

Commission decision expected in second quarter

Page 26: xcel energy  6_26_07BOASECilingJune2007

Minnesota Cost Recovery MechanismsMinnesota Cost Recovery Mechanisms

Projected electric fuel and purchased energy costs billed for the current month with subsequent true-up; MISO energy and ancillary services being recovered through FCA

Projected purchased gas cost billed for the current monthwith subsequent true-up

Conservation Improvement Program rider which providesrecovery of program costs plus incentives

Metro Emission Reduction Program, Renewable Development Fund and State Energy Policy rider in place

General Transmission rider authorized by law

Mercury Reduction and Environmental Improvement rider authorized by law

Projected electric fuel and purchased energy costs billed for Projected electric fuel and purchased energy costs billed for the current month with subsequent truethe current month with subsequent true--up; MISO energy and up; MISO energy and ancillary services being recovered through FCA ancillary services being recovered through FCA

Projected purchased gas cost billed for the current monthProjected purchased gas cost billed for the current monthwith subsequent truewith subsequent true--upup

Conservation Improvement Program rider which providesConservation Improvement Program rider which providesrecovery of program costs plus incentivesrecovery of program costs plus incentives

Metro Emission Reduction Program, Renewable Development Metro Emission Reduction Program, Renewable Development Fund and State Energy Policy rider in place Fund and State Energy Policy rider in place

General Transmission rider authorized by lawGeneral Transmission rider authorized by law

Mercury Reduction and Environmental Improvement rider Mercury Reduction and Environmental Improvement rider authorized by lawauthorized by law

Page 27: xcel energy  6_26_07BOASECilingJune2007

Colorado Cost Recovery MechanismsColorado Cost Recovery MechanismsQuarterly Energy Cost Adjustment to recover electric fuel and Quarterly Energy Cost Adjustment to recover electric fuel and purchased energy costspurchased energy costsMonthly Gas Cost Adjustment recovers natural gas commodity, Monthly Gas Cost Adjustment recovers natural gas commodity, interstate pipeline and storage costsinterstate pipeline and storage costsAnnual Purchased Capacity Adjustment to recover capacity Annual Purchased Capacity Adjustment to recover capacity costs of purchased power contracts through 2010 costs of purchased power contracts through 2010 Fuel Cost Adjustment recovers electric fuel and purchased Fuel Cost Adjustment recovers electric fuel and purchased energy costs from wholesale customersenergy costs from wholesale customersDemandDemand--side Management Cost Adjustment rider side Management Cost Adjustment rider Air Quality Improvement rider (recovers cost of emission Air Quality Improvement rider (recovers cost of emission controls on several Denver metro generation facilities)controls on several Denver metro generation facilities)Recovery of Comanche 3 construction workRecovery of Comanche 3 construction work--inin--progress progress Recovery of expenditures for renewable mandateRecovery of expenditures for renewable mandateRider recovery of IGCCRider recovery of IGCC

Page 28: xcel energy  6_26_07BOASECilingJune2007

SPS Cost Recovery MechanismsSPS Cost Recovery Mechanisms

Fuel and purchased energy costs are recovered through a Fuel and purchased energy costs are recovered through a fixedfixed--fuel and purchased energy recovery factor, which is fuel and purchased energy recovery factor, which is part of the retail electric ratespart of the retail electric ratesThe Texas ECA retail fuel factors change each May 1st and The Texas ECA retail fuel factors change each May 1st and November 1st based on projected costsNovember 1st based on projected costsMaterial over or under recovery estimates may cause the Material over or under recovery estimates may cause the factor to be revised based on application by SPS or action factor to be revised based on application by SPS or action by the PUCTby the PUCTFuel reconciliation every two yearsFuel reconciliation every two years

Fuel and purchased power cost are recovered throughFuel and purchased power cost are recovered througha fuel and purchased power adjustment clausea fuel and purchased power adjustment clauseThe New Mexico adjustment clause is reset monthlyThe New Mexico adjustment clause is reset monthly

TexasTexas

New MexicoNew Mexico

Page 29: xcel energy  6_26_07BOASECilingJune2007

Wisconsin Cost Recovery MechanismsWisconsin Cost Recovery Mechanisms

Projected electric fuel and purchased energy costs areProjected electric fuel and purchased energy costs areincluded in base ratesincluded in base ratesProspective adjustments are handled via the fuel rules Prospective adjustments are handled via the fuel rules monitoring process which allows for positive or negative monitoring process which allows for positive or negative adjustments to be applied to the fuel recovery rateadjustments to be applied to the fuel recovery rateThe fuel recovery rate is reset annually on January 1The fuel recovery rate is reset annually on January 1stst

of each year and may be adjusted during the calendarof each year and may be adjusted during the calendaryear if costs are outside a determined bandwidthyear if costs are outside a determined bandwidthWholesale energy costs are recovered via the Fuel Clause Wholesale energy costs are recovered via the Fuel Clause AdjustmentAdjustment

Page 30: xcel energy  6_26_07BOASECilingJune2007

Dakota Cost Recovery MechanismsDakota Cost Recovery Mechanisms

North DakotaNorth Dakota’’s fuel and purchased power costs are s fuel and purchased power costs are recovered through a fuel clause, which is reset based recovered through a fuel clause, which is reset based on the previous four months average rateon the previous four months average rate

North DakotaNorth Dakota

South DakotaSouth Dakota

South DakotaSouth Dakota’’s fuel and purchased power costs are s fuel and purchased power costs are recovered through a fuel clause, which is reset based recovered through a fuel clause, which is reset based on the previous two months average rateon the previous two months average rate