(silence)
I know this is uh, an IOU heavy group. But you all don't
have to sit in your open meeting, your open meeting
location. If you, if you don't want to. Uh, hey everybody.
(item:0.1:Welcome & Introductions- David Smeltzer, PUC Director Rules & Projects) Uh, my name is David Smeltzer. I'm the Director of Rules
and Projects for here at the Public Utility Commission.
We are gathered today for a Resiliency Workshop. Um
joining me at the dais is uh, Chris from Infrastructure,
Ramya from Markets and Rama from my shop here in Rules
and Projects. And Bill Abbott and Terese, and some other
PUC luminaries are in the back, should we need them.
(item:0.2:David Smeltzer lays out Workshop Objectives/Order of Events) Um the order of events today, we have a, a draft. That
was um you know, Staff's very busy. We've got a lot
to implement. So uh the, the ERCOT IOUs and others
provided a base draft, um just for purposes of commentary.
It doesn't reflect the positions of any individual
company or Commission Staff. It's just for discussion
purposes today. Um for order of events, we'll probably
just start at the top and work down. Uh for those of
you that have been in any of our recent DER Workshops.
This should be sort of a familiar uh, proceeding. But
basically, uh if you want to speak on any topic or
provide commentary, you don't need to raise your hand
or whatever. Just come up to one of these front mics
and we'll sort of call you in as best as we can
the order that people came up. Um and I would also
say that in the DER Workshops, we sort of developed
an informal protocol of when we're going down the line.
You know if in between speakers, if you're wanting
to speak on the current topic. You know, you could
hold up a 1. If you want to speak on and the
2nd one, hold up a 2. Then we'll sort of know, like
if you're waiting to speak on something else too. So
we'll know who to call on next. And then there's the
Ned Bonskowski protocol. Which is, if you just want to
agree without slowing things down, you can just hold
up a 3. Uh one other uh new protocol for this week. Is I
think we do need some audience participation. So we're
gonna do one test run. I'm gonna say hello and everyone's
gonna repeat after me. Hello. That was the test run. Here's
the important one. Happy Birthday, Rama.
Happy Birthday, Rama.
Well we, we got two hours and a lot to cover. So
that is all I will, to will torture her uh on that.
But um I guess we will start at the top, uh unless
anyone has opening remarks.
All right. So I don't know if, uh
generally speaking, I mean. The task today is we have
180 day implementation deadline for this rule.
Which means we've got to get it on September 15th
Open Meeting in PFP form. So we've got not a lot of
time to do it. So if at any point you're thinking like
maybe should I come up, maybe should I not now? Now
is the best time to let us know what we need to
be thinking about as we finish this draft. So um we'll
weave in the discussion uh questions as we go. But I guess
does anyone have anything to say about the purpose
in applicability language?
Okay. This is good. If, if this draft is just perfect
that's gonna be easy for everybody. Um okay. So yeah
and then there's the standard applicability. And, and
I guess if, as we're moving on to the definitions,
there are a lot of definitions here. So if you think
you're gonna wanna discuss any of the provided definitions.
Or whether or not you think the definitions are needed
feel free.
All right.
And I'll go ahead and prompt, I'll go ahead and prompt.
(item:1: Ramya Ramaswamy, PUC Markets with question on definitions) Hey David, can I ask a question? Sure. So, um this is my question here
is like um the definitions that are here. Um is it
should the rule be defining these definitions? Um or
should we let the people who filed the plan define
what these mean to them?
Suspicious you guys, it's very suspicious.
And I know you've been waiting for this forever. Um
(item:1:Brian Lloyd with Oncor on rulemaking categories) Brian Lloyd with Oncor. I mean I, I think that the general sense
is, is we thought it was helpful as the Commission considered
this rulemaking. To have some idea of the types of
things that, that are in these categories. You'll see
all of these kind of have it included, but not limited
to. So in recognition that there's, there's a tight
time period on the rulemaking. There's a tight time
period on the proceedings of six months as well. We
thought it's somewhat helpful to say look, this is
these are kind of some examples of the types of things
that, that many of the utilities I think are starting
to contemplate as part of these, these filings. Recognizing
for every the other challenge being, every utility
is gonna have kind of a different set of things. Even
within a category, there may be a different set of
things. So again, we thought it was helpful to flesh
out a little bit of detail there. But recognize that
that there may be other things that kind of come in.
As well as come in over time for some of these technology
advances and things like that.
(item:1:Jessica Seuss with AEP Texas on definitions) Jessica Seuss with AEP Texas. Um I think we kind of
echo Brian sentiments. I don't think having these in
the definitions or having these definitions is strictly
necessary. It might be slightly better to let these
be defined by the utilities. Uh but this guidance is
helpful and having something like this in the preamble
um may be the appropriate place for that. Okay.
(item:1:David Smeltzer on ) And so the, so the general sentiment seems to be, we
need you know the, the applicants need flexibility
uh to deal with the different topping. Uh you know
but uh you know topographies of their system etcetera.
But the guidance is helpful so that, you know, ALJs
etcetera. People that aren't experts in this stuff.
Have a general idea of what we're talking about. Is
that uh, uh does anyone disagree with that being sort
of the posture of where the draft should be on things
like this?
All right, this is going very smoothly. (item:1:Rama Rastogi, Commission Staff Rules & Projects with question on definition of resiliency) I did wanna
ask uh or no uh you know, for you all to know
that there is a definition of resiliency also in there.
So is, should we take it that there is general consensus
on what the, the definition of resiliency is here or
are there thoughts?
(item:1:David Smeltzer on defining resiliency) And to add to that? I know that defining resiliency
generally speaking, is a, a national effort that is
you know, has a lot of divergent thoughts on it. So
there was some level of concern on staff's part about
whether or not we wanted to have a definition of that
anywhere. But I understand this would be contextual
(item:1:Sam Chang with CenterPoint Energy on ) Yeah, Sam Chang with on, with CenterPoint Energy. Um
we do believe having the definition of resilience or
resiliency is helpful. And again, this is something
that 8 utilities agree to from a language perspective.
And if you look at the definition, it's very event
based versus um approaches taken by NARUC and FERC. That
are more concept based. And so we do think it's helpful
to have that definition.
(item:1:Ramya Ramaswamy with question on resiliency) So I have a question on that. Um so I, I can
see with the event and especially if it is an event
that is
more um a large unique event. More than, you know,
something that happens. Like Summer comes every year
so, uh with that in mind. Um one of the things that
I've been struggling with is also thinking of resiliency.
More as a system based rather than infrastructure or
specific to smaller ones. Because a lot of the individual
components or individual, um the way we think of it.
Can be also fall, fall into the reliability bucket.
Compared to like resilience, which can be overarching
of the system. And try and you know, going with the
definition of um ability to prepare, adapt, respond
and recover for the system as a whole. For unique or
you know, larger events that occur not very frequently.
(item:1:Sam Chang with CenterPoint Energy on distinction between resiliency and reliability) Yeah, and I'd agree with you. And you touch upon the
distinction between resiliency and reliability. In
our view, we view resiliency as how hard of a punch
can you take? As far as high impact, low frequency events
and how fast can you recover from that punch. Whereas
reliability is more of a can you provide service on
a blue sky day?
(item:1:Micalah Spenrath with TAEBA on resiliency) Hi uh Micalah with TAEBA, just to kind of chime in. So
I think TAEBA is in favor of a holistic understanding
of resiliency and including like long term sustainability
of the system. I think event based definitions are
fine right now, but we might also want to consider
just like growing demand and just encompassing stress
on the system. It's not exactly an event. Um like you
said, Summer occurs every year and demand spikes um
which stresses the system. So resiliency can also be
the ability to withstand changes in that demand and
of course, come back from it. So I think, I think we
don't have any language suggestions just yet on this
and we don't have to move away from event based language
but stress in general might also be captured under
this. (item:1:Ramya Ramaswamy on reliability of the system) Um so, so this is something again I'm struggling
with, especially, you know, because we are also trying
to think of what is an emergency. And, you know, especially
here in Texas with Summer being one of in the past
has been our peak Load in our system and stress on
the system. I agree, but that also becomes more reliability
because that is what we are designing our system for
for the everyday. Yes, we've had 40 days this Summer
of peak, 100 plus degree days in Austin. But that is
what we have to meet as a system and it's not a
unique long term event, right? So that is what the
between the reliable, reliable system and the resilient
that we are building for um or planning for, you
know, as the utility has to plan for, right. So that's
that, that's what I was trying to touch upon. So, um
I hope that clarifies. Yeah, thank you.
(item:1:Cyrus Reed with Sierra Club on resiliency plan) Cyrus Reed, Sierra Club. Um to build on the uh previous
commenters comments. Um I don't have any issue with
these definitions, but you might want to make them
a little wider to look at those other stresses. And
as an example, the definition of resiliency plan very
much follows HB2555, if I've got the number right.
And list everything that was listed in that Legislation
which is fine. But you might not want to limit it to
those things. And I say that because um there are concepts
like non wires alternative. There's the 2021 SB, can't
remember the number, storage one which allows storage
as a service. Those for, for help in the distribution
grid. So there may be other things that a utility not
required but might want to do as part of a resiliency
plan um that could be incorporated. And I think we
should allow that to happen by either saying not limited
to or maybe adding something like non wires alternatives
in this list. So that would be, and I don't have specific
language today. But just having a wider definition
obviously, when you guys get to the reviewing the plan
and other stakeholders get to looking at the cost.
There'll be debates about what should be included.
But I think of the definitions, we should be probably
wider than what, what's in this list. Okay, yeah. (item:1:David Smeltzer's question to Cyrus Reed) Because
if, if you're measuring is something you might
want to measure it against other measures that aren't
there. I see what you mean, yeah. Um and you when
you were saying that we, we might want it to be broader.
You mean the actual resiliency plans themselves might
include measures that are not on this list. (item:1:Cyrus Reed's follow-up to David Smeltzer) Exactly.
And, and um even the way um, you know, separately
the, the utilities have demand response programs which
are not resiliency plans. Uh but when they're not
being used for eea events maybe they help make
the system more resilient. By the use of those demand
response programs. So I, you know, I haven't thought
through this but I. (item:1:David Smeltzer comments on resiliency) Yeah, no see what you mean. And I think that
I'd had a uh, we got a three back here. Proper use
of the Bonskowski protocol over here. Um, yeah. I, I've
been thinking about that too. I mean there are other
measures that resiliency can have. And the question
is like, do they become a part of this? Or do they
become something that if you want to do one of these
you've got to prove that you shouldn't have done that
other thing instead? You know, I mean so where the
line is drawn. (item:1:Cyrus Reed's thoughts on David Smeltzer's comments) Or are they just a reference we have
these other tools that we can use that also uh, allow
for resiliency. But not, are not necessarily recovered
through, you know, the cost on ratepayers. But at least
they're, they're acknowledged. Yeah, that's
a dynamic we're thinking about for sure yeah. (item:1:John Ross Hubbard with TIEC on blurring lines of resiliency and reliability) John Ross Hubbard
Texas Industrial Energy Consumers. Um we were just
cautioned against confusing resiliency kind of blurring
the line between resiliency and reliability. Um because
I think event base is a very clear distinction as it
was drafted. Um and I think that's a helpful way to
distinguish the two. And once you start blurring that
line, it gets just a little more complicated. And so
we'd caution against that.
And what's the, what's the fear? That there would be
that it would end up costing consumers a lot more money.
Because the. Liability measures would be pulled into
the.
Yes. (item:1:Ramya Ramaswamy question on definition of an event) So then would we also add a definition for an event?
I haven't thought about that.
Yeah I, I I'm not sure. (item:1:John Ross Hubbard with TIEC on definition of an event) I think how it's, I don't
see an issue with how it's drafted without a definition
for an event. Um and off the cuff, I can't think of
a negative for including one. But
thank you. Because it sounds like a fussy definition
to write that's the next, it would be very fussy work.
Um, okay. Anybody else want to comment on uh, resiliency
definition?
All right, let's keep on scrolling.
(item:1:David Smeltzer opens floor for comments on Subsection D, Resiliency Plan Review & Approval Process) Resiliency plan, undergrounding, vegetation management.
Anyone can holler at any point?
Okay so making it through the definitions. Um uh Subsection
D is about the resiliency plan, uh review and approval
process. Um I guess I'll just because it's not a super
chatty bunch today. I'll open up the, open up the floor
for commentary on this Subsection. If anyone has thoughts
on generally on the review and approval of these plans.
Yes.
(item:1:Zach Stevenson with TEC on denial/approval of a resiliency plan) Morning, Zach Stevenson for Texas Electric Cooperatives
Uh our comment is limited to Subsection 6 within
this section. I don't know if anyone else has anything
before that?
We can, we can skip around.
And that's uh in particular 6C.
Uh we know we recognize that this tracks the statutory
language. However, this might be one of those areas
where it might be appropriate for the Commission to
read in uh the appropriate inverse. And just add in
the denial or approval of a resiliency plan is not
considered to be a finding.
Yeah, to make sure the issues preserved for review
to a rate case. Exactly. See what you mean. Does anyone
want to have thoughts on that particular notion? I
do. (item:1:George Hoyt with Entergy Texas on approving a plan) Um George Hoyt for Entergy Texas. So there has to be a
meaning to approving a plan um and the measures in
the plan. And so, while the utility will always be
under an ongoing duty to prudently manage and implement
the investment. You know, our view is that it does
mean something when the Commission approves the plan
and the measure in it. So to the extent that, you know
there's not a change in material circumstances and
the utility prudently implements the plan. Um, we don't
think that the decision to, you know, undertake the
the, the measure ordered by the Commission is subject
to rereview
Counter?
(item:1:Zach Stevenson with TEC on rereview) Well, I think the rereview is contemplated with the
um uh true up on the rate case. (item:1:George Hoyt with Entergy Texas follow-up on rereview) And so, yeah well
just to be clear. The rereview is whether the utility
has prudently incurred the actual cost. So what their
wasted cost was there a cost overrun that wasn't justified.
But the decision to build the project that was approved
as part of a plan, absent change circumstances is not
subject to review. Okay. Anyone else to speak on this
narrower topic?
Okay, Zach you got anything else? Nothing else. All
right. Thank you very much. (item:1:Lauren Damen with NRG on REP notification) I'd like to back up quickly
to 5 and hopefully this is not controversial. Uh
Lauren Damen on behalf of NRG. I would just like to
put a plug in, that y'all add a provision for REPs
to get notice 45 days before the actual rider goes
into effect. With this timing, I can see where we would
definitely know 90 days from the filing, 90 days ahead
of time. But it looks like there's some provisions
where that is just not entirely clear. So regardless it
would be great for REPs to get notice. So that we can
update our EFLs and make system changes. To make sure
that the customers can be apprised of the changes.
Any objections?
Seems reasonable for PFP purposes.
(item:1:Nicholas Hodgie George with the City of Houston on area of lower performance) Hi, my name is Nicholas Hodgie George from the City
of Houston. Um we have a comment on Section 4 in
uh the language about what the Commission shall consider
um Subsection A. There says that uh the Commission should
consider whether the plan prioritizes areas of lower
performance. Um we just didn't see any language in
here that built on what that means? How the utilities
should report on that? And, and how it exactly should
be considered? So we, our recommendation is to build
that out and um further specify what it means to prioritize
an area of lower performance. And it could maybe go
into the definition section of what an area of low
performance is.
That's an interesting notion. Does anyone wanna any
thoughts on that?
Yeah, that's worth worth thinking about. Um Do you
have any suggestions on what you think of the uh what
a low area of lower performance mean? It could be areas
that experience a greater number of outages, circuits
that are lower performance. Uh circuits areas that
are affected by um you know circuits in flood plain,
circuits in hazardous areas. (item:1:David Smeltzer's thoughts on areas of performance) Yeah, I understand. Yeah
that's sort of an interesting one. Because
you know, each type of event happens with different
frequencies. So you'd almost measure what an area of
performance is differently depending on what aspect
of resiliency you're trying to address. So it's kind
of a tricky wicket. But I think what you're saying
is not and not crazy. Yeah. (item:1:Sean Meredith with Entergy on areas of performance) Hi. Yeah, Sean Meredith
from uh Entergy. Um one of the concerns I have with, with
trying to specify that on the front end is exactly
what you were just alluding to. Depending on the part
of the state you're in. One is if you're looking at
low performing from a reliability perspective. That
could be very different from a resilience perspective.
You could have a circuit doesn't have poor performing
reliability. But it could have a very high resilience
impact. If a storm comes like on the coast, for instance.
And the circuits built to 100 miles an hour, it may
do fine day-to-day. The whole circuit may end up on
the ground after an event. So you got to weigh those
types of things. And I think the burden of proof is
on us the beginning to say. Here's the highest likelihood
of failure. Here's why we're attacking this from a
resilience perspective. And if we specify that we could
end up actually going in working on something that
has less resilient benefit.
I have a clarifying question. So are you trying to
say that you are going in your resiliency plans. You
are going to be defining what is the resiliency problem
that you are solving to? (item:1: Sean Meredith's follow-up response to Rama Rastogi) That's absolutely it. The burden
of proof is on us to define. Here's the benefits, here's
the problem on each utility. Because each of us will
have a, may have a very different challenge from a resilience
perspective depending on where we are in the state
or what type of infrastructure we have. So we will
have to provide that and express the benefit that we're
going to receive for the investment. So I think specifying
that on the front end could really hamper the ability
It may steer actually the utilities to go and invest
in something to make for whatever the criteria set
versus identifying the most beneficial to our customers
and communities. (item:1:Rama Rastogi's follow-up question to Sean Meredith with Entergy) I do have a follow-up question which
is actually coming from the one of the questions in
the memo. That talks about alternatives for the problem
that you are solving. So there may be one resiliency
one solution to the resiliency problem that you've
identified. And there could be, you know, more than
one and there is a cost implication to the choice of
the solution that you choose for solving that problem
So that's a question, not just for you but for the
floor as well. Like you know what is, what do you
all think about that? Yeah, happy to address that.
(item:1:Sean Meredith with Entergy on being most cost effective) So it's again, the burden of proof is on us to explain
why the so the solution we have picked is the most
cost effective for our customer. And we have to defend
that and show that. And if there are questions around
other alternatives, we need to explain why we're not
utilizing that because of Xy and Z. Um But again, to
the, the point of I think redefining that could steer
utilities away from the right solution. So it's on
us to show the most cost effective. Um but. Oh, not trying
to cut you off. (item:1:George Hoyt with Entergy on areas of low performance) Um George Hoyt again for Entergy. Uh just a couple
of points. Um on the, um you know, defining areas of
low performance. I think the unintended consequence
could be that not only that you, some of these factors
are focused on reliability, not resiliency. But also
that you could inadvertently exclude areas of low performance
say I don't know, a cyber security area. Um because
you've, you've taken an arbitrary subset of areas that
would be considered low performance. And then all of
a sudden, you know, the utility is not addressing it.
Even though it's a very cost effective and worthwhile
measure. Um the other thing with on, on the alternatives
whether you know, that should be a requirement to specify
alternatives. Um I, I think as Sean said, the utility
should have the latitude to do that where it makes
sense and it's necessary to meet its burden of proof.
But if we, if we insert a requirement that for every
measure a utility proposes in a plan. It has to put
forward some alternative. That may pollute these, these
plans and cause a lot of unnecessary work and helpful
information. There may be circumstances where, you
know, there's an alternative that's technically feasible.
But clearly um, you know, not practical or cost effective.
(item:1:David Smeltzer's comments on adding language on areas of performance) And so, so wouldn't that be an easy, wouldn't that
be an easy paragraph of a plan to write?
It would be like. You know, there's this other unfeasible
alternative and, you know, in x area sure we could
bulldoze through all like this 7 ft of granite to underground
all these lines. But uh there's all granite in this
area. So we I mean, it seems like that would not be.
I understand what you're saying about like we don't
want to set, we don't wanna affect. We want you guys
to think about these in terms of what's going to achieve
the maximum amount of resiliency, not what's gonna
make the application easiest to fill out. Um but uh
I don't know if it's that. (item:1:George Hoyt's follow-up to David Smeltzer's comments) The, the flip side of that.
You're absolutely right. It's an easy paragraph to
write. But it, it is not a particularly meaningful
paragraph for anyone either, right. So to the extent
it's easy that means it's obvious and, and it's, it's
consuming resources. It, it you know making this
take longer to review, harder to review. It's more voluminous.
It's just, it doesn't appear to be providing meaningful
information to the Commission. Now there it may very
well be the case. That, um you know want to specify
alternatives to demonstrate that a particular product
or, or measure is the appropriate one in that situation.
So I, I anticipate that you will see that quite a
bit. Um, I just would caution against you know kind
of prescriptive things in the rule to that effect where
it might not make sense. Yeah, I'm trying to think
from like a. We've only got 180 days to approve
these plans. And so it almost seems like the strategic
move from the plan writer would be to sort of immediately
disavow all the things that are broken so that you're
not hearing them from interveners perspective. But
to your point whether or not that should be a requirement
or something that just works its way through uh is
(item:1:Ramya Ramaswamy on quantitative and qualitative language) So can I ask something? So the the words that come
before the prioritize, prioritization is having qualitative
and quantitative measures, right? Those basically are
gonna drive the factors that drive this. So those can
be um you can make those attribute based or performance
based. And that can, I mean, that's how I am thinking
about how these plans should be. That they are still
going to be specific. It is a plan that addresses something.
But because of those quantitative and qualitative,
it should list the steps in the plans. That are the
steps that a process that is planned. Am I? (item:1:Sean Meredith's follow-up to Ramya Ramaswamy's comments) You
you think about that correctly. So it would uh just
an example a hypothetical would be. Project A you
expect to get these three benefits that are quantitative.
That's absolutely what the plan is gonna encompass
right? It's gonna be very specific to here's the benefits.
Project A cost has these benefits associated with
it. Right. That's, that's exactly how we, how I read
that and how, what the intent is. But going back to
the prioritization of the lower. Um how does that come
with resiliency and not reliability is my struggle.
Okay. So, um as I said earlier. I think it was an
excellent definition is reliability is to provide the
quantity and quality of power we want on a blue sky
so day to day. So I hit the light switch, it's there.
The way I want it resilience is, is very this high
impact low frequency event based. So looking at it
from a a day to day perspective is say to you say.
We don't wanna, you don't wanna use those type of metrics
because of the those impacts. What we have to look at
It's got to be defined by what the event you're, you're
being resilient to. So whether that's a wildfire, in
our case we're a Coastal utility. Hurricanes is obviously
one of the things we're very concerned with. Um So
from our perspective, you know, those type of metrics
are. How fast can you get the lights back on? It's
not that the lights aren't going to go out. I said
how fast are you going to get them back on? And what's
the, what's the cost of the, uh for getting the lights
back on? And that's really when you start measuring
resilience, that's just one way to look at it. There's
obviously depending on where you are in the state or
what your event or threat is. Um, it will really drive
that discussion. (item:1:Ramya Ramaswamy on details of the distribution system) So this is why it's like during the
definition section, I had brought up the system rather
than, you know, the smaller component. So it's like
even when you're thinking about um, we most probably
are talking of the same thing. But I just want to make
it very clear here that at least my understanding
right. That's what I'm trying to, to hone
into. Is the resiliency plan should be thinking still
of the system as a whole, the distribution system or
the system that you guys are, the utility is focused
as a whole. And not to say that okay, I'm just going
to make sure that 78704 to pick a zip code is going
to be my target resiliency. Is that a fair way to think
about it? (item:1:Sean Meredith with Entergy on system perspective) Well you have to, you have to analyze it
from a system perspective. But as you're putting your
plan together, obviously it's very tactical. And you
need to understand how those individual components
impact the system. But you are looking at it from a
system perspective that utilities perspective. Yes.
But, but it is very tactical. And what you're going
to do because some substations are more prone to flooding
than others, right? Things like that. So you've
got to look at it from that. And, but you have to
understand the impact of that substation to the area.
(item:1:Sam Chang with CenterPoint Energy's introduction of Eric Easton) So I have with me, Eric Easton, who's our VP of
Grid Transformation and Investment. And also in his
prior role, he oversaw high voltage operations. I think
he can provide additional context to this discussion. Sure,
thank you. (item:1:Eric Easton with CenterPoint Energy on performance based vs. event based approachs) Um so we do agree and echo the concerns
that Entergy had, uh just a few caveats. Um you know, you mentioned
a little bit about the system perspective. I think
we think about it not only from the electric system
but also those critical loads that we have on our system.
That are important during a disaster or public health
situation, such as a hurricane or some other event.
And so that's where I think there's a divergence between
the performance based, which is more performance based
on reliability versus the event based approach. Where
we are planning for a specific event. And during that
specific event, there may be other critical infrastructures
that are important. That we would emphasize investment
from a resiliency standpoint from the entire societal
benefit, not only just the electric system. And then
there's also things that are electric system based
that we would want to put prioritization on. And so
I think if we only looked at the performance of the
electric system we may, as Entergy said. Have some misalignment
between the investments that we would make from a reliability
perspective and that of a resiliency perspective. So
I didn't want that to be lost as well. That the electric
system is one part of a broader system during an emergency.
And because they are very event based, we might focus
on specific parts of the system regardless of their
day to day reliability. I think the other thing is
that when we make resiliency investments and this kind
of goes back to the optimization of those investments.
that sometimes the same investment helps for multiple
events. And so that's something else that utilities
are going to look at. I would presume I know that center
point will that if we make an investment, does it help
us with multiple high impact low frequency events?
And so if we start to have too much prescription in
the steps that we need to take, it might avoid or impair
our ability to do some of that optimization.
(item:1:David Smeltzer's comments concerning language on prioritized areas of lower performance) So as I as, I am thinking about it and listening to
you guys make what I think some pretty reasonable arguments.
Um I still wonder kind of what we're supposed to do
with this language about uh you know, areas on what
prioritized areas of lower performance. And is maybe,
is maybe the way we should think about it is, you know
there's sort of different categories of action that
you can take, you know. Um or different types of resiliency
measures. And so just uh so elevated substations to
avoid flooding versus vegetation management, to avoid
those sorts of line outages. And is maybe the way to
think about it. Is not that we should be,
you know, if you guys have a plan that comes in with
vegetation management. Maybe we shouldn't be asking
whether or not vegetation management from a system
perspective is a, a greater or lesser area of need
like lower performance. But within each category, like
if you're going to elevate substations or rather, you
know, if you have an application to focus on. Uh one
area and not the other, I don't know that we should
be denying it because this isn't your most urgent need.
But maybe if you're gonna start elevating substations
uh you should start with the ones that are of areas
most. You know, like to use it within each category
rather than across categories. So I was trying to imagine
sometimes you prioritize things that are lower hanging
fruit rather than that are the most acute need. And
so anyway, that's just a. I think that's. Another way
to think about it. (item:1:Jessica Seuss with AEP Energy on language on prioritizing lower performance) I think that's a reasonable thought.
And I think the biggest thing is we don't want to be
as everyone has said, overly prescriptive in this rule.
That language about prioritizing lower performance
is in the statute. If we wanna just copy it from the
statute and the rule or leave it out of the rule. I
think that's a good plan. And then we can just leave
it up to each utility to, in their applications explain
how they're considering that factor. Yeah, because
it's kind of interesting because it doesn't say we
can't approve plans that don't do that, you know. But
we, you know, it's there for some reason.
(item:1:Eric Easton with CenterPoint Energy on priorities in the overall plan) Yeah, I think in some cases it's a supplemental benefit.
So when we can align we do, we try to. But as
you just mentioned, it's not a requirement. Because
it's still based on the individual utilities perspective
of what are the priorities in the overall plan.
(item:1:George Hoyt with Entergy's thoughts resiliency vs. reliability) And I agree generally with what others have said. I
would say, you know, you can also look at areas of
lower performance in the context of what resiliency
is as opposed to reliability, right? So, um an area
of lower performance and a resiliency context can be
thought of an area that's susceptible, right? So, um
just offer that as well. (item:1:Micalah Spenrath with TAEBA on higher risk language) I actually wanted to chime
in. And maybe we're getting hung up on the word performance
but maybe it's like higher risk. So from a utility
perspective, like maybe your areas that are more susceptible
to these events, higher risk might be where you need
to, to look at. But in terms of defining that I would
defer to the utility community. Yeah, and I think for
me, regardless of exactly how we take, take it. Just
because you like maybe, just because the utility
is most at risk of floods doesn't mean we don't also
want them to be doing resiliency measures in other
areas. Even maybe first because that's what they know
how to solve in that moment. You know what I mean?
I don't know. It's unclear. That's the, what.
Uh. (item:1:Rama Rastogi on low hanging fruit vs. acute need) I think I have a follow up question about uh the
low, the low hanging fruit versus the acute need. So
in your resiliency plan what is, what is the general
uh thought around. Would the resiliency plan be uh
you know, bigger plan of uh you know, that consists
of smaller sub plans? That kind of solve um you know
specific resiliency problem in pockets of your service
territory. How do you kind of? (item:1:Sean Meredith with Entergy on plan meeting multiple tenants) So, so I see it as
being you have a plan that will meet multiple tenants
that are listed there and I'll speak on ours. So when
you look at it, obviously hardening is a huge component
being a coastal utility. Also flood mitigation is another
very large component for us. There are other things
in there that we also have to consider. But it would
it would be sections for each one of those explaining
why these are the largest benefit to our customers
for the cost associated with them. So for instance
it would say, you know, feed or a harden this many
poles basically to rebuild. Here's the cost, but here
are the associated benefits for that. And it would really
break it down to that level is how I foresee defending
defending that. (item:1:Rama Rastogi with follow-up question to Sean Meredith with Entergy) I guess I'm kind of thinking from the
staff's perspective of approvals. So like if you, if
the plan is made up of like three subplans. Of kind
of taking care of something on the coastal area, something
on uh would we have an ability to kind of do uh
you know, choose any two or would it be like something
that this is the whole plan? And all three subparts
are a part of the plan? So either the whole plan gets
approved
or. (item:1:David Smeltzer on comprehensive resiliency) And I think maybe some of the tension that she's referring
to is when, when we hear from individual utilities
or whatever about these. The, the real benefit of this
statute is supposed to be. We can think about, we can
think about our resiliency comprehensively like this.
We, we can't we've previously not been able to think
about it comprehensively. And like okay, comprehensively.
But then when you actually start to think about the
plans, the analysis breaks down. Because like what each
individual measure is gonna have to be measured in
different ways and they're gonna apply to different
problems and you can't really compare across. And so
is it, is it comprehensive or is it not you, you know
what I mean? So it's just that there's a tension there
between what level of analysis we're supposed to be.
(item:1:Sam Chang with CenterPoint Energy on statutory language) Yeah, so I would refer to the statutory language that
allows the PUC to approve as filed, modify or deny.
So I think you have a wide range of options as far
as what you wanna do uh come approval time. Sam is
recommending denial, this is what I'm hearing. I'll
hold on to it. (item:1:Rama Rastogi on alternatives) I, I do have uh, uh I'm gonna
go back to, I want to be labor a little bit about the
alternatives. Uh because uh I think uh from your previous
comment, I'm talking to the Entergy comment. About that we
don't have uh, we can't revisit uh the planned components
once it's approved by the Commission. But the amount
of time that we really do have uh is very limited.
So in a scenario where Staff has very limited time
to review the plan. Uh and it is a new thing, would
it. I, I would personally feel that it would help the
Staff also if there were, there was more hand holding
in terms of you explaining. Uh why uh you know, the
the entity chose a particular resiliency problem? Why
you chose a solution? And why, you know, if vegetation
management was there there less expensive alternative
but you still went ahead with the, you know, lifting
the substation up for a flood risk. What was the rationale
for it? All I'm saying is that that's going to help
the Staff kind of understand your position much better
and I'll stop here. (item:1:George Hoyt with Entergy on alternatives) Yeah. I,I I understand what you're
getting at and, and like I said. I, I think you're
going to see a healthy discussion of alternatives in
many cases. This was simply a point about not kind
of requiring a box to be checked. That's going to pollute
these plans and increase your work by describing a
bunch of clearly implausible alternatives. So where
an alternative needs to be discussed, to establish
that it is the right thing to do for customers at the
best, most effective at the least cost, that sort of
thing, then we certainly intend to do that. (item:1:Jessica Seuss with AEP Energy on alternatives) And I think
to echo those points. We can and intend to provide
a lot of explanation on our decision making process.
and plans. But that's not always going to be best achieved
by discussing alternatives if none existed. Or if they're
so out of the box that they're not really that helpful.
And it's just going to increase the amount of things
that Staff has to read. And increase the cost of preparing
these plans. Um yeah.
All right. This is uh feels like we've had a pretty
robust discussion on this point. Are we uh
all right, very good.
Yeah.
Um I have a thing on 4B. We have the estimated
cost of implementing the measures proposed in the resiliency
plan. Can we add timeline, estimated cost and timeline
of implementing the measures proposed in the resiliency
plan?
So we got some, we got some threes over here.
So
Bill, do you have thoughts not on, not on this particular
question? He's getting, you have another question for
for the, for the crowd.
Yeah, go for it. Um So I, I guess I have a
question on uh on the riders on Part 5 basically.
Um especially in light of the relative attractiveness
of the big asset recovery. Um Would there be uh opposition
to a requirement that the rider uh be limited to the
DCRF or the TCRF for the non-ERCOT utilities? Or is
there is a sense that we, we needed to establish, you
know, the details of a new rider for this. (item:1:George Hoyt with Entergy on riders) George Hoyt on
behalf of Entergy. Yeah, Bill. Um our point of view is that
the rider, uh a new rider is, is specified. Is
dictated by the statute. Um And it, in fact, the statute
says that in approving or considering, you know, in
approving a rider. The commission will determine the
appropriate terms of the rider. And I can't make that
read correctly if it's just the DCRF. Um So uh the
DCRF may also have a different scope um of costs they're
eligible for in this rider. So I, I think that um
while it, it, you know, I would love for the deferral
option to be as attractive as possible. Um I think
that it's appropriate to, you know, allow the Commission
um to uh adopt a new rider, consistent statue. Okay.
And obviously, the statute does allow recovery through
the DCRF or the non-ERCOT TCRF. How do you interpret the
language requiring the Commission established that
the terms of the rider and the plan. If the utility
is not going to seek um, a rider outside the DCRF
or, or TCRF?
(item:1:George Hoyt with Entergy on determination of appropriate terms of riders) I'm sorry, are you you're asking why or how the Commission
would determine the appropriate terms of the rider
if the utility is not seeking one? Right. It would not
like it. The utility would have the choice under the
statute, whether to request a rider when it proposes
its plan. And if it requests a rider and the Commission
will then will then determine the appropriate terms
of the rider, right? So if the utility says I'm not
requesting a writer, then the Commission doesn't have
work to do on that front. Yeah. Yeah, I mean, that
was my interpretation as well. Which suggested, you
know, maybe if everyone was okay with not requesting
a separate rider, you know. The rule could specify
that it, you know, has to be in the DCRF/TCRF. Obviously
the statute doesn't limit it to that. But if you know
no one was actually interested in having a separate
rider that would definitely potentially make things
a lot easier on drafting rider language on the rule.
But you know if, if you know what I'm hearing is that
you, you want, you want the rule to establish
some stuff about uh an additional rider, resiliency
rider. So okay, great. That's helpful. Thank you.
Just a quick follow up. Good morning, everyone. Uh
I'm just gonna ask a question. Uh is it the utilities
view that the statute requires or at least contemplates
a low growth adjustment?
Brian Lloyd serving the public interest. Oh, wait.
(item:2:Brian Lloyd with Oncor on DCRF option for distribution invested capital) Um I again Brian Lloyd for Oncor. Um,
let's, let's kind of talk through that. I, I think
where you, where a utility uses the DCRF option for
distribution invested capital. There's already a low
growth adjustment for that, right? So you're gonna
kind of pick it up in that one. I think in the
case where on the invested capital piece and I'll,
I'll come back to, to another piece in a second. Where
a utility uses a rider um for Oncor. It's not
something we thought a lot about using. I think our
preference is to, is to just use the DCRF. But as
we thought about it, I think the way the formula works
in the DCRF is you're effectively picking up all of
the low growth there. And so if you have a separate
rider and you want to do low growth on that too, you
have to then start thinking about, well, how do I portion
low growth between these two riders because of the
way that formula works. So I think, I think my current
thought is if a utility does a rider. You don't need
to worry about low growth there. Because it's, the
all of this is limited to distribution invested capital.
And, and I guess the one caveat would be if a utility
doesn't have a DCRF, then maybe you pick up something
there. But assuming a utility is filing both DCRFs
and a resiliency rider. I think you've already got
all the low growth accounted for in the DCRFs. Um
I think then the second piece is on the deferral. It
is our view that, that section of the statute
uses the term costs, which is inclusive of both invested
capital as well as ONM. Then you get to the question
of, do you need some kind of low growth adjustment
for that? That one's a little bit harder for me to
think about. Um I'm not sure you need that because
you've got, let's say you use vegetation management
maybe as, as an example. When the utilities rates are
set, let's say we have $50 million of education management
in rates. The utility of course, is going to spend
above or below that every year. So it's a little bit
different than invested capital. I think what's true
with what the statute says as well. If you had $50
million of VM in your base rates. You can't cut that
to 45 spend 60 then get that whole delta. It would
only be the increment above that. Um I think if you
think of the other inflationary pressures that utilities
have particularly right now. Interest rates, labor
expenses, things like that. I think the intent of the
statute is, is to incentivize and motivate these types
of investments. Um again saying in a rate case that
$50 million was gonna buy x number of miles of, of
vegetation management. To, to it's just hard for me to
think of a how a low growth adjustment to that individual
component of the O and M cost of service really makes
any sense in this context. So um so I I to to
give you the shorter answer. I think, I think on invested
capital, I think we argue is, I think it's taken care
of in the DCRF piece on the deferral piece. And again
we can maybe get to, when does the deferral get recovered.
Does that have to wait to the rate case? Is there a
component of DCRF that starts to recover that, that
reg asset piece? I don't think we view that there's
a low growth piece. That's there. The one other analogy
I use is, is um kind of storm costs, right? When, when
a utility books storm costs to its deferred account
those costs just get booked. There's no, there's no
offset to that for some, some calculation as to what
the low growth looks like between your last rate case
and when your storm occurred. And things like that
It's kind of a fixed amount of dollars that then kind
of rolls in. Now you do get the benefit of low growth
right? Whenever you set the rate as you have low growth
your billing units will grow. So that rate will get
basically get bought down by those billing units.
So I think that's, I think our view is it all kind
of works without some kind of other explicit adjustment
there. That makes sense? Yeah I, I mean, I think uh huh
just speaking for myself. I mean, I think you identify
and have addressed some of the potential nuanced complexities
of trying to incorporate specific language in a rule.
Um I just looked at some of these things this morning
and I just looked a short while ago. I said language
in 36.210 the DCRF legislation regarding Load growth.
and the language, there is different from the language
in this Bill. And it, it, that's why I kind of framed
the question as is it, is it required? Or is does it
does the statute at least contemplate the uh a growth
adjustment? And I think, I think I heard you say the
answer is kind of depends. (item:2:Brian Lloyd with Oncor on DCRF statute) Well I mean again, I mean
one of the options for recovery then refers back to
the DCRF statute, right? So again, you kind of pick
it up there. And again, whether anybody at the capital
thought about this or not. Because we're talking about
just a potential different recovery mechanism for some
distribution costs. And, and we have no doubt that if
it's in DCRF, it can't be in some other rider right.
I think the statute is clear on that as well. Something
is in base rate. You can't kind of come and get it
over here. I, I think when you go look at even if
you do the right or how the low growth adjustment works
in DC R, I think you pick it all up there already
And, and again, maybe your one caveat is if the utility
is not using the DCRF and is getting some distribution
capital here. Do you think about maybe that's where
that adjustment shows up? But then again, as you as
a utility layers in these things, if they're using
both mechanisms, you gotta, you gotta think about double
counting of that adjustment. Uh Well, interesting cause
cause uh uh I was talking with someone else this morning
a bill. Um And uh we were talking about some of those
very things, just the potential risk. I'll call it
potential risk of some sort of double counting thing
that that could inadvertently happen. And we just were
trying to see, we're trying to think about whether
there may be some sort of specific rule language that
could make sure that that does not happen. (item:2:Brian Llyod with Oncor on low growth adjustment in multiple places) Yeah, I
mean, I think, I think it's the case that you can't
get the same thing in multiple places. I think it has
to also be the case. You can't make the same low growth
adjustment in multiple places as well. So I think that's
the general principle. Again, I wrap my brain in knots
around this when I first started thinking about how
these things might work together. But that
was kind of where, where our team kind of got on. We
think it's all on the capital piece. We think it's
all handled there on any kind of ONM pieces. In a, in
a deferred asset. We don't think that, we don't think
that's necessary. Thank you, Brian. You're welcome. I'm a
(inaudible)
And those last two speakers from Staff side were Bill
Abbott and Darryl. They, they just started here. So
they don't know about the convention of saying your
name when you finished speaking.
(item:2:John Ross Hubbard with TIEC on riders) John Ross Hubbard with TIEC. Um Darryl, to your question about whether
or not the rider should include low growth. That
we it's our position that it should. Um even though
it is part of DCRF. It, a rider should include uh
load growth adjustments. Uh George has a retort.
(item:2:George Hoyt with Entergy on load growth adjustment) Darryl as you pointed out um you know, the DCRF statute
expressly calls for load growth adjustment. The TCRF
does not and it doesn't have one. The GCRR does not
and it doesn't have one. Load growth adjustment is accounted
for when you you know, factor in current building determinants
and the rider. So it's going to take account as Oncor
suggested for low growth already. We don't need a second
adjustment for that in the rider.
I need to think on that more. I just wanna make sure
that it's uh that, that it's being accounted in some
capacity. Uh
Yeah.
I'm sure our rates, folks might have something to put
in the rule language. And comments will be considered on
that at that point too. Ok. So we're having a lot of
fun in um, paragraph five. Does anybody else, uh does
anyone else have any questions that are either on this
paragraph or the larger subsection that we're currently
nuzzled into that?
(item:2:David Smeltzer's question on eligible cost for different recovery mechanisms) Okay. Yeah. And I think one of our, one of our briefing
questions was what types of costs are gonna be eligible
to be in different recovery mechanisms. I don't know
if that's a discussion that people want have today
or not? Or rate thinks they understand what they need
for this sort of thing.
All right. We're good.
Yeah. Okay. See, I guess let's uh let's see what's next.
Let's scroll a little bit.
Approve, modifier or deny. I think that's interesting.
Um
the modification seems weird that we would modify it
not through settlement agreement, but maybe the commissioners
would order different things
anyway. Uh there's not discussion on that. I'm just
reflecting on how I could see it would put you guys
in a weird position if we were ordering weird modifications
to your plans. Um okay. Updated resiliency plans. Any
thoughts on this subsection?
Another perfect subsection. This is fantastic
Costs.
All right, welcome back. Thanks. (item:2:John Ross Hubbard with TIEC on calculation of incremental operations & maintenance costs) John Ross Hubbard, TIEC. Um I
was I had a question about the language in one, starting
with an electric utility may calculate the incremental
operations and maintenance costs. Is this referring
to in a rider or in what context? I just
wasn't sure of the purpose of this language.
Again, this was an industry draft. So I, I wanna to
pine on, yeah.
(item:2:Brian Lloyd with Oncor on costs booked to deferred asset) Uh Brian Llyod with Oncor. Again I, I think again, at least from
our perspective, the way we were thinking of it. As
as, as costs that would be booked to the deferred asset.
And, you know, again I use VM as the example. It sort
of called on specifically in the bill identifiable
in the cost of service study. The, the language here
we had sort of about kind of how you might calculate
that was sort of one way of doing that. Where, you know
as a utility that just got the pleasure of going through
a fully litigated rate case. Um That's a rarely available
kind of thing for us and was sort of an easy way
to do the end. There was sort of a there might need
to be another method where you've had some case, get
settled in the past there. But at least from our perspective
the idea was that this is, this is part of what is
eligible for the deferred, deferred asset there. So
it would take place in the rate case most likely. Um
So again, I think we'll get to that later. I think
ultimately, these costs all get reconciled in a rate
case. Again, whether the deferred asset um starts to
get recovered as part of a DCRF, including an OMN.
That, that's booked there. We think the statute contemplates
that and, and whether that, whether there's language
about how that formula DCRF formula works. Or if there's
a separate rider. Like we're doing a temporary gen
whether that's in here or a DCRF amendment, I think
we would probably kind of look at you all as to where
you, where you might prefer that that happening. Um
But I think there's no doubt that these costs ultimately
get reconciled at the end of the day. And so again
my example was, well, you had $50 million in your,
in your residency plan, you had cut it and then increased
it back a little bit. That would be fair game for people
to say, well, no, there was, there was adequate money
in your case. See, here's the line item and you didn't
spend up to that. Therefore, there's nothing incremental
there, but that would be fair. That that's of course
fair game if it had come in through the rider at some
point.
(item:2:John Ross Hubbard with TIEC on language concerns) Uh I guess we're just struggling with the language
a little bit because it seems like in a rate case,
this would be automatic. And so why does this language
need to exist?
What's automatic that it would account for the like
that? I would look at the ONM and it would
be reference the amounts and it would reconcile the
two.
(item:2:Brian Lloyd with Oncor on reference clarification) Well, so yeah so let's again. Let's, let's take maybe
Oncor as an example. We had a test year of 2021 for
a rate case. Again, I'm just picking a number. It says
it's $50 million in vegetation management. We file
our resiliency plan next year. We say, hey, upping
the vegetation management budget to $75 million really
handles resiliency in this particular area of our,
of our service territory Commission says absolutely
we agree with you. Then that incremental 25 starts
to get booked to the deferred asset. And again, whether
recovery starts in the DCRF or whether recovery waits
for the rate case in either event that gets reconciled
and looked at in the rate case, did you in fact spend
70 that incremental money on VM? That makes sense.
Yeah, that makes sense. Yeah, thank you.
And again, is the easy one to kind of think about.
There may be other ONM things that are a little
bit harder to suss out kind of what exactly that is.
And again, that I think that obligation is on us as
part of the resiliency plan to say. Okay, here's the
incremental spend from what we think was in the right
case. And again, that that would be fair game for folks
or again, later in the reconciliation, I, I think we
fully expect folks to kind of say we don't think you
calculate that right. And we would have that, that
discussion there.
(item:2:George Hoyt with Entergy on rider in regard to capital & ONM) Same topic. Um George Hoyt again for Entergy. Um I
think that the, the rider scope with regard to capital
and ONM ought to be the same as the deferral. I can't
see a reason why it wouldn't. Um But is with regard
to the ONM incremental ONM expense. I mean
I think this recognizes that you, you could begin a
deferral in between rate cases because your plans approved
So the Commission says go forth and do these measures
They have ONM associated with them and then you
are only recovering what was established in your rate
case. This is incremental to it. And so that's the
idea of a deferral is that you don't lose that expense
you preserve it for future recovery. So this is, um
I think part of this is designed to get at incremental
costs in between rate cases.
(item:2:Darryl Tietjen with PUC Staff on costs included in plan) David, can I hijack one more time. I'm just for the record this is Darryl Tietjen, for the record everybody.
PUC Staff for the last um, two weeks. Um And I apologize
that this is sort of in the utilities draft rule. Uh
Maybe I just need to read it more closely. I is it
do the utilities believe that at the time they filed
the plan that there is any sort of Commission discretion.
or to what degree is there, Commission discretion with
regard to the amount of the costs that are included
in the plan stated in another way is, is during the
Commission's consideration of the plan and all the
party's consideration of the plan, is that a time where
the, the cost amounts are contestable to any degree
Or is that, is this kind of okay, here's the plan. It's
$100 Commission approve it and we'll argue about the
amounts later.
To what degree is it contestable in the plan versus
the final true review in a comprehensive rate case
(item:2:Brian Lloyd with Oncor on general costs) Yeah I, I think I understand your question. Let me
let me, let me sort of try it this way. I, I
think our view is that the Commission is gonna want
to know as it approves a plan and components of a plan
What does everybody think that's gonna cost? So again
let's say vegetation management. Um as, as one example
us doing X number of more miles is gonna cost Y number
of dollars now again, and they ultimately cost a different
amount. But the Commission is saying, ok, yes, in concept
this number of miles or this number of amount of incremental
cost we think is a, is the correct thing to do as
part of your resiliency plan. We think the Commission
can change that. I mean, I think that goes back to
the prior discussion on, on, maybe that's where modify
comes in. You know, I really, I don't really want you
to spend another $100 million. Maybe I want you to
spend $75 million on this. Um, but again, the ultimate
then expense gets reconciled later is I don't think
we view and I think the statute is clear about this
that you're fixing in necessarily the dollar spent
You may, I mean, the utility may say I want to spend
X dollars and the Commission may approve that utility
may say I want to do vegetation management for X number
of more miles. I think when you think of the capital
piece, similarly, I'm gonna spend this amount of money
to change out wood poles, the composite poles or, or
something like that. I think the Commission is using
at that point, the cost numbers as an assessment of
what does this, does this feel like the right thing
to do for the dollars? And, and what, what the utility
has proposed or the Commission concludes is the benefit
from that again, between a plan being approved and
then the investment going into service and then the
rate case, the cost of things may change. And I think
the statute is clear that you're not, you're not sort
of locking people into their forecast at the time again
The utility still has the obligation to prove it was
it was prudently incurred and all that. Um But, but
I think that's, I think that's how you think about
where the costs come into this. (item:2:Darryl Tietjen on costs being overstated) And, and I guess Brian
my concern is just speaking for myself again, is that
to the extent that part of you say, you know what this
cost is way overstated or this estimated cost is way
overstated, it essentially becomes what so often happens
around here becomes essentially the equivalent of a
comprehensive rate case. So the companies file their
their plan TIEC, Staff, whomever said. You know what
this is, you know, this is the way overstate it. It
should be something less. Well, ok. Uh let's do a procedure
schedule all these parties, file testimony, staff files
testimony goes to hearing that's sort of my concern
or my question. How does that process work or is that
even contemplated as part of what the process is supposed
to be or what it will inevitably?
(item:2:Brian Lloyd with Oncor on structure of rider language) I mean let me, let me try, try this. I don't
think you're setting a rate as part of these plans
You may be approving a structure of a rider and the
rider language has some suggestions on how that thing
gets filed and updated for that process. I think, I
think what the Commission is approving is elements
of the plan. It is using potentially things like costs
as its assessment is, is this in the public interest
for me to approve or whatever languages there. But
you're not setting a rate per se out of this with the
recognition that later all of this gets reconciled
in, in, I think at least the way we're thinking about
it in the next comprehensive rate case, the way DCRF
and interim T cost gets, gets reconciled. Does that help?
(item:2:Liz Jones with Oncor on costs) So and, and I would add because sometimes more people
from Oncor are better. Liz Jones with Oncor. Um So for
instance, in a CCN proceeding, we talk about costs
and their estimates and they may deviate in the end
But the cost as the cost estimate helps the Commission
evaluate its options under that proceeding. And I would
envision something similar happening inside of a resiliency
plan case. So, so you're saying the the sort of a reasonable
comparison point are CNN is a CCN proceeding? I think
so. (item:2:Brian Lloyd with Oncor's follow-up to costs) Yeah. And I think in the evaluation of the plan
a utility that says, hey, me underground, this many
miles is going to cost X. I think parties would be
free to come in and say they are a low ball on
that, don't you? If you approve that this thing is
going to be way more expensive and, and again, that
can be that the Commission can consider what everybody
argues that evidence is in deciding whether to approve
the plan. But, but I don't think you're locking in
any of the costs in the same way as Liz said, you
don't lock those in, in a CCN.
(item:2:Sam Chang with CenterPoint Energy) Yeah, Darryl and just strategically, parties may choose
to challenge costs during the resiliency plan review
time just to preserve their ability to challenge it
come reconciliation time. But practically that might
happen.
(item:2:Brian Lloyd with Oncor on cost locking) I think. So, I think one, one additional point, I think. On
on the cost one and, and I think why we think it's
very important that you, you're not locking the costs
here is I, I think at least the way we view the
statute is once the Commission approves a plan absent
you getting a good cause exception, you're expected
they may be required to do the plan. And so for a
utility to say, look, we think it's going to cost if
it ends up costing two acts and the utility comes in
and says, I don't, we like a good cause exception to
maybe not do this now. And the Commission says too
bad, you got to do it. I don't think you can then
say, ha ha gotcha. So I think that's why we think ultimately
the, the ultimate rate proceeding and reconciliation
is a place you look at where those reasonable costs
And if, if again, a Commission thinks something is
I'm sorry, if the utility, think something is blown
out there is this good cause exception but absent that
we, we think the expectation of the Commission is going
to be, you go do everything we told you that we approved
you doing. So, Brian, you're trying to use the burden
is always on the utility argument. Well, I mean, what
I'm saying is that there is a difference here from
other things where the utility, where the Commission
is, in essence buying into this plan and telling a
utility. Yes, this is a good thing for you to go do
and we believe it's in the public interest for the
benefits that presumably the Commission is going to
find in approving these plans. And that that's different
than a lot of other things that's different than almost
everything else we do. Maybe with the exception of
even energy efficiency, I think there's some kind of
bandwidth to move money around here. But again, depending
on how these plans are presented and how the Commission
approves it, we think that's a buy in from both the
utility and the regulator that these are worthwhile
efforts to do and you gotta come ask to not do them
at that point.
Cool, thank you, Brian. (item:2:David Smeltzer with Commission Staff on question on rate cases) So this, this is maybe just
me not knowing a lot about how rate cases work and
asking you to teach me in public. So that's fine. Um
I, I get the idea that, you know, when we approve a
measure, you don't have complete cost certainty. So
on the tail end we're evaluating. Okay. But is the money
that you did spend prudent? Like, you know, you're
not over bidding, whatever. Uh when you talk about
the idea that and I think this makes sense that in
some cases, there might actually the plan might be
a dollar figure, like, ok, we just want to spend X
amount. And so then on the tail end prudency determination
uh you wouldn't be able to guarantee just like before
that X amount would, you know, the, the financial world
might change and so would, would the prudency determination
in the background be like? Well, did you do as much
vegetation management as you should have been able
to do with this much money? And if not, we're gonna
take some of it back like, or is that, is that something
that a rate case can handle if it's structured in that
way or you get? That makes sense? (item:2:Brian Lloyd with Oncor on how are constructed) Yeah, I mean I, I
I see the point there. I think um
I again, I mean, it gets, it gets the kind of how
the plans are constructed. I think we, we again where
the metric or the, the plan is again, miles of em or
or a general description of, of underground or, or
some of the other resiliency kind of things that looks
much more similar. I think if somebody does propose
a, we're gonna spend X dollars and then the question
is later is a, well, what, what did you get for the
X dollars? Um I mean, my gut is, there's, there's still
a prudency review there, right? I can't, I can't tell
you $75 million is gonna buy you 1000 miles of additional
vegetation management and then do two miles. I think
there's got to be kind of a sanity check, right. So
intellectual, I understand how you might do that analysis
but I have not worked enough for, I have not worked
rates cases. So I think is that sort of analysis achievable
in the rate case context. And I will tell you our view
is there um people have, have appeared to have more
than adequate time to address a wide range of issues
in rate cases. And I can't imagine this one adds much
more to the colonoscopy that comes in that proceeding.
So I'll take it.
(item:2:George Hoyt with Entergy on cost effective measures) Yeah, I would just add. I think, you know, the utility
having the burden approved to establish that the measures
are cost effective. Um That may be a challenge if I
say tell me $65 million is cost effective. Um The utilities
I think are gonna do more than that. Um So I'm not
too worried about that example. Um But where utility
is outlining specific components of a plan measures
this many poles in this places, this kind of stuff
those projects are not the decision to proceed with
that project is not subject to reconsideration once
it's approved. Um the, the way your prudence determination
at that point is how you implemented the project and
whether you, you know, you you executed it prudently
um, spent the costs prudently, that sort of thing.
(item:2:Brian Lloyd with Oncor on elevation of substation) Yeah, I'm just, maybe to help you think about it. I
mean, let's, let's take an elevation of a substation
example. Right. Commission approves. Yes, I want you
to elevate this substation in some urban area that's
critical low. That is subject to flooding. This is
great. I'm gonna go do that. They finished the project
and realize they've done it wrong, tear it down and
have to do it over again. I think there'd be no doubt
at that point. That's gonna get a prudency question
as to the total dollars or what of that? What did the
utility do that that caused that or a contractor do
And what's kind of the risk there? So I think that's
that's clearly a case where, where you've said this
thing, the cost of that thing is still kind of up for
fair game. Um Now if I, if I said I'm gonna elevate
that substation, it's gonna cost $50 million because
of inflation. It cost $60 million. The utilities got
approved. Well, why, why was that delta appropriate
Oh, okay. Well, here's the cost, invoices, here's the
materials cost, here's the labor cost. I think the
view is you just don't get a ha ha $10 million. You're
out. The utility has to kind of demonstrate that. But
there's no, there's no just um, it was, it was X plus
two and therefore you lose two, I think the statute
and, and I think the draft we've given you is kind
of meant meant to protect against that kind of that
kind of situation because again, we're gonna follow
these plans in year one. They may cover three years
you may not be doing some of these projects until year
four. And a lot of things can change that, that impacts
cost between that. (item:2:David Smeltzer on conditional elements) Whichever envision. And I think,
you know, I like what you're saying. Once, once the
plan is approved, you're sort of expected to do it
unless you come good cause exception. Would you, would
you ever imagine a plan including conditional elements
where you're sort of presetting up the conditions for
a good cause exception.
That's that question I don't need a off the cuff.
I think I'd want to think through and I don't know
that it needs to be in there. You know, people can
settle on a lot of stuff. (item:2:Brian Lloyd on modifications) Yeah, I mean I, I again.
I, I think modifies an expansive term. I think there's
probably modification in some ways, maybe goes beyond
what the commission can do, right? I mean, you guys
are noticing some other kind of problems to just the
Commission to kind of, you know, throw it out and say
well, here's our plan, we just kind of made up for
you. But I think conditional aspects of do this accept
in these circumstances. I mean, my gut is, there's
probably a way for the Commission to, to do that. If
it, if it sees the need to do that. But I think
I wanna think about that. Oh, and I was, I was not
just whether or not we would do that but because you
guys request that.
And I don't know that it would need to be written into
the rule. I'm just sort of thinking about stuff in
real time. Here's, here's maybe an example where, where
you could think of how and, and I'm not sure I would
call it conditional, but, um, let's say there's a cyber
project and it's, you know, we, at the time we filed
the plan, this is the particular technology we're gonna
use to address this particular cyber risk in that space
Of course, technology changes fast and it could be
a condition that I'm going to use this particular thing
unless I find something better, better or cheaper or
more efficient or address other problems. And then
again, you may have been on the back end and in the
prudency that, that utility has to demonstrate. Well
why did you pick that new, new thing that came out
over the thing that, that we had talked about three
years ago in your case. And so I could see, I could
see how we wouldn't like, the Commission wouldn't want
you guys to feel like, oh, we gotta use this worse
technology. So we don't have to go through the trouble
of coming and applying again. Or, you know, uh coming
in modifying. Yeah, we wouldn't want to lock you in.
So, I mean, there is the challenge with the way the
statute is written that to modify a plan, there's this
language that says it can't take effect until kind
of the end of your current plan. And so there again
I don't, I, I can't imagine that, that for any component
of, say our plan that's gonna address something like
cyber, we're gonna walk into a particular solution
again, just given the, the pace at which that technology
changes. But that as, as an example of maybe where
there'd be some conditionality. If people thought they
needed to get that specific in these kind of plans
may, maybe that's the way to think about it. But again
I think that that this is all stuff that I think is
on the utility to demonstrate within the plan and have
that discussion with the stakeholders and the Commission
during that. But I'll think I'll think more about that.
Um Are you done? We're done. (item:2:Rama Rastogi with Commission Staff on plan effectiveness) I have a follow up question
that what you said made me think about another issue
that I want to tee up for discussion about the resiliency
plan effectiveness. So, um I mean, there is, there
is a point that, you know, you're building to something
that event might not ever occur and there is an element
of cyber security expenses that, you know, would need
to be kind of, you want to look back, modify it and
that would lead to incremental expenses. So how would
you articulate your plans effectiveness in different
you know, the different methods that you use in some
cases? It might be not possible proof. (item:3:Brian Lloyd with Oncor on plan effectiveness) I mean I, I
think it's so I, I think the, the general concept I
think is difficult to do in, in the rule because depending
on what component of a resiliency plan you're talking
about, you may get different things. Um There may be
certain things that one of your metrics might be. Is
there an Ancillary safety and safety benefit? Right
And, and some of these things, it is, it's, it's hard
to prove the counterfactual of the avoidance of the
thing that you avoided, right? So I elevated the substation
there was some degree of flooding did I really need
to elevate that substation for that particular thing
I mean, that's going to be a very challenging thing
to kind of do. Again, I think on the front end, there's
this general concept of, are these the things that
make sense um on, on things like some of the faster
moving threats like cyber, I think similarly are at
the and and again, thinking about a three year plan
at the time, the Commission reviews the plan, it may
be, these are the current threats in the spaces are
rapidly changing. It may be well, somewhere in this
process that was no longer the threat that didn't mean
there's not a benefit to what we did from resiliency
because that threat could reemerge at some point. But
then here's this other threat that's happening. And
again, whether that's encompassed in the plan or being
in a subsequent plan. Um, you know, I think that that's
that's the challenge of some of this. I don't know
if that answered your question. Sort of, I'll take
sort of that so. (item:3:Rama Rastogi on cyber security) At least with the cyber security bid
and I'm kind of just thinking about it that because
the technology changes so often getting into contracts
that kind of build in or factor that aspect for long
term. So there is some visibility of certainty about
the costs that are going to be thrown at us rather
than kind of going back and modifying it and adding
the incremental cost part of it, at least like for
the cyber security piece. (item:3:Brian Lloyd with Oncor on cyber security) Yeah. Well, and again, we
have existing, of course, is not all new, we have existing
programs on this within ray cases. We talk at length
about what are the dollars associated with it and cyber
and things like that to the extent this is an increment
above that we would, I think do a similar explanation
on the front end and then again, have the reconciliation
on the back end as well. And then again, depending
on what other components of the plan are. If there's
other technology that you're adopting as part of a
resiliency and hardening and a variety of things, there
may be a cyber component to that, right? So I put switching
devices in remote things that let me reroute power to be
more resilient. I'm gonna want to make sure there's
a cyber component to protect those as well to the extent
that they're vulnerable to that.
I want to kind of just ask uh if anyone has any
other comments on the resiliency plan effectiveness
That's a question that came from one of our Staff members.
Okay.
(item:3:Jessica Seuss with AEP Energy on resiliency plan effectiveness) Um I'm answering under the assumption, assumption that
this is the question that was posed in the kind of
pre questions in the agenda. So okay I thought of.
Not, not exactly, but this just came up from one of
the Staff members. Um Yeah, as far as effectiveness
and metrics around that, you know, I think one of the
difficulties around this is resiliency is typically
measured as far as effectiveness, more on a terms of
decades rather than years. Um And I think having that
look back after these plans have been in place for
a while, certainly makes sense and people will be able
to get together that information on a shorter term
basis as far as effectiveness. I think we'd be looking
much more towards how effective have the utilities
been in implementing the plans that they've presented
Uh And for these things that they presented, can they
say what benefit they are expected to provide? So if
you're doing something like pole replacements for a
different type of pull you can talk about, we've done
X many replacements and now X percent of our system
is when loaded to this amount. And I think that that's
how we would be measuring effectiveness on a short
term basis.
Anyone else on this batch of topics I guess?
(item:2:Bill Abbott with Commission Staff on distribution costs) I did have a question or two. This is Bill again. Um
I did have a question or two um from both the non-ERCOT and, and
um I guess the other utilities. Um So looking at subsection
K of the statute, um first of all, I want, is it
clear that it's only the distribution costs that can
be booked as a direct asset? Is that in doubt or in
dispute
Bill, I think the subsection does say distribution
related costs. Um and kind of in light of that, I guess
and it um you know, uh allows that uh the use of
uh you know, the DCRF and the non-ERCOT TCRF. So I
guess part of my, one of my questions is, how do, so
I assume that, that you'll interpret that as allowing
you know, ONM cost booked the asset as recoverable
under the DCRF. Is that correct?
(item:2:Brian Lloyd with Oncor on distribution costs) I think the short answer is yes. Um and, and again
I think there's um
the kind of walk you through, I think the way we're
thinking of it, let's say a resiliency investment comes
let me do the capital piece first, a resiliency investment
comes into service January 1. We start booking the
depreciation and return. It comes into a DCRS,
DCRF. That's effective say May 1. At that point, we
stop any booking of that because the DCRF now keeps
that. So now we've got a chunk of dollars here in deferred
asset. We then have ONM components of the spend
that are incremental to what's in rates today as those
get incurred, get booked to the right asset. I think
our view is, is the efficient thing to do is in the
rate, sorry, in the DCRF, then you start recovering
the asset as well. So this does not build up over time
and over time and over time. Um And, and you sort of
have this rolling recovery of this asset as you're
incurring the cost you'll always be behind. Of course
there's still gonna be some lag there. But again, we
think we think the intent of the statute was to, to
foster these investments and, and kind of do that.
(item:2:Bill Abbott follow-up comments on distribution costs) Yeah. Yeah. And I guess the, the more general question
is to what degree did the current limitations in the
DCRF and non-ERCOT TCRF constrain? Because like typically
you wouldn't allow, I mean, oh, and costs that are
not normally um uh both, you know. Uh So what's the
word capitalized? Yes. Um uh capitalized wouldn't be
include in a DCRF. But I guess your view is that
this, the statute allows that and similarly, normally
distribution costs wouldn't be include in a non-ERCOT
TCRF. Um so, so I have the pleasure of not having
to think about non-ERCOT TCRFs. Very fortunate. (item:3:Brian Lloyd with Oncor on deferred ONM) I, I,
I'll, I'll say yes. I mean, I think, I think the analogy
you can think of and again, the Commissions kind of
split it a little bit differently, but the, the temporary
generation piece has a deferred ONM piece to it, of that
asset that again the Commission has decided to split
into a different thing. But you, you just, you can
kind of do it in that proceeding. I think what was
contemplated. I think the same thing is true here that
the resiliency statute talks about the costs that are
allowed to be recovered. And then the DCRF is one
of the mechanisms to do that. And again, our, I think
hopefully nobody here understands the Staff challenges
of, of labor as much as I do. Our view is to
try to make us efficient and utilize the DCRF for
that. And I think, I think a little whether you do
it as a a on the DC RF, whether you do it
as a separate component, sort of a separate charge
that gets done in the DCRF proceeding, I think is
a little bit immaterial to the, to the idea that you
start the recovery there. Again, it all gets reconciled
in, in your next base rate case anyway. Yeah. Okay. Yeah
Yeah. So, yeah, that's helpful. I get it not clear
to me how much to what degree this override the existing
restrictions and the rules. But, you know, I'm sure
I'm sure the attorneys and other parties will have
a lot of opinions on that. So, thanks.
(item:2:Rama Rastogi with question concerning costs) While we are all here, I did have a question about
cost and it's, it's really just a curiosity question
at this stage for the resiliency plans or you know
the
the plan that you, that you make, are you able to kind
of monetize that cost in some way? Like do your insurance
costs go down or anything else that it has a positive
impact on in terms of reducing your costs because you
are now planning for taking care of risk. So there's
a level of risk that goes down. Are you able to kind
of monetize it somewhere
(item:2:Sean Meredith with Entergy in response costs question) Sean Meredith from Entergy. Um So yeah, we're talking about
the cost, there's a couple of aspects there. So I would
I would say that the first one is we're looking at
the impact of, of how that implementation of those
projects is impacting the restoration costs. So that's
that's piece one. So it's
in those high vulnerable or high consequence areas
It's how are we reducing that impact to what it's going
to cost to rest, to restore and ultimately will impact
our customers and communities so that there's a piece
to that there's also a piece that when you start looking
at the, the duration and the customer and it's interrupted
those types of things. It's also looking at what's
the societal impact with that? That's an important
aspect of it from whether it's a large industrial or
commercial residential, there's that impact also of
costs that we need to really understand and show how
those projects and whatever it is from the resilience
how you're doing it, how that is also having a positive
impact on, on that part of the equation so. (item:2:Rama Rastogi with question on cost risk) I, I guess
um I wanna probably clarify. I'm not talking about
the economic impact or the society benefit. That is
that is something that is going to happen and that
is the intent of the plan. But does it kind of impact
your books in any way that your costs come down because
your risk at some level is also kind of getting addressed
with these plans,
(item:2:Eric Easton with CenterPoint Energy on cost risks) Eric Easton, CenterPoint. So, so I think one of the things
that we anticipate is that as we make those investments
in resiliency, we have some avo avoided cost from the
damages that would have happened to the assets if we
didn't make those investments. So if you think about
a flood scenario, if we were to go ahead and elevate
that substation prior to it flooding, then the cost
to rebuild it will be different than the investment
to actually do the mitigation. There's a couple of
reasons for that one is that we would incorporate it
into the design. And then two, once we've had a disaster
type of event, we're typically doing things on an expedited
time frame. And so once we start to have to expedite
that project, the costs go up incrementally. So if
we're able to do that on a more uh planned basis as
opposed to an expedited basis, then there's a cost
savings not only to the utility but to the customer
as well.
More on this?
All right,
we've been sort of addressing cost resiliency, cost
plan, review and reconciliation as we've gone. But
as we formally get to Subsection G. Is there anyone who
wants to opine on this topic further?
Is there anyone who would like to opine on any topic
uh, related to this discussion further as we reach
the bottom of the, of the page here? Have we done it,
have we solved all the problems?
(item:3:Cyrus Reed with Sierra Club on SB415) Cyrus Reed, Lone Star Chapter Sierra Club. The, the Bill I
mentioned earlier was SB415 from the 21 Session. Which
includes the potential for contracts. So just making
that clear, I don't know if any utility would want
to use it for resiliency, but to the extent they wanted
to, that language does exist.
And I think that's being taken up with the, it's being
bundled in with the mobile general making. We are gonna
try and do a double feature today. But uh, of this
and that. But Maria is in the Northwest and so that
critical staffing failure. Um okay so I think uh ,uh
yeah, me too. (item:3:David Smeltzer on reporting mechanisms) Uh So I think that we, we've been sort
of addressed it tangentially a little bit, but Rama
reminded me that one of our post questions is where
um you know, we're perpetually thinking about like
reporting mechanisms at the tail end. And I think that
it's been addressed to some extent today, but since
it was a posed question, if there's anyone else that
wants to talk about reporting mechanisms on the effectiveness
of the plans and whether or not that's a good idea
and uh what we would use that for, um I guess we'll
create a little bit of space for that now, before
we wrap up.
In some of these discussions we've had behind closed
doors, but, you know, Commissioners and others are
watching now. So it's the, it's the time. (item:3:Sean Meredith with Entergy on reporting mechanisms) Sean Meredith
from Entergy. Um I think it's important to report on the, the
effectiveness of how we've implemented the plan. So
as we said earlier, um we committed to putting 100
distribution poles in the ground of this wind loading
at this cost. We've executed that because we've already
the burden of proof party met for this was a good plan
to go execute. It's on us to prudently execute that
now. So I think that's 100% especially in the short
term when we're talking resilience because it is a
broader topic. Um There was something that was said
earlier that I just, I also wanted to address. So looking
at Sadie safety to measure the effectiveness of this
I would, I would caution against for a couple, a couple
of reasons. Um So is obviously we're looking at duration
and when you, we're talking duration, there are so
many variables in, in these major events. So we we'll
just take a Hurricane Harvey as an example. Um when
you're talking duration, there is areas you can't get
to potentially in a storm like that for days, which
has a drastic impact on the Sadie. So the Sadie one excludes
major events to begin with. So if you were to back
up and take pure Sadie, that's not excluding the major
events, even that's drastically impacted by the type
of event, or you could have a very fast moving storm
where you could get there immediately. So it's very
hard to compare apples to apples and normalize that
similar with frequency. So safety, you could have years
where you have maybe one event. So your frequency starts
to go down. But on the flip side of that, you could
have a year like some people have experienced where
you have 6, 7, 8, 10 events. So it's a, it's a very it's
hard to normalize that for these major events. So I
would really, those are very strong reliability metrics
But from a resilience perspective, I don't, I don't
think we'll effectively measure the effectiveness of
your resilience investment.
(item:3: Sam Chang with CenterPoint Energy on reporting mechanisms) We'd agree with that. We don't think Sadie safety
is a good proxy on resiliency as it relates to reporting
We think it's a good idea. It gives you guys visibility
as far as what we've done, what we plan to do, how
much we've incurred. Um We did discuss in previous
meetings kind of Florida's regime. We think that's
a little too robust and it's too much as far as information
Um But something along the lines of an annual report
um similar to how we file monthly construction reports
uh we think that's a good format to give you guys visibility.
And then there and then to responding to questions
that other people are pinging. (item:3:David Smeltzer's question on metrics) Um I think you guys
are it, it sounds like you guys would want to have
individual metrics for based on the different types
of measures that would be just as part of the plan
or are there external known metrics that uh are expected
to be utilized at that we know of at this point?
So, so at this point, so if not Sadie safety, is
there another answer to that question? (item:3:Sean Meredith with Entergy on metrics) So at this point
there's not a uh an industry standard how to measure
resilience because as we've already addressed, there's
a lot of different things that go into resiliency.
So that's we do not have a proposal on how it would
be on how we're implementing the plan and how we've
shown that, that's gonna provide that resilient benefit
just our effectiveness to implement that. (item:3:Rama Rastogi on metrics) I guess that
that's a fair point. Uh But can we do something, for
example, if you replace the, the wood poles with concrete
and there is an existing uh example of something like
this in Florida happening and they kind of ahead of
us in a few years by how they've done it and there
are, you know, results or some data available about
if, if it's helped at all. So is there a is that
fair to ask you all to kind of provide any comparatives
if not within the state? But you know, there is data
to hold on to the analysis to compare because it is
a new territory for all of us. I I think it would
be fair to say if you've completed these projects,
can we receive data on the back end of the after the
event to see how that, how those assets perform? So
for instance, if we put concrete poles in the ground
or those concrete poles all still standing, that doesn't
mean something is not wrapped in the wire, right? Because
there's some things that come out of our control. So
you know, but the key is that the poles are in the
air that significantly reduces the work we need to
go after the event. And that's the key is to get back
faster. So I think it's very fair to say, hey, you've
completed. All these projects are the, are the assets
doing what they need to do and have us say yes. And
here's our data to support that. Um But as far as a
metric that would identify and really point to, to
go, you know, to drive that home, I don't, I think
that would, is a, is a significant challenge just because
of the variability at this point. I know this is a
this is in the, the industry knows that we are, we
are, oh, we got a lot of smart people previously trying
to understand how to put a metric around this. And
I'll say there's a lot of smart folks that are struggling
with this right now. So much smarter than me is up
here trying to explain it. (item:3:Liz Jones with Oncor on metrics) So I would ask Liz Jones
for Oncor. I would ask that you all focus on including
as an element of the plan proposal, the metrics that
the utility intends to use rather than in the rule
trying to establish sort of generalized performance
metrics. I think the plan, I think so, Oncor has a
wide variety of service area. You know, we got Sandy
we got Woody, we got urban, we got rural depending
on what kind of plan and what area of our system we
were addressing. You might find uh that we would recommend
very different kinds of metrics and much like our earlier
discussion on areas of lower. I can't remember the
term that was used lower performance. Thank you. Um
I think this is something that is better worked through
in a case than in the rule.
I'm just happy to hear you identified woody as a resiliency
risk. He'll be thrilled to hear that.
Sometimes it's capitalized sometimes.
All right. So I guess we're, we're reaching the end
of our time. Does anyone else have any other, um,
anything else I want to talk about?
All right. Well, I guess, I guess our final piece of
business, which is the final piece of business in the
DER world. Um is, you know, is it Staffs ongoing efforts
to make these things uh more casual and fun and
DER workshops. We, we always uh uh awarded
a, a jacket of the a jacket of the workshop for the
person who was wearing the most interesting stuff.
And I think people started responding to that this
group wasn't broken into that, but I think Theresa
is the winner today.
Our first, our first Staff winner of the, of the Jacket
contest with a lovely blue number. Good job.
So, so next time you're all on notice. Uh you know
I let's see, competition. (item:3:David Smeltzer's final information for workshop attendees) Thanks everybody for coming
to the resiliency workshop. We anticipate the proposal
for publication being on the, you know, the mid September
um the mid September open meeting. And I would say
that, you know, our internal review process is usually
we have to get drafts to the hallway two weeks in advance
And so if anyone has any last minute ideas, getting
them to us this month, uh would be the optimal time
for staff's workload. So reach out, you know how to
get us. Uh and hopefully we'll come up with a good
product. (item:3:David Smeltzer closes workshop) This was really helpful today. Thank you.
Thank you very much.
(inaudible)