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                            March 19, 2024

       Brian Van Abel
       Executive Vice President and Chief Financial Officer
       Xcel Energy, Inc.
       414 Nicollet Mall
       Minneapolis, MN 55401

                                                        Re: Xcel Energy, Inc.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2023
                                                            Filed February 21,
2024
                                                            File No. 001-03034

       Dear Brian Van Abel:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year ended December 31, 2023

       Management's Discussion and Analysis, page 26

   1.                                                   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.

                                                        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.
 Brian Van Abel
Xcel Energy, Inc.
March 19, 2024
Page 2
         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.

       Please contact Sondra Snyder at 202-551-3332 or Robert Babula at
202-551-3339 with
any questions.



FirstName LastNameBrian Van Abel                              Sincerely,
Comapany NameXcel Energy, Inc.
                                                              Division of
Corporation Finance
March 19, 2024 Page 2                                         Office of Energy
& Transportation
FirstName LastName