- Good morning, this meeting of the Public Utility Commission
of Texas, will come to order to consider matters that have
been duly posted with the Secretary of State of Texas,
for November 30, 2022. For the record, my name is Peter
Lake, and today I'm joined by Will McAdams, Lori Cobos,
Jimmy, Glotfelty and Kathleen Jackson. Mr. Journeay,
could you please walk us through the consent items
on today's agenda? Good morning Commissioners, by individual
ballot, the following items were placed on your consent
agenda 3, 10 and 14. Thank you sir. Do we have a
motion to approve the items just described by Mr. Journeay? So moved. Second.
All in favor say aye. Aye. None opposed, motion passes. At this
point we'll move to the public comment portion of our
agenda. Oral comments related to a specific agenda
item will be heard when that item is taken up. This
segment is for general comments only. When we do get
to oral comments on specific items, stakeholders should
not approach the table unless oral argument has been
granted or they have been invited by a Commissioner.
As always speakers will be limited to three minutes
each. Mr. Journeay, we have anyone from the public signed up
to speak? No sir, no one signed up this morning. Thank
you sir. Public comment is now closed. Next item on
our agenda please sir. (item:2:54272) Item 2 is docket 54272,
it's a petition for an order appointing a temporary manager
for L and T Waterworks. Commission Staff filed a petition
to appoint Monarch Utilities as temporary manager. Uh,
of this system.
Thank you sir. At this point, I believe we need to recess
this meeting of the PUC, and uh, start a separate hearing
on this item. So we'll give the reporter and admin a moment
to set up.
That was a very efficient moment. Alright, so at this
point we're recessed from the original PUC meeting.
And a new meeting of the Public Utility Commission of
Texas, will come to order for the merits. (item:2:54272 - Hearing on the Merits) Hearing in
docket 54272, which has been duly posted with the
Secretary of State of Texas, for November 30, 2022.
We'll turn it over to our Commission ALJ for administration
of the hearing. Good morning Commissioners. I call
to order docket number 54272. Which is Commission Staff's
petition for an order appointing a temporary manager
for L and T Waterworks. This is Katie Marks, I am
assisting the Commissioner's this morning. And the purpose
of this hearing is to determine whether a temporary
manager should be appointed. We had a pre-hearing conference
yesterday, and I admitted four exhibits. Exhibit 1,
which is a copy of the petition and all attachments.
Exhibit 2, the affidavit of Rose Ramirez and all attachments.
Exhibit 3, a copy of the notice of hearing. And
exhibit 4, which is a copy of the divorce decree
of Curtis Logan and Regina Logan. At this time we'll
take appearances of the party starting with Commission
Staff. Jenna Keller for Commission Staff. Cody Faulk
on behalf of Monarch Utilities 1LP, now known as
Texas Water Utilities LP. Okay, have either of y'all
heard anything from the Utility or a representative
of the Utility? Staff has not. We've had conversations
as part of the closing of the transaction, but other
than that no other conversations have occurred. Okay.
Um, we'll start with opening statements beginning with
staff, if any? None your honor. We have none. Okay. Yesterday
we did not swear in any witnesses. Do either of you
have witnesses for this morning? Staff does not. The
company does not, but Brian Barr, head of regulatory
for the company is available, should the Commissioners
have any questions? Okay. Commissioners, do you have any questions?
Commission staff, any closing statements? No, your honor.
No your honor. All right. We are adjourned, thank you.
- Thank you all. (item:2:Reconvene Public meeting) The merits hearing on docket 54272 is
hereby adjourned at 9:37 am. Thank ya'll. Thank you. We
will now reconvene the open meeting of the Public Utility
Commission at 9:38am. Resuming with item 10, docket
54044. Item 2, sir. Sorry.
- Alright, thoughts?
Comments? Just from my perspective, I'd like to recognize that
uh and, acknowledge Mr. Logan no longer owns L and T Waterworks.
As stated in the divorce decree, Ms. Logan was awarded
the business and the divorce decree as her sole and
separate property. So, in my view we should continue
to move forward with Staff's request. Uh, to consider
appointing a temporary manager. Yeah, name change is important.
Thank you for highlighting that. Uh, yes sir, and divorce decrees.
Um, and with that said I uh, would move to approve the petition
for an order appointing Texas Water Utilities, LLC,
as temporary manager of Curtis D. Logan, DBA L and
T Waterworks, LLC. An indefinite basis, because the
Utility abandoned operations for the reasons cited in
the petition. Set the temporary manager compensation
at $15 per connection per month. Waive the requirement
regarding the temporary manager's duty to post financial
assurance, as recommended by Commission Staff. And direct
OPDM, to draft an order consistent um, with previous Commission
orders. All right. Chairman. Yes ma'am. Can I interrupt really quickly? I
have a quick request regarding the final order. Monarch's
application for a name change was just approved in
docket number 53636. So, Texas Water Utilities LP, is
the correct name for the temporary manager, as opposed
to Monarch. And that should be reflected in the final
order. Okay, are you?
Yes. As a matter of fact I. That was her motion. Okay. I did say Texas Water Utilities. Oh,
great. Yeah. Alright. Thank you for the clarification. Thank you though.
- Alright, we have a motion, do we have a second? Second. Motion is Second.
All in favor say aye. Aye. None opposed, the motion passes.
Next item, please sir.
- (item:9:52952) Uh, I believe the next item sir is item 9, project
52952. The year end 2021 Electric Utility Earnings
Report. Commission Staff filed a memo discussing
the Utilities Earnings Reports. Thank you sir. I appreciate
the Staff's work on this. Um, I'm satisfied with the
recommendation they've laid out. Uh, but of course, happy
to hear thoughts and comments. As am I, I have no nothing
to add on it. Same. I was just gonna say, we'll keep a good
eye on it. There's a reason for this, and uh, and we gotta
keep protecting the consumer. So it's a good, uh it's
a good report. But we'll keep an eye and make sure folks
don't over earn. Uh, as always, and I think those those
referenced in recent memory. Reports have been proactive
and been coming forward, and hope that trend continues. Right.
- All right. I don't think we don't have any formal action
on this item. So we'll move on to the next time. Item
was consented. I don't have anything on 11. I believe
the next one's 12, sir. All right. (item:12:53403 - Chapter 25.101 Transmission rule making) Item 12, this project 53403
is the review of Chapter uh, 25.
Review of chapter 25, 101. Um, okay. Yup, this is a. There's a proposal by the Commission
Staff, filed a memo on proposal for adopting amendments to 25.101.
- Yeah, there's there's a, bit more meat on that bone.
- Uh, Mr. Smeltzer. Um, appreciate you being available. Do
you have anything you want to lay out, before we begin
our discussion? Sure. This uh, there are three primary
objectives to this rulemaking. Um, the first and foremost
is the swift implementation of SB1281. Which has a
few components that adopts a new uh, congestion based
test for the approval of economic transmission lines.
Um, it tightens the requirements that ERCOT has to consider
with regard to its load forecasts for uh, transmission
planning. And it uh, adopts a new may be potentially first
of its kind, resiliency criteria that will serve as
a plus factor for the approval of transmission lines.
Um and to provide clarity, because there was I think confusion
about this. Uh, it is not a third path for the approval
of transmission lines, but if it allows for some additional
considerations for economic and reliability projects.
Should they meet certain pre-identified resiliency
um, issues by ERCOT. The second objective, um yeah, so the
resiliency is the second objective. Of making the third
is the implementation of HB1510. Which just uh, clarified
the status of um, certain CCN requirements for non-ERCOT
utilities. I'm available for any questions that you
may have. Thank you sir.
Thoughts, comments? Questions for Mr. Smeltzer? I'm happy to go
first here on this. First of all, um, I know this wasn't uh,
as timely implementation as the Legislature had wanted
us to have. But uh, I gotta tell you, we've done it.
Our Staff has done a great job on it. And um. We've
had a lot going on in the meantime. We've had a lot
going on. And um, while this is an important issue, it's
it's as important as the other ones that are being
discussed. So, um I thank the Staff and and, the industry.
Um but you know, the Staff for putting the time and
effort into uh, this first step. And and and, it is a
first step, but it's a really, really important first
step. Because, it solves a lot of the issues that industry
brings up as problems on our transmission system. So
um, I think uh, the fact that um, some of the longer
term implementation by, by uh implementing an economic
test is is really a solid foundation. Um, the uh, the
longer term horizon, um for a test. Yeah, I'm hopeful that uh,
ERCOT can create one fairly quickly. Um, and you
will have something that creates certainty for the
industry going forward. Um, the one thing that uh, that
I hope on this and we've had discussions with ERCOT.
I hope I'm speaking for all the Commissioners, and that
is the modeling efforts, um uh, to determine economic
projects should begin immediately. Um, and that is,
we need to have these identified and begin a process.
They've uh, there have been years that we haven't gone
by. That have gone by where we haven't been able to
identify these projects. There may be a backlog
of some, there may not. I mean, I wouldn't tell the
industry, I would tell the industry that I wouldn't
expect a list of 25 or 30 projects. But we'll see what
we get and the most important projects. Um, you know
we'll move to the front line for discussion. And um,
and that's what we want, that's what the Legislature
wants and hopefully that's what we're implementing
here. So I believe that's what we're implementing here.
I know some believe that um, uh, over building of transmission
uh, could come from this rule and other transmission
efforts that will be working on, you know, here in
the future. Um, I don't believe that such thing is
gonna happen. It's incumbent upon us to be prudent
with the projects that we review. But um, I also think
that um, around the country and perhaps around the globe.
Um, we aren't uh, we have an overbuilt transmission. Um
it's been utilized in the future. We have congestion
today, which means that we've under built transmission
over the years. So, um, but front loading transmission
gold plating, it is not what we intend to do. But we
want to be proactive and have a long, uh uh, horizon for
which we're looking, uh for the, for the industry of
Texas. For the economic development of Texas, and for
the people of Texas. Um,
what else? Um, the resiliency plus factor, I think
is a fantastic um, interim step. Obviously, Commissioner
Cobos and I have had discussions about resiliency.
Um, we're gonna continue to do more to talk about that
here in a little bit. But I think the plus factor is
an important interim step. Um, that I applaud the Staff
for, for coming up with that and for for utilizing
that. Um, we all have to be cognizant of resiliency,
resilient. A resiliency plus factor. Um, you know,
these lines are, could be some of the most important
lines that get built. They will always have a reliability
component, um, but resiliency as we define it in the
future will help us bring the system up quicker in
the event of a major, you know, weather outage or a
major event. Um, and I think the plus factor is a great
interim step in in that regard. Um, I look forward
to talking with Commissioner Cobos about the uh, uh the cost
benefit, um, timelines. Um, in here, I know she had
some some issues on the uh, the time horizon by which
we determine costs for this economic transmission.
Um, I agree that we uh, have to do more than the first
year. Uh, we have to get a better uh, understanding. First
year is always the highest cost. Uh, so if we can average
that over a certain number of years, which hopefully
we can agree on. I know there's an issue of whether
we define it here or we leave it in ERCOT protocols.
But um, I'm ready for that debate. And, and I know that
as long as we move past one, we're better off uh, in the
future than we are today. Um, I also would say that
um, you know, a lot of the things that um, are a
handful of the things that are being discussed in here.
Um, were highlighted in the Brattle Report in 2013.
On ways to enhance transmission planning and we'll
take other things in that regard, um, as we look at
transmission going forward. But um, I believe that uh, this
is a really strong first step. And um, I'm eager to
see what comes out of this. Again we're, we're looking
at transmission planning and transmission congestion
through a lens of having not done any of these for
a long time. So once we begin to look at that, we'll
be able to see what comes out. And take the next proactive
steps in solving the next set of problems. But we'll
identify these with this rule um, and have a long term
process in place for this. And uh, that's really a great
step for Texas in my opinion. Thank You. Well put, iterated and improve.
- Yeah, sure. Thank you, Commissioner Glotfelty, for your
feedback. Um, I agree with everything you said. Um, I
think it's, you know, I want to thank David Smeltzer
and Rama for their work on this rule. Um, it's very
important uh, legislation that we have to implement. And
uh, a lot of very important pieces in there, with respect
to economic criteria, reliability criteria and resiliency.
Um and, I do appreciate the Staff working to address
the many issues that we had, um, addressed in the prior
iteration of the rule. So thank you for that. Dave
and Rama, and um, everybody else involved. Um, as Commissioner
Glotfelty referenced, um I, there's the uh, on page 47
of the rules, subsection A. There is a reference to um,
where the new congestion cost savings test is discussed,
as back for background purposes. When this rule is adopted
if we adopt this role, the um, ERCOT will be using the
generator revenue reduction test and the production
cost savings test. In the interim while ERCOT develops
a long term, uh, congestion cost savings test. And so,
the rule spells out that the congestion cost savings
test must include: analysis of whether the levelized
ERCOT wide annual congestion cost savings attributable
to the proposed project are equal to or greater than
the average of the first three years annual revenue
requirement of the proposed project. And so I, I appreciate
Staff putting an average cost in there three years.
And I'm not necessarily opposed to the average of three
years. Um, the only um, I guess point of discussion I
wanted to have was, you know, whether we wanted to put
the average three years of annual revenue requirement
in the rule. Um, or would we want to, um, have ERCOT
put an average annual revenue requirement cost. Um, in
the protocol that develops the new congestion cost
savings test. So that we have flexibility in the future
without having to open the rule through and modifying
the protocol to adjust that average annual revenue
requirement. Um, in the future and that way, ERCOT can
um, you know, develop the test and put in that average
annual revenue requirement over there. And if we decide
to move the dial up or back. Then they can just do
that through protocol change rather than us having
to open up the rule. Uh I mean, I think your sentiment
towards optionality is good. But I know, I think, I
think the Staff captures that, by starting out at the
first step, like Jimmy said. Like this first step is
an old existing framework, that everybody's familiar
with. And then as we move to the next step we can
answer the questions that you just, you just articulated.
Uh, but I think for, for this for today and this, this
version of this rule. I think it's probably a good
start to go with the old framework that everybody's
familiar and comfortable with. Well, right, And, and
that's I agree with that. And, and so the new congestion
cost savings test hasn't been developed. Right. And, and so
that will and so ERCOT will be developing that, you
know, through the protocol process. And so what, what
the direction and this rule is, is just some direction
to them as they build that test out, out there. So we're
we're gonna work on the GR. We're gonna use the GR test.
The production cost savings test right now in the interim
as you described. But as we're building, as ERCOT is
building the new test, does it make sense to go ahead
and put that three year average in the rule? Because,
if ultimately they build a test out at ERCOT. Um, and
they decide that well maybe we should after getting
more data and they go through the, you know, stakeholder
or ERCOT Staff review process of the new test. That
maybe we should go to five year average or stay at
three. Then they can do that out there without having
to come back and say Commission open the rule and adjust
that. Any of those protocol changes would come back
to us anyway. But it's in rule and we'd have to open
the rule. The protocol change would be in the system. I think the plan is to open the rule
down the road, anyway. That was what, Jimmy was talking about then.
An iterative process. We're gonna have to at some point in time. I mean either way I'm good, I
just wanted to have this discussion. Because, you know.
- Yeah, that's right, and so whichever, whatever you
guys decide on this. I mean, it's set, you know, two
sides of the equation, cost cost savings. So right
now, for the cost savings part, it's the same six year
load study that it's always been. And that can be modified
by ERCOT, if they want to adopt a new load study. Um,
and we would have to approve that under SB2 approval.
And then, the rule is written on the cost side. Old
test is one year, like it's always been. New test
is average of three years. And so whether or not we
want to uh, put the three in this or not. Either way
the Commission would have approval authority on the
back end. But I'm not, uh, if we want to leave the
three in here. I'm not afraid of reopening the rule
to adjust it later if we need to. Um so It's whatever
you, whatever you guys decide. Uh, Staff is happy to
go with on this point. I just want to put out
there for discussion. Sure, sure. Just because I'm always looking
for flexibility and you know, an efficient process.
And I'm good either way. Um, I just wanted to have the
discussion on it. Um, because ultimately, you know, I know
you're very busy and uh, the less rulemaking the better.
And, and rule making involved the Administrative Procedure
Act process and stakeholder comments. And, but we're
going to reopen the role either way down the road.
And I mean that's fine. I just wanted to kind of have
the discussion. I could not appreciate that sentiment more. So
uh, thank you very much. Well and, and I'd also highlight,
we've had at least three Legislative letters on this
rule, um filed. There's a lot of opinions out there.
Um, Staff tried to stick to the uh, letter of the law.
They did, um and and then we tried to uh, utilize good
policy making principles. Uh, on the way in, on some of the
more pressing. Uh the issue of resiliency. Which they
adapted to all of our uh, concerns and wishes. As well
as, broad high level concepts discussed in um, different
conversations on Legislative intent. I would say for
the purposes of flexibility, there is such visibility
on this particular topic and such interest and passion.
Within the policy making body down the street, which
is about to convene for 140 days. In which case,
they can direct us pretty uh, broadly and black letter
law. Um, that it seems prudent for the time being. Staffs
path is a, is one that is the most visible and transparent.
Um where we can, we fully intend to take this up in
the future. To refine and, and and employ reforms as
better information becomes available. But uh, it seems
like the path forward through rulemaking. Uh is appropriate
given the Legislative input we have received thus far. Okay.
Yeah. And uh always, always appreciate, uh, opportunities for flexibility
and efficiency. And Smeltzer always appreciates, um, less
rule makings less frequently. And as Commission McAdams
said, we always welcome clarification from the Legislature. You betcha.
- No, that's great feedback. And I appreciate, you know, um
I don't know if you have anything Commissioner Jackson?
But I just wanted to put that out there and see what
you all thought. And I appreciate the feedback. And I'm
good either way, you know, I just wanted to put it
out there. Yeah. Okay. I think we've got a good, good spot
for a, we're in a good spot for today. Uh, let me just say
one thing. And that is, you know, I think that's a good.
I think Commissioner Cobos brought up something that's
that's a good thought. You know, now that we, we have
an independent board ERCOT. Uh, that's not stakeholder
driven, but it is driven for the people in the reliability
of the State. Some of these things may be able to go
to ERCOT. Uh in that regard, in their protocols, because
we know that they're not gonna be self interested.
They're gonna be, you know, for the good of the State.
So, um I think it's a, it's a good uh type of
discussion to have. Not only on this, but other issues
that go forward. Because. Absolutely. As you said, Mr. Chairman,
you know, the protocol changes will come back to us
anyway. Yeah. And to your earlier point, this whole
economic test has the, universe of economic test
has got a lot of dust on it. So there's value in
putting one foot in the water, seeing what happens. Getting
some market feedback, and then uh, adjusting course from
there. Right. Okay, um next topic. Um, page 48. And just, for some
verification, I think this is important. Um as, as we
were discussing, the first interim step is for ERCOT
to use the GR test. And, and the production cost savings
test to evaluate economic projects. And in the long
term, um, once they developed a new congestion cost
savings test. They'll use that new congestion cost
savings test, and the, and the production cost savings
test. And the rule says that a project can pass either
or. Um is Woody here? Yeah. Woody, can you please come up?
I think this is an important discussion to have. Um.
Uh so Woody. Um, the generator revenue reduction test,
and ultimately the new congestion cost savings test.
They're, they're both consumer benefit tests, that are
intended to address generation, I mean I'm sorry, load
pockets. And the production cost savings test is intended
to address a generation pocket. They work differently,
right? That's correct, yes. Um so if, if you were to require a project to
meet both tests, how would that impact transmission
planning for you? I think it would make it much less
likely to approve economic projects, if they have to
meet both tests. So if you have an and, it's much less
likely to that you're gonna approve economic projects.
- What would you also state your name and who you are with? I'm sorry. Woody Rickerson
with ERCOT, Vice President Planning. Okay, I think that's
important to note is we're trying to, you know, move
from the backlog, of um, or get the economic project
evaluation kick started again. In terms of, you know
the two tests look at two different issues. And requiring
both, as I was trying to understand from you without
what, how that would impact transmission projects.
Thank you for that. Um, the next issue um, is on page
50, the reliability criteria.
And that is subsection 2.
Its Staff made some modifications from the prior proposal
publication, I think are important to highlight. Um,
in the reference language says, the forecasted load
growth and additional load currently seeking (inaudible)
connection must be substantiated by quantifiable evidence
of projected load growth. Um Woody, from your transmission
planning perspective, um, would that allow for TSPs,
for transmission companies to uh, submit third party
independent consultant studies to um, justify regional
load growth? Yes, I think it would. I think we used those
in the past, and I think that's something we could use
in the future. Great. So that, that the whole portion
of the reliability criteria about additional load seeking
your connection is important addition. As we are
growing State, and we want to facilitate additional.
Um, you know we want to make sure we have a little
bit of flexibility. Obviously balancing consumer costs
and transmission build out is very important. But um, this
edition by Staff I think is important. Because it does
allow the transmission companies, as I know, Oncor has
done in the past for the Far West Zone, through the
IHS Study. Um, has submitted prior past this, this
new language does help, uh, provide some flexibility. And
there for, the TSPs to come back with some
studies and other information there. So, thank you for
that. Um, with respect to resiliency. Um and I do thank
Staff for working on developed, you know, develop
further refining this language, so that resiliency is
a plus factor rather than the third test. I think the
prior language was gray and kind of, I had some concerns
with it. And I do appreciate your hard work on that.
Uh, Dave um. You know, Woody from your perspective, there's
a proposed resiliency evaluation framework. That Staff
has developed in the role provide you with sufficient
guardrails to um, conduct your transmission planning process.
That doesn't sort of open the floodgates to mass amount
of transmission overbuild. Yeah, I think the clarification
that was made that it's not a third path, it's almost
view it as an accelerator for existing resiliency or
economic projects. I think that, that makes that clear.
I think we can work within that. And probably the, the
latest example, I think that's very important to highlight
is the long term Lower Rio Grande Valley Project. Right.
Yeah, I think that's a that's a really good case study,
for how to use the resiliency criteria. Fantastic.
Alright. Thank you Woody. All right. Appreciate it. Um, and just
in closing as Commissioner Glotfelty noted, you know,
this is an interim step on resiliency. Right? And so,
there's much more that needs to be looked at from the
resiliency angle. And I do look forward to working with
you Commissioner Glotfelty. On taking a more comprehensive
look at this issue, um, here in the near future. Good
points all. Thank you for laying those out. And more
importantly it's, it's been a bit now, but thank you
again for spearheading that Rio Grande Valley Project.
I was down there a couple of months ago. Uh, and it is
not only critically important to that part of the State,
but to the entire ERCOT ecosystem. Especially with
the uh, storm systems and hurricanes, hurricane risk from
the Gulf. And the loads that are coming down there. I mean, it's amazing what's
what's staring RGB in the face right now, so. Critically
important. Thank you for that. And I'm glad you had
an opportunity to go down there. I think it was important.
- Hugely important. We had, had a new Corpus Christi every
year in this State. A staggering amount of growth in population. Several of them
near Corpus Christi, so.
- Yeah, absolutely. But they don't bring the megawatts
with them. Nope.
- All right. Any other thoughts, comments? Other than just
to say? Um, I think a great job on resiliency and it's
been kind of noted that it is interim, but it's also
a first. I think is as David recognized. And you know, I
think so important that it's an add on, and that it's
that first step. And that we've recognized this as being
important and build out, um, for the long term viability
of the system as a whole, right. And so, um, we could
theoretically have, you know, generation, but we need
the transmission and we need to be resilient. And I
think the Staff has done a great job in terms of bounding
it. And actually defining what that is, for this initial
first step. And I, think it's, it's, a great
add on to, um to the, to test either or that will
be used kind of moving forward to get transmission
built. So good job on that. Excellent points. Thank
you. All right, any other thoughts comments or a motion to approve
the proposal for adoption? I would move to approve
the proposal for adoption consistent with our discussion
here today. Second. Got a motion and a Second. All in
favor say aye. Aye. None opposed, motion passes. Thank
you all. Smeltz and team, well done. Well done David. Thank you.
Next item please. (item:13:53911 ADER Pilot Project) The next item is item 13, project
53911. Aggregated Distributed Energy Resource, ERCOT
Pilot Project. Commissioners McAdams, and Glotfelty filed
a memorandum.
- Thanks sir. Thank you members. Um Commissioner Glotfelty
and I filed a joint memo identifying areas of customer
protection to be given as guidance. Uh, to market participants
in the ADER Pilot Project, and that's what's before
you. Underlying this guidance, is the expectation that
established customer protection rules and policies.
Will be applicable to interactions between uh, the distributed
energy resource aggregators, who are participating in
the pilot, and their premise level customers. And uh,
the overarching uh, issue here uh, enshrined in the memo. And
encapsulating the memo, is that we're in uncharted waters
with the Pilot. And we are dealing with new uh, energy
companies, energy actors who are now engaging and will
engage with our customers. Uh at, at their homes and at
their businesses. And under a uh, at a definitional level.
We just want to make sure that there is an expectation uh,
set out on the front end by at least several of us.
Um in the joint memo and potentially all of us. Uh, in terms
of discussion and comments, that uh, basic foundational
principles of customer protections still apply. And
we will consider that as the pilot rolls out, and becomes
active in January over the next year. Um, and that as
we start to hear feedback on how customers are uh, either
satisfied or dissatisfied with their interactions, with
energy companies. That uh, we do consider uh, protections
that are in law and in rule to uh, to be complied
with. And so, that's what you see in the memo. Um, we
have engaged with Staff. I consider this a product
of the task force engagement where Staff is participating
in that. Um that, you know, they they raised concerns
that we want to make sure everybody's speaking the
same language. In terms of how they engage with both
customers and how they engage with each other. From
a QSC to the retail electric provider. And uh, ultimately
we hope that this can be enshrined in and encapsulated
in both rule and potentially law. When we know more
about what we're dealing with, in terms of the business
practices of these aggregators as the Pilot launches
and potentially could be scaled. So I think this is
a good first step so that we're all speaking the same
language. But, I look forward to any feedback and I
sincerely appreciate the support of Commissioner Glotfelty
and Staff, and our staff to catch this on the front
end. Um, so that expectations are level set at the
inauguration of this, this new first of its kind program.
- A good addition to what is an unprecedented program
in ERCOT. Y'all (inaudible) a lot of pieces very, very quickly.
Uh. We want to make sure that none fall off the table
and break. Well and I know uh, Commissioner Glotfelty
mentioned it earlier, but in our earlier discussion.
Um, but it's, it's the same theme, that you all are discussing
today. At the, at the end of the day, this is all
about delivering reliable power, at the lowest cost to
customers. Yes sir. With the emphasis on customers. That's homes
and households. Uh, that's what this is all about. So
thank ya'll for putting that extra consideration
for those customers on this unprecedented project.
- Let me just say real quick. Um, first of all, I think
that uh, the task force has done a remarkable job. Um,
highlighting the issues finding the path forward for
this Pilot. And um, the issues that have come up. Um,
I think there was a little intimidation factor from
the Staff early on. They were invited to a bunch of
meetings. Uh, but when you have two Commissioners kind
of working on this thing, it's like a new paradigm
here. And like, do we really, are we really able to
say something or not? I think we've got it all straightened
out. The Consumer Protection issue is one of those
that they brought up. Uh, and I'm very glad that they
did. Thank you all for uh, for making sure that, that
rose to the top. That we uh, we've addressed it both
in uh, the task force and uh, enshrined in the memo. Um, that
uh, Commissioner McAdams did uh, such a fine job writing.
Um and I just initialed. Um, but um, I think that um, this
again, you know. I can't, I'm very pleased with the
fact that, you know, Staff is totally engaged in this.
They think differently than we do up here. And from
the industry and it's a very important perspective
to consider on all of our issues. So I'm appreciative
of that. This is gonna pay big dividends later on. When we
start talking about more megawatts and how to, how to
expand this. So uh, the engagements, awesome. That's the
merit of a pilot project. We identified these issues
when they're little issues before they become big issues. Right.
- This is working exactly how we, how we hope to do.
- Thank you for looking at that issue. I think customer
protection, as we have new entities into the market
or, or new arrangements that are engaging with consumers.
It's important to look at the Customer Protection rules.
I know we did that a couple of years ago with the
broker registration. Uh, we were involved in it when I
was at OPUC. And it's always important to make sure
that there are protections in there for the consumers
with these new entities and arrangements entering the
market. That was foremost in our mind, that experience.
You know, we just wanted to get ahead of this, rather
than behind. And again, no formal action is necessary
on the part of the Commission. This is a communication
strategy that we were rolling out earlier, rather than
later. And trust are participants in the Pilot Project
are watching and listening closely. I think they're
committed. They are committed. And uh, as always a good reminder
that nothing, uh, around here happens without our dedicated
and competent Staff.
- Thank you, Chairman. Um, and just on on behalf of the
Staff, I wanted, I wanted to thank Commissioners McAdams
and Glotfelty. Um for their leadership and their flexibility
and patience as we create this new paradigm of Commissioner
lead projects. Um, I think you adaptly described it.
It was, it's not just the Staff, but the stakeholders
as well. Um,getting used to an environment where uh,
Commissioners are are leading policy discussions at
the workshop level. And um, you have each spent a lot
of time with Staff, um you know, helping us work on
processes to make that run more smoothly. And um, we
we really appreciate it, and thank you for your leadership
and guidance on this issue. Appreciate it Connie, absolutely. Of course
nothing gets done without Connie. Or approved. Or approved.
- All right, thanks all. Uh, I think 14 was consented. I don't have
anything for items 15, 16 or 17. (item:18:Update on ERCOT Transmission Planning Reform) I understand Commissioner
Glotfelty has some comments on item 18. Yeah, so, uh
in, in the uh, continuing the vein and discussion about
transmission planning. I'm excited to give just a few
updates. Um, this isn't gonna be long in depth policy
discussion. But just some things that we've been, been
working on in the process, um, to help solve some transmission
planning issues. Um, I want to assure folks that we're
gonna take this methodically and we're gonna solve
issue. We're not gonna create solutions to problems
that are not existent. Um, I think there's a, a uh
some of these um, issues um, when you look at the transmission
planning process at ERCOT and at the PUC are not problems.
This is just a long term process. It takes a long time
for a reason. We're gonna try to shorten it, but we're
not gonna uh, solve a problem that's not there. So, um.
A little bit about where my mind is as we go forward.
First of all, um what we did today by approving the
the implementation World Center Bill 1281, I think is
a fantastic first step. As I said, um, the identification
and evaluation of economic upgrades does a lot of things
for our market. Um, not only economically but on the
reliability side as well. Um, it will eliminate uh, some
of the most costly generic transmission constraints.
Uh, we think that that will be a critical outcome from
uh, this economic analysis. And um, we all know or I
hope we know that um, this isn't a solution for fixing
every single generic transmission constraint. And every
single constraint around Texas, because we've always
had them and we always will in the future. So, these
are to fix the most important ones that are costly
to our consumers. Um and, and the Senate Bill 1281 rule
will help us do that. Also fixing transmission and
GTCs is not a um, a solution for poor generation
citing decisions. So, it is not our responsibility and
that of every ratepayer across the State um, for um,
uh, to fix major transmission constraints that get created
as a result of poor sighting. So just keep that in
mind. And um, I have a discussion item here in a minute
that I'll get to that might help that process that
we've talked with ERCOT about. Um, other there are
just a few other things. First of all, um, as I've said
in the past, I believe we should be better stewards
of our limited rights of way. As our population grows,
we have to think of higher voltage lines. We have to
think of utilizing 765 lines or HVDC lines, within
ERCOT. Obviously, right now we only have DC ties
outside of ERCOT, but how we would utilize them
inside ERCOT is a totally different ball game. It's
a totally different animal on how we would, uh, plan
for this system. And ERCOT has, has teed that up with
um, the initial indication of studying an HVDC
line from West Texas, to solve the West Texas export.
Um, challenge and I applaud them for doing that. But
we've got a lot of work to do in that space. And
I think that um, this is not a directive that we will
use HVDC all across the State. There have to be economic
factors there as well. But um, there are places, we
are a big enough State that HVDC projects can be of
huge value to our consumers. Um, in our discussion with
ERCOT about uh, these higher capacity lines um, and HVDC
lines 765 whatever. Um, I've asked them to host a series
of meetings with industry and um, different stakeholders
and vendors. To really get down to the nuts and bolts
of the issues that need to be resolved, either at the
ERCOT process or at the PUC, to make those a reality.
So um, ERCOT has agreed to do that. I hope uh, early in
2023, we will begin that process. Woody, I appreciate
your, your efforts. Um, and that of Pablo, who is on
the same page. Um, that pushing more power down our existing
rights away is a really important objective going forward.
Um, I would say it's my opinion that going to a higher
voltage is uh, it's not really a debate. It's something
that we're gonna have to do. We're gonna have to look
at it very seriously. Uh, up to this point, it has always
been a uh, well maybe, but we'll always fall back to
345. And I think as we go forward now. again with population
and load growth, we need to think more seriously about
it, and believe ERCOT is doing that. Um, we've taken
a step today on defining resiliency, um, in the long
term. Um, we are gonna be doing more on this, this is
a buzzword kinda like smart grid I think. But uh, the
reality is resiliency has um, a very important piece
and transmission planning. And that is what are those
limited numbers of lines that really help um, ensure
that large population centers have the power that they
can get during the most extreme times. Um, and um, that
could be a weather event, it could be a cyber attack.
Um, but but going down this road of defining resiliency
um, is uh, there's a lot of things under resiliency modeling
and -1,-1 and -2, I mean it all gets into the weeds.
But the fact is that we're kicking it off, and we're
going to do it. Um, Commissioner Cobos has uh, has a
very big interest in this. And uh, is eager to help. And
I'm, I'm eager to work with her uh on, on resiliency. Um,
as we go forward here. Um,
the issue of technology has come up. In fact my first
memo that I wrote here was on dynamic line rating.
A very, very important issue to me, I say that in just
but it's really pretty, pretty cool technology. Um, ERCOT's
let me know that uh, we dynamically rate uh, in the neighborhood
of 65% of our lines, and that's a higher percentage
on 345 lines. Um, part of this issue, um, in my
opinion is we probably don't get credit, or ERCOT doesn't
get credit. TDSPs don't get credit for the amount
of work that they're doing with this technology already.
So, it is a huge benefit that we are utilizing this
technology. There are other technologies that can help
us um, make the system um, more efficient um, and resilient
as well. That will be digging into facts, devices and
synchronous condensers and other things, that will improve
the system. Especially as we grow to a more intermittent
type of resource. And to your point, I believe that
on dynamic line rating, ERCOT is a leader in utilizing
that technology not only in the US, if not globally.
- Absolutely. I mean I, I think globally, but my guess
would be that if they are the leader in the US, then
they're definitely the leader globally. But um, we've been
way ahead of the rest of the United States. And that
and, just to get the numbers out there and show that
we are um, utilizing these technologies is a valuable
component to having an efficient transmission system.
Um, the uh,
these technologies may be um, I say dynamic line rating
facts, devices, synchronous condensers. Maybe a solution
for some of our GTCs, where we have major stability
problems. Long lines that have don't have, that don't
have interim voltage support but are needed. Um, this
is an area that we're gonna continue to look at. It's
my belief that we ought to have them identified. And
we will in the, in a grid stability study that, that
ERCOT does as a part of the resiliency exercise. Um,
and if we need to, we ought to be able to order
the transmission companies in order uh, to fix these. Um,
and it's that's a, a new area where we would order it.
But, I think it's important for the system and for us
to consider. Um finally, you know, the what 1281 does.
In terms of how we identify load growth, how we look
at third party studies is, is a, is a sea change in
my opinion. Um and hugely valuable component to how
ERCOT will look at these lines, uh, in their transmission
planning efforts going forward. We'll continue to look
at possible improvements at ERCOT and at the PUC. Uh,
Commissioner Cobos, informed me that she and her staff
had looked at some of the CCN improvements, um, about
a year ago. Uh, we look forward to working on that and, and
seeing if we can implement any of those. Again, this
is a long process. Uh, we have to make improvements where
we can, but we won't go searching for problems that
don't exist. Um, finally I have uh, I got a couple of
questions for Woody. If you don't mind, would you come
up? And um, you know, there's one area that I, that I
want to have a discussion about. And um.
- Woody Rickerson, ERCOT, yeah. Thank you, Woody. Um, is it right
that proper generation sighting can solve transmission
constraints on our system? In a lot of cases, yeah.
It's a major part of solving congestion. And that is,
that some congestion is created by poor citing decisions
or more generation going on, you know, I guess the
far side of a constraint. But it can also be resolved
resolved either by building transmission or by better
citing decisions, is that right? That's correct. Um,
so I know other regions have done this and perhaps
ERCOT has, has done this in the past. Um, but is it
possible for ERCOT, to identify the best places on
the system?
Where, where new generation could be cited in order
to reduce congestion and help the system as a whole
operate more efficiently and better?
- I think ERCOT can provide some, some uh, insight into areas
of the system, that if you were to put new generation
there would not be any congestion, empty space there
for generation. The part we're not really going to
have much insight on, is uh, are the other utilities
there too? Is there a gas pipeline there? Is there wind there?
There's a solar there? That kind of thing, but as far
as what the grid has. Um, if you, what, what kind of
generation could be added at different places in the
grid without causing any congestion. We can certainly
do that. And, and that could be a solution to transmission
congestion. Certainly, yes. So what I'm trying to highlight here is
that transmission problems can be solved by building
transmission and building generation. Sure. And that proper
generation sighting is something that we can utilize.
And in my belief, we should utilize and ERCOT should
utilize to reduce transmission builds. And, and you believe
that there is something more to be gained other than
analysis of locational, marginal prices, you know,
that they already look at. Because again that, that
reflects congestion and that's the foundational principle
of what they do, right? So there's something more to
be gained from studies and evaluations on the part
of ERCOT, they'll see more. Who are you talking? I'm talking about
the generators? Well listen, the generators have a
a, an incomplete set of data um, compared to ERCOT. Okay.
- Um, ERCOT is looking at a system as a whole. Um, as opposed
to where I want to build a generating facility to make
the most money. To Will's point, I think that's all
those LMPs, are also a very good market signal
for batteries. It's a whole lot to put about. It's
a lot easier to put a battery behind some congestion
that is a pipeline, you know gas plant or something
like it needs a lot more acreage. Uh, which is fantastic
if we can get quick responding generation resources
behind those constraints. Uh and, and the economics
drive it, that's the mark, the mark, it drives that
that's one of the great benefits of LMPs. It would be
my hope that that we could um, have ERCOT do that. Um
and, and publish something. Um, so that we can uh, inform
the industry of good places where we might cite worst
generation might be cited again. This is a transmission
piece in my opinion, this is how you solve congestion
by better sighting of generation.
Um and finally, you know, there are some other areas
that uh, you know, ultimately offshore wind um, in Texas'
might happen. Um, interesting discussion I had the other
day with someone that has built in the North Sea. And
I, asked them how they deal with hurricanes. As might
we might encounter in the Gulf of Mexico, and they
said, well in the North Sea it blows 90 miles an hour
every day. Like okay. That's unique perspective. Um.
So, uh, a lot for us to learn in that regard, but
but it's again, a different animal on who pays and
and how offshore transmission might be uh integrated
into a ERCOT system. And um, something that will, will
look at it, it's probably not the nearest term issue
to tackle. Uh, because Texas has a lot of land. Um, and the
cost of onshore wind is probably lower than offshore
wind, uh but we'll see. So if that's, if that's gonna
change going forward anyway. Um, that's kind of the
end of my update. Um, this isn't a uh, um, this is
a uh, kind of an update to where we're going on these
things. And um we're doing a ADER
Task Force. We'll work on some of these with ERCOT,
with others. And uh, try to make the system more efficient
and planning horizons more appropriate for what Texas
is looking at in the future. Commission Glotfelty, just
got a few things. Um and, thank you for tackling the
transmission efficiency. Um, review that you're, you're
doing. I think at various times throughout the last
year and a half, I've looked at different angles on
trying to improve that process as well. Obviously ended
up using statutory authority to having the Commission
use statutory authority to order the second circuit
that has never been used before. So, um as you're looking
at, at that gaining efficiencies. And I appreciate you
saying that you're not trying to reinvent the wheel
or fix problems that don't exist. I think that's important
because we do build transmission faster than other
markets in the country, probably in the world. Um, and
so we don't want to, you know, create problems where
there is not problems. And, and I'm glad you, you are
definitely focused on, on just trying to make it more
efficient. Um. Can I interrupt you real quick? Just to
add a point to that. So, um, while other areas maybe
stuck around the country may be stuck on transmission
planning or long lead time transmission development.
Um, according to our court system planning report, and as
of August 31, of this year, uh currently reviewing
$394 million worth of new transmission projects. Projects
endorsed in 2022, is 2.2 billion. All the projects currently
in engineering, routing, licensing and construction
is over 9 billion. And projects energized in 2022,
is approximately approximately 1.5 billion, as of June
1st. So Commissioner Cobos, you're absolutely right.
We are building this. It's not that we are stuck. We
are building a lot and we need to be cognizant about
that going forward. But we're improving something that
works, we're not improving something that's broken.
And I think a key aspect of that, and you're keenly
aware with this, Commissioner Glotfelty is that the
other markets um, have multiple states, and within the
market. Right? So multiple PUCs, and then you have
to get certain approvals from FERG. Because we have
just one PUC in Texas and we're not regulated by FERG.
On these matters, you know, that's, that's, that's
how we are much more efficient in transmission build
out in Texas. And that's a very key distinction from
the rest of the markets in the United States. So, um
I thank you for your work on that. I think, you know
um, as we sort of plan forward on kicking off, you know
ERCOT starts reviewing economic projects. And um, resiliency
as a plus factor and everything. I think it's important
that, you know, um ERCOT Staff continues to, you know
build up to whatever resources they need . To be able
to more efficiently um, review those projects. And get
things done within the 150 day deadline. Um in the, in
the protocols. Um with respect to resiliency and you
highlighted subsequent condensers and the voltage support
they provide. As we have a huge State, with long lines
that need that stability. I think one thing we got
to be cognizant of um, that we looked at several years
ago, was the interaction between subsequent condensers
and um, inverter based technology, like solar. And the
potential issues that can result there. Um, but as we
look at um, you know, what can what equipment can be
added to stabilize the system. I think that's, you
know, something that I know the Commission looked at
at nauseum a few years ago. Um and, so because we're
gonna have a lot of solar on the system. And so FYI,
Um, and um, and you mentioned the CCM process. I
think we have had some discussions on it. We, we did
a lot of research on what, um what, can be done on
our end to make the CCM process more efficient. I know
Connie we had some discussions, you know, maybe trimming
down the environmental assessment requirements. Um.
environmental assessment requirement and CCN application
some. And there's some nicks we can make, you know,
but the fact of the matter is with project that's deemed
critical for reliability, you're not going to really
be able to trim anything. Um, I think the trimming could
come in the regular transmission projects, that um, come
before the Commission. Where there could be some trimming
um, and some procedures that can happen at the Commission
to make things more efficient before we farm it out
to refer the case out to SOAH. But, the but I
do agree with you, I think the majority of the um, the
time is taken probably at ERCOT, and with, with construction.
But I'm happy to provide the analysis that we've come
up with, and see if there's any nicking we can do on
that.
- Thank you. Hey Mr Chairman. While we're talking high
level thoughts, um, in front of the public. Uh, do you
have a thought on a federal permitting bill which gives
FERC authority, uh, for citing transmission. And uh, do
we need to discuss that today or I mean because it.
- Can ERCOT? Uh anywhere in Texas, I mean we have four million customers
in non ERCOT areas of Texas. Um and anyway, so this
will be coming up, I hear in the lame duck session
of Congress. And positions are being taken by Commissions
all over the country in order to, you know, help inform
their Congressional delegations. But, do you have a
thought on it? Well, I believe that FERC has jurisdiction
outside of our crop but not inside of our crop. Okay, but
on sighting of transmission, because that's kind of
a new thing for FERC. So I mean, as a uh, as
a developer of interstate transmission lines, it's
a very frustrating process. I think the fact that um,
the issue that other states have is the federal government
kind of trying to understand. And how they would cite
all interstate lines and I think they're biting off
more than they can chew. Me too. I really think that
if we leave the bulk of the transmission sighting and
process with the states, um that is the right approach. Okay.
- But I do believe that there should be a single um, network
overlay. I, I think FERC and Congress are speaking way
too big. That they haven't defined the problem. If the
if the problem that they're trying to solve is a sharing
of resources across our entire country. You don't need
multiple networks to do that. You need one large HVDC
network to do it. That would be one set of lines
you know, that would connect, you know, those resources
and those uh those loads. So I think, I think everybody
seems to be fighting about a big problem that's really
only one line. And we can still talk about that, but
um, it's still gonna be a ways before. Um I mean, uh
and in uh, in full disclosure, I was the one who helped
write the national interest electric transmission corridor
language. That was initially in the in the 2005 Act.
Because we couldn't get states to um, look outside their
borders even. As our TOs were growing outside their
borders. So, um but this is an amplification of that
as I understand it, kind of what they're attempting
to designate. You know, I think the way that it was
implemented initially. Uh, so we we passed this in 2005,
and exactly zero projects have been built utilizing
that, that that that language. So, um I don't know
if it is a huge expanse of growth or not. But this
doesn't solve the cost allocation issue that has to
be resolved, in that in that debate also. So, um you
know, I think that the vast majority of the sighting
decisions ought to be at the State level.
- To your question Commissioner McAdams, I'm highly confident
that we always prefer our Legislature to make those
decisions. Uh, and keep as much authority and decision
making, uh, with our, our Legislature and Governor. Uh,
and less of it in D.C.
Alright, there's no formal action on this item. Commissioner
Glotfelty, always appreciate the updates. And uh, more
importantly appreciate your leadership on all things
transmission. And of course, you bring a wealth of experience
to bear, both in the public and private sector on that.
So, thank you for spearheading all of those efforts.
No formal action item 18,(item:19:TRE and NERC discussion) which brings us to item
19. Very quickly. Thank you, Woody. Very quickly, I just
wanted to say that as the uh, designated board member
for the Texas Regional Entity. They haven't had much
of a presence here. I've noticed. Um, and we're trying to change that.
Um, uh both Chris Echo, from OPEC and I currently sit
on that board. Um, but I've invited Jim Albright to come
talk to us about the, what's going on at NERC. And
what's going on within the Texas Regional Entity at
the next meeting. Um, some of those things that I've
asked him to talk about are, um, inverter based resources
and what Mark is doing in terms of new rules to ensure
that IBRs, um, do not have um, voltage problems
on the system. So can we use different types of inverters
that are good forming. Um, or they just are they helping
the system, are they just drawing from the system?
So he'll, he'll talk to us about the reports that have
come out. Um and the new rules that that NERC has been
working on for inverter based resources. And I think
it'll be, there'll be no action on it. Um, but I just
want the Commission to be informed of what's going
on at that level, and in that side of the business. Uh, very
much look forward to hearing anything at all from them.
And especially on the inverter based resources as Commissioner
Cobos acknowledged earlier. With the extraordinary amount
of wind and solar, we've got that's a huge issue that
is growing rapidly, that needs to be addressed. Look
forward to look forward to that. No formal action item
19. We don't have anything on 20 or 21. Which brings
us to item 22, Mr. Journeay. (item:22:52935) Item 22 is project 52935,
is the calendar year 2020 Rule Making Calendar.
No formal action on this item, but with the adoption of
today's rule. I want to recognize that at this point
we have completed a total of 22 rulemaking since the
end of last session. Which is at least three times the
amount that this agency does. And we've done it with
three times the amount of work on rule making with
the same Staff. Which is an extraordinary amount of
accomplishments. Uh, I know there's been a lot of vacations
and holidays missed to get that done. The Legislature,
Legislature gave us a heavy burden to carry a lot of
work to get done. And it is outstanding that this Staff
has gotten that done in time for this session. So big
thanks to everybody in rules and projects, and all the
subject matter experts. It knocked it out uh, apologies
to Smeltzers new kid. Who spent a lot of nights uh, stepping
on his keyboard. And uh, want to also acknowledge the
fact that, this agency needs more resources. I got a
question from the Media about that yesterday in our
press conference. Uh, the Sunset Report acknowledges that
this agency needs more resources. The Media has noticed
and observed. This agency needs more resources. Uh,
while, while this team of folks has done extraordinary
work in a short amount of time. Uh we, we need to
give them some help. I know the Legislature is hearing
that message. So we, we need more resources. We know
what happens when we don't have the resources we need.
Uh, and so look forward to having that discussion as
we get into session. Most importantly, uh sincere and
heartfelt thanks to you all for a tremendous amount
of work. And a great, great deal of accomplishments.
Connie started clapping, do what Connie says.
Alright, No, no formal action but many thanks. We don't
have anything on item 23. (item:24:Sunset Commission update) We do have an update from
our Executive Director on item 24. Thank you. Mr. Chairman.
Good morning Commissioners. Um, I'll start with Sunset,
since you mentioned that Chairman. Our comments and
replies to the Sunset Staff reporter due today, Will
be filing those by three o'clock. I want to thank you
all for your input on our responses. Thanks Staff for
all the tireless work over the last year to get us
to this point. Um, as you mentioned, you know, we have
a resource issue here. And other sister agencies have
what I would call the luxury of dedicating staff just
to work on Sunset. We don't have that luxury here.
Uh, so I want to thank Staff and in particular Tom Hunter,
who has led our efforts with Sunset. You know, a decade
ago when we last went through the Sunset process. He
and I led that effort. And he has done that by himself
this time coordinating everything. Um and, and he has
a lot of other jobs to around here, including making
sure that I stay out of trouble legally. So uh, it's
a it's a heavy burden. And as you all saw in the
Sunset Staff Report, they're recommending six years
for us. So um, Tom doesn't know it yet but we'll be
working on, a on a way to keep him, keep
him around. Or a way to bring him back in six years.
Uh, to be able to work on this again. So I want
to thank everybody. And like I said, also you all for
your input on our responses. I appreciate that. And,
Tom is truly one of the hidden treasures of this agency
- Absolutely a regulatory treasure, if ever there was
one. And uh and secondly, you know as we're always
trying here to attract talented, capable Staff. To, to
improve upon the work that we do, dare I say improve
our agency staffs resilience. Um, happy to announce
that Jess she is filling out her GR Team has
hired a new Deputy Director of GR, Brooke Commit, from
OPUC, will be joining us tomorrow. Brooks, right there.
And you know, this continues a recent trend of us being
successful in attracting talented Staff from other
agencies. Not just at the Staff level of course, but
also at the Commissioner level. So we hope to to continue
that going forward. So we're filling out our team heading
into the next Legislative session and, and very happy
that Brooke is coming aboard. Very thrilled, very excited
to have her. Welcome aboard, Brooke. Look forward to working
with you all. Um, you and Jess, as we go into this Legislative
session. I appreciate the update. I don't have anything
else for our agenda today and we will not go into closed
session today. So there being no further business to
come before the Commission, this meeting of the Public
Utility Commission of Texas, is hereby adjourned.