XELXcel Energy

We note that your measures of the electric and natural gas margins on pages 28 and 29 appear to exclude certain amounts that would be attributable to cost of revenues and reflected in measures of gross margin in accordance with GAAP, such as operating and maintenance expenses and depreciation and amortization.

Rest of the question

Therefore, it appears that your margin measures should be identified as non-GAAP measures and that you would need to adhere to the disclosure requirements in Item 10(e) of Regulation S-K. For example, electric gross margin and natural gas gross margin, each reflecting all costs and expenses applicable to revenues, would be identified as the most directly comparable GAAP measures in providing the disclosures required by Item 10(e)(1)(i)(A) and (B) of Regulation S-K; reconciliations to your non-GAAP measures should begin with these GAAP measures. Please also include analyses of the changes in these most directly comparable GAAP measures, similar to those provided for changes in your non-GAAP measures of the electric and gas margins. Your may refer to the answers to Questions 100.05 and 102.10(a) and (b) of our C&DI's pertaining to Non-GAAP measures if you require further clarification. You may view this guidance at the following website address: https://www.sec.gov/corpfin/non-gaap-financial-measures.htm Please submit the revisions that you propose to address these concerns also with respect to any corresponding disclosures made by your four utility subsidiaries. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Xcel Energy acknowledges the Staff’s view that electric and natural gas margin should be identified as non-GAAP measures and reconciled to the most directly comparable GAAP measure of gross margin. For future Form 10-K and Form 10-Q filings, beginning with the quarter ending March 31, 2024, Xcel Energy and its four utility subsidiaries will no longer present electric and natural gas margin.

Rest of the answer

If Xcel Energy presents electric and natural gas margin in future filings, these amounts will be identified as non-GAAP measures and reconciled to gross margin.

If you would like to discuss Xcel Energy’s responses to the Staff’s comments or have any other questions, please contact me at (612) 330-6747.

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