Political Contributions (Uniform Policy)

Summary

Xcel Energy and its subsidiaries shall comply with all federal laws restricting the
making of political contributions or expenditures using corporate funds in
connection with elections for federal offices.

Applicability

This policy applies to all employees (and directors) of Xcel Energy Inc., its wholly
owned subsidiaries and affiliates (“Xcel Energy”).

Definitions

Xcel Energy

Xcel Energy Inc., its wholly owned subsidiaries and affiliates
(“Xcel Energy”)

Content

Xcel Energy believes interaction with the legislative and policy-making
environments is important to our business. Company employees have the
opportunity to join together in political action committees (PACs) on both the
federal and state levels, and to have those voluntary contributions donated,
through the votes of their respective boards of directors, to candidates and office
holders. The company’s political action committees are required to publicly
disclose receipts and contributions to the Federal Elections Commission and in
states where contributions are made.

Xcel Energy also may provide financial support to political candidates, committees
and other political organizations by making corporate contributions where it is
legally permissible to do so. All corporate political contributions are subject to
review for compliance and approved as noted below.

All contributions are publicly disclosed as required by applicable federal and state
laws. Federal and state laws require candidate campaign committees, political
committees and ballot committees to report the contributions they receive.
Certain states require reporting of corporate contributions made in those states.

After careful consideration of specific federal, state and local laws that may impact
such decisions, the corporation may make such expenditures, if it is legal, under
the following conditions:

• Corporate contributions to a candidate campaign, require prior approval of the
head of Regulatory and Government Affairs, the Law Department and the
operating company CEO of the jurisdiction where the expenditure will be
made.

• Corporate contributions to an entity organized and operating under Section
527 of the Internal Revenue Code (26 USC § 527), require prior approval from
the head of Regulatory and Government Affairs, the Law Department, the
operating company CEO of the jurisdiction where the expenditure will be made
and the CEO of Xcel Energy. The director of Political Action, prior to any
formal or informal commitment being made, shall coordinate contributions.

Posting on Corporate Web Site

On an annual basis, corporate contributions to a candidate campaign, or to an
entity organized under Section 527 of the Code, will be disclosed on our corporate
Web site.

Xcel Energy will make reasonable efforts to obtain from trade associations
receiving more than minimal annual dues or payments about what percentage of
the company’s dues or payments were used for expenditures or contribution that,
if made directly by the company, would not be deductible under section 162(e)(1)
of the Internal Revenue Code, and providing as possible a breakdown for
subsections 162(e)(1)(A), 162(e)(1)(B), 162(e)(1)(C), and 162(e)(1)(D). For the
first two years, dues or payments of less than $25,000 will be considered minimal;
the threshold will be reanalyzed in subsequent years. The report on our company
Web site will set forth the dollar amounts that those trade association inform the
company are not deductible under 162(e)(1) and other breakdowns that are
provided.

Annual Review

An appropriate committee of the board of directors will review this policy, and the
contributions made, on an annual basis.

Accountabilities

Individual(s) accountable for various aspects of the policy include the following:

Review Date

This policy was last reviewed on March 13, 2007.

Supercedure

This is the initial issuance of this policy.

Approval

This policy has been approved by Paul J. Bonavia, President, Utilities Group and
Richard C. Kelly, Chairman, President and Chief Executive Officer.

2007 Xcel Energy Political Contributions Report (20.7KB pdf)