WEBVTT

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(inaudible)

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(inaudible)

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(item:1: David Smeltzer, PUC Director of Rules and Projects Division, welcomes participants and lays out 1st session objective) Hello everyone. Welcome to the first of 3 sessions

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or the, the first in a trilogy of Legislative

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Implementation Workshops that we'll be hosting today.

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Uh my name is David Smeltzer. I'm the Director of the

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Rules and Projects Division here at the PUC. Uh joining

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me up at the dias, Mackenzie Arthur and Rama Rastogi,

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also from the Rules and Projects Division. Um the reason

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we're having these workshops today is because uh you

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know, the Legislature passed a great. You know, they

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passed several dozen uh statutes that are going to

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require rulemakings. And last Session, we had a similar

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situation. Where we had a lot of rulemakings and a lot

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of them had deadlines. To where they were basically

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sequenced out for us. The Legislature determined what

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the priorities were and we did them in the order in

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which they directed. This Session, they have given us

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more flexibility in determining what order we need

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to pass the, you know, do rule makings. To implement the

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various statutes that they passed. And as Staff is

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working on its recommendations to the Commissioners

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on how we should prioritize these rulemakings. We

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have identified an initial set of rulemakings that

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have either statutory deadlines or real world, you

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know, effective deadlines based on need to get them

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done quickly. But we wanted to give an opportunity

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for stakeholder feedback and public feedback on, you

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know, how we should prioritize the rest of these, the

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rest of these you know implementations. And I think that ultimately

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it will be up to the Commissioners to determine what

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order we do these rules in. But in crafting Staff's

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recommendation. We're very cognizant of the fact that

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we don't run utilities and we don't necessarily experience

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all of the situations that customers do out there.

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And so we wanted to give everyone a chance to let us

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know of any uh anything out there that we should know

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and coming up with our rulemaking schedule. (item:1:David Smeltzer lays out housekeeping information) So a couple

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of housekeeping first, I think that uh some questions

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that we've gotten in advance already is what if I'm

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unable to attend today in-person. And so this is being

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broadcast on Texas Admin. And we did invite anyone to

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file, file comments ahead of time if they needed to.

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But if in watching this, anyone who's not able to attend.

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Um notices something or has an idea for an efficiency

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or whatever. We will be accepting written comments

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in the project until close of business Friday. If anyone

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has additional concise recommendations that they would

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like to make. But I will say that it is much more

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helpful if they're made in-person today. So that they

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can be discussed by the group. Um the other, the other

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question that we're getting is that we often get for

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these. Is, you know, where the Commissioners um some 

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at these workshops. And the Commissioners have all expressed

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to me excitement over this. They're very excited about

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public feedback and I know that they're both watching

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and will be briefed on what is discussed today. But

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just as a, as a realistic concern. We found that people

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are more comfortable telling me that I'm wrong. Than

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coming in to tell the Chairman that she's wrong. And

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so today, I invite everyone to tell me when we're wrong

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about things because that's, that's really helpful.

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Um in terms of how we will proceed today um with these

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workshops. A lot of times we like to use a discussion

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format. Which means if at any point on a topic you

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would like to chime in, you know. It, it you know I, you don't need

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to be invited. Just come on up to the, the front dias.

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And we'll sort of call you in the, uh you know, the

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order that you're here. And should there be multiple

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topics under discussion. Sort of an informal protocol

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that we use is. If you're, if you're wanting to discuss

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something that is currently being discussed, you can

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kind of hold up a one. But if you're just waiting to

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talk about something different, you can sort of give

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me the two. And then it's like ok we'll, we'll get

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to you afterwards. Um, I think that the Legislative

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focus this time by the Legislature was a lot heavier

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in the electric and water spaces in terms of the number

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of um, statutes that we've been given to implement.

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But we wanted to make sure that we heard from all of

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our industries. And so we're starting off with telecom.

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And um we're eager to hear from you guys, if you have

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any input on our implementations. (item:1:David Smeltzer lays out Staff's assestment on telecom rules) Um as far as we,

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as far as in Staff's assessments. There were only three

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items that required uh Legislative action. Um and they

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were, they were listed in the memo, but I will.

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Adrian, can you scroll down a little bit? So we think

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these are the three bills, HB1597, SB1425 and

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SB1710. And as you know, um we already were in

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the process of doing a rule review of our telecom rules.

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In which we accepted um written comments on potential

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proposals to do rule changes. And as was indicated

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in the memo, there are a couple, you know, there are

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upwards of 20 plus rules that we're gonna be amending

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as part of this uh telecom rule review. And so our

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goal was as long as we're doing this, let's try and

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knock out all of these rules as part of the Chapter

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26 rule review. And so far that's we've been, we've

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been drafting to that end. And so um of utmost interest

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to us today. Is uh, you know, if any of these statutes

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we think are complicated for reasons that may not be

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obvious to us from our perspective and might merit

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treatment in a separate rulemaking process. That's

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valuable feedback. But also just any um implementation

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uh, ideas that you have. And so, um I guess by order

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of events. Um we'll sort of go, we'll just kind of

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go down to the discussion topics in the, in the

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in the memo. And so first I would say, is this

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list complete? Have we, uh is there anyone who has

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identified any additional um telecom related legislation

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that needs to be implemented other than what we have

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listed?

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And again, if upon a review, you later learned that

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we have failed to identify anything. You can always

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reach out to us or, or file comments in the docket.

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Okay. Well, that's good news.

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Real quick. The only, the only one I can think of.

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Oh, will you hop up. Just so that, just for the mic,

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yeah.

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And if you'll just identify yourself for knowledge.

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(item:1:Daniel Gibson with TSTCI, question on mapping in conjunction with the Comptroller's Office) Yeah, I'm Daniel Gibson and I work with uh TSTCI. 

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The only thing I could think of. Is that there is the

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project for doing the mapping in conjunction with the

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Comptroller's Office. I don't think that requires any

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rulemaking as far as this goes. But I didn't know if

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that was something that could be talked about or not.

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Or if we wanna do that later as we get closer to

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looking at that, so. Yeah, I think that we agree that

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we didn't have that peg to something that needed a

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rulemaking. And, and uh that's not really the sort

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of thing we're gonna talk about today. But I, I suspect

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that we'll be finished before um, our allotted hour.

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Based on the number of telecom topics. So we can, we

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can discuss that a little bit.

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Perfect. Yeah, if, if anyone's on the fence about

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whether or not they want to bring something up. I would

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encourage you to bring it up. So that we can make sure

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that there's, you know, no gaps in our understanding.

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Of what, what industry uh the public needs from the

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Commission. Um, okay. So the list, the list is complete.

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That's good. Uh is there any um, we also along with

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this memo. Published a memo on the uh, the different

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items that we're going to be including in our Chapter

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24 rule review. And so if anyone has any additional

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comments or questions on which items were going to

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be included or not included. We would welcome any feedback

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on that at this point.

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Okay. Well I think that predictably, I think that telecom

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was, was not a focus. I'm glad everyone's here. So

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I'm just, I think at this point I'll just open it up.

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And say, are there any Legislative items or questions

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um, in the telecom space. That are of interest for discussion

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today?

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Okay. So, oh, yeah. Yeah. Come on up, come on up.

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(item:1.4:Katherine K. Mudge with Mudge Law Firm, concerning VoIP) Good morning. I'm Katherine Mudge with law firm, the

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Mudge Law Firm. Okay. And I do have one question and I, I

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apologize for not having the Bill number. But the Governor

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vetoed a Bill dealing with uh, VoIP. And uh part

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of that provision was that basically that. Uh a SPCOA

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holder or ACOA holder. Uh could utilize VoIP

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for purposes of uh meeting the requirements of uh of

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all the statute and the rules. And um he vetoed it.

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Uh and his message was is basically, based on the,

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the dialogue that was going on between about property

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tax relief. And my question is, is that if in the next

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in this special session. That Bill comes back up and

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it passes, because it passed both uh houses or chambers.

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Will the Staff, how will the Staff or have you thought

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about how the Staff would handle that particular uh

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statute? In the context of either this project or would

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it require a separate project? So that's a good question.

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(item:1.4:David Smeltzer's response and comments on rule implementation) And I will say that we had a lot of Bills to

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review. So I, I you know we focused our attention

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on the ones that we did have to implement. So uh I

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think that's probably a logistical question. In terms

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of, if we've already published. If we, if we've gotten

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to the point to where we've published a proposal, then

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we're sort of locked into the rules that we can amend.

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And uh but I our, our goal would be to get as

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many of these done in this project as possible. So

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if time allows, we will make that. And so assuming

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you're more familiar in the details of the Bill that

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I might be. Do you, if it passes as it was before.

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Is it a bill that you anticipate would be subject to

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a lot of um interpretation? Or would it be a relatively

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straightforward rule making in your opinion? (item:1.4:Katherine Mudge on rulemaking) From my

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personal perspective, it's very straightforward. And

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in fact it would, if anything. It would clarify the,

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the interpretation of current statute. Perfect. So that, that

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so that's really my. I, I just wanted to kind of get

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in my head about how. If something happens during a

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Special Session that applies. Whether it's telecom

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or, or some other Bill. Uh that got vetoed during that

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uh going back and forth. I, I just was trying to get

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an idea of, of how we might want to ensure that um

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those issues are handled in the context of this broader

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rulemaking. Sure. That, that's a great thought.

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(item:1.4:David Smeltzer's comments on comprehensive and extensive rule reviews.) And yeah especially for, for you know. I mean already

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with the number of rules we're including in this project.

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It is expanded beyond what we would have envisioned.

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But um that is based on sunset recommendations, that's

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the way they want us to be conducting our rule reviews.

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They want them to be comprehensive and extensive. And

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so that's the approach that we've taken. And especially

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uh as you know, assuming that you are right that this

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that it is not subject to a lot of interpretation when

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we read it. That's exactly the sort of box that we

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wanna get checked in this, this project. So if it's

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logistically possible based on timing, um we would

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include it. Would that be something though? And, and

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I apologize for, for prolonging this discussion. But

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would that be something that if it does happen? Would

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and, and there are parties that are interested in ensuring

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that the Commission Staff is not only aware of it.

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But to figure out what we would do with it. Would we

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file something in this project? Even though logistically

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say, for example, the proposed telecom rules are already

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out for publication? What would be your suggestion

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let me ask you that? What would be your suggestion?

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The um I have a great faith in uh Justin Brook. To

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of our GR team, to let me to make sure that we

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are have the situational awareness that it, that it

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happened. (item:1.4:David Smeltzer on implementing that new Legislation) But if you do um uh. So I guess there's two, two, one

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in the Chapter 26 rule review docket. I'm not I, I

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would never be opposed to you filing something. Says

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hey this, this new Legislation passed. Just

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make sure, you know, and what would be particularly

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helpful. Is if in implementing that Legislation, we

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will have already proposed a certain number of rules.

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And so if we have opened up the rule that is relevant

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for other reasons. Then that might be something we

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could consider including. And so uh if, if in the

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filed comments. You would clarify which rules you think

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are most affected by it, which maybe that's a simple

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thing, maybe not. I just don't know the issue off hand.

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Um that that would help us make the decision quicker.

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That's great. Thank you so much.

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Sure. (item:1.4:Jason Danowski for Foster, Danowski & Texas Cable Association on conforming changes to Rule 26.111) Good morning. Morning. Um Jason Danowski for Foster, Danowski

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and the Texas Cable Association. And we followed comments

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yesterday on a, on a somewhat related note. Uh which

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is uh on the subject of uh conforming changes to Rule

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26.111. Um and we would propose that, that rule be amended

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to conform with the uh Commission's decisions in the

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demon systems and earth grade cases. Um in which case

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the uh the Commission confirmed that neither PURA nor

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the Texas Admin Code. Prohibited the Commission from

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granting an SBCOA. To an applicant that does not

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provide or intend to provide local exchange, telephone

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service, basic local telecommunications service or

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switched to access service. And could in fact provide

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services such as VoIP, DSL, etcetera. So we think

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uh it would be a good idea to amend the provision to

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conform to that. And uh we filed written comments yesterday

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So I'm not gonna go into a lot of detail. That's I

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can kind of stop there, but I can also speak to the

00:13:55.639 --> 00:13:57.619
other comments we filed, but I don't know if we wanna

00:13:57.759 --> 00:14:00.379
stop there or go on to other subjects. I think that

00:14:00.389 --> 00:14:04.979
we're, we have the time to entertain uh other pressing

00:14:04.989 --> 00:14:07.200
rulemaking priorities that you think apply to this,

00:14:07.210 --> 00:14:08.849
this industry. What I will ask on that first question.

00:14:08.859 --> 00:14:11.509
Is uh which, where did you file those comments? So that

00:14:11.519 --> 00:14:16.570
we can look at them, do you know? Um 55156.

00:14:18.729 --> 00:14:22.379
Yeah, should we file it in uh 54589 as well? Actually

00:14:22.389 --> 00:14:25.119
I think we may have filed similar comments in that

00:14:25.129 --> 00:14:29.979
one. Yeah, we filed not identical but similar comments

00:14:29.989 --> 00:14:31.830
in uh both proceedings.

00:14:33.849 --> 00:14:38.950
Okay. Um we will um uh I don't wanna make any representations

00:14:38.960 --> 00:14:40.629
about whether or not we would include it in this rulemaking.

00:14:40.639 --> 00:14:43.548
But we will take a look at your filing and

00:14:43.558 --> 00:14:47.668
um, um include it, if we think that we can. (item:1.4:David Smeltzer's additional thoughts on implementing rulemaking) And I think

00:14:47.678 --> 00:14:50.038
for, for our general um

00:14:51.658 --> 00:14:56.500
uh our general decision. Sort of filter for the

00:14:56.649 --> 00:15:00.308
the rulemaking beyond what was required by Legislation

00:15:00.320 --> 00:15:03.129
was whether or not we think that it was sort of minor

00:15:03.139 --> 00:15:05.519
or didn't require sufficient investigation or we thought

00:15:05.529 --> 00:15:09.298
it was sort of clear cut on direction. And so if, uh

00:15:09.308 --> 00:15:12.979
if it sort of meets those criteria, we might include

00:15:12.989 --> 00:15:15.899
it. But if not, we would not include it. And then eventually

00:15:15.908 --> 00:15:17.629
we'll be filing something to the Commissioners and

00:15:17.639 --> 00:15:20.219
say these are all the recommended ideas for the Chapter

00:15:20.229 --> 00:15:23.029
26 rule review that we did not accept. So that they

00:15:23.038 --> 00:15:26.009
can um, determine whether or not they want to direct

00:15:26.019 --> 00:15:28.710
us. To treat those items in a different rulemaking

00:15:28.719 --> 00:15:31.269
at the appropriate time. Thank you. Thanks.

00:15:44.969 --> 00:15:48.279
And I would at this point say the floor has opened

00:15:48.288 --> 00:15:53.158
for any telecom related rule making, priority discussion

00:15:53.168 --> 00:15:54.538
topics that are of interest.

00:15:59.070 --> 00:16:02.759
(item:1.4:David Smeltzer closes 1st session) All right, hearing none. Uh thank you for attending

00:16:02.769 --> 00:16:06.729
today. And uh these uh I hadn't really thought about

00:16:06.739 --> 00:16:09.580
these ongoing Legislation items. That might be coming

00:16:09.590 --> 00:16:11.759
up in Special, so I appreciate that note. And thank

00:16:11.769 --> 00:16:13.918
you for directing us to that filing. We'll take a look

00:16:13.928 --> 00:16:17.308
as I indicated. And um the first, the first part of

00:16:17.320 --> 00:16:19.678
this trilogy was a short one, but it was good to wet

00:16:19.690 --> 00:16:22.759
everyone's appetite uh for the, the session that works

00:16:22.769 --> 00:16:23.940
have to come. So, thanks for coming.

00:16:38.109 --> 00:16:43.239
(item:2:David Smeltzer welcomes water participants & lays out 2nd Session objective) Hello, water people. Welcome to the 2nd of the

00:16:43.250 --> 00:16:47.859
three Commission Staff um Legislative implementation

00:16:47.869 --> 00:16:50.168
workshops for today. Um

00:16:51.808 --> 00:16:54.379
for those that were not here for the first one. Commission

00:16:54.389 --> 00:16:58.538
Staff thanks you all for coming. Um our goal is uh

00:16:58.940 --> 00:17:02.009
you know this Legislature gave us. Yeah, this session

00:17:02.019 --> 00:17:05.449
the Legislature gave us, you know, estimates our estimates

00:17:05.459 --> 00:17:08.348
are maybe 39 or 40 potential rulemaking. Something that we could

00:17:08.358 --> 00:17:13.199
have coming out of this session. And we have identified

00:17:13.209 --> 00:17:15.789
the Commission Staff will be providing the Commission

00:17:15.799 --> 00:17:18.799
with recommendations on the order. In which we should

00:17:19.049 --> 00:17:20.578
you know the sequence and order in which we should

00:17:20.588 --> 00:17:24.049
prioritize these. And before we did that, we wanted

00:17:24.059 --> 00:17:26.269
to give the public an opportunity and stakeholders

00:17:26.279 --> 00:17:29.299
an opportunity to let us know what we may have missed

00:17:29.309 --> 00:17:32.670
on our list. Give us some perspective on which of these

00:17:32.680 --> 00:17:35.549
issues are most pressing for your industries. And 

00:17:35.559 --> 00:17:38.640
provide any other priorities that we should be considering

00:17:38.894 --> 00:17:43.834
in addition to those that are listed here. And so we

00:17:43.844 --> 00:17:47.025
finished telecom early compared to that was a quick

00:17:47.035 --> 00:17:48.634
discussion. Because there weren't very many telecom

00:17:48.644 --> 00:17:52.255
bills that were passed. Water is sort of an interesting

00:17:52.535 --> 00:17:55.713
landscape here. Because you know, there were a number

00:17:55.723 --> 00:17:57.505
of water bills that were passed but none of them had

00:17:57.515 --> 00:18:00.993
statutory deadlines. And so the two bills that we listed

00:18:01.005 --> 00:18:03.943
in our memo just reflect our current rule making efforts

00:18:03.953 --> 00:18:06.424
which are implementing a number of bills from last

00:18:06.434 --> 00:18:10.348
session. And that doesn't mean that we won't be chugging

00:18:10.358 --> 00:18:12.390
along through implementing the water bills this session.

00:18:12.400 --> 00:18:14.989
We just wanted to get feedback before we determined

00:18:15.000 --> 00:18:18.910
what the, you know, the first priority should be. (item:2:David Smeltzer provides housekeeping notes) Um

00:18:19.250 --> 00:18:22.750
some additional sort of housekeeping notes. Um, if

00:18:22.759 --> 00:18:26.299
you hear anything today that upon reflection later.

00:18:26.309 --> 00:18:27.828
You think oh, maybe that's a little bit right. Here's

00:18:27.838 --> 00:18:31.189
another idea for how they can do this more efficiently.

00:18:31.219 --> 00:18:35.130
We'll be accepting sort of concise filed comments through

00:18:35.140 --> 00:18:37.588
the end of the week. Um, and we'll, we'll publish some

00:18:37.598 --> 00:18:41.368
instructions on that a little bit later. And the other

00:18:41.380 --> 00:18:43.900
comment I would note. Is if it turns out that there's

00:18:43.910 --> 00:18:47.750
a number of things to uh as we're talking. You don't

00:18:47.759 --> 00:18:49.838
have to ask permission to come up, just go ahead and

00:18:49.848 --> 00:18:52.140
come up and sit at one of the chairs. If you have,

00:18:52.150 --> 00:18:54.670
if you want to comment on the topic under discussion.

00:18:54.858 --> 00:18:56.949
And we'll sort of call on you at the appropriate time.

00:18:57.170 --> 00:18:59.750
And if there are multiple people waiting, uh the sort

00:18:59.759 --> 00:19:02.348
of convention that I use. Is if you want, if you're

00:19:02.358 --> 00:19:04.250
waiting to talk on whatever is currently being talked

00:19:04.259 --> 00:19:06.739
about. Give me a little one and if you're just waiting

00:19:06.750 --> 00:19:08.809
to talk about something else, a little two. So that

00:19:08.818 --> 00:19:12.049
way we don't do the sort of awkward dance of who, who

00:19:12.059 --> 00:19:15.979
should be talking next. Um so yeah, there we go. Uh

00:19:15.989 --> 00:19:18.250
My name is, I guess I should have said at the beginning.

00:19:18.380 --> 00:19:20.479
My name is David Smeltzer. I'm the Director of Rules

00:19:20.489 --> 00:19:24.140
and Projects here. And joining me at the dias are um

00:19:24.299 --> 00:19:27.828
Rama Rastogi, Mackenzie Arthur and Iliana De La Fuente from RAP.

00:19:27.838 --> 00:19:30.799
And of course, Tammy Benter the Head of our Duo division

00:19:30.969 --> 00:19:35.479
and um, uh, most knowledgeable person I know on water

00:19:35.489 --> 00:19:37.868
and sewer topics. So, thank you for coming.

00:19:40.009 --> 00:19:43.199
So, I guess for starters um, we'll just work through

00:19:43.469 --> 00:19:48.160
uh, one item at a time. Uh does anyone have any comments

00:19:48.170 --> 00:19:51.650
on um. So we've got the 2 that are ongoing now and

00:19:51.660 --> 00:19:53.368
I think that these are known. Because there are comments

00:19:53.380 --> 00:19:56.578
on these, but in terms of the Bills that were passed.

00:19:56.588 --> 00:20:00.539
For this session, has anyone identified any pieces

00:20:00.549 --> 00:20:02.939
of Legislation that they think require rulemakings

00:20:02.949 --> 00:20:06.699
that they did not see on our list? Have we missed anything?

00:20:18.699 --> 00:20:18.750
Thanks.

00:20:20.549 --> 00:20:24.250
(item:2.1:Jeff Kirshbaum, General Counsel, Texas Association of Water Companies) Hi, Jeff Kirshbaum with the Law Firm Terrill & Waldrop, I represent

00:20:24.259 --> 00:20:26.858
Texas Association of Water Companies. I serve as their

00:20:26.868 --> 00:20:30.279
General Counsel. Uh we appreciate the ongoing effort

00:20:30.289 --> 00:20:34.209
in Project 53924. Obviously that was from last Session.

00:20:34.338 --> 00:20:38.000
We did not see on the list what was uh planned for

00:20:38.009 --> 00:20:41.930
implementation of 88th Session items. And on my list

00:20:41.939 --> 00:20:48.618
I have the uh HB2373 which repealed the requirement.

00:20:48.630 --> 00:20:52.410
To have substantial similarity among systems for consolidation

00:20:52.420 --> 00:20:58.170
on a tariff. That is, that was in 13.145 of the

00:20:58.180 --> 00:21:04.608
Water Code and in the Rules 24.25KNM. Implement

00:21:04.618 --> 00:21:07.880
that language from 13.145 and there was a repeal.

00:21:07.890 --> 00:21:10.108
So those that should just be removed from the rules

00:21:10.328 --> 00:21:14.180
Okay. And I think when you so the memo listed the, um

00:21:14.189 --> 00:21:15.930
you're right. Those are the 87 things we're currently

00:21:15.939 --> 00:21:17.559
working on. I think there was a chart at the bottom

00:21:17.568 --> 00:21:19.309
that listed was the, was the item that you're mentioning

00:21:19.318 --> 00:21:22.809
on that chart? Yes, it's number 24. Okay, cool. So, okay

00:21:22.920 --> 00:21:26.380
so it's on there. Um and so we agree this uh in

00:21:26.390 --> 00:21:28.789
terms of our own internal prioritization. The repeal

00:21:28.799 --> 00:21:33.009
of the substantial test, we identify that as a critical

00:21:33.019 --> 00:21:35.088
for getting some of these systems consolidated quickly

00:21:35.098 --> 00:21:39.868
so. We appreciate the focus on that. Okay. Um so, so

00:21:39.880 --> 00:21:42.368
that was one that our organization was involved with.

00:21:42.380 --> 00:21:51.049
And also uh SB1, SB1778. Um there's some language

00:21:51.059 --> 00:21:57.390
in 24.161A. That's number 22 on the chart. (item:2.1:Jeff Kirshbaum on written service applications) I think

00:21:57.400 --> 00:22:01.539
what probably what needs to happen there is. Uh, some

00:22:01.549 --> 00:22:03.578
thought given to the requirement for a written service

00:22:03.588 --> 00:22:06.529
application. Because what that statute says is it can

00:22:06.539 --> 00:22:09.848
be in some other form. And I think there's probably

00:22:09.858 --> 00:22:12.430
some TCEQ coordination that needs to go on with that

00:22:12.439 --> 00:22:15.410
one as well as far as a service agreement or service

00:22:15.420 --> 00:22:16.568
application in writing.

00:22:19.189 --> 00:22:20.598
The other one

00:22:22.400 --> 00:22:23.269
I three.

00:22:25.838 --> 00:22:28.150
And, and while he's talking, I will say that that Jeff

00:22:28.160 --> 00:22:29.930
is doing exactly what we hope for, which is, you know

00:22:29.939 --> 00:22:32.689
implementation ideas, priorities, anything we may have

00:22:32.699 --> 00:22:35.818
missed. And I'm not an expert on every Bill that passed.

00:22:35.828 --> 00:22:38.279
I'm not a West Wing character, but we will be reviewing

00:22:38.289 --> 00:22:41.000
these uh later in the video and incorporating them

00:22:41.009 --> 00:22:43.049
into our thinking. So uh so yeah, we appreciate these

00:22:43.059 --> 00:22:50.029
sorts of notes. (item.2.1:Jeff Kirshbaum on Senate Bill 1965) Uh Senate Bill 1965 was one that the

00:22:50.039 --> 00:22:54.630
intent of it was to create an easier way for investor

00:22:54.640 --> 00:22:57.750
own utilities serving as temporary managers. To acquire

00:22:58.229 --> 00:23:00.890
systems that are in trouble, you know, more permanently.

00:23:01.189 --> 00:23:04.348
And there's, there's some language in there about creating

00:23:04.358 --> 00:23:07.068
an expedited way to acquire those systems either through

00:23:07.078 --> 00:23:10.088
the asset or stock transfer procedures. And then what

00:23:10.098 --> 00:23:12.719
you would get in terms of any investment that you made

00:23:12.729 --> 00:23:15.068
during your temporary manager later in a rate case.

00:23:15.250 --> 00:23:17.250
So there's some very different rules. I think that

00:23:17.259 --> 00:23:26.900
that would go into probably 24.239, 24.243. Uh cause

00:23:26.910 --> 00:23:32.390
of service changes could be 24.41. Um there may also

00:23:32.400 --> 00:23:35.949
need to be in addition to Subchapter K. About having

00:23:35.959 --> 00:23:38.578
a reasonable time to bring the systems into compliance.

00:23:38.809 --> 00:23:41.459
And that's another one that I think there's a PUC

00:23:41.469 --> 00:23:46.108
component to it. And a TCEQ need for a rule allowing

00:23:46.118 --> 00:23:49.799
a reasonable time. For bringing a system acquired under

00:23:49.809 --> 00:23:52.500
temporary manager in compliance after it's acquired.

00:23:53.739 --> 00:23:55.858
Tammy, so far does this sound like what we were thinking?

00:23:56.459 --> 00:23:59.189
Yes. That's good news. (item:2.1:David Smeltzer questions on purpose of rules listed) Um and, and of course

00:23:59.670 --> 00:24:02.269
the rule, you listed a number of rules. I mean, just

00:24:02.279 --> 00:24:04.719
for Tammy may know this already. But are these rules

00:24:04.729 --> 00:24:06.759
that you of the rules that you listed, that we need

00:24:06.769 --> 00:24:08.469
to identify for those purposes? Do you know? Do we

00:24:08.479 --> 00:24:11.410
need to open them for other purposes on this list

00:24:11.420 --> 00:24:13.459
for efficiency's sake? Are there, are these rules of

00:24:13.469 --> 00:24:17.150
interest for other reasons? So the sale transfer merger

00:24:17.160 --> 00:24:19.910
rules are definitely something I think that needs to

00:24:19.920 --> 00:24:22.259
be reviewed comprehensively, not just for the purpose

00:24:22.269 --> 00:24:26.130
of this Senate Bill 1965 implementation. There's a lot

00:24:26.140 --> 00:24:29.068
of concerns about the process right now. Okay. So I think

00:24:29.078 --> 00:24:31.209
that's, I think that's probably one of the top issues

00:24:31.219 --> 00:24:34.189
on our list as an organization. And I know that there

00:24:34.199 --> 00:24:37.890
were, there were comments in the um the initial rates

00:24:37.900 --> 00:24:42.140
uh draft. That we should consider moving those provisions

00:24:42.150 --> 00:24:44.640
from their own section into the Sale Transfer Merger

00:24:44.739 --> 00:24:47.328
section that would also treat that rule. And I think

00:24:47.338 --> 00:24:49.670
that those comments are well received. And I, you know

00:24:49.680 --> 00:24:51.598
I don't wanna say for sure what we're gonna do. But

00:24:51.608 --> 00:24:54.358
we, I definitely understood what. That's one issue.

00:24:54.368 --> 00:24:55.848
The thought behind that. (item:2.1:Jeff Kirshbaum on STM process) I think there's been a lot

00:24:55.858 --> 00:24:58.250
of issues with respect to financial review. As well

00:24:58.259 --> 00:25:01.769
in, in both the amendment and the STM process. We'd

00:25:01.779 --> 00:25:05.068
like to see that looked at uh that just generally the

00:25:05.078 --> 00:25:08.529
the STM process right now. You get an order, you get

00:25:08.539 --> 00:25:10.868
to go close your transaction and then on the back end

00:25:10.880 --> 00:25:13.479
there's this final order. We kind of have an issue

00:25:13.489 --> 00:25:16.588
with during the interim. Like what, what needs to,

00:25:16.598 --> 00:25:19.489
we would prefer just to be one order. Where you get

00:25:19.500 --> 00:25:22.500
to the approval to close and all the regulatory approvals

00:25:22.509 --> 00:25:25.328
that you need are contingent maybe on that closing

00:25:25.338 --> 00:25:28.650
but it's all at one in one step. Yeah. So I think

00:25:28.660 --> 00:25:30.519
this is why I like the discussion format. I think that

00:25:30.529 --> 00:25:32.689
we probably we're gonna pull for other ideas a little

00:25:32.699 --> 00:25:35.199
bit later. But as long as we're, as long as we're on

00:25:35.209 --> 00:25:37.699
the topic of the sale transfer merger rules. So anyone

00:25:37.709 --> 00:25:40.500
that has any other comments they want to make about

00:25:40.509 --> 00:25:43.199
that rule or priorities? And you know, we obviously

00:25:43.209 --> 00:25:44.930
when we open the rule there specifically. But in terms

00:25:44.939 --> 00:25:49.709
of pressing issues. That if we open that rule for implementation

00:25:49.719 --> 00:25:51.500
is, does anyone else have any other comments that they

00:25:51.509 --> 00:25:55.108
want to add to the discussion? (item:2.1:Brian Barr with Texas Water Utilities, Midway Water Utilities, SWWC Utilities DPA on STM) Uh I'm Brian Barr with

00:25:55.118 --> 00:25:57.949
Texas Water Utilities, Midway Water Utilities and

00:25:57.959 --> 00:26:01.828
SWWC Utilities DPA, number of few different things.

00:26:02.108 --> 00:26:04.328
Um and you're also the official guy that tells me which

00:26:04.338 --> 00:26:07.380
item on the chart the, the Bill is the chart. We

00:26:07.390 --> 00:26:11.630
appreciate that already. I um yeah, so um I guess just

00:26:11.640 --> 00:26:16.250
to reiterate what Jeff said. Uh number of STM and CCN

00:26:16.259 --> 00:26:19.598
applications too, but mostly focused on the STM. Where

00:26:19.809 --> 00:26:23.078
that window between the closing of the transaction

00:26:23.088 --> 00:26:25.489
and the file notice of approval. Creates some problems

00:26:25.500 --> 00:26:29.019
that probably weren't originally contemplated. When

00:26:29.029 --> 00:26:32.309
the rule was drafted, namely when say the filed rate

00:26:32.318 --> 00:26:36.078
doctrine bill was passed. That uh for rates, post acquisition.

00:26:36.259 --> 00:26:38.939
And I know we have the rulemaking open now to address

00:26:38.949 --> 00:26:42.660
that. But uh just to reiterate what Jeff said. We could

00:26:42.670 --> 00:26:47.420
resolve a lot of issues by mitigating or eliminating

00:26:47.430 --> 00:26:50.420
or decreasing that window between closing and final

00:26:50.430 --> 00:26:53.299
most of approval. So that's something that we advocate

00:26:53.309 --> 00:26:54.140
for, for sure.

00:26:55.670 --> 00:26:57.818
Um do you have any follow up questions on that point?

00:26:57.828 --> 00:27:01.318
(item:2.1:Tammy Benter, Director of Water Utility Regulation, on STM) I don't know how if this works, but that requires some

00:27:01.328 --> 00:27:06.318
TCEQ, sorry. TCEQ coordination also. Because they recognize

00:27:06.328 --> 00:27:10.750
a sale once we issue the order saying it's done. Um

00:27:10.759 --> 00:27:14.729
and so that in between. Um there's a lot of coordination

00:27:14.750 --> 00:27:17.088
that goes on with them. Because they're continuing to

00:27:17.098 --> 00:27:19.219
do their inspections and everything. And so it's like

00:27:19.229 --> 00:27:21.559
who officially owns it. And so it's gonna require a

00:27:21.568 --> 00:27:24.858
lot of coordination there. Yeah, I agree completely.

00:27:24.868 --> 00:27:28.309
That's, yeah. (item:2.1:Brian Barr on HB2373) Uh and then one other general comment

00:27:28.318 --> 00:27:31.809
uh related to what Jeff said. He named three bills

00:27:31.818 --> 00:27:35.049
here. That I think the water industry in general are

00:27:35.059 --> 00:27:39.118
most interested in. Numbers 22 and 23 and 24 on the

00:27:39.130 --> 00:27:42.358
chart. Let me just suggest and I really not trying

00:27:42.368 --> 00:27:45.269
to step on anyone's toes or. That's why we're here.

00:27:45.390 --> 00:27:52.368
Um specifically for HB2373, that's number 24. I would

00:27:52.380 --> 00:27:55.568
respectfully recommend that, that one be taken up. Because

00:27:55.578 --> 00:27:59.469
that is a assuming there are no surprises that is a

00:27:59.479 --> 00:28:02.318
really quick and easy rulemaking. In which all we have

00:28:02.328 --> 00:28:07.959
to do is strike Section K of TAC 24.25, and potentially

00:28:07.969 --> 00:28:11.559
Section M as well. Right, Jeff? Yes. It's not really

00:28:11.568 --> 00:28:14.000
an amendment where we need to open it up and have a

00:28:14.009 --> 00:28:17.630
lot of comments and discussions. Really just strike

00:28:17.640 --> 00:28:20.199
that language to be consistent with the Legislative

00:28:20.209 --> 00:28:23.660
Bill. So, just polling the room by room, by show of

00:28:23.670 --> 00:28:26.108
hands. Does anyone disagree with the sentiment that

00:28:26.118 --> 00:28:27.630
that would be a quick, easy one?

00:28:29.709 --> 00:28:30.699
All right. That's always good.

00:28:32.549 --> 00:28:34.059
And that one's in effect now.

00:28:36.858 --> 00:28:40.618
Correct. Yeah. Okay. So I think uh there are other folks at the

00:28:40.630 --> 00:28:44.509
table we uh waiting to. Are we still on the question

00:28:44.519 --> 00:28:48.078
of items for recommendation that we may not? We've

00:28:48.088 --> 00:28:50.219
gone a little off the path, but that was the originating

00:28:50.229 --> 00:28:53.689
question. So if, if you have anyone who has, yes. Uh

00:28:53.719 --> 00:28:57.368
well. (item:2.1:Ashley Myers, Executive Director of Texas Association of Water Companies on HB1484 & HB1963) Ashley Myers, Executive Director of Texas Association

00:28:57.380 --> 00:29:00.858
of Water Companies. Um you know, of course, a lot

00:29:00.868 --> 00:29:03.189
of you in this room know about the Association. And

00:29:03.199 --> 00:29:06.910
know that um we've worked pretty hard on a lot of this

00:29:06.920 --> 00:29:08.930
Legislation that's in front of you guys and in front

00:29:08.939 --> 00:29:14.868
of the Commission. Um we're glad that HB1484 has

00:29:14.880 --> 00:29:16.559
been opened up that we have gotten to the fed rate

00:29:16.568 --> 00:29:21.269
doctor. And I think that's TWC 13 3001 or 3011.

00:29:24.250 --> 00:29:28.900
I just want to impress upon Staff. That I think we can

00:29:28.910 --> 00:29:31.959
resolve a lot of confusion and just get some clarity

00:29:31.969 --> 00:29:35.199
once this rulemaking is, is complete. Um we do have

00:29:35.209 --> 00:29:37.559
some reservations about some of the ideas that have

00:29:37.568 --> 00:29:39.818
been tossed around. We did of course submit some comments

00:29:39.828 --> 00:29:46.250
and reply to the um uh comments in there, in that uh

00:29:46.568 --> 00:29:48.500
project. I'm sorry. I can't remember the number right

00:29:48.509 --> 00:29:53.449
now. But I think just continuing these conversations

00:29:53.459 --> 00:29:57.318
and working with stakeholders as you always do. To try

00:29:57.328 --> 00:30:01.430
to align the statute as it's written with rulemaking.

00:30:01.439 --> 00:30:04.709
Is really the goal for us right now. Of course, 88th

00:30:04.719 --> 00:30:07.588
Legislative Session that those items are important

00:30:07.598 --> 00:30:10.459
to us. I think the Temporary Management Bill, uh HB1963

00:30:10.969 --> 00:30:18.930
which is or 1965 is Item 23. Um that is also

00:30:18.939 --> 00:30:22.789
a safety concern. We've seen first hand what it looks

00:30:22.799 --> 00:30:26.858
like when systems fail or abandoned. And it's a terrible

00:30:26.868 --> 00:30:28.809
situation for those people and we want to make sure

00:30:28.818 --> 00:30:31.818
that we that, that never happens again. Um and I think

00:30:31.828 --> 00:30:33.949
that this is a great step forward and I would love

00:30:33.959 --> 00:30:37.199
to see that taken up pretty soon here as well. And

00:30:37.209 --> 00:30:40.229
our members are eager to take advantage of it. And be

00:30:40.239 --> 00:30:43.568
of use and help to the state and those failing systems.

00:30:43.578 --> 00:30:46.479
Um so just from the Association, Association standpoint

00:30:46.489 --> 00:30:48.259
we appreciate this conversation. I don't know if we've

00:30:48.269 --> 00:30:50.900
ever actually had anything like this before. I, I mean

00:30:50.910 --> 00:30:53.818
I'm new to the industry. But it sounds like this kind

00:30:53.828 --> 00:30:56.479
of conversation is new and we really appreciate it.

00:30:56.489 --> 00:30:59.578
Because it brings everyone to the table to have that

00:30:59.588 --> 00:31:02.939
open discussion about rulemaking. Um, and what the

00:31:02.949 --> 00:31:05.939
concerns of the industry folks are. And, you know, they're

00:31:05.949 --> 00:31:07.939
in this every single day just like you guys are. So

00:31:07.949 --> 00:31:10.199
they know, and you guys know how hard it can be and

00:31:10.209 --> 00:31:12.660
how difficult it can be. And everyone's out here trying

00:31:12.670 --> 00:31:15.068
to do the best that they can. With our members strive

00:31:15.078 --> 00:31:17.828
to come to you guys with administratively complete

00:31:17.838 --> 00:31:22.449
applications. But unless they have the clarity of what

00:31:22.459 --> 00:31:24.608
you guys need from them. It makes it really difficult

00:31:24.618 --> 00:31:28.029
to do that and to get that achieve that goal. So I'm

00:31:28.449 --> 00:31:31.489
just generally speaking, uh very excited to see the

00:31:31.500 --> 00:31:35.559
rule making open on um valery doctrine. And then of course

00:31:35.568 --> 00:31:39.189
we would impress upon the Commission to take up the

00:31:39.199 --> 00:31:41.140
substantial similarity and the temporary management

00:31:41.150 --> 00:31:44.779
as well as soon as possible. Perfect. I think that's

00:31:44.789 --> 00:31:47.578
uh that's good. And on the, and I will admit, I think

00:31:47.588 --> 00:31:50.289
that there's a, there's a robust and really good exchange

00:31:50.299 --> 00:31:52.858
in the comments going on in there. And as someone who

00:31:52.868 --> 00:31:54.549
spends most of his time thinking about electric. I've

00:31:54.559 --> 00:31:57.000
really appreciated the comments filed on both sides

00:31:57.009 --> 00:31:59.789
of some of those questions. And I think those are high

00:31:59.799 --> 00:32:03.180
level policy questions that will ultimately, you know

00:32:03.189 --> 00:32:05.269
every decision is made by the Commissioners, but some

00:32:05.279 --> 00:32:07.529
of them are most important, you know, some of them

00:32:07.539 --> 00:32:11.979
are most more worthy of them giving an in depth look

00:32:11.989 --> 00:32:14.328
than not. And I think that the the speed at which some

00:32:14.338 --> 00:32:17.219
of these transfers are processed and how, how we do

00:32:17.229 --> 00:32:19.439
those are definitely ones that I know that they're

00:32:19.449 --> 00:32:23.259
interested in. And so uh your comments are understood

00:32:23.269 --> 00:32:26.630
and well received on the importance of those. (item:2.4:Brian Barr's response to questions prior from David Smeltzer) Uh David

00:32:26.640 --> 00:32:29.239
you had asked two specific questions I want, we've

00:32:29.250 --> 00:32:31.500
kind of been talking at least I have about thoughts

00:32:31.509 --> 00:32:33.559
I had in the car on the way over here. I want

00:32:33.568 --> 00:32:35.578
to make sure I addressed your questions specifically

00:32:35.588 --> 00:32:40.150
One was um are there any uh legislation that wasn't

00:32:40.160 --> 00:32:43.348
identified by Staff in the chart and per my review

00:32:43.358 --> 00:32:45.828
No, you guys did a good job. You nailed it all. I

00:32:45.838 --> 00:32:47.670
didn't see anything that was in there. There was one

00:32:47.680 --> 00:32:49.890
I thought I caught I was really happy about and then

00:32:49.900 --> 00:32:53.739
Jeff corrected me, it's a TCEQ item. So thank you, Jeff.

00:32:53.789 --> 00:32:56.759
Never mind. I, I was really prepared to have my moment

00:32:56.769 --> 00:33:00.420
in the sun there. Uh but uh then the other question

00:33:00.430 --> 00:33:03.459
you asked was uh are there any efficiencies that can

00:33:03.469 --> 00:33:06.670
be gained by combining certain ones? And you know,

00:33:06.680 --> 00:33:09.380
and Jeff mentioned the comprehensive rulemaking around

00:33:09.390 --> 00:33:14.979
STMs. Um I didn't identify any specific ones that

00:33:14.989 --> 00:33:19.818
could be uh, combined into a single rulemaking. Okay.

00:33:20.930 --> 00:33:23.068
Well, that, that's helpful. I know, I know. I look

00:33:23.078 --> 00:33:27.598
to Jeff, you know, he always corrects me. You're correct.

00:33:27.608 --> 00:33:31.180
And, and for our filed comments we, we agree with

00:33:31.189 --> 00:33:33.338
that. And, and, um, question three and four.

00:33:36.868 --> 00:33:39.479
Yeah, David. (item:2.4:Joe Freeland with Matthews & Freeland on additional bills not listed) Joe Freeland, uh, Matthew and Freeland.

00:33:39.489 --> 00:33:43.539
Um, as to bills you didn't identify on, on the list

00:33:43.549 --> 00:33:51.279
I think HB4559, which is the, that decade correction

00:33:51.289 --> 00:33:55.818
of population figures. Uh, it, it, I know it at least

00:33:55.828 --> 00:34:03.219
address 13.2541. Those, all the brackets in particularly

00:34:03.229 --> 00:34:07.019
254 25.41. All the brackets in Chapter 13 were probably

00:34:07.029 --> 00:34:11.989
adjusted somewhat in that bill. Uh and I, I suspect

00:34:12.000 --> 00:34:13.938
that ought to be. I mean, that's an easy correction

00:34:13.949 --> 00:34:18.168
for a rule. You just change 2000 to 2200 to whatever

00:34:18.179 --> 00:34:23.320
the change is in the bill. Um, it, it could cause some

00:34:23.329 --> 00:34:27.159
confusion on filings, filings in the near future.

00:34:27.168 --> 00:34:29.878
Because they're gonna be areas that look in the rule

00:34:29.889 --> 00:34:32.409
look, appear to be outside of the Commission's jurisdiction.

00:34:32.418 --> 00:34:35.478
Which are suddenly actually because the bill or in

00:34:35.909 --> 00:34:40.829
the jurisdiction. Okay. That's a good note. And I, uh

00:34:41.320 --> 00:34:44.668
we'll, we'll take a look at, I, I don't know. How is

00:34:44.679 --> 00:34:45.780
that one that we're tracking, do you know?

00:34:48.148 --> 00:34:50.697
Yeah, it, it, it's a stealth bill. It comes every year.

00:34:50.708 --> 00:34:55.407
They, once the, the census is done. The, the Land Council

00:34:55.418 --> 00:34:59.188
go back and they review the bills and fix those um

00:34:59.197 --> 00:35:03.137
population criteria in the, in the brackets. Okay, perfect.

00:35:03.148 --> 00:35:05.958
We will uh take a look at that and I don't, I

00:35:05.969 --> 00:35:08.389
guess we'll take a look to see if that's done by rule.

00:35:08.398 --> 00:35:10.679
And if we, it sounds like you've given it more thought

00:35:10.688 --> 00:35:13.559
than us. And so uh maybe we'll reach out if we have

00:35:13.570 --> 00:35:16.059
questions on the way you're thinking about it for implementation.

00:35:16.070 --> 00:35:17.860
But thanks for, thanks for making a note of that. 

00:35:17.869 --> 00:35:22.079
Sure. (item:2.3:Joe Freeland with Matthews & Freeland on HB3689) And, and I'll, I'll put my um other hat on my

00:35:22.090 --> 00:35:24.809
San Antonio Water System hat. Uh thank the Commission

00:35:24.820 --> 00:35:29.489
for starting rulemaking on um in 54932 . To implement

00:35:29.590 --> 00:35:35.050
HB3689. That was a Bill is was worked on Session before.

00:35:35.059 --> 00:35:39.378
Um and that was tied into a rulemaking which we had

00:35:39.389 --> 00:35:42.750
drafted for the Commission back in about 2018. Which

00:35:42.760 --> 00:35:45.300
addressed both that issue, which we sort of refer to

00:35:45.309 --> 00:35:48.938
as the wood lock issue. And then also addressed uh just

00:35:48.949 --> 00:35:55.688
the petition requirements under um 13.043B. Right

00:35:55.699 --> 00:35:59.000
to appeal from outside city ratemakers or outside

00:35:59.010 --> 00:36:03.208
city customers or um district customers. That, that

00:36:03.219 --> 00:36:05.639
appeal process, right? They file a petition if they

00:36:05.648 --> 00:36:10.228
get 10% or more. The rules don't address that very

00:36:10.239 --> 00:36:13.128
well. There's no real clear pro process in the Commission's

00:36:13.139 --> 00:36:17.340
rules now. And so we had drafted some language in 2018

00:36:17.349 --> 00:36:21.519
2019. Um, which we brought and chopped to the Commissioners.

00:36:21.530 --> 00:36:25.168
Um, and then Chairman Walker had told us she was going

00:36:25.179 --> 00:36:28.208
to do a comprehensive fix of the water bills and then

00:36:28.219 --> 00:36:32.820
February 2021 came. And so, um, all of that has sort

00:36:32.829 --> 00:36:36.010
of dropped off. We have that already drafted. I mean

00:36:36.019 --> 00:36:38.378
Tammy, you probably, you probably still have a copy of

00:36:38.389 --> 00:36:42.099
that. We um if we could try to find a way to

00:36:42.110 --> 00:36:45.340
put it back into the, the priority list somewhere.

00:36:45.739 --> 00:36:50.619
Sure. Uh I, I uh and will not be making any, making

00:36:50.628 --> 00:36:52.760
any off the cuff commitments today. But if you feel

00:36:52.769 --> 00:36:55.800
do, do we have a copy? I think I do. Can you

00:36:55.809 --> 00:36:58.918
just make sure I can, I can resend it to you. Um

00:36:59.119 --> 00:37:01.590
And we, we, you know, we can take out the, the, the

00:37:01.599 --> 00:37:05.369
stuff that was fixed in 54932 and maybe do a little

00:37:05.378 --> 00:37:08.918
clean up on it otherwise. But it, it was a, a process

00:37:08.929 --> 00:37:12.139
that would actually streamline um Commission Staff

00:37:12.148 --> 00:37:15.300
review. So, and it would sort of shift the burden from

00:37:15.429 --> 00:37:20.599
Staff back to the utility. Sure. Um I don't work on

00:37:20.610 --> 00:37:22.648
these contested cases but I'm sure that the members

00:37:22.659 --> 00:37:24.739
of our Staff that do would appreciate streamlining.

00:37:24.869 --> 00:37:26.800
Uh So yeah, send it, send it over, we'll take a look.

00:37:31.780 --> 00:37:34.289
Uh the Association doesn't have any other comments.

00:37:34.300 --> 00:37:38.659
So uh just one general comment and that's, uh, Jeff

00:37:38.668 --> 00:37:41.889
kind of touched on earlier. (item:2.4:Brian Barr on STM form) But, um, as we do the rule

00:37:41.898 --> 00:37:45.958
makings. If there are any reviews necessary for applications

00:37:45.969 --> 00:37:49.070
or notices or that sort of thing, that could be really

00:37:49.079 --> 00:37:51.530
helpful to do those. Maybe if not part of the rule

00:37:51.539 --> 00:37:54.039
making, concurrent with the rulemaking. I'm thinking

00:37:54.050 --> 00:37:57.878
specifically of the STM form, um, that, and notices

00:37:57.889 --> 00:38:01.500
that we send out that sort of thing, Uh just um throw

00:38:01.510 --> 00:38:05.309
that out there. Yeah, agreed that our are

00:38:07.030 --> 00:38:11.019
process for uh rethinking about forms and sort of stuff

00:38:11.030 --> 00:38:13.320
that's Ancillary to rules is, is under review right

00:38:13.329 --> 00:38:17.208
now. And, you know, sometimes Tammy will, will practically

00:38:17.219 --> 00:38:20.030
implement things that can form with the rules and sometimes

00:38:20.039 --> 00:38:24.010
we do it through process and we are the, the last two

00:38:24.019 --> 00:38:25.559
sessions since we've booted up the rules and projects

00:38:25.570 --> 00:38:27.679
division has been sort of a learning couple of years

00:38:27.688 --> 00:38:30.309
but I appreciate what you're saying. I don't know if

00:38:30.320 --> 00:38:32.489
it's under the daily wick of this discussion, but just

00:38:32.500 --> 00:38:36.708
want to throw it out there. And we've got enough time

00:38:36.719 --> 00:38:41.059
to where all topics. And David one one last thing, if I maybe.

00:38:41.070 --> 00:38:44.938
(item:2.4:Joe Freeland on SB893) Uh SB893. I, I don't know the priority that y'all

00:38:44.949 --> 00:38:48.300
want to work on that. That's the one to correct boundary

00:38:48.309 --> 00:38:52.340
issues on CCNs. And, and I, you know, I suspect that

00:38:52.349 --> 00:38:55.969
you'll start seeing applications being filed uh prior

00:38:55.978 --> 00:38:59.289
to rule making on that. So I don't know how y'all want

00:38:59.300 --> 00:39:01.869
to address it. That would, from, from SAWS perspective

00:39:01.878 --> 00:39:03.849
that would be a fairly high priority. Because we have

00:39:03.860 --> 00:39:08.728
a lot of boundary issues that need to be resolved within

00:39:08.809 --> 00:39:12.889
a SAWS CCN. Yeah. So, I mean, I, I don't know

00:39:12.898 --> 00:39:14.918
what order we'll be able to be able to take it up

00:39:14.929 --> 00:39:18.739
in, but, you know, generally speaking, statutes take

00:39:18.750 --> 00:39:22.159
precedent over rules and so that's why, you know, I'm

00:39:22.168 --> 00:39:24.168
without commenting on the specific things. I think

00:39:24.179 --> 00:39:27.628
that, you know, your regulatory attorneys can help

00:39:27.639 --> 00:39:30.699
you with that. But, uh, sometimes we practically have

00:39:30.708 --> 00:39:32.579
to defer to statutes for a while while we're waiting

00:39:32.590 --> 00:39:34.869
for rules to come out and that one's effective immediately

00:39:36.280 --> 00:39:38.579
So we're already too late now. I just gotta get, uh

00:39:38.750 --> 00:39:42.750
very good. No, we'll, uh, that's good note.

00:39:45.849 --> 00:39:49.750
Um, ok. So just checking base, I think that we've gotten

00:39:49.760 --> 00:39:53.019
a few are going to line. Is there, are there any other

00:39:53.030 --> 00:39:55.889
bills that we think need maybe legislative treatment

00:39:55.898 --> 00:39:57.929
that have not been touched on that anyone is aware

00:39:57.938 --> 00:39:58.280
of?

00:39:59.969 --> 00:40:04.579
And then are there any other, uh, as anyone like to

00:40:04.590 --> 00:40:08.719
advocate for any, uh, please do the, these ones first

00:40:08.728 --> 00:40:11.478
that we haven't heard yet about?

00:40:13.119 --> 00:40:17.320
And are there any other pressing, um, any other pressing

00:40:17.329 --> 00:40:20.530
priorities faced by your industry that are not reflected

00:40:20.539 --> 00:40:23.329
in Legislation. That you would like the Commissioners

00:40:23.340 --> 00:40:26.570
to consider to be taken up prior to Legislation? And

00:40:26.579 --> 00:40:28.349
I know that we heard a little bit about the Financial

00:40:28.360 --> 00:40:32.780
Assurance um uh topic. Which is not a surprise to me

00:40:32.789 --> 00:40:37.559
to hear. Um, but yes, uh not related to that question

00:40:37.570 --> 00:40:40.360
directly. (item:2.4:Bill Barr question on mechanisms other than rulemakin) But, um, one of the questions on here was

00:40:40.539 --> 00:40:43.579
uh are there any items listed for rule making that

00:40:43.590 --> 00:40:46.260
should be implemented using a different method such

00:40:46.269 --> 00:40:50.389
as an order or directive? Um I don't know if we identified

00:40:50.398 --> 00:40:55.590
anything but I could you explain very briefly, um what

00:40:55.599 --> 00:40:57.978
sort of mechanisms other than rulemaking? There might

00:40:57.989 --> 00:41:03.418
be? Sure. (item:2.4:David Smeltzer on rule and statute differences) I think that in some cases, a rule is not

00:41:03.429 --> 00:41:06.860
necessary and a statute provides sufficient guidance

00:41:06.869 --> 00:41:08.750
to a rulemaking is not necessary. And I think that

00:41:08.929 --> 00:41:12.708
also that question is probably more relevant in the

00:41:12.719 --> 00:41:15.590
electric world because there's a lot of things that

00:41:15.659 --> 00:41:19.989
ERCOT can do um that, you know, like if we need to

00:41:20.000 --> 00:41:21.769
develop a new Ancillary service or something that might

00:41:21.780 --> 00:41:23.599
that might be the sort of thing that they can do without

00:41:23.610 --> 00:41:27.929
a rule. Um And so, or uh yeah, so working from statute

00:41:27.938 --> 00:41:30.878
stuff that we don't without a rule or in limited cases

00:41:30.889 --> 00:41:32.989
the Commission might be able to issue an order, directing

00:41:33.000 --> 00:41:37.378
entities to do things um like if we have to file reports

00:41:37.389 --> 00:41:40.409
or things like that. And so um we're looking for any

00:41:40.418 --> 00:41:42.780
efficiency, we can squeeze out of this. And so probably

00:41:42.789 --> 00:41:45.139
that, that question is most relevant to electric where

00:41:45.148 --> 00:41:47.668
there might be uh specific things where it's like,

00:41:47.679 --> 00:41:49.519
oh no, we think we have enough guidance to file this

00:41:49.530 --> 00:41:51.918
report without you having to do a rule on it or, or

00:41:51.929 --> 00:41:53.664
I can do instead. So that's the sort of stuff you were

00:41:53.675 --> 00:41:55.965
thinking about. Got you. Thank you very much. Is that

00:41:55.974 --> 00:41:58.434
uh or in your industry? If, if we've identified something

00:41:58.445 --> 00:42:00.103
you're like, no, no, this is a TCEQ thing, not a you

00:42:00.114 --> 00:42:02.204
thing. That would be the sort of comment maybe. So

00:42:02.215 --> 00:42:05.764
Is that like um I'm thinking of an instance where I

00:42:05.773 --> 00:42:10.043
think a rule making was opened related to filing electronically

00:42:10.054 --> 00:42:14.030
at the PUC and then nothing ever. I'm seeing some blank

00:42:14.039 --> 00:42:16.260
there. That no, no, that that is there is that is a

00:42:16.269 --> 00:42:19.860
storied is that. And that alternative mechanism was

00:42:20.039 --> 00:42:25.469
used to change something. That, that like many things is one. (item:2.4:David Smeltzer on comprehensive overhaul on how filings are processed) Where uh

00:42:25.760 --> 00:42:27.938
our Executive Director Thomas Gleeson has said that

00:42:27.949 --> 00:42:30.139
we will be accepting electronic filings and we still

00:42:30.148 --> 00:42:33.780
are. And that rule has been under review for a while

00:42:33.789 --> 00:42:35.510
and we're actively working on the draft. I know it

00:42:35.519 --> 00:42:38.188
may not seem like it, but that has, that has turned

00:42:38.199 --> 00:42:41.260
from, we're actually looking at a more comprehensive

00:42:41.269 --> 00:42:44.668
overhaul of 2271 that where we're rethinking our confidential

00:42:44.679 --> 00:42:47.119
filing requirements and we're rethinking open meeting

00:42:47.128 --> 00:42:49.519
posting documents. And for reasons you can understand

00:42:49.530 --> 00:42:51.728
that's something that are the operation side of our

00:42:51.739 --> 00:42:54.340
agency is very interested in. And I know that the public

00:42:54.349 --> 00:42:56.559
needs would like guidance on some of those things.

00:42:56.570 --> 00:42:59.139
So we're doing it. But there have been a lot of um

00:42:59.829 --> 00:43:02.079
you know, in our core subject industries, we regulate

00:43:02.090 --> 00:43:04.228
It's been difficult to carve out the review time. But

00:43:04.239 --> 00:43:06.579
actually Mac has been desperately hoping that I would

00:43:06.590 --> 00:43:08.829
review his uh spend more time with his draft on that.

00:43:08.840 --> 00:43:12.000
But uh but that is an example where as a patchwork

00:43:12.010 --> 00:43:15.000
approach, we've been following uh Gleason's guidance

00:43:15.010 --> 00:43:18.019
rather than making you guys file paper copies until

00:43:18.030 --> 00:43:20.269
we get the rule done. But that's a good example. Thanks.

00:43:20.280 --> 00:43:23.110
I really, I was just that, that is an active project

00:43:23.119 --> 00:43:25.208
for anyone who's, who's interested in that. Okay. I,

00:43:25.228 --> 00:43:27.519
I was really just trying to understand for purposes

00:43:27.530 --> 00:43:30.010
of review. If there was one that I could recommend

00:43:30.659 --> 00:43:34.860
uh be used uh through an alternative method rather

00:43:34.869 --> 00:43:37.300
than a rule making but nothing off the top of my head

00:43:37.309 --> 00:43:39.320
I'll review afterwards. Yeah. And I think that the

00:43:39.329 --> 00:43:41.688
example that for me that I, I think that after the

00:43:41.699 --> 00:43:43.878
last session nays are a number of bills like uh on

00:43:43.889 --> 00:43:46.610
designating critical water facilities and things like

00:43:46.619 --> 00:43:51.489
that where uh uh we sort of were taking practical approaches

00:43:51.500 --> 00:43:53.188
rather than waiting for rulemaking that I, I'm not

00:43:53.199 --> 00:43:56.208
aware of this many this this time around. Yeah, that

00:43:56.219 --> 00:43:59.610
SB3 was pretty comprehensive indeed.

00:44:02.378 --> 00:44:04.869
OK. Well, that being the case I will will now say that

00:44:04.878 --> 00:44:07.659
you know, while we're all here. We have another you

00:44:07.668 --> 00:44:10.679
know, some time allocated before, before we break.

00:44:10.688 --> 00:44:15.989
Uh So the floor is open for items of discussion for

00:44:16.000 --> 00:44:17.188
the folks in the room.

00:44:24.159 --> 00:44:27.260
All right. Well, fantastic. This was good. (Item:2.4:David Smeltzer closes 2nd session) This accomplished

00:44:27.269 --> 00:44:29.250
everything that we were hoping for. We got a few notes

00:44:29.260 --> 00:44:33.320
on items that they were not on our radar. Some good

00:44:33.329 --> 00:44:36.550
focus on priorities that are outside of the implementation

00:44:36.780 --> 00:44:39.739
schedule here. And uh we appreciate your feedback and

00:44:39.750 --> 00:44:43.809
participation and navigational guidance of the agenda

00:44:43.820 --> 00:44:45.079
by participants.

00:44:47.128 --> 00:44:50.398
And uh thus ended the workshop. Thank you.

00:44:56.438 --> 00:45:00.809
(item:3:David Smeltzer welcome participants and opens 3rd session) Welcome all to the stunning conclusion of the Staff

00:45:00.820 --> 00:45:04.179
Legislative implementation trilogy today. Uh We had

00:45:04.188 --> 00:45:06.769
good sessions this morning on telecom and water and

00:45:06.780 --> 00:45:10.559
predictably the room is the fullest for this uh electric

00:45:10.570 --> 00:45:12.840
panel. Because that's what we received the most bills

00:45:12.849 --> 00:45:15.889
on. Uh my name is David Smeltzer. I'm the Director

00:45:15.898 --> 00:45:18.329
of the Rules and Project Division with me. Here is

00:45:18.340 --> 00:45:21.510
Rama Rastogi. She's a Project Manager for the Rules and

00:45:21.519 --> 00:45:24.510
Project Division. And there are a number of other Staff

00:45:24.519 --> 00:45:27.260
in the room who we will introduce you to if it is

00:45:27.269 --> 00:45:29.199
fitting for them to come up as part of any of the

00:45:29.208 --> 00:45:29.809
discussion.

00:45:31.679 --> 00:45:34.769
(item:3:David Smeltzer lays out 3rd session objective) The main reason that we're having this workshop today

00:45:34.780 --> 00:45:38.090
is for those of you who have been part of the fund

00:45:38.099 --> 00:45:40.250
for the last couple of years, I think coming out of

00:45:40.260 --> 00:45:44.000
the 87th Legislative Session. We got the largest sort

00:45:44.010 --> 00:45:46.409
of rule making assignment load from the Legislature

00:45:46.418 --> 00:45:50.019
that we've seen. And last Session, I think we got a

00:45:50.030 --> 00:45:52.378
lot of statutory deadlines that provided the sort of

00:45:52.389 --> 00:45:56.199
guidance on the issues that we should prioritize and

00:45:56.208 --> 00:45:58.949
the way that we should sequence our rule making efforts

00:45:58.958 --> 00:46:01.688
This session. Thankfully, from my perspective, the

00:46:01.699 --> 00:46:04.079
Legislature gave us fewer hard deadlines which will

00:46:04.090 --> 00:46:07.300
make it easier to accommodate. But also that gives

00:46:07.309 --> 00:46:10.849
us more flexibility in determining the order in which

00:46:10.860 --> 00:46:13.668
we should do these. So as everyone knows, a lot of

00:46:13.679 --> 00:46:17.260
times, you know, we are confined by the Administrative

00:46:17.269 --> 00:46:20.309
Procedure Act and staffing realities and a number of

00:46:20.320 --> 00:46:23.619
other factors in terms of how we can actually execute

00:46:23.628 --> 00:46:27.139
these rules in order. However, as Commission Staff

00:46:27.148 --> 00:46:29.449
assembles its recommendations to the Commissioners

00:46:29.458 --> 00:46:32.409
on how we should proceed with these rule makings, we

00:46:32.418 --> 00:46:34.849
wanted to give a chance for stakeholders and other

00:46:34.860 --> 00:46:38.300
members of the public. To have a voice in that and let

00:46:38.309 --> 00:46:41.059
us know where we might be off what mistakes we might

00:46:41.070 --> 00:46:44.059
have made. And what additional input and priorities

00:46:44.070 --> 00:46:47.250
exist for the industry to answer some, some common

00:46:47.260 --> 00:46:49.769
questions we get. Some folks reached out that were

00:46:49.780 --> 00:46:52.929
not able to not able to attend today. And as you would

00:46:52.938 --> 00:46:56.000
have seen in the workshop notice, we did offer the

00:46:56.010 --> 00:46:59.929
option to file comments and we are going to extend

00:46:59.938 --> 00:47:02.760
the deadline for filing comments on that to close of

00:47:02.769 --> 00:47:06.519
business on Friday. And we will file a memo or something

00:47:06.530 --> 00:47:11.050
of that regard to that effect shortly. But I will say

00:47:11.320 --> 00:47:13.789
that one of the reasons we wanted to do the workshop

00:47:13.800 --> 00:47:16.969
format is because we've had a lot of success with the

00:47:16.978 --> 00:47:20.809
ADER workshops. And I think that there is the ability

00:47:20.820 --> 00:47:23.208
to sort of vet and discuss priorities in real time

00:47:23.219 --> 00:47:26.619
with different folks at the table uh leads to better

00:47:26.628 --> 00:47:29.340
outcomes. And so if you are at any point sitting on

00:47:29.349 --> 00:47:32.059
your hands, saying should I come talk or should I just

00:47:32.070 --> 00:47:35.829
file it? Get up to the dias right now is the time

00:47:36.349 --> 00:47:39.179
the other question that we often get with these sorts

00:47:39.188 --> 00:47:42.128
of things is if this is a Commission project where

00:47:42.139 --> 00:47:44.969
the Commissioners. And I would say that the Commissioners

00:47:44.978 --> 00:47:47.219
have all expressed to me, they are excited about this

00:47:47.228 --> 00:47:49.969
input. And they, they're tuning in. And in fact, I think

00:47:49.978 --> 00:47:53.168
several Legislators are tuning in as well. And so the

00:47:53.648 --> 00:47:56.168
you know, they will be listening and we will be briefing

00:47:56.179 --> 00:48:00.168
them on any comments that are filed. But I think sometimes

00:48:00.929 --> 00:48:05.780
folks are more willing to come speak candidly with

00:48:05.789 --> 00:48:09.168
Staff than with Commissioners. And also it's easier

00:48:09.179 --> 00:48:11.429
not to have to call an open meeting. So, you know,

00:48:11.438 --> 00:48:14.898
the Commissioners are, will be receiving all your comments

00:48:14.909 --> 00:48:16.340
and they're very valuable to them.

00:48:18.188 --> 00:48:22.090
(item:3:David Smeltzer lays out housekeeping details) So a few housekeeping matters, those were some, some

00:48:22.099 --> 00:48:25.559
more are the way that we will be proceeding today is

00:48:25.570 --> 00:48:29.119
by discussion format. So unlike at an open meeting

00:48:29.139 --> 00:48:30.789
we've got a number of,

00:48:33.559 --> 00:48:36.820
if I'm, if I'm not the only one who hasn't turned off

00:48:36.829 --> 00:48:38.349
your phone. That would be a good thing to do now.

00:48:38.860 --> 00:48:41.369
Um, you know, if at any point we get to a discussion

00:48:41.378 --> 00:48:43.250
topic where you think you have something to contribute

00:48:43.260 --> 00:48:46.958
find an open chair. Um, and we will sort of call on

00:48:46.969 --> 00:48:48.889
you as you come up and manage a discussion as best

00:48:48.898 --> 00:48:52.168
we can. And also sort of informal protocol that we

00:48:52.179 --> 00:48:55.510
developed in the, the ADER workshops. Is if you are

00:48:55.728 --> 00:48:58.369
up at the dais because you are interested in speaking on

00:48:58.378 --> 00:49:01.119
the current topic. You know, you can wave a little

00:49:01.128 --> 00:49:02.849
one when we see you speaking and if you are waiting

00:49:02.860 --> 00:49:05.510
to talk on another topic, um you can just give us a

00:49:05.519 --> 00:49:08.398
two. So that way we know who to call on first.

00:49:13.188 --> 00:49:17.148
So let's, let's get started, I guess, unlike the other

00:49:17.159 --> 00:49:20.369
two that we had. There were, there was

00:49:20.378 --> 00:49:23.168
a lot of legislation in the electric, in the electric

00:49:23.179 --> 00:49:26.438
space this time. (item:3.1:David Smeltzer on SB365) And so I guess I'll briefly review

00:49:26.449 --> 00:49:29.898
why staff's initial recommendations for the first wave.

00:49:29.978 --> 00:49:33.708
And I will say that for, you know, pending Commissioner

00:49:33.719 --> 00:49:36.530
agreement and any discussion that we have today. I

00:49:36.539 --> 00:49:40.260
think that we, we did have a few statutory deadlines

00:49:40.269 --> 00:49:43.079
and a few real world realities that made it. So I think

00:49:43.090 --> 00:49:45.969
that we've fairly well identified what we think are

00:49:45.978 --> 00:49:49.340
our first wave of rule making that were either booted

00:49:49.349 --> 00:49:53.668
up or starting to boot up. And so the list is, was

00:49:55.449 --> 00:49:58.128
uh so the, you know, the list that's included in the

00:49:58.139 --> 00:50:00.639
memo here and I'll just tell you why they're there.

00:50:00.648 --> 00:50:03.059
(item:3.2:David Smeltzer on SB1076) The first of which was we're working on implementing

00:50:03.070 --> 00:50:07.789
SB365 and um sort of facilitating implementation

00:50:07.800 --> 00:50:11.059
of SB1076. And the reason is, is one of the

00:50:11.070 --> 00:50:14.644
challenges that are Commission and the industry face

00:50:14.655 --> 00:50:18.304
right now is that we have to, we're working on expediting

00:50:18.313 --> 00:50:20.954
the transmission process so that we can get transmission

00:50:20.965 --> 00:50:23.494
lines built faster and accordingly, the legislature

00:50:23.503 --> 00:50:26.125
provided direction that we needed to increase. Rather

00:50:26.135 --> 00:50:31.215
we need to decrease the timeline from 360 to 180 days.

00:50:31.324 --> 00:50:34.543
And so, in order to help meet that, we, we've already

00:50:34.554 --> 00:50:38.494
initiated a rule making to modify the notice provisions

00:50:38.503 --> 00:50:40.594
you know, procedural notice provisions for intervention

00:50:40.800 --> 00:50:43.239
And so that's why that was the top of the list. And

00:50:43.250 --> 00:50:46.550
that same rule making will allow us to implement 365,

00:50:46.559 --> 00:50:50.469
SB365. Which requires additional notice to be provided

00:50:50.478 --> 00:50:54.349
to landowners adjacent to proposed substations. And

00:50:54.360 --> 00:50:56.530
so that was, that was an easy start because you know

00:50:56.539 --> 00:50:58.809
the CCN application is already coming in and we want

00:50:58.820 --> 00:51:01.869
to be able to process these transmission lines quickly.

00:51:02.639 --> 00:51:05.570
(item:3.4:David Smeltzer on HB2555) The next cluster of rules that we've identified that

00:51:05.579 --> 00:51:08.438
we want to start looking at now have to do with resiliency

00:51:08.449 --> 00:51:12.760
and reliability planning. The resiliency planning HB2555

00:51:12.769 --> 00:51:18.418
allows transmission and distribution utilities

00:51:18.429 --> 00:51:21.489
to propose resiliency plans for which they can get

00:51:21.500 --> 00:51:25.159
recovery. This is included on the first wave implementation

00:51:25.168 --> 00:51:28.989
list because it came with 180 day implementation timeline

00:51:29.000 --> 00:51:34.378
and that clock is already ticking. (item:3.5:David Smeltzer on HB5066) Similarly, HB5066

00:51:34.389 --> 00:51:37.929
reliability plans. We are still and this can be

00:51:37.938 --> 00:51:41.559
a discussion point today. But we are still, we don't

00:51:41.570 --> 00:51:44.168
have a deadline for implementing the rule. The rule

00:51:44.179 --> 00:51:47.958
that allows us to require ERCOT to develop reliability

00:51:47.969 --> 00:51:51.539
plans for regions with insufficient capacity that is

00:51:51.550 --> 00:51:54.320
open ended. But we do specifically have to direct them

00:51:54.329 --> 00:51:57.228
to develop a reliability plan for the Permian Basin

00:51:57.239 --> 00:52:00.510
region by January. And so we're currently evaluating

00:52:00.519 --> 00:52:04.349
whether or not we need the rule making to proceed that

00:52:04.360 --> 00:52:06.978
order if we or if we can order them more directly without.

00:52:07.458 --> 00:52:11.059
(item:3.6:David Smeltzer on HB1500) Um similarly, um another one that came with the deadline

00:52:11.070 --> 00:52:15.030
for us was in HB1500, Section 9. Which is listed

00:52:15.039 --> 00:52:18.019
here as transmission interconnection allowance. But

00:52:18.369 --> 00:52:22.119
essentially this is here because of 180 deadline.

00:52:22.128 --> 00:52:26.418
And it similar to how um loads of a certain size have

00:52:26.429 --> 00:52:28.340
to pay a standard allowance for interconnection will

00:52:28.349 --> 00:52:31.809
be thinking through a similar uh similar provision

00:52:31.820 --> 00:52:35.579
for generation. (item:3.6:David Smeltzer on HB1500, 2nd Section 13, TDUs circuit segmentation study) Um another item that we have listed

00:52:35.590 --> 00:52:37.938
here that we're looking at that may actually not be

00:52:37.949 --> 00:52:42.780
through rulemaking, I don't think is HB1500, 2nd Section

00:52:42.789 --> 00:52:47.750
13 orders the TDUs to do a circuit segmentation study.

00:52:48.050 --> 00:52:50.780
Um basically, you know, we want the Legislature would

00:52:50.789 --> 00:52:52.769
like them to look at their systems and figure out if

00:52:52.780 --> 00:52:58.179
they can take the units which they are able to, um

00:52:58.719 --> 00:53:01.079
you know, when they shed Load and divide those into

00:53:01.090 --> 00:53:03.449
smaller units. I think that there are a lot of technical

00:53:03.708 --> 00:53:06.989
known technical issues with that and we need to explore

00:53:07.000 --> 00:53:09.179
that further. The reason this is on the list is, I

00:53:09.188 --> 00:53:11.438
think we've been getting a lot of questions on if we're

00:53:11.449 --> 00:53:13.820
going to be doing a rule making on this. And presently

00:53:13.829 --> 00:53:17.728
our plan is to release something like a discussion

00:53:17.739 --> 00:53:20.639
draft, but it said it will be a proposed order will

00:53:20.648 --> 00:53:23.139
allow you guys to have a comment on whether or not

00:53:23.289 --> 00:53:25.489
we're ordering the right kind of information that would

00:53:25.500 --> 00:53:28.300
be most useful in determining whether or not circuit

00:53:28.309 --> 00:53:32.500
segmentation is appropriate or not. And then we will

00:53:32.510 --> 00:53:36.228
be formally issuing the order with enough time for

00:53:36.500 --> 00:53:42.039
the TDUs to, to do that. (item:3.7:David Smeltzer on HB1500, Section 17) Another key item that made

00:53:42.050 --> 00:53:45.679
it on the list is HP 1500, Section 17. Which has to

00:53:45.688 --> 00:53:48.360
do with ERCOT directives. But that rule making will

00:53:48.369 --> 00:53:51.269
also include um you know, some SB3 provisions

00:53:51.280 --> 00:53:54.010
that had to do with other ERCOT governance things and

00:53:54.019 --> 00:53:58.750
under SB or under HB1500. The ways in which the Commission

00:53:58.760 --> 00:54:04.599
is able to direct ERCOT to do things has been um has

00:54:04.610 --> 00:54:06.510
been modified. And so instead of being able to give

00:54:06.519 --> 00:54:08.849
verbal directives at open meetings, in most cases,

00:54:08.949 --> 00:54:11.519
we're going to have to either do a written order or

00:54:11.530 --> 00:54:14.369
a rule making or contested case. And I think that a

00:54:14.378 --> 00:54:17.728
lot of stakeholders and members of the public and Commission

00:54:17.918 --> 00:54:21.398
will benefit from additional clarity on the ways that

00:54:21.409 --> 00:54:23.708
ERCOT can be directed by the Commission. And so

00:54:23.719 --> 00:54:26.289
we are, we're including that on our first wave as sort

00:54:26.300 --> 00:54:30.418
of an operational necessity to improve, you know, predictability

00:54:30.429 --> 00:54:34.260
and transparency in the in PUC process. I also will

00:54:34.269 --> 00:54:38.039
note that one of the prompts for discussion today is

00:54:38.050 --> 00:54:40.938
um one of the prompts for discussion today. Is are

00:54:40.949 --> 00:54:45.398
there any things that can be implemented, you know

00:54:45.409 --> 00:54:49.119
without a rule making? And so, you know, directives

00:54:49.128 --> 00:54:51.829
ERCOT may be one of the answers in some situations

00:54:51.840 --> 00:54:55.159
and you'll see a few items down for the.

00:54:56.760 --> 00:54:59.619
(item:3.8:David Smeltzer on HB1500, Section 22) Oh, in fact, the next item that uh HB1500, Section

00:54:59.628 --> 00:55:03.050
22 has to do with the development of a dispatch reliability

00:55:03.059 --> 00:55:04.978
reserve service. And I think presently, we think that

00:55:04.989 --> 00:55:09.398
can be accomplished by directive rather than by rulemaking

00:55:09.510 --> 00:55:12.969
and whether or not any directives get done prior to

00:55:12.978 --> 00:55:17.179
September 1st or after September 1st uh impact the

00:55:17.188 --> 00:55:20.239
ways in which we're able to uh provide those directives.

00:55:21.320 --> 00:55:24.039
(item:3.9:David Smeltzer on HB1500, Section 40) The next rule making that we've identified as being

00:55:24.050 --> 00:55:28.148
a first wave rulemaking is HP 1500 section 40 which

00:55:28.159 --> 00:55:30.688
has to do with a significant power outage has to do

00:55:30.699 --> 00:55:33.849
with allowing transmission and distribution utilities

00:55:33.958 --> 00:55:37.019
to lease out mobile generation units and other similar

00:55:37.030 --> 00:55:40.570
things to respond significant power outages. This

00:55:40.579 --> 00:55:43.168
did not have a deadline, but we actually had an ongoing

00:55:43.179 --> 00:55:46.500
rule making for the version of this legislation from

00:55:46.510 --> 00:55:49.639
last session. So the rule making team is was already

00:55:49.648 --> 00:55:52.389
assembled. So like okay press on, we've had the first

00:55:52.398 --> 00:55:55.349
wave of contested cases. We have new legislation and

00:55:55.360 --> 00:55:58.469
we know that this is critical in terms of our abilities

00:55:58.478 --> 00:56:01.708
to respond to ongoing power outages. So we wanted to

00:56:01.719 --> 00:56:04.789
prioritize that as well. And I think for those interested

00:56:04.800 --> 00:56:09.139
the project team is also exploring including SB415

00:56:09.320 --> 00:56:13.239
as part of that rule making projects work, which is

00:56:13.250 --> 00:56:16.019
a similar provision from last session that has to do

00:56:16.030 --> 00:56:19.648
with TDUs ability to use energy storage solutions.

00:56:21.559 --> 00:56:24.349
(item:4.1:David Smeltzer on SB3, Section 18) Also included on the list just for public awareness

00:56:24.360 --> 00:56:26.449
because it's been posted for a long, it's been posted

00:56:26.458 --> 00:56:29.478
on the rule making calendar for a long time. Is Section

00:56:29.489 --> 00:56:32.599
18 from SP3 last time which directs the Commission

00:56:32.610 --> 00:56:36.579
to develop an emergency pricing program. Um We have

00:56:36.590 --> 00:56:38.929
uh we have been interested in doing that for a long

00:56:38.938 --> 00:56:41.840
time but because of heavy rule making Load, we haven't

00:56:41.849 --> 00:56:45.300
gotten to it yet, but the team is assembled and beginning

00:56:45.309 --> 00:56:49.958
to have discussions with a on developing that on that

00:56:49.969 --> 00:56:52.469
now. (item:4.2:David Smeltzer on SB2627) And then finally, the last one is part of our

00:56:52.860 --> 00:56:55.090
you know, we're trying to get started right away is

00:56:55.099 --> 00:56:59.918
SB2627 which creates the Texas Energy Fund. And, um

00:57:01.329 --> 00:57:04.059
you know, the back uh backup program and this is one

00:57:04.070 --> 00:57:08.699
that is, uh, it's a, it's a complicated piece of legislation

00:57:08.708 --> 00:57:10.239
and it's a little bit different than anything that

00:57:10.250 --> 00:57:13.829
the Commission does. And so we are already starting

00:57:13.840 --> 00:57:17.429
to have discussions with other agencies that have similar

00:57:17.438 --> 00:57:20.449
types of funds such as the Swift Fund at TWDB. So that

00:57:20.458 --> 00:57:22.820
we can um build up our expertise that's going to be

00:57:22.829 --> 00:57:26.269
necessary to implement such a thing. And our current

00:57:26.539 --> 00:57:30.579
one, one weird aspect about the Texas Energy Fund is

00:57:30.590 --> 00:57:34.898
that it is not actually it has to be, there's a corresponding

00:57:34.909 --> 00:57:37.070
constitutional amendment that has to be adopted by

00:57:37.079 --> 00:57:39.679
a public referendum in the November election. And so

00:57:39.688 --> 00:57:42.780
the way we're trying to sort of split the work on this

00:57:42.789 --> 00:57:46.898
is staff currently hopes to file, you know, at the

00:57:46.909 --> 00:57:49.519
beginning of the rule making process, we file a draft

00:57:49.530 --> 00:57:52.780
of a rule for public comment and that has most of the

00:57:52.789 --> 00:57:55.458
logistics of the rule worked out. And then at the end

00:57:55.469 --> 00:57:58.280
of the rule making process, we have to issue a final

00:57:58.289 --> 00:58:01.378
order which is the final rule and it has responses

00:58:01.389 --> 00:58:05.728
to all public comments. And the assembly of that final

00:58:05.739 --> 00:58:08.378
order can sometimes take weeks and depending on the

00:58:08.389 --> 00:58:12.708
complication, how complicated a rule is could be several

00:58:12.719 --> 00:58:15.369
100 pages long. And so the, the way we're, we're currently

00:58:15.530 --> 00:58:17.769
the way that Staff is recommending the Commission proceed

00:58:17.780 --> 00:58:20.458
on that at this time is to try and get the, the

00:58:20.469 --> 00:58:23.500
draft rule out prior to the November election and do

00:58:23.510 --> 00:58:26.110
the, the final order and a couple of weeks of work

00:58:26.119 --> 00:58:29.579
associated with that after the November election. And

00:58:29.590 --> 00:58:34.228
so this is, that is Staff's current plan. And so the

00:58:34.239 --> 00:58:37.050
first are the, your Staff's current recommendations

00:58:37.059 --> 00:58:40.449
for what are the obvious first tier implementation

00:58:40.719 --> 00:58:44.699
items from this uh this most recent session? And so

00:58:44.708 --> 00:58:47.750
I will now say that the first prompt and reason for

00:58:47.760 --> 00:58:52.500
this rule making is or for this workshop rather is

00:58:52.510 --> 00:58:56.059
Uh is there anything else that should be on this list

00:58:56.070 --> 00:58:59.648
either based on a statutory implementation deadline

00:58:59.659 --> 00:59:04.260
that I may have missed or a real world practicality

00:59:04.349 --> 00:59:07.260
that merits something being taken up first. (item:4:David Smeltzer on HB1500 Renewable Energy) And actually

00:59:07.269 --> 00:59:10.739
as I looked down, I realized I skipped one in HB1500.

00:59:10.750 --> 00:59:13.300
There's also sort of a repeal of the goals associated

00:59:13.309 --> 00:59:16.849
with the Renewable Energy credit trading program. And

00:59:16.860 --> 00:59:19.969
we've had stakeholders reach out to us already looking

00:59:19.978 --> 00:59:22.769
for guidance in how they are supposed to comply with

00:59:22.780 --> 00:59:25.679
this year since it's based on a calendar year. And

00:59:25.688 --> 00:59:29.989
so our Staff is already exploring possible guidance

00:59:30.000 --> 00:59:33.760
on how best to comply with the, the rule and statute

00:59:33.769 --> 00:59:37.260
in that regard. And so um returning back to the prompt

00:59:37.269 --> 00:59:40.050
that I was getting at okay. (item:3:David Smeltzer asks if any additional items to be added to list) First wave of rulemaking

00:59:40.059 --> 00:59:43.059
Is there anything that's not on this list that should

00:59:43.070 --> 00:59:47.090
be? And I would invite anyone who has anything um to

00:59:47.099 --> 00:59:50.000
discuss on that matter to join, join us at the front

00:59:53.438 --> 00:59:55.929
And when you, when you uh if you, if you come up

00:59:55.938 --> 00:59:58.728
when you speak, if you will identify your name and

00:59:58.739 --> 01:00:01.329
anyone that you represent that will help us later.

01:00:01.628 --> 01:00:04.898
Um I'll also say that today we, you know, we will get

01:00:04.909 --> 01:00:08.000
into details, we will get into details to the extent

01:00:08.010 --> 01:00:11.789
that it is helpful for discussion, but flagging and

01:00:11.800 --> 01:00:14.590
identifying the issues is what is the best way for

01:00:14.599 --> 01:00:16.849
us to use our sort of two hours today. And then if

01:00:16.860 --> 01:00:19.458
we need to have follow up meetings or conversations

01:00:19.469 --> 01:00:22.719
we will know how to find you either because we already

01:00:22.728 --> 01:00:24.728
know you or we'll check, we'll check the sign up sheet

01:00:24.739 --> 01:00:25.688
that was outside the door.

01:00:27.510 --> 01:00:31.269
(item:3:Jason Danowski with Young Energy on moratoriums against disconnections during weather emergencies) Good afternoon. Uh My name is Jason Danowski. I'm here

01:00:31.280 --> 01:00:34.610
representing Young Energy. Been certified as

01:00:34.619 --> 01:00:39.289
a rep since 2005 and uh here today to talk about something

01:00:39.300 --> 01:00:42.059
that's not a legislative matter. But it is concerning

01:00:42.070 --> 01:00:46.128
a real world issue, which is uh moratoriums against

01:00:46.139 --> 01:00:49.159
disconnections during extreme weather emergencies.

01:00:49.760 --> 01:00:52.820
So, in the past couple of years, there's been a number

01:00:52.829 --> 01:00:56.978
of investigations and sanctions with regards to disconnection

01:00:56.989 --> 01:01:02.260
moratoriums. And our concern is that these investigations

01:01:02.269 --> 01:01:06.128
and sanctions don't address the systemic issues that

01:01:06.139 --> 01:01:09.909
are leading to not in compliance. For that reason, we

01:01:09.918 --> 01:01:13.489
would propose a future PUC workshop that could address

01:01:13.500 --> 01:01:16.250
these systemic issues. To give an example of what I'm

01:01:16.260 --> 01:01:21.128
talking about. So, uh TD us are not obligated to provide

01:01:21.139 --> 01:01:27.780
reps the uh the subscribers county of record. However

01:01:27.789 --> 01:01:30.449
national weather service advisories, which are the

01:01:30.458 --> 01:01:34.550
basis of these extreme weather emergencies are issued

01:01:34.559 --> 01:01:38.679
county by county. So an REP could inadvertently uh

01:01:38.699 --> 01:01:43.099
issue a disconnection for nonpayment during a moratorium

01:01:43.110 --> 01:01:45.309
to someone in a county because they don't have the

01:01:45.320 --> 01:01:49.570
right county and getting these counties. And this information

01:01:49.579 --> 01:01:53.668
from third party aggregators is often inaccurate. So

01:01:54.378 --> 01:01:55.978
you know, there's no one better for us to get it from

01:01:55.989 --> 01:02:01.030
than the TDUs. Um workshop could also address uh the

01:02:01.039 --> 01:02:04.639
development and sharing of methods by which these advisories

01:02:04.648 --> 01:02:09.978
are incorporated into TDU and REP systems. The advisories

01:02:09.989 --> 01:02:13.469
that I mentioned they're sent by email. So that means

01:02:13.478 --> 01:02:17.019
TDU and REP Staff have to manually look at emails and

01:02:17.030 --> 01:02:18.969
then manually incorporate the information of those

01:02:18.978 --> 01:02:22.679
emails into their systems which could lead to delay

01:02:23.010 --> 01:02:26.938
into user error. Likewise, the uh communications between

01:02:26.949 --> 01:02:29.969
TDUs and REPs on these matters is also by email again

01:02:29.978 --> 01:02:35.789
you have delay and user error. Um So, you know, developing

01:02:35.800 --> 01:02:38.000
systems that could do a better handshake or otherwise

01:02:38.010 --> 01:02:41.168
incorporate this information would benefit Texas consumers

01:02:41.708 --> 01:02:45.889
uh and marketplace participants. Uh The workshop could

01:02:45.898 --> 01:02:49.159
also be followed by a rule making proceeding to address

01:02:49.168 --> 01:02:51.719
issues such as consistency between the rule and the

01:02:51.728 --> 01:02:56.139
statute and to consider a safe harbor provision. Uh

01:02:56.628 --> 01:03:00.728
The alliance for retail markets filed comments in the

01:03:00.739 --> 01:03:03.750
uh in the proceeding ending in 89. I apologize. I don't

01:03:03.760 --> 01:03:05.659
have that number right in front of me. But the other

01:03:05.668 --> 01:03:09.019
proceeding which they proposed a two hour safe harbor.

01:03:09.458 --> 01:03:12.898
Young Energy endorses that safe harbor concept. So

01:03:12.909 --> 01:03:16.148
two hours after the weather moratorium begins would

01:03:16.159 --> 01:03:19.769
be, uh you know, an opportunity for if we inadvertently

01:03:19.780 --> 01:03:22.289
set out a disconnection to correct that disconnection

01:03:22.300 --> 01:03:26.849
before then. Um, but we'd also note that if the systemic

01:03:26.860 --> 01:03:28.539
issues are addressed, you could have a shorter safe

01:03:28.550 --> 01:03:31.260
harbor. Because you wouldn't be sending out as many

01:03:31.269 --> 01:03:34.800
inadvertent disconnections. Uh thank you. Thank you.

01:03:35.489 --> 01:03:41.648
Uh, okay so as some housekeeping off of that. (item:3:David Smeltzer's response the Young Energy) I think

01:03:41.719 --> 01:03:44.250
and I think we discussed before and I knew that this

01:03:44.260 --> 01:03:46.228
was going to be an issue. It's a known issue that comes

01:03:46.239 --> 01:03:49.898
up. Um And so I think, you know, that is a short

01:03:49.909 --> 01:03:53.809
level of detail as far as like why the issue is important

01:03:53.820 --> 01:03:56.628
to you or your client that allows us to flag it. And

01:03:56.639 --> 01:03:59.599
I think just so that we know Staff is not going to

01:03:59.610 --> 01:04:03.579
be making any reactions or, you know, unless there's

01:04:03.590 --> 01:04:06.090
known interest by the Commissioners to do something.

01:04:06.099 --> 01:04:07.639
For the most part, I think this is going to be an

01:04:07.648 --> 01:04:10.829
exercise about receiving other priorities for consideration

01:04:11.250 --> 01:04:15.418
So, thank you. Thank you for coming. Um, and I guess

01:04:15.429 --> 01:04:18.958
I guess quickly in terms of assembling interest in

01:04:18.969 --> 01:04:21.978
stakeholders, are there other um by show hands. Are

01:04:21.989 --> 01:04:23.938
there other people in the room for which this is a

01:04:23.949 --> 01:04:25.159
uh an item of interest?

01:04:27.300 --> 01:04:33.300
Okay. So, so that's excellent. Uh one other um and, and

01:04:33.309 --> 01:04:35.079
if we want to talk a little bit more about whether

01:04:35.090 --> 01:04:37.289
or not there should be a party we can do. So one

01:04:37.300 --> 01:04:41.329
other bad on my part. I think that uh uh presently

01:04:41.340 --> 01:04:43.110
the way that I should have surfaced, uh the way that

01:04:43.119 --> 01:04:45.369
I should have prefaced this, this first phase of the

01:04:45.378 --> 01:04:49.188
the workshop and I did not was um are there any legislative

01:04:49.199 --> 01:04:51.989
implementation items from the 88th Session that we

01:04:52.000 --> 01:04:54.269
should have higher up on the to do list? And then a

01:04:54.280 --> 01:04:56.708
little bit later in the workshop, we'll have other

01:04:56.719 --> 01:04:58.860
non legislative priorities. And so this was, I did

01:04:58.869 --> 01:05:00.889
not clarify. So that's exactly the sort of feedback

01:05:00.898 --> 01:05:03.590
that we're going to want um at that at the appropriate

01:05:03.599 --> 01:05:06.708
time in this workshop. So no harm, no harm, no foul.

01:05:06.719 --> 01:05:11.199
Did anyone have any um uh comments on whether or not

01:05:11.208 --> 01:05:13.639
the suggestion that we just received is something that

01:05:13.648 --> 01:05:16.599
should be brought up in the near future. And, and,

01:05:16.610 --> 01:05:18.679
and the intention is not to get into the nitty gritty

01:05:18.688 --> 01:05:21.668
about what the right solution is here necessarily.

01:05:21.760 --> 01:05:24.878
But um whether or not it should be considered a priority

01:05:25.809 --> 01:05:28.340
I mean? (item:3:Carrie Collier Brown with Alliance for Retail Markets on Project 54844, disconnection rules) Carrie Collier Brown with Alliance for Retail

01:05:28.349 --> 01:05:36.148
Markets. And um we filed comments in Project 54844 with

01:05:36.159 --> 01:05:41.918
some suggestions um on how to improve the disconnection

01:05:41.929 --> 01:05:45.070
rules within that. Um And you know, we understand you

01:05:45.079 --> 01:05:48.849
guys have a lot on your plate um and implementation

01:05:48.860 --> 01:05:53.978
of um new legislation. But um you know, we think that

01:05:53.989 --> 01:05:57.648
uh you know, there's, there's a way to, to make that

01:05:57.659 --> 01:06:03.168
process better um for customers, REPs, TDUs. And that

01:06:03.179 --> 01:06:06.449
it could be done fairly easily even if it's just, um

01:06:06.458 --> 01:06:09.159
you know, jumping off the comments that we had proposed

01:06:09.168 --> 01:06:11.679
in that other rule making. Okay. Excellent.

01:06:13.269 --> 01:06:15.519
Do I have any, do I have any ones on this topic

01:06:16.849 --> 01:06:22.289
on the price or the, uh, moratorium or? Oh, the electric

01:06:22.300 --> 01:06:24.019
disconnection? Ok. Got you.

01:06:26.079 --> 01:06:30.750
(item:3:Ned Boskoski with Vistra in agreement with mortarium) Uh, Ned Boskoski with Vistra. Um, we're a member of

01:06:30.760 --> 01:06:35.099
ARM. So just as an, a housekeeping, uh, item. If I

01:06:35.110 --> 01:06:38.329
could say ditto or support Carrie. I don't wanna belabor the

01:06:38.340 --> 01:06:44.889
topic. Yeah. Ditto. We will do uh I will uh we

01:06:44.898 --> 01:06:47.840
can do uh, I'll, I'll do the polling of the room like

01:06:47.849 --> 01:06:50.869
I did before for you. Yeah, three can be ditto. A new protocol

01:06:50.878 --> 01:06:53.780
was born. The but the, but the Boskoski option is

01:06:53.789 --> 01:06:58.188
three for ditto. Okay. So uh on to the topic uh back

01:06:58.199 --> 01:07:01.269
to the other legislative items from the 88th that should

01:07:01.280 --> 01:07:05.869
be considered for, um, immediate treatment. Ok. Uh

01:07:05.878 --> 01:07:09.628
(item:3:Michelle Richmond with TX Competitive Power Advocates on reliability standard not reflected in list) Michelle Richmond, uh, Texas Competitive Power Advocates

01:07:09.639 --> 01:07:14.590
and representing the 14 member companies of TCPA.

01:07:14.780 --> 01:07:19.010
Um I don't know that it, I think it was probably unintentional

01:07:19.019 --> 01:07:22.829
but the reliability standard is not anywhere on here.

01:07:22.840 --> 01:07:26.239
And I know that that's in process, but that is a top

01:07:26.250 --> 01:07:30.688
priority. And we really view that as you know, everything

01:07:30.699 --> 01:07:33.250
else that you're implementing to a large extent is

01:07:33.260 --> 01:07:36.739
going to flow from that. So we need to know what we're

01:07:36.750 --> 01:07:40.030
actually solving for when we look at all of the other

01:07:40.039 --> 01:07:44.438
market design um standards that, that y'all are gonna

01:07:44.449 --> 01:07:49.228
be implementing. Um whether that's DRRS or you know

01:07:49.239 --> 01:07:53.688
the performance credit mechanism or, you know, really

01:07:53.699 --> 01:07:56.579
any other aspect of market design. And so we wanna

01:07:56.590 --> 01:07:59.909
make sure that, that that remains a top priority that

01:07:59.918 --> 01:08:04.449
that um is really kind of full speed ahead. Um But

01:08:04.458 --> 01:08:07.050
because we have some significant concerns that without

01:08:07.059 --> 01:08:10.989
a reliability standard that everybody knows and understands

01:08:11.000 --> 01:08:14.478
um it's gonna be very hard to determine some of these

01:08:14.489 --> 01:08:19.229
other aspects. Um And, and the implementation of those

01:08:19.239 --> 01:08:21.279
So yeah, I think that's, that's good feedback. (item:3:David Smeltzer's comments on reliability standard) And

01:08:21.289 --> 01:08:23.548
I would say that there, there are certain issues that

01:08:23.699 --> 01:08:29.750
um uh I said projects that were ongoing prior to the

01:08:29.759 --> 01:08:32.659
88th session unless you hear otherwise it's safe

01:08:32.668 --> 01:08:35.159
to assume that they, they're still ongoing and in particular

01:08:35.338 --> 01:08:39.310
the reliability standard and things related to the

01:08:39.319 --> 01:08:43.259
PUC generally. Um I sort of view those as even above

01:08:43.270 --> 01:08:45.810
my head. Because a lot of heavy Commissioner engagement

01:08:45.819 --> 01:08:49.810
on that. So I'm agree with you and I'm, I, I suspect

01:08:49.819 --> 01:08:52.600
that they view that as a top priority as well. Great

01:08:52.609 --> 01:08:56.079
(item:3:Michelle Richmond on PUC directives) And then, um we just wanna make sure that the, the

01:08:56.088 --> 01:09:01.498
component related to the PUC directives um is addressed

01:09:01.507 --> 01:09:04.738
really early on in, in this bout of rule making because

01:09:04.748 --> 01:09:07.979
again, that implement that implementation is gonna

01:09:07.988 --> 01:09:11.179
be critical to, you know, market participants being

01:09:11.188 --> 01:09:15.269
able to effectively engage um in the process and understand

01:09:15.278 --> 01:09:19.938
what the the rules are. And you know, with the opinion

01:09:19.948 --> 01:09:23.364
that says that protocols or rules subject to APA.

01:09:23.375 --> 01:09:25.884
We want to understand what the processes are there

01:09:25.895 --> 01:09:30.074
as well. Um And so, you know, those are, those are

01:09:30.083 --> 01:09:32.845
some of the, the things and then you've mentioned the

01:09:32.854 --> 01:09:35.914
the emergency pricing. And so we just very much support

01:09:35.923 --> 01:09:40.833
making sure that the things from the 2021 Session are

01:09:41.204 --> 01:09:45.923
at the very top to implement soon. Um Yeah, and, and

01:09:45.935 --> 01:09:49.149
on that note, I will, I will say that the uh any

01:09:49.159 --> 01:09:52.100
remaining items from the 87th session were not necessarily

01:09:52.109 --> 01:09:55.899
included on this list, but they have, they uh are still

01:09:55.909 --> 01:09:59.100
on our master lists and uh our items that we know that

01:09:59.109 --> 01:10:02.020
we need to. Yeah, I if, if I can just draw your

01:10:02.029 --> 01:10:04.439
attention. (item:3:Michelle Richmond on emergency pricing program) There's a component of the emergency pricing

01:10:04.449 --> 01:10:07.159
program that I think gets kind of forgotten. And that's

01:10:07.168 --> 01:10:12.208
the making sure that resource owners can, um, recoup

01:10:12.220 --> 01:10:17.628
their, uh, verifiable, um, operating costs. That, that's

01:10:17.640 --> 01:10:20.180
pretty important. And so you can make sure that, that

01:10:20.189 --> 01:10:22.680
that is included in what you do with the emergency

01:10:22.689 --> 01:10:26.449
pricing program. Agree. (item:3:Rama Rastogi with Commission Staff on 87th Session items) I think just to add to what

01:10:26.458 --> 01:10:30.869
Smeltzer just said that the items from the 87th legislature

01:10:30.878 --> 01:10:34.029
you would routinely now see on the rule making calendar

01:10:34.039 --> 01:10:37.319
and that would be the place where you should follow.

01:10:37.588 --> 01:10:39.529
It is still on our list and we're working through those

01:10:39.539 --> 01:10:42.600
lists. But, but I would say that when we get to the

01:10:42.609 --> 01:10:44.829
the, you know section, like if, if there's anything

01:10:44.838 --> 01:10:47.189
lingering that you're like, no, this is, we need it

01:10:47.199 --> 01:10:49.509
now. I want that to be a part of this discussion. That's

01:10:49.520 --> 01:10:53.909
all one other um message from message from the box.

01:10:53.918 --> 01:10:55.859
That I just got is as we're going through any items

01:10:55.869 --> 01:10:59.600
from the 88th session. Um We, we do not uh have all

01:10:59.609 --> 01:11:01.668
the bill numbers and content memorized. So to the extent

01:11:01.680 --> 01:11:04.949
that you can referring to them by uh by their bill

01:11:04.958 --> 01:11:08.359
number is helpful to us. It to facilitate this discussion

01:11:08.979 --> 01:11:12.619
If I could encourage everyone who's speaking to speak

01:11:12.628 --> 01:11:15.899
closer to the microphone. It's actually quite hard

01:11:15.909 --> 01:11:18.708
to hear people who are facing away from us. And I can

01:11:18.720 --> 01:11:23.220
only imagine what it's probably like the adminmonitor.

01:11:24.189 --> 01:11:25.399
Thank you, agreed.

01:11:27.619 --> 01:11:31.819
That, that's what I have. Continuing on with um some

01:11:31.829 --> 01:11:34.539
comments that Michelle had and going in line with what

01:11:34.548 --> 01:11:37.958
you have on your document for implementation along

01:11:37.970 --> 01:11:42.319
with HB1500, Section 17 for ERCOT directives. Um it may

01:11:42.329 --> 01:11:45.239
be good to consider also in that project implementation

01:11:45.250 --> 01:11:49.088
of HB 1500, Section 15, which was the change to the

01:11:49.100 --> 01:11:51.720
statute that talked about how protocols are not effective

01:11:51.729 --> 01:11:54.345
until they're approved the Commission. And so then

01:11:54.354 --> 01:11:56.884
that brings into the question, well, what is an approval

01:11:56.895 --> 01:11:59.673
Is it a case? Is it a rule making? And that becomes

01:11:59.685 --> 01:12:02.125
particularly important because of the third court's

01:12:02.134 --> 01:12:05.265
opinion and the RWE case, which found that many of

01:12:05.274 --> 01:12:07.395
the protocols can actually be ruled subject to the

01:12:07.583 --> 01:12:11.289
APA. And the answers from that rule making. If you do

01:12:11.298 --> 01:12:14.109
that sooner rather than later will help inform all

01:12:14.119 --> 01:12:16.180
of the direction the Commission may feel like they

01:12:16.189 --> 01:12:18.779
need to provide ERCOT in the implementation of the

01:12:18.789 --> 01:12:21.439
reliability standard as well as in the PCM. Which

01:12:21.449 --> 01:12:23.659
thanks for clarifying that those are priorities. Um

01:12:23.668 --> 01:12:26.029
Even though we don't see them specifically listed.

01:12:26.588 --> 01:12:33.489
Um And then the last thing that we would add is from

01:12:33.500 --> 01:12:36.350
legislation, but at the same time may not necessarily

01:12:36.359 --> 01:12:39.659
require rule making at least part of it. So in Senate

01:12:39.668 --> 01:12:44.079
Bill 1699 the latter half of the bill talks about

01:12:44.088 --> 01:12:47.609
the residential demand response schools in and also

01:12:47.619 --> 01:12:52.229
talks about rep demand response programs being eligible

01:12:52.239 --> 01:12:54.890
for receiving funding through TDU energy efficiency

01:12:54.899 --> 01:12:58.390
programs. If it's possible that the latter part of

01:12:58.399 --> 01:13:01.338
that, the funding through the EE programs is something

01:13:01.390 --> 01:13:04.970
that can be done either in the energy efficiency, implementation

01:13:04.979 --> 01:13:08.680
planning process or in another forum that wouldn't

01:13:08.689 --> 01:13:11.479
necessarily require rule making, then that would be

01:13:11.489 --> 01:13:14.180
helpful and might also alleviate some of the burden

01:13:14.189 --> 01:13:16.909
that you all as the Commission have in terms of rule

01:13:16.918 --> 01:13:21.600
making. So I will, I will flag that as a concrete proposal

01:13:21.609 --> 01:13:23.689
for something that doesn't need a rule making. Is there

01:13:23.699 --> 01:13:25.579
anyone else who would like to address the topic of

01:13:25.588 --> 01:13:29.838
whether or not uh the TDU program can be implemented?

01:13:29.850 --> 01:13:32.069
not through rulemaking or through the E IP process

01:13:32.319 --> 01:13:35.208
Well, I was just gonna raise 1699 as something for

01:13:35.220 --> 01:13:38.689
you guys to add in your maybe in the first priority

01:13:38.699 --> 01:13:42.168
both because it implements some of the virtual power

01:13:42.180 --> 01:13:45.399
plans and um the pilot program that you have ongoing.

01:13:45.409 --> 01:13:51.548
There are some specific statutory changes there, most

01:13:51.560 --> 01:13:53.640
of which I don't think will require rule making. They're

01:13:53.649 --> 01:13:57.140
really just clarifying, for example, that REPs don't

01:13:57.149 --> 01:13:59.640
have to register as power generation companies if they're

01:13:59.649 --> 01:14:05.149
involved in DER or pilot projects. But there may be

01:14:05.159 --> 01:14:08.859
some other aspects that might need rule making. But

01:14:08.869 --> 01:14:11.949
then there is another aspect of that bill involving

01:14:12.100 --> 01:14:17.229
both setting some goals for residential, DR uh And

01:14:17.239 --> 01:14:22.378
as, as um Christina said, um I get people's names all

01:14:22.390 --> 01:14:24.890
wrong all the time. Um I think I got your name right

01:14:24.899 --> 01:14:31.668
which is good for me. Um as you said, um also allows

01:14:31.689 --> 01:14:34.680
money from the energy efficiency programs of utilities

01:14:34.689 --> 01:14:38.439
to be used for REP programs, um you know, kind of a

01:14:38.449 --> 01:14:44.649
directive or, and given that those, that the companies

01:14:44.659 --> 01:14:47.479
that run those programs that's being discussed right

01:14:47.489 --> 01:14:51.850
now through the ECRFs for 2024. And this has a deadline

01:14:51.859 --> 01:14:55.819
of kind of 2024. So it's, I don't know if it requires

01:14:55.829 --> 01:14:57.939
rule making or not. I'm not really a patenting on this

01:14:57.949 --> 01:15:00.189
but we at least need a project opened on it to have

01:15:00.199 --> 01:15:03.588
those discussions. And then generally, as you know

01:15:03.600 --> 01:15:07.079
and I raised this before the Commission has said they

01:15:07.088 --> 01:15:10.329
want to look at the energy efficiency programs in general

01:15:10.439 --> 01:15:12.680
There was a series of stakeholder meetings through

01:15:12.689 --> 01:15:16.208
the EIP. There's some sense that that will lead to

01:15:16.220 --> 01:15:19.009
rule making. I don't know the timing of that, but all

01:15:19.020 --> 01:15:23.088
these things are related to each other. So to the extent

01:15:23.100 --> 01:15:26.628
we want to open up a project or end our rule making

01:15:26.829 --> 01:15:29.520
on the energy efficiency programs and specifically

01:15:29.529 --> 01:15:32.779
on residential DR. I think that would be a good thing.

01:15:32.789 --> 01:15:35.699
And I would argue it's, it's a, it should be, it's

01:15:35.708 --> 01:15:37.798
a priority for me. I think it should be a priority

01:15:37.810 --> 01:15:41.479
for you. So now is the time to make those arguments

01:15:41.489 --> 01:15:44.989
So I'm making the argument prioritize that I again

01:15:45.000 --> 01:15:48.520
I can't, I don't know whether all aspects of that need

01:15:48.529 --> 01:15:53.220
rule making or more discussions but um we can cross

01:15:53.229 --> 01:15:56.520
that bridge when we get there. Yes. So the thought

01:15:56.529 --> 01:16:01.140
about the um DR program TDU Energy efficiency funding

01:16:01.149 --> 01:16:03.685
connection, possibly being done without rule making

01:16:03.694 --> 01:16:06.494
project is that it could expedite at least that part

01:16:06.654 --> 01:16:10.805
of the statute and where you would set up programs

01:16:10.814 --> 01:16:12.935
that would be able to help facilitate meeting the goals

01:16:12.944 --> 01:16:15.173
And so the goals themselves will probably be a rule

01:16:15.185 --> 01:16:18.125
making project. But given the laundry list of things

01:16:18.134 --> 01:16:19.875
that you all have to do, we understand as time and

01:16:19.884 --> 01:16:22.694
resources permit, we do think it is an important thing

01:16:22.704 --> 01:16:25.444
to add, but we just don't know where in the, in the

01:16:25.454 --> 01:16:27.234
list of things that you have that you'll be able to

01:16:27.244 --> 01:16:31.180
add it. Ok. So I'm gonna say that there are, there

01:16:31.189 --> 01:16:34.199
are currently at least two, two discussion points on the

01:16:34.208 --> 01:16:37.390
topic and one is whether or not um the residential

01:16:37.399 --> 01:16:40.539
programs can be done without uh without a rulemaking

01:16:40.548 --> 01:16:42.949
The second is uh the contention. This, this should

01:16:42.958 --> 01:16:46.479
be a priority. So uh one's on either of those topics

01:16:47.220 --> 01:16:49.750
(item:3.3:Ned Boskoski with Vistra on SB1699) Ned Boskoski with Vistra. I'm trying to speak close to

01:16:49.759 --> 01:16:53.569
the mic. Um Let's keep me honest if this is too, too

01:16:53.579 --> 01:16:58.750
quiet. Um So first off, I, I agree largely with uh

01:16:58.759 --> 01:17:02.369
with how Christina framed it, there are provisions

01:17:02.378 --> 01:17:05.989
in SB1699 that can possibly be implemented more quickly

01:17:06.000 --> 01:17:08.310
And Cyrus, I think you, you correctly noted that the

01:17:08.319 --> 01:17:12.310
ADER pilot does not, does not necessarily need a

01:17:12.319 --> 01:17:14.918
rule change in order to continue to move forward. But

01:17:14.930 --> 01:17:17.100
those changes were really clarifications that were

01:17:17.109 --> 01:17:20.930
aligned with it. So again, agree with Christina

01:17:20.939 --> 01:17:24.539
that the Commission can prioritize that as, as resources

01:17:24.548 --> 01:17:27.560
allow. Although there's certainly interest in, in getting

01:17:27.869 --> 01:17:33.000
uh some clarity along those lines. Um And then just

01:17:33.009 --> 01:17:36.560
so I can, you know, kind of finish my piece and probably

01:17:36.569 --> 01:17:39.939
back up and, and yield the floor. (item:3:Ned Bosonski with Vistra on Project 55156) Um I did wanna highlight

01:17:40.310 --> 01:17:44.449
um you know, Vistra did file comments in project 55146

01:17:44.458 --> 01:17:50.479
or sorry 156, 55156. Thank you. Uh We filed those

01:17:50.489 --> 01:17:52.979
yesterday. Um So those are there for your review and

01:17:52.989 --> 01:17:55.069
I think the comments are generally consistent with

01:17:55.079 --> 01:17:58.798
y'all have laid out. Um You know, we, we highlight

01:17:58.810 --> 01:18:01.899
the need to, as Michelle mentioned, uh clear out some

01:18:01.909 --> 01:18:04.739
of those issues from the 87th legislation, legislative

01:18:04.750 --> 01:18:08.729
session, including the emergency pricing program, the

01:18:08.739 --> 01:18:12.859
um you know, to the extent that the um the reliability

01:18:12.869 --> 01:18:15.708
standard is ongoing, we support that uh that effort

01:18:15.720 --> 01:18:18.409
uh the PCM effort and getting clarity on the implementation

01:18:18.418 --> 01:18:21.770
plan for that we support um as well as the bridge solution

01:18:21.779 --> 01:18:24.020
which I know the Commission has already asked ERCOT

01:18:24.079 --> 01:18:26.680
to uh provide a recommendation for and is sitting before

01:18:26.689 --> 01:18:29.720
them. So, um we support all of those activities and

01:18:29.729 --> 01:18:31.600
then I, I really appreciate it that you highlighted

01:18:31.609 --> 01:18:36.310
at the outset David, um the RPS wind down and there

01:18:36.319 --> 01:18:39.439
were a few decision points on that, that, that we tried

01:18:39.449 --> 01:18:42.909
to at least highlight in our comments, um including

01:18:43.000 --> 01:18:45.640
you know, how do you deal with a solar only RPS that

01:18:45.649 --> 01:18:48.259
applies to the entire RPS goal? And is that, you know

01:18:48.270 --> 01:18:51.239
all 2023 is it only part of 2023? How do you step

01:18:51.250 --> 01:18:53.869
that down? And what do you do with compliance premiums

01:18:53.878 --> 01:18:56.949
which are really a deferral of an RPS obligation and

01:18:56.958 --> 01:19:00.680
make sure that that winds down um appropriately within

01:19:00.689 --> 01:19:03.890
the time frame. Um And then the, you already noted

01:19:03.899 --> 01:19:06.359
the 180 day timeline on the uh transmission

01:19:06.369 --> 01:19:09.720
interconnection cost allocation. So I will pause there

01:19:09.729 --> 01:19:13.500
and say thank you are now going to all look side eyes

01:19:13.509 --> 01:19:17.418
at Ned a little bit for expanding beyond the 1699

01:19:17.430 --> 01:19:19.039
discussion point that was currently on the table. I

01:19:19.109 --> 01:19:22.579
was trying to it up. No, no, those were all previously

01:19:22.588 --> 01:19:25.168
mentioned items. So we'll consider them fair as there

01:19:25.180 --> 01:19:28.369
are other folks on the 1699 discussion. And David just

01:19:28.378 --> 01:19:32.060
shortly um Rashma on behalf of the team. Um We just kind

01:19:32.069 --> 01:19:37.279
of want to say that we also agree with and I

01:19:37.289 --> 01:19:41.180
missed the other person names comments. Um uh regarding

01:19:41.189 --> 01:19:43.759
involvement in these programs, making them priority

01:19:43.770 --> 01:19:47.449
and also um that they can be done outside the rule

01:19:47.458 --> 01:19:49.009
making process.

01:19:51.159 --> 01:19:54.989
ARMs in agreement with all of that. Three from ARM.

01:19:58.199 --> 01:20:03.009
Ditto. Anyone else on this on the 1699 or related discussions?

01:20:04.489 --> 01:20:07.720
But you're clear that part of it is gonna need rulemaking

01:20:07.729 --> 01:20:09.180
Right. The 1699.

01:20:11.180 --> 01:20:14.770
Right. Oh, right. Yeah. Yeah, I, I, yeah, as I said

01:20:14.779 --> 01:20:18.119
before, I'm, uh, trying to be on the record is on a

01:20:18.128 --> 01:20:20.140
few things that I don't feel confident about in my

01:20:20.149 --> 01:20:22.899
head right now. But, uh that is, yeah, that's probably

01:20:22.909 --> 01:20:28.520
right. Um I believe Taylor is next. Um I actually wanted

01:20:28.529 --> 01:20:31.208
to get back to one of Christina's first points on uh

01:20:31.378 --> 01:20:33.369
ERCOT directives and thank you for bringing that up

01:20:33.378 --> 01:20:36.720
and that uh that will probably need to be more than

01:20:36.729 --> 01:20:40.319
just ERCOT directives. It'll be helpful to have more

01:20:40.329 --> 01:20:43.569
of a feel for what the protocol uh approval process

01:20:43.579 --> 01:20:49.649
works like. Um (item:3:ERCOT Board changes) Adding to that again, uh I did note

01:20:49.659 --> 01:20:52.759
that uh the ERCOT Board has changed dramatically in

01:20:52.770 --> 01:20:55.708
the past few years uh with Senate Bill 2 in particular.

01:20:55.878 --> 01:20:59.029
uh the PUCs rules have not kept up with that

01:20:59.039 --> 01:21:02.909
Uh particularly 25362 still refers to unaffiliated

01:21:02.918 --> 01:21:07.449
affiliated directors. And so fixing that as a matter

01:21:07.458 --> 01:21:10.989
of carryover from the 87th would be helpful, uh particularly

01:21:11.000 --> 01:21:14.418
that's important given now that ERCOT has, is entitled

01:21:14.430 --> 01:21:18.609
to sovereign immunity. Um The Texas Supreme Court based

01:21:18.619 --> 01:21:22.489
that on uh the P ECs complete authority over ERCOT

01:21:23.159 --> 01:21:27.649
and if the PUCs rules don't apply to the way ERCOT

01:21:27.659 --> 01:21:30.079
is structured. Now, we'd be curious as to whether or

01:21:30.088 --> 01:21:32.109
not there's a disconnect there. And so we'd advocate

01:21:32.119 --> 01:21:35.569
that that also be expanded to include a revision of

01:21:35.579 --> 01:21:40.439
kind of the way the way uh PUC oversees a generally

01:21:40.449 --> 01:21:43.449
the ERCOT Board particularly. Excellent and we're gonna give

01:21:43.878 --> 01:21:46.579
extra points for both the specific bill number and

01:21:46.588 --> 01:21:49.989
a specific rule number. So uh well done TPPA and yeah

01:21:50.000 --> 01:21:54.609
I think that, that, that cluster of questions are questions

01:21:54.619 --> 01:21:57.810
that we need to start addressing now that we have more

01:21:57.819 --> 01:21:59.949
specific guidance from the legislature. And I think

01:21:59.958 --> 01:22:02.168
that I don't have it off hand, but the current project

01:22:02.180 --> 01:22:05.689
that is labeled a governance and related issues or

01:22:05.699 --> 01:22:08.529
whatever that's been on the, the pending list on the

01:22:08.539 --> 01:22:11.140
rule making calendar is where, where all that is presently

01:22:11.149 --> 01:22:14.729
intended to be housed. Um But uh that's a, that's a

01:22:14.739 --> 01:22:15.289
good catch.

01:22:17.189 --> 01:22:19.039
Is there anyone else who wants to speak on the topic

01:22:19.048 --> 01:22:22.458
of ERCOT directives or other related ERCOT governance

01:22:22.470 --> 01:22:23.069
items?

01:22:24.619 --> 01:22:27.869
Well, the, the only thing I'd add is on um section

01:22:27.878 --> 01:22:31.270
22 the dispatch, reliability reserve services, obviously

01:22:31.279 --> 01:22:34.949
you know, you have been given a very specific directive

01:22:34.958 --> 01:22:39.989
on timing on that and I know has already come forward

01:22:40.000 --> 01:22:43.329
with a couple different options. Um And, you know,

01:22:43.338 --> 01:22:47.600
we're obviously supportive of that moving forward but

01:22:47.609 --> 01:22:51.369
still opening up a project and making sure it's clear

01:22:51.378 --> 01:22:54.259
what the procedure is. And how that's implemented.

01:22:54.270 --> 01:22:56.609
It is going to be important vis a vis the protocols

01:22:56.619 --> 01:23:00.029
et cetera. So just having clarity on that, I think

01:23:00.039 --> 01:23:01.399
will be important going forward.

01:23:06.779 --> 01:23:10.390
(item:3.7:Shana Joyce with TXOGA on ERCOT directive) This is Shana Joyce with TXOGA. And um once again, I

01:23:10.399 --> 01:23:14.439
agree with Cyrus on that. Um I think that opening up

01:23:14.449 --> 01:23:18.060
the um ERCOT directive is important before we began a lot of these

01:23:18.069 --> 01:23:20.298
other rule makings and it's especially important for

01:23:20.310 --> 01:23:22.359
DRS, which is important to our members.

01:23:24.579 --> 01:23:25.588
And so I, I

01:23:28.039 --> 01:23:31.100
granted, I, I'm trying to decide what is pro commentary

01:23:31.109 --> 01:23:34.729
not because I think it is, it, it. (item:3.7:David Smeltzer on ERCOT directive) It may be unlikely

01:23:34.739 --> 01:23:37.779
that we get through an entire ERCOT directive rule making

01:23:37.789 --> 01:23:41.439
prior to the need to start taking action on DRS. But

01:23:41.449 --> 01:23:45.119
I, I take the comments to be that there is a significant

01:23:45.128 --> 01:23:48.088
interest in how people can participate and contribute

01:23:48.100 --> 01:23:51.529
to the outcomes in the DRS rule making. And so I that

01:23:51.539 --> 01:23:55.529
can be flagged as a issue for consideration by the

01:23:55.539 --> 01:23:59.609
Commissioners. Uh So thank you for your, in our comments

01:23:59.619 --> 01:24:03.029
We noted that um if there is a need to do something

01:24:03.039 --> 01:24:06.079
in the interim with DRS, because they can't under that

01:24:06.088 --> 01:24:09.689
time frame, do a full scale that doesn't prevent them

01:24:09.699 --> 01:24:12.149
from moving forward in the future or making changes

01:24:12.159 --> 01:24:15.770
so you could implement something sooner, but then also

01:24:15.779 --> 01:24:18.470
look at any other changes that were needed in the future

01:24:18.479 --> 01:24:23.770
So we have indeed uh proven a willingness to, to phase

01:24:25.079 --> 01:24:27.168
no commitment on this one, but I understood it.

01:24:29.359 --> 01:24:33.369
ERCOT governance, ERCOT directive related comments?

01:24:34.470 --> 01:24:37.970
Uh Taylor TPPA, again, I just wanted to flag we had

01:24:37.979 --> 01:24:41.229
that conversation earlier with Michelle about carryover

01:24:41.239 --> 01:24:45.060
things from previous years. Uh real time marketization is not mentioned

01:24:45.069 --> 01:24:49.939
in here. That is obviously a prerequisite for PCM implementation

01:24:50.229 --> 01:24:52.159
And so we would hope that that would also be considered

01:24:52.168 --> 01:24:55.739
a priority even though it's already been uh approved

01:24:55.750 --> 01:24:59.489
by the Commission several years ago. Is that something

01:24:59.949 --> 01:25:03.720
(item:3.7:David Smeltzer on TPPA's comments on rulemaking) I'm pulling up the thinking out loud. I know it's dangerous

01:25:04.168 --> 01:25:07.659
It is, as I said in prior prior workshops, uh we're

01:25:07.668 --> 01:25:09.659
not all like West Wing members, so we don't have the

01:25:09.668 --> 01:25:12.279
full roll of everything right away. Is that something

01:25:12.289 --> 01:25:15.149
where TPPA is recommending that we need rule making action

01:25:15.159 --> 01:25:17.079
in order to proceed on or no? Yes, it is for sure

01:25:17.088 --> 01:25:21.869
Right. It is. Uh I have not reviewed 503, 25503 recently.

01:25:21.878 --> 01:25:24.930
To see what that would require uh the general kind

01:25:24.939 --> 01:25:28.640
of follow what ERCOT needs you to do. Uh Chances are

01:25:28.649 --> 01:25:31.989
probably be accomplished just at ERCOT. But while we're

01:25:32.000 --> 01:25:35.560
talking about DRRS and maybe we need to do rules at

01:25:35.569 --> 01:25:36.189
both.

01:25:37.819 --> 01:25:40.970
I hesitate to say the word agency. Uh both PUC and

01:25:41.279 --> 01:25:44.180
ERCOT, uh RTC might require some of the similar actions.

01:25:44.659 --> 01:25:46.699
And I saw some various nodding in different directions

01:25:46.708 --> 01:25:49.069
So we'll just, if there are real time co optimization

01:25:49.079 --> 01:25:54.009
related uh implementation comments. Uh there is an open

01:25:54.020 --> 01:25:56.949
PUC rule making project for real time co optimization.

01:25:57.270 --> 01:25:59.909
Um I think that was pending, you know, getting closer

01:25:59.918 --> 01:26:02.979
to the go live of the gray box language that the ERCOT

01:26:02.989 --> 01:26:06.270
board has already approved. And I know is reinitiating

01:26:06.279 --> 01:26:09.659
their uh real time optimization implementation plan

01:26:09.668 --> 01:26:12.708
So that would probably be something I suspect would

01:26:12.720 --> 01:26:14.949
be closer to, to go live where you would want to have

01:26:14.958 --> 01:26:17.390
those line up. Absolutely.

01:26:19.859 --> 01:26:23.779
Um One other thought and this is again, at the risk

01:26:23.789 --> 01:26:26.000
of, of thinking on the fly and, and in, in front of

01:26:26.009 --> 01:26:28.909
a camera and a live studio audience. Um if you just

01:26:28.918 --> 01:26:33.168
say off the record, then, well, you know, from a directive

01:26:33.180 --> 01:26:35.720
standpoint, the Commission may want to consider directives

01:26:35.729 --> 01:26:38.569
that the legislature has directed the commission to

01:26:38.579 --> 01:26:42.699
give to ERCOT versus directives that uh that, you know

01:26:42.708 --> 01:26:44.789
the Commission gives independently to ERCOT, there

01:26:44.798 --> 01:26:47.208
may be some distinction there to, to think through

01:26:47.220 --> 01:26:48.949
I don't have a formal recommendation but,

01:26:50.668 --> 01:26:53.640
and I uh the, the powers that be, have said that in

01:26:53.649 --> 01:26:55.829
in, in most cases, folks have been good about identifying

01:26:55.838 --> 01:26:57.989
the organization, but in a few cases that hasn't been

01:26:58.000 --> 01:27:01.009
the case. So if you, for the first time when you come

01:27:01.020 --> 01:27:04.500
to the mic, uh make sure that you remind us of uh

01:27:04.509 --> 01:27:06.569
who you're with. If you're, if you're representing

01:27:06.579 --> 01:27:11.128
anyone, I believe the open topics now are ERCOT directives

01:27:11.189 --> 01:27:15.029
ERCOT governance, DRS and real time co-optimization. Uh

01:27:15.039 --> 01:27:18.100
keep this tightly organized. Are there any uh comments

01:27:18.109 --> 01:27:23.048
on any of these. (item:3.9:ARM's comments on changes in ancillary services) Um on the DRRS um which is House

01:27:23.060 --> 01:27:27.588
Bill 1500, Section 40 for ARM's from ours perspective

01:27:27.600 --> 01:27:30.088
I think the main thing that we want to highlight there

01:27:30.100 --> 01:27:35.520
is that any changes in Ancillary service um uh services

01:27:35.529 --> 01:27:39.489
drive increased costs for REPs. And that our hope is

01:27:39.500 --> 01:27:43.199
that the, the PUC would recognize that under the customer

01:27:43.208 --> 01:27:46.600
protection role, which is 25.475B 5. That was

01:27:46.609 --> 01:27:49.189
amended a couple of years ago. So I just wanted to

01:27:49.199 --> 01:27:52.359
mention that part in the conversation of DRRS changes

01:27:52.970 --> 01:27:54.128
Yeah. And I, I think that are

01:27:57.069 --> 01:28:00.048
again, thing I fly from, from what I recall that

01:28:00.060 --> 01:28:02.918
(item:3.9:David Smeltzer response to ARM) I think it was always the, it appeared to be if I

01:28:02.930 --> 01:28:05.479
remember the Commission's intention was that when a

01:28:05.489 --> 01:28:08.060
REP thinks or when the REP community thinks that, that

01:28:08.069 --> 01:28:11.539
standard is met, such that it justifies the adjustment

01:28:11.548 --> 01:28:16.850
of fixed rate tax contracts that the onus would be

01:28:16.859 --> 01:28:19.020
on you guys in that project to come tell us. And so

01:28:19.029 --> 01:28:23.708
we will um we will consider that but uh uh in the

01:28:23.720 --> 01:28:25.859
course of that rule making is that I don't know if

01:28:25.869 --> 01:28:28.009
it would be in the course of the rule making or afterwards.

01:28:28.020 --> 01:28:32.378
But um uh I encourage you to be diligent in your contacts

01:28:32.390 --> 01:28:35.779
with us on that to the extent it is a priority. But

01:28:35.789 --> 01:28:37.168
I understand what you're saying? Thank you.

01:28:44.350 --> 01:28:47.369
I was waiting for like a specific tee up above something

01:28:47.378 --> 01:28:50.759
that got mentioned, but it wasn't in your official

01:28:50.770 --> 01:28:53.560
teeing up. So let me know when I can

01:28:55.180 --> 01:28:58.560
address their contracts. That's right. Uh I dodged

01:28:58.588 --> 01:29:01.029
you there. Um, well, you're the only one that do you

01:29:01.039 --> 01:29:03.689
have anything on the current topics? Um yeah, so something

01:29:03.699 --> 01:29:08.399
that was mentioned. (item:3:ARM's thoughts on RPS) Was the, um, clarification on, uh

01:29:08.409 --> 01:29:12.779
the RPS, which is um House Bill 1500, Section 53. I

01:29:12.789 --> 01:29:16.720
think. Um I just want to say that we, we think that

01:29:16.729 --> 01:29:22.520
the clarification of the um compliance for this year

01:29:22.529 --> 01:29:24.970
can be done without a rule making. And then of course

01:29:24.979 --> 01:29:28.279
you know, a rule making for the, the rest of it um

01:29:28.289 --> 01:29:31.329
can be done. But we, we're, we're working on that um

01:29:31.338 --> 01:29:34.750
with y'all and, and um hope to have some consensus

01:29:36.119 --> 01:29:39.250
Excellent. Thanks. And I, I hope that that's true because

01:29:39.259 --> 01:29:42.279
we certainly can't get it all done that quickly. Um

01:29:42.949 --> 01:29:44.798
Is anyone on any of the current topics?

01:29:46.458 --> 01:29:49.720
All right. So just as a reminder that aside from the

01:29:49.958 --> 01:29:52.270
four topics, I just listed the global discussion right

01:29:52.279 --> 01:29:55.680
now. (item:3:David Smeltzer confirming if any other bills from 88th Session be added to list) Is on whether or not there are any bills from the

01:29:55.689 --> 01:30:00.199
88th Session that merit immediate or urgent attention

01:30:00.208 --> 01:30:03.509
and the Staff's recommendation to the Commissioners

01:30:03.520 --> 01:30:06.259
on how they should prioritize projects. Um

01:30:08.259 --> 01:30:12.520
I see the floor is cleared. So I'm going to presume

01:30:12.529 --> 01:30:15.909
that anyone who has anyone in the room today who has

01:30:15.918 --> 01:30:18.418
priorities from the 88th that they would like to advocate

01:30:18.430 --> 01:30:19.859
for has done so

01:30:21.458 --> 01:30:22.189
excellent.

01:30:32.539 --> 01:30:38.470
Uh And so the next prompt on the memo is, uh, does

01:30:38.479 --> 01:30:41.479
anyone else have any recommendations on things that

01:30:41.489 --> 01:30:43.949
have been, you know, you know, we aired on the side

01:30:43.958 --> 01:30:47.020
of including things on the list, um rather, rather

01:30:47.029 --> 01:30:51.239
than not, but if anyone has any um advocacies or anything

01:30:51.250 --> 01:30:53.979
they'd like to recommend right now that they think

01:30:53.989 --> 01:30:58.539
is on the lists that do not require rule making or

01:30:58.548 --> 01:31:02.569
can maybe be done. Um Either the statute provides sufficient

01:31:02.579 --> 01:31:05.668
direction to go off of for the time being or can be

01:31:05.680 --> 01:31:08.449
done through our co directive or some other means.

01:31:08.560 --> 01:31:11.390
If there are any recommendations of that time of that

01:31:11.399 --> 01:31:16.449
type, uh now would be a good time to come for it

01:31:18.708 --> 01:31:21.810
This is the David can do less work category. So gold

01:31:21.819 --> 01:31:25.859
stars for any um recommendations in this area, Taylor

01:31:25.869 --> 01:31:29.390
I think you may be one. (item:3:TPPA on Senate Bill 1093) Yes, sir. So uh Senate Bill 1093

01:31:29.399 --> 01:31:34.390
is the one that requires uh MOUs, Co-ops and uh

01:31:34.539 --> 01:31:36.680
the investor-owned to provide maps to the Commission

01:31:36.689 --> 01:31:40.619
by September, by September. Um I think y'all are progressing

01:31:40.628 --> 01:31:43.838
on the right way to not require rule making for that

01:31:43.850 --> 01:31:46.109
deadline. Um I understand y'all are working on some

01:31:46.119 --> 01:31:49.079
guidance material to let us know who to submit to.

01:31:49.208 --> 01:31:52.739
Thank you. That's great. Uh The second thing that that

01:31:52.750 --> 01:31:58.279
bill does is allow again MOUs, Co-ops and investor

01:31:58.289 --> 01:32:01.439
and utilities access to their portion of the map on

01:32:01.449 --> 01:32:05.720
request. Um Any sort of guidance that you could provide

01:32:05.729 --> 01:32:08.378
on how we make that request is that request to you

01:32:08.390 --> 01:32:11.350
Is that request to uh would be really helpful. And

01:32:11.359 --> 01:32:14.819
that's obviously not a rule making. That is a uh memo

01:32:14.829 --> 01:32:16.958
probably I don't think I should be texting them kid

01:32:16.970 --> 01:32:21.338
about it. And so uh help, there would be great. The

01:32:21.350 --> 01:32:25.039
uh I'm gonna wait to see if there wants to peer pressure

01:32:25.048 --> 01:32:26.259
and if she doesn't, I will.

01:32:31.500 --> 01:32:34.579
As Liz's primary role at this workshop is volume control,

01:32:34.588 --> 01:32:36.208
we will give Therese priority on.

01:32:37.798 --> 01:32:41.838
(item:3:Therese Harris with PUC on SB1093)All right there, Therese Harris PUC. So thank you Taylor for

01:32:41.850 --> 01:32:44.949
that question. We actually have already gotten a request

01:32:44.958 --> 01:32:47.909
from one of the utilities and it as simple as that.

01:32:47.918 --> 01:32:53.109
So SB1093 lines out what needs to happen before the

01:32:53.119 --> 01:32:56.509
request is made. And that would be, you know, submission

01:32:56.520 --> 01:33:00.909
of your service area boundary map. After that, you

01:33:00.918 --> 01:33:04.890
can contact the infrastructure division and we can

01:33:04.899 --> 01:33:08.689
work with you to develop that map. So it would be a

01:33:08.699 --> 01:33:12.039
map. It would be just your service area boundary and

01:33:12.048 --> 01:33:15.548
it would have only the facilities that are in your

01:33:15.560 --> 01:33:18.659
service area boundary that are critical natural gas

01:33:18.668 --> 01:33:22.520
facilities and we have that done and ready. What we're

01:33:22.529 --> 01:33:27.689
waiting on is to get the MOU and the, the MOU signed

01:33:27.699 --> 01:33:32.020
between the Railroad Commission and ERCOT. And that is forthcoming

01:33:32.029 --> 01:33:35.609
I think that's going to happen relatively soon and

01:33:35.619 --> 01:33:39.409
as soon as that happens, you're good to go. And so

01:33:39.418 --> 01:33:42.418
that request and I swear, I said preplanned. Uh does

01:33:42.430 --> 01:33:45.088
that go to just infrastructure@puc.texas.

01:33:45.100 --> 01:33:49.378
gov or? Well, so we are, we are opening a project and

01:33:49.390 --> 01:33:52.600
that will probably be filed on Friday. You know, it

01:33:52.609 --> 01:33:56.088
will have a letter explaining how to submit your electric

01:33:56.100 --> 01:34:00.189
service area boundary map. We will follow that opening

01:34:00.199 --> 01:34:04.220
of a control number with a letter out to the entities

01:34:04.270 --> 01:34:07.229
so that they get double notice. Um I think another

01:34:07.239 --> 01:34:10.579
thing that we plan to do is also to reach out to

01:34:10.588 --> 01:34:14.989
you and reach out to um the individual in charge of

01:34:15.000 --> 01:34:18.939
the Texas Electric Cooperatives. And they can also

01:34:18.949 --> 01:34:22.060
and you can also, you know, disseminate as you would

01:34:22.069 --> 01:34:24.159
like. Thank you. I know I've been a pain about this

01:34:24.168 --> 01:34:25.930
but I really do. No, you know, you're not, you're not

01:34:26.060 --> 01:34:28.149
a pain. I've been a pain.

01:34:31.079 --> 01:34:36.199
So we are dealing with other state agencies. So, no

01:34:36.378 --> 01:34:40.189
hang on. Everyone knows what needs to happen and we're

01:34:40.199 --> 01:34:44.250
gonna make it happen and we already have one map completed

01:34:44.259 --> 01:34:48.500
ready to go as soon as the um MOU assigned. Thank you.

01:34:48.729 --> 01:34:50.628
(item:3:Liz Jones with Oncor on NDAs) And that was the only thing I was gonna add and, and

01:34:50.640 --> 01:34:52.810
I think it's actually a nondisclosure agreement but

01:34:52.819 --> 01:34:54.890
whatever we're calling it, um

01:34:56.689 --> 01:34:59.298
the Railroad Commission and ERCOT have not agreed on

01:34:59.310 --> 01:35:02.520
the language and I'm not sure what the Railroad Commission

01:35:02.529 --> 01:35:06.100
concerns are, but given that we all have an existing

01:35:06.109 --> 01:35:09.418
NDA with ERCOT. I'm at an utter loss as to the

01:35:09.430 --> 01:35:13.208
delay. But Therese, are you the right person to come

01:35:13.220 --> 01:35:17.579
back to you and ask for an escalation? Because, you

01:35:17.588 --> 01:35:22.470
know, we need this information and I think we're entitled

01:35:22.479 --> 01:35:25.069
to this information and it's a source of frustration

01:35:25.289 --> 01:35:28.128
that you don't feel like you can give it to us at

01:35:28.140 --> 01:35:32.140
this time based on other agency activities. Right.

01:35:32.149 --> 01:35:35.359
No activities of other agents. Right. Right. Right

01:35:35.369 --> 01:35:38.430
(item:3:Therese Harris, PUC on NDAs) Yes, please, you know, go ahead and reach out to me

01:35:38.439 --> 01:35:41.189
Um, I would involve, you know, Tom Hunter and Casey

01:35:41.199 --> 01:35:44.878
Feldman who are, you know, our General Counsel. So

01:35:44.890 --> 01:35:47.989
um, that would occur too and I've been working with

01:35:48.000 --> 01:35:49.020
Casey. Thank you. Okay.

01:35:50.979 --> 01:35:53.140
The two important takeaways from this conversation

01:35:53.149 --> 01:35:55.319
are what, you know, I've said it many times, the less

01:35:55.329 --> 01:35:58.069
I'm involved, the quicker things get taken care of

01:35:58.079 --> 01:36:00.399
So that's fantastic. And also everyone may or may not

01:36:00.409 --> 01:36:02.489
know. I used to, I used to work for Taylor in the

01:36:02.500 --> 01:36:04.500
first division and that might be the first time. He's

01:36:04.509 --> 01:36:06.829
called me, sir at the beginning of this. So I just

01:36:06.838 --> 01:36:09.310
take a moment to appreciate that we are on camera.

01:36:11.140 --> 01:36:13.789
Um, okay. Is there anything else, uh Taylor, are you

01:36:13.798 --> 01:36:16.069
done with your item? I have one more thing but not

01:36:16.079 --> 01:36:18.479
it's different. Does anyone have any other discussion

01:36:18.489 --> 01:36:21.668
related to the ability to request maps that Therese

01:36:21.680 --> 01:36:22.970
and Liz and Taylor were just discussing?

01:36:25.109 --> 01:36:28.509
Okay. Uh So, yeah, so thank you for pulling this list

01:36:28.520 --> 01:36:31.060
up. Actually, when we were reviewing this list, we

01:36:31.069 --> 01:36:34.628
did flag that everything on here are, are bills. Uh

01:36:34.649 --> 01:36:37.979
(item:3:TPPA on non statutory directives) We did note that the Sunset Commission also issued

01:36:37.989 --> 01:36:41.298
several management non statutory directives to PUC.

01:36:41.588 --> 01:36:44.708
Some of those are just procedural post open meeting

01:36:44.720 --> 01:36:48.569
minutes. Um Allow testimony on all agenda items. Some

01:36:48.579 --> 01:36:51.779
are a little more substantive. One of them, for instance

01:36:51.789 --> 01:36:54.878
to Michelle's point earlier is for the PUC to establish

01:36:54.890 --> 01:37:00.250
a liability standard by May of 2023, 2 months ago. Um

01:37:00.259 --> 01:37:03.289
And, and so our kind of question is, are you all expecting

01:37:03.298 --> 01:37:10.869
to uh get a lot of those management nonsmoking process

01:37:11.100 --> 01:37:14.439
or um should we be saying, you know, this might need

01:37:14.449 --> 01:37:16.180
a rule making, this might need a role and this might

01:37:16.189 --> 01:37:20.270
need a rule making. (item:3:David Smeltzer on non statutory directives) I think that in our review, we

01:37:20.279 --> 01:37:24.378
uh uh we're, we're pulling to get, get this together

01:37:24.390 --> 01:37:26.588
pretty quickly. And I don't know that, that I specifically

01:37:26.600 --> 01:37:29.750
thought through exhaustively the management recommendations

01:37:29.759 --> 01:37:31.958
And as you guys know, we're working to implement a

01:37:31.970 --> 01:37:33.859
lot of those not through the rule making process. Or

01:37:33.869 --> 01:37:37.009
for instance, our Chapter 26 rule review is much more

01:37:37.020 --> 01:37:39.680
significant than it would have been otherwise. But

01:37:39.689 --> 01:37:43.720
um yeah, to the extent that uh we'll go back and look

01:37:43.729 --> 01:37:45.289
over that, but to the extent that you think that there

01:37:45.298 --> 01:37:49.649
are items that um uh definitely need rule makings from

01:37:49.659 --> 01:37:53.310
those management directives. Um, feel free to file

01:37:53.319 --> 01:37:56.350
a note on that or uh, let me know. Awesome. Thank you

01:37:56.359 --> 01:37:57.810
That is a, that is an excellent reminder.

01:38:00.128 --> 01:38:02.529
Awesome. (item:3:John Russ Hubbard with Texas Industrial Energy Consumers on DRS) John Russ Hubbard on behalf of Texas Industrial

01:38:02.539 --> 01:38:05.250
Energy Consumers. Um I just wanted to reiterate the

01:38:05.259 --> 01:38:07.859
point you made earlier about DRS. We don't believe

01:38:07.869 --> 01:38:09.668
that needs a rule making and it can be done through

01:38:09.680 --> 01:38:10.699
a Commission directive.

01:38:13.759 --> 01:38:18.189
Thank you. I'm sure. Sure. Yeah. Um (item:3.5:Shana Joyce with TXOGA on HB5066) Shana with TXOGA.

01:38:18.439 --> 01:38:23.520
I wanted to bring up um HB5066 regarding transmission

01:38:23.529 --> 01:38:26.958
in the Permian Basin and this requires the development

01:38:26.970 --> 01:38:30.000
of a reliability plan for the Permian Basin. And while

01:38:30.009 --> 01:38:33.270
we don't necessarily think that you need a rule making

01:38:33.279 --> 01:38:36.958
for this, we are concerned about stakeholders voices

01:38:36.970 --> 01:38:42.149
in this process. Um And we'd also request that the

01:38:42.159 --> 01:38:45.739
reliability plan be based on the demand forecast that

01:38:45.750 --> 01:38:49.600
was developed in the SNPIHS market study that was

01:38:49.609 --> 01:38:53.500
published in March of this year. And so with the increased

01:38:53.509 --> 01:38:56.939
electrification of our industry and the adequacy of

01:38:56.949 --> 01:39:00.020
high voltage for the serving the needs of oil and natural

01:39:00.029 --> 01:39:03.168
gas for our state. Um the Permian Basin and other areas

01:39:03.180 --> 01:39:05.859
of high growth are paramount to our state. So we wanted

01:39:05.869 --> 01:39:08.838
to make sure that this process is robust and implementing

01:39:08.850 --> 01:39:11.579
this bill. But don't necessarily think that you need

01:39:11.588 --> 01:39:14.378
a rule making, but stakeholder, stakeholder input is

01:39:14.390 --> 01:39:15.088
imperative.

01:39:18.029 --> 01:39:20.939
I failed to introduce myself. Sorry. (item:3.5:Liz Jones with Oncor on supporting initiative) Liz Jones with

01:39:20.949 --> 01:39:26.100
Oncor. We recognize and support that initiative and

01:39:27.069 --> 01:39:30.878
it doesn't take a rule making. But I think a workshop

01:39:30.949 --> 01:39:36.588
that is widely noticed to both, um, retail customers

01:39:36.600 --> 01:39:39.539
in the Permian Basin and also the utilities that serve

01:39:39.548 --> 01:39:43.649
them would be very beneficial to talk through what

01:39:43.659 --> 01:39:46.319
that might look like. I think that's right. Would you

01:39:46.329 --> 01:39:50.649
um, in my head just out of, you know, bucketing things

01:39:50.659 --> 01:39:53.970
that we've talked about how doing a workshop on that

01:39:53.979 --> 01:39:56.449
and a workshop on res the resiliency stuff. But those

01:39:56.458 --> 01:39:56.739
are,

01:39:58.458 --> 01:40:02.009
uh are those, those are not addressing something? Would

01:40:02.020 --> 01:40:05.390
you recommend that that can be a, a one day affair

01:40:05.399 --> 01:40:07.329
This is sufficiently distinct that we shouldn't be

01:40:07.338 --> 01:40:09.918
thinking about them in the same bucket. I think they're

01:40:09.930 --> 01:40:12.208
sufficiently different. But if you wanted, you could

01:40:12.220 --> 01:40:14.729
do morning and afternoon, I was thinking that I think

01:40:14.739 --> 01:40:16.899
they're different. But if you wanted to split the days

01:40:16.909 --> 01:40:19.750
I think, but making sure that you give ample time to

01:40:19.759 --> 01:40:24.560
both of the important topics. Um And is this, uh

01:40:26.208 --> 01:40:30.180
with regards to the reliability plan, is there enough

01:40:30.189 --> 01:40:31.970
(item:3.5:David Smeltzer's follow-up to Oncor) It sounds like there's enough specific content out

01:40:31.979 --> 01:40:35.338
there where maybe even prior to getting feedback from

01:40:35.350 --> 01:40:37.149
the Commissioners on orders and things like that, we

01:40:37.359 --> 01:40:40.569
we opened up a project. Are there immediate recommendations

01:40:40.579 --> 01:40:42.958
or studies that would make sense? To be filed right

01:40:42.970 --> 01:40:46.689
away that we can start looking at. So, although it's

01:40:46.699 --> 01:40:52.088
somewhat dated. Oncor actually sponsored an IHS study

01:40:52.500 --> 01:40:57.279
that was issued in 2020. And I believe both that and

01:40:57.289 --> 01:41:02.850
the producer study would provide a foundation on which

01:41:02.859 --> 01:41:04.850
to have this discussion. I agree with that.

01:41:06.798 --> 01:41:09.970
So I, I that is a reasonable enough suggestion that

01:41:09.979 --> 01:41:12.659
I feel comfortable saying that uh that uh I think we

01:41:12.668 --> 01:41:16.319
can look into opening a project number so that interested

01:41:16.329 --> 01:41:19.489
parties can start populating it with uh foundational

01:41:19.500 --> 01:41:23.569
background documents and knowledge so that we can even

01:41:23.579 --> 01:41:25.529
without a rule making so that we can act swiftly. And

01:41:25.539 --> 01:41:27.609
I think to the extent that stakeholders want to be

01:41:27.619 --> 01:41:29.548
involved, that seems that seems appropriate. Yes, sir

01:41:29.930 --> 01:41:30.529
Yes. Thank you.

01:41:32.289 --> 01:41:35.199
Yes, thank you. Thank you. (item:3.5:Larry Linenschmidt with Hill Country Institute on HB5066) My name is Larry Linenschmidt. I'm with

01:41:35.208 --> 01:41:38.199
the Hill Country Institute, a Christian nonprofit.

01:41:38.208 --> 01:41:41.329
Uh We're very interested in creation care including

01:41:41.489 --> 01:41:46.378
uh how power is generated, transmitted and used. And

01:41:46.489 --> 01:41:51.659
uh House Bill 5066 specifically addresses the Permian

01:41:51.668 --> 01:41:54.189
Basin, but it also is open to needs in the rest of

01:41:54.199 --> 01:41:58.279
the state. And uh we have, you know, during Winter

01:41:58.289 --> 01:42:01.949
Storm Uri. We had 5000 megawatts of energy that we

01:42:01.958 --> 01:42:05.208
couldn't get from South Texas to where it was needed.

01:42:05.489 --> 01:42:09.989
I hope that, that that 5066 will open the door to

01:42:10.000 --> 01:42:14.520
expand transmission lines in the state. Uh We've had

01:42:14.529 --> 01:42:17.869
very limited amount of transmission lines built in

01:42:17.878 --> 01:42:22.369
the last few years. And as you direct ERCOT and their

01:42:22.378 --> 01:42:25.838
underwriting and their methodology, I hope the door

01:42:25.850 --> 01:42:28.399
will open because it takes several years and we're

01:42:28.409 --> 01:42:31.720
already behind where we should be. So I work with a

01:42:31.729 --> 01:42:34.310
number of groups including the citizens climate lobby

01:42:34.539 --> 01:42:38.819
the republican, and, uh, and others. And we're all

01:42:38.829 --> 01:42:44.430
very hopeful that this bill and your general knowledge

01:42:44.439 --> 01:42:47.628
of the need for more transmission lines will open up

01:42:47.640 --> 01:42:51.890
the door for more to be built in Texas. Yes, sir. Thank

01:42:51.899 --> 01:42:53.189
you. Thank you.

01:43:01.119 --> 01:43:03.789
(item:3.5:David Smeltzer comments on Permian Basin) Um I guess as long as we're on the topic, are there

01:43:03.798 --> 01:43:06.140
additional, um uh

01:43:07.739 --> 01:43:11.560
is there any additional uh commentary on either reliability

01:43:11.569 --> 01:43:15.100
plans? The uh which I think eventually will need a

01:43:15.109 --> 01:43:19.149
rule making? But uh on the Permian Basin, uh well,

01:43:19.239 --> 01:43:22.310
we'll see on the Permian Basin, immediate directive

01:43:22.319 --> 01:43:25.838
ERCOT to develop reliability plan or the resiliency

01:43:25.850 --> 01:43:30.949
plan, um pieces of legislation. (item:3.4:Rama Rastogi on HB2555) So I just wanna add

01:43:30.958 --> 01:43:33.588
the resiliency plan that David is mentioning is HB2555.

01:43:33.600 --> 01:43:37.588
If anyone has a comment on that,

01:43:40.689 --> 01:43:42.539
very good. And I think, yeah, and, and on both of those

01:43:42.548 --> 01:43:46.298
those are sufficiently complex technical topics and

01:43:46.310 --> 01:43:50.168
it seems uh likely that we'll have want to have a technical

01:43:50.180 --> 01:43:52.659
workshop of some kind on those, but uh we'll, we'll

01:43:52.668 --> 01:43:58.079
see uh how things are structured. Um Okay. I think we

01:43:58.088 --> 01:44:01.619
are on the still on the, the global topic of items

01:44:01.628 --> 01:44:04.720
that folks want to advocate for that might be on the

01:44:04.729 --> 01:44:07.449
list but might not need a rule making. Um, is there

01:44:07.458 --> 01:44:10.720
any other, um, is there anyone else who wants to speak

01:44:10.729 --> 01:44:11.489
to any of these?

01:44:13.729 --> 01:44:15.869
And in particular on this topic when, when we say that

01:44:15.878 --> 01:44:19.100
we've expanded the, the, the comment deadline for a

01:44:19.109 --> 01:44:21.729
couple of days, uh, these, these, these are the sorts

01:44:21.739 --> 01:44:23.489
of efficiencies that are, that are very helpful to

01:44:23.500 --> 01:44:25.810
us. I mean, in, in the next topic on the menu is

01:44:25.819 --> 01:44:30.140
another on the, you know, on the agenda is also comfortable.

01:44:30.149 --> 01:44:32.418
(item:3:David Smeltzer on natural pairings) That to the extent that there are natural pairings

01:44:32.430 --> 01:44:34.649
I think, you know, last legislative session, a lot

01:44:34.659 --> 01:44:37.539
of our to do items came from SB3and it was

01:44:37.548 --> 01:44:41.680
uh uh sort of a chunk of legislation that sort of directed

01:44:41.689 --> 01:44:44.619
things. And I think this time there's HB1500 but there's

01:44:44.628 --> 01:44:47.878
a lot of like numerically, there are more bills in

01:44:47.890 --> 01:44:50.250
play than before. And so one of the other questions

01:44:50.259 --> 01:44:53.048
is if you think that there are natural pairings between

01:44:53.060 --> 01:44:56.829
topics that can be addressed together, that is another

01:44:56.838 --> 01:44:59.958
piece of advice that we would find helpful both either

01:44:59.970 --> 01:45:03.619
today or if anyone behind the scenes is like, here's

01:45:03.628 --> 01:45:05.539
the master plan. This is how you get it all done at

01:45:05.548 --> 01:45:08.859
once. Um That is, that is always helpful and it is

01:45:08.869 --> 01:45:11.149
possible because if you read the whole memo, we are

01:45:11.159 --> 01:45:13.119
trying to do all of the telecom stuff in one rule.

01:45:13.128 --> 01:45:15.569
So if the electric industry can get together and match

01:45:15.579 --> 01:45:18.039
that, that will be, that will be very helpful to us

01:45:19.520 --> 01:45:21.048
But is there, is there anyone that has anything on

01:45:21.060 --> 01:45:21.708
these topics?

01:45:26.189 --> 01:45:30.369
Ok. So I think that brings us to the, um,

01:45:34.878 --> 01:45:37.009
so I think that brings us to the sort of grab bag

01:45:37.020 --> 01:45:40.310
topic. (item:3:David Smeltzer on rulemaking calendar) Which is, um, you know, our, our rule making

01:45:40.319 --> 01:45:42.560
calendar even, even the last two years when we are

01:45:42.569 --> 01:45:44.279
really busy and even the next two years when we're

01:45:44.289 --> 01:45:46.619
really busy from time to time Commission Staff opens

01:45:46.628 --> 01:45:50.220
up rules in relation to real world ex agencies or Commissioner

01:45:50.229 --> 01:45:55.369
directive or just other known issues out in the world

01:45:55.378 --> 01:45:58.529
And so I'd like now like to open up the floor to

01:45:59.649 --> 01:46:03.989
any items that, you know, as we face down the 40th

01:46:04.000 --> 01:46:05.869
or so rule making that we may have to do coming out

01:46:05.878 --> 01:46:09.289
of the session. Are there other items of interest that

01:46:09.298 --> 01:46:12.668
folks want to that folks believe the Commissioner should

01:46:12.680 --> 01:46:17.759
consider as important or more important than some of

01:46:17.770 --> 01:46:20.500
the legislative implementation? So we've had some discussion

01:46:20.619 --> 01:46:24.739
of, we had some discussion already of the emergency

01:46:24.750 --> 01:46:28.319
weather, the weather disconnection, moratoriums. And

01:46:28.329 --> 01:46:32.588
I think that, um, I think, I think that some of Cyrus

01:46:32.600 --> 01:46:34.909
energy efficiency recommendations go beyond the scope

01:46:34.918 --> 01:46:38.770
of what's strictly required by, um, by legislation

01:46:38.779 --> 01:46:40.378
And so I think those two items are there, but are there

01:46:40.390 --> 01:46:44.020
other, are there other rule making priorities or policy

01:46:44.029 --> 01:46:48.588
priorities that folks would like to soapbox about briefly

01:46:57.659 --> 01:47:01.350
(item:3.1:John Ross Hubbard, TIEC on interconnection timelines)John Ross Hubbard on behalf of TIEC during the Oncor rate

01:47:01.359 --> 01:47:03.729
case, there are a number of issues about interconnections

01:47:03.739 --> 01:47:06.979
and interconnection timelines. Um And, and that probably

01:47:06.989 --> 01:47:10.979
requires opening up the proform tariff. And so doing

01:47:10.989 --> 01:47:15.000
that while doing some of the CCN changes could be a

01:47:15.009 --> 01:47:20.838
good fit. Um So specifically with Project 55153 or

01:47:20.850 --> 01:47:24.489
potentially when implementing 5066.

01:47:29.069 --> 01:47:33.239
Does anyone have any, does anyone want to address the

01:47:33.250 --> 01:47:36.270
possibility of opening up the performer tariff or the

01:47:36.279 --> 01:47:38.640
issue of interconnection timeline just generally?

01:47:44.899 --> 01:47:48.088
Okay. And we will um if we have specific questions or

01:47:48.100 --> 01:47:50.168
if the Commissioners, do we know where to find you

01:47:50.899 --> 01:47:52.708
to continue the discussion? Thank you. Bye.

01:47:55.909 --> 01:47:58.250
(item:3:Mark Walker with Matthews & Freeland on advanced metering rule) Hi, I'm Mark Walker. I'm with Matthews and Freeland

01:47:58.259 --> 01:48:01.539
and I have a new client Mission Data. I wasn't planning

01:48:01.548 --> 01:48:03.918
on saying anything today, but given that we've kind

01:48:03.930 --> 01:48:06.048
of opened the scope up a little bit. I thought it'd

01:48:06.060 --> 01:48:08.279
be remiss not to. And you'd ask, well, why didn't you

01:48:08.289 --> 01:48:11.479
say something about this issue? And that is about advanced

01:48:11.489 --> 01:48:15.869
advanced metering rule. Uh We believe there are the

01:48:15.878 --> 01:48:18.600
technology has kind of outstripped the current rule

01:48:18.609 --> 01:48:22.789
and a lot of the implementation of the, the usability

01:48:22.798 --> 01:48:25.909
and functionality of advanced meters. And we think

01:48:25.918 --> 01:48:28.539
it's timely given all the other changes and the benefits

01:48:28.548 --> 01:48:32.649
that a fully functional and you know, superiorly, you

01:48:32.659 --> 01:48:35.850
know, a better functioning uh advanced meter process

01:48:35.859 --> 01:48:40.000
would be beneficial. Uh It's also timely given that

01:48:40.009 --> 01:48:42.930
there are some of the utilities are starting, I believe

01:48:42.939 --> 01:48:47.009
starting to look at the second generation of deployments

01:48:47.020 --> 01:48:49.180
And so it's timely to, to understand if there are any

01:48:49.189 --> 01:48:52.729
changes we need to make, to ensure the next generation

01:48:52.979 --> 01:48:56.449
is going to fully capture that capability and support

01:48:56.458 --> 01:48:59.458
all the other objectives of the Commission. And I also

01:48:59.470 --> 01:49:01.958
want to be clear that nothing that we would be proposing

01:49:01.970 --> 01:49:05.149
would have any, any impact on already approved plans

01:49:05.310 --> 01:49:11.699
So, um no, no darts from Excel. Um They uh so anyway

01:49:11.708 --> 01:49:13.869
and also apologies to stakeholders. I have plans to

01:49:13.878 --> 01:49:16.289
come meet with, we, you know, we plan to come visit

01:49:16.298 --> 01:49:18.680
with folks before and obviously with the, with the

01:49:18.689 --> 01:49:22.359
Commission Staff as well, right? Um Given that you

01:49:22.369 --> 01:49:24.239
you've opened the floor here, I, I felt like I needed

01:49:24.250 --> 01:49:28.520
to chime in. No. Yeah, and uh that's great. Yeah, getting

01:49:28.529 --> 01:49:30.649
an idea of the issue, landscape and things that might

01:49:30.659 --> 01:49:34.838
be coming to us that are not yet fully formed is helpful

01:49:34.850 --> 01:49:37.189
for our planning purposes. So do I, should I take that

01:49:37.199 --> 01:49:40.128
last comment to mean this is a heads up but that you

01:49:40.140 --> 01:49:42.289
might be approaching with something more concrete in

01:49:42.298 --> 01:49:44.878
the future. That's right. We're working on the specifics

01:49:44.890 --> 01:49:48.250
now and we'll, you know, you, you're top of my list

01:49:48.659 --> 01:49:51.069
and we will uh as soon as we and, and I, you

01:49:51.079 --> 01:49:54.939
know, I, we certainly plan to, to, to work collaboratively

01:49:54.949 --> 01:49:56.869
with uh with other stakeholders and be clear about

01:49:56.878 --> 01:49:59.199
what we're looking for and to hear other perspectives

01:49:59.208 --> 01:50:02.479
But we do think it's a vitally important and, and should

01:50:02.489 --> 01:50:04.909
be a priority for the commission as well. Ok. Thank

01:50:04.918 --> 01:50:08.409
you. I'd just like to add that, you know, any synergies

01:50:08.418 --> 01:50:11.970
that you can identify for the, the A MS with the current

01:50:11.979 --> 01:50:15.729
legislative, uh you know, list of things that we have

01:50:15.739 --> 01:50:19.609
that would be helpful to us. Like if you can pre identify

01:50:19.729 --> 01:50:23.140
something that can be synergistic or paired with something

01:50:23.149 --> 01:50:24.668
else that we are already planning to do.

01:50:26.600 --> 01:50:28.029
Thank you. Great suggestion. Thank you.

01:50:34.338 --> 01:50:38.159
The floor is open and we have 51 remaining scheduled

01:50:38.168 --> 01:50:40.729
minutes where people can ask for whatever they want

01:50:42.708 --> 01:50:43.918
anybody have anything.

01:50:49.048 --> 01:50:50.720
All right. Um

01:50:54.128 --> 01:50:55.109
Yeah, yeah, sure, sure.

01:51:10.628 --> 01:51:14.189
Um Can you hear me? Yes, ma'am. (item:4.2:Tina Lee, VP of Watt Bridge Energy on SB2627) Uh So Tina Lee, I'm

01:51:14.199 --> 01:51:17.088
Vice President of Watt Bridge Energy. Um And as you

01:51:17.100 --> 01:51:20.668
may have heard my uh CEO speak during the legislative

01:51:20.680 --> 01:51:24.359
session, Watt Bridge has built out a portfolio of 2400

01:51:24.369 --> 01:51:28.009
megawatts of uh fast start dispatch gas generation

01:51:28.020 --> 01:51:30.798
during the last three years and raised $2 billion for

01:51:30.810 --> 01:51:33.770
this initiative. So just trying to provide, given that

01:51:33.779 --> 01:51:37.039
experience, I like to provide some feedback on SB2627

01:51:37.048 --> 01:51:41.588
on the Texas Energy Fund. On the first item is just

01:51:41.600 --> 01:51:45.399
the loan program timing. We agree with staff's plans

01:51:45.409 --> 01:51:48.270
to complete the draft rule making before the November

01:51:48.279 --> 01:51:51.619
election. On the constitutional amendment, we also

01:51:51.628 --> 01:51:54.479
agree and encourage the PUC to adopt the final rule

01:51:54.489 --> 01:51:59.168
making no later than January 2024 upon a favorable

01:51:59.180 --> 01:52:03.369
November vote outcome. Faster implementation helps

01:52:03.378 --> 01:52:07.109
to avoid risks related to long lead equipment and better

01:52:07.119 --> 01:52:10.319
preserves the value um intended in the Texas Energy

01:52:10.329 --> 01:52:13.979
Fund. On the second point of the loan mechanics, um

01:52:13.989 --> 01:52:17.140
Watt Bridge plans to apply for both the loan and the

01:52:17.149 --> 01:52:21.369
completion bonus. Um Having only one or the other will

01:52:21.378 --> 01:52:24.180
be detrimental to Watt Bridge's proposed build out

01:52:24.270 --> 01:52:28.470
under the Texas Energy Fund. Based on our evaluation

01:52:28.479 --> 01:52:31.100
the split between the loan and completion bonus. If

01:52:31.109 --> 01:52:34.128
you're looking for allocation of how to use the fund

01:52:34.289 --> 01:52:40.199
is approximately 86% and 14% respectively for a more

01:52:40.208 --> 01:52:42.838
efficient use of the equity. We also recommend that

01:52:42.850 --> 01:52:46.739
the 3% escrow amount be satisfied with a letter of

01:52:46.750 --> 01:52:49.829
credit in lieu of cash, only, letters of credit are

01:52:49.838 --> 01:52:53.708
standard and commercially available approach. We also

01:52:53.720 --> 01:52:57.750
support the mortgage style repayment of the loan. Um

01:52:57.759 --> 01:53:03.109
All project costs including natural gas, water infrastructure

01:53:03.119 --> 01:53:06.668
land procurement design engineering should be eligible

01:53:06.680 --> 01:53:11.180
within the construction costs. Uh The the loan program

01:53:11.189 --> 01:53:16.000
fees can be deducted from the 3% escrow amount and

01:53:16.009 --> 01:53:18.789
we seek review and selection of the loan applications

01:53:18.798 --> 01:53:22.909
on a rolling basis will allow projects to meet the

01:53:22.918 --> 01:53:26.759
intended in service date of summer 2026 and on the

01:53:26.770 --> 01:53:29.720
final point of the Texas Energy Fund Administration

01:53:29.890 --> 01:53:32.649
if the fund is not going to be able to provide the

01:53:32.659 --> 01:53:36.229
letters of credit capacity, which is standard and typical

01:53:36.239 --> 01:53:41.060
in debt financing. Um then we then we recommend allowing

01:53:41.069 --> 01:53:44.350
commercial bank involvement to provide that LC capacity

01:53:44.369 --> 01:53:48.029
in parallel with the loan program. And then for more

01:53:48.039 --> 01:53:51.109
efficient optimization of the new asset, we recommend

01:53:51.119 --> 01:53:54.939
that the state share the first lean position with potential

01:53:54.949 --> 01:53:58.039
hedge counter parties. This is actually a very standard

01:53:58.048 --> 01:54:02.149
uh project or approach and all six of watt bridges

01:54:02.159 --> 01:54:06.329
hedged projects have this structure in place. And then

01:54:06.338 --> 01:54:09.609
finally, we recommend outsourcing the administration

01:54:09.619 --> 01:54:12.569
of the Texas Energy Fund to commercial banks to leverage

01:54:12.579 --> 01:54:15.770
their infrastructure and to accelerate the implementation

01:54:15.779 --> 01:54:19.579
Thank you. So, so I think the one, thank you. Those

01:54:19.588 --> 01:54:22.253
are helped comments. (item:4.2:David Smeltzer's response to Watt Bridge) The one that I I would like to

01:54:22.265 --> 01:54:24.814
solicit feedback on specifically with regard to our

01:54:24.824 --> 01:54:28.435
implementation schedule is there was a request that

01:54:28.444 --> 01:54:32.475
the final rule making be adopted by, by January of

01:54:32.484 --> 01:54:37.744
2024. And I think that given when the given, when the

01:54:37.753 --> 01:54:41.239
election takes place, that is a real holiday killer

01:54:41.250 --> 01:54:46.119
for, for my team. But in terms of the real world practicalities

01:54:46.128 --> 01:54:49.680
of when you know, so we have to begin accepting applications

01:54:49.689 --> 01:54:52.350
in June at the latest under the legislation. And I

01:54:52.359 --> 01:54:55.088
know that we want to get the draft out there prior

01:54:55.100 --> 01:54:57.759
to the November election. But does anyone want to comment

01:54:57.770 --> 01:55:03.838
on real world implications of when this rule is adopted

01:55:03.850 --> 01:55:06.520
Like so her contention is that it will help reduce

01:55:06.529 --> 01:55:09.338
risk if it's the final rule is adopted by January.

01:55:09.350 --> 01:55:12.850
Does anyone have a formed position on that topic that

01:55:12.859 --> 01:55:15.279
might help us in scheduling our activities? And if

01:55:15.289 --> 01:55:17.319
you weren't expecting that question today, that's fine

01:55:17.329 --> 01:55:21.509
But if anyone has a views on that, that is certainly

01:55:21.939 --> 01:55:25.310
relevant to our implementation calendar discussion

01:55:30.270 --> 01:55:33.409
Well, if you, if you come to have views on that topic

01:55:33.418 --> 01:55:35.869
do let me know because I, I do not, I do not

01:55:35.878 --> 01:55:38.789
build power plants. So I do not know all of the real

01:55:38.798 --> 01:55:42.180
world uh practicalities that, that you guys face. Um

01:55:42.189 --> 01:55:42.859
So thank you.

01:55:45.798 --> 01:55:50.689
Are there any other um policy priorities or timing

01:55:50.699 --> 01:55:54.020
implementation issues or anything within the purview

01:55:54.029 --> 01:55:57.579
of this workshop that folks would like to discuss at

01:55:57.588 --> 01:55:58.128
this time?

01:56:10.239 --> 01:56:13.918
(item:3.8:Johnny Carlock with Pioneer Natural Resources on HB1500, Section 22) Good afternoon. Uh Johnny Carlock with Pioneer Natural

01:56:13.930 --> 01:56:18.369
Resources. I would like to request. Is there a possibility

01:56:18.378 --> 01:56:22.159
of getting a workshop? We've got several Bills, both

01:56:22.168 --> 01:56:27.869
House and Senate uh related to generation and part

01:56:27.878 --> 01:56:31.699
of the issue even with Senate Bill 2627. Is there

01:56:31.708 --> 01:56:36.128
a potential interaction between uh House Bill 1500, 

01:56:36.180 --> 01:56:41.199
Section 22 and also the multiple sections relative

01:56:41.208 --> 01:56:44.878
to renewable energy credits? So I guess the question

01:56:44.890 --> 01:56:48.560
is as far as the timing and the implementation, are

01:56:48.569 --> 01:56:51.759
there, is there potential for unintended consequences

01:56:51.770 --> 01:56:54.628
for implementing something that may impact one of those

01:56:54.640 --> 01:56:57.409
other um areas?

01:56:59.689 --> 01:57:01.979
(item:3.8:David Smeltzer's comments to Pioneer Natural) That is probably a good question that we can take under

01:57:01.989 --> 01:57:05.100
consideration. I, I don't have an off the cuff response

01:57:05.458 --> 01:57:08.109
and, and, and I guess just as an end user in the

01:57:08.119 --> 01:57:11.600
Permian Basin, all of these potentially impact us,

01:57:11.819 --> 01:57:14.859
I mean, right now we are working through some of this

01:57:14.869 --> 01:57:20.798
legislation addressed um the actual uh wires of the

01:57:20.810 --> 01:57:24.109
transmission and the substation infrastructure at some

01:57:24.119 --> 01:57:27.100
point in time as the forecast that loads start coming

01:57:27.109 --> 01:57:31.159
online, we we have seeing the potential for a generation

01:57:31.168 --> 01:57:35.208
shortfall. And so the question here is long term planning

01:57:35.750 --> 01:57:40.220
what is the overall holistic plan from a generation

01:57:40.229 --> 01:57:43.338
standpoint to ensure that the generation is there once

01:57:43.350 --> 01:57:46.899
the wires issues are resolved. So just backing up to

01:57:46.909 --> 01:57:51.539
answer your question, how as an end user do we get

01:57:51.548 --> 01:57:56.060
some type of vision on what is the overall plan looking

01:57:56.069 --> 01:57:59.619
at the interaction of all of these different implementations.

01:58:02.659 --> 01:58:05.009
That is a, that is a good and complicated question.

01:58:05.390 --> 01:58:08.289
And if anyone has a position on the overall plan, but

01:58:08.298 --> 01:58:10.600
behind the interaction of all these pieces, it would

01:58:10.609 --> 01:58:12.369
now would be now would be the time to lay out the

01:58:12.378 --> 01:58:14.359
the master. No, that, that is a good question and I'm

01:58:14.369 --> 01:58:15.989
only making light of it because it's such a difficult

01:58:16.000 --> 01:58:20.310
question. Um And uh uh thank you. Thank you for posing

01:58:20.319 --> 01:58:23.239
and I don't have a off the cuff response. Okay. Thank

01:58:23.250 --> 01:58:23.329
you.

01:58:38.119 --> 01:58:42.939
Pending no other last minute comments. (item:3:David Smeltzer closes workshop) I want to thank

01:58:42.949 --> 01:58:46.970
everyone for coming today. We've had a lot of, you

01:58:46.979 --> 01:58:49.128
know, we have dozens and dozens of bills to analyze

01:58:49.140 --> 01:58:52.600
and we have dozens of rule makings ahead of us. So

01:58:52.958 --> 01:58:57.000
I think that given the given that there are fewer statutory

01:58:57.009 --> 01:58:59.119
deadlines this time, we're going to try and have more

01:58:59.140 --> 01:59:02.939
of these types of events on specific policy topics

01:59:02.949 --> 01:59:06.350
that we can as long as folks believe that they are

01:59:06.659 --> 01:59:10.128
helpful and productive. And I'm always open to process

01:59:10.140 --> 01:59:11.949
feedback behind the scenes. If you think there are

01:59:11.958 --> 01:59:14.918
ways the Staff can be processing or handling these

01:59:14.930 --> 01:59:19.814
things better, so free to reach out to me. Um Thank

01:59:19.824 --> 01:59:23.324
you for your participation and I'm sure that the Commissioners

01:59:23.333 --> 01:59:26.555
and some Legislators were watching and will find this

01:59:26.564 --> 01:59:29.503
input very valuable in determining the way that the

01:59:29.515 --> 01:59:32.564
Commission should proceed in its rule making agenda

01:59:34.100 --> 01:59:36.739
I, I guess we can reclaim the rest of the time. Thanks

01:59:36.750 --> 01:59:39.009
for coming.