WEBVTT 00:00:03.470 --> 00:00:03.660 (silence) 00:00:06.980 --> 00:00:07.009 (silence) 00:00:12.989 --> 00:00:15.448 I know this is uh, an IOU heavy group. But you all don't 00:00:15.460 --> 00:00:17.969 have to sit in your open meeting, your open meeting 00:00:17.978 --> 00:00:20.620 location. If you, if you don't want to. Uh, hey everybody. 00:00:20.629 --> 00:00:22.769 (item:0.1:Welcome & Introductions- David Smeltzer, PUC Director Rules & Projects) Uh, my name is David Smeltzer. I'm the Director of Rules 00:00:22.780 --> 00:00:25.399 and Projects for here at the Public Utility Commission. 00:00:25.609 --> 00:00:29.000 We are gathered today for a Resiliency Workshop. Um 00:00:29.010 --> 00:00:33.889 joining me at the dais is uh, Chris from Infrastructure, 00:00:33.899 --> 00:00:38.579 Ramya from Markets and Rama from my shop here in Rules 00:00:38.590 --> 00:00:41.668 and Projects. And Bill Abbott and Terese, and some other 00:00:41.679 --> 00:00:43.889 PUC luminaries are in the back, should we need them. 00:00:44.770 --> 00:00:49.450 (item:0.2:David Smeltzer lays out Workshop Objectives/Order of Events) Um the order of events today, we have a, a draft. That 00:00:49.459 --> 00:00:52.848 was um you know, Staff's very busy. We've got a lot 00:00:52.859 --> 00:00:56.348 to implement. So uh the, the ERCOT IOUs and others 00:00:56.359 --> 00:01:01.459 provided a base draft, um just for purposes of commentary. 00:01:01.469 --> 00:01:03.618 It doesn't reflect the positions of any individual 00:01:03.630 --> 00:01:06.308 company or Commission Staff. It's just for discussion 00:01:06.319 --> 00:01:09.760 purposes today. Um for order of events, we'll probably 00:01:09.769 --> 00:01:12.528 just start at the top and work down. Uh for those of 00:01:12.540 --> 00:01:16.150 you that have been in any of our recent DER Workshops. 00:01:16.159 --> 00:01:20.209 This should be sort of a familiar uh, proceeding. But 00:01:20.219 --> 00:01:23.459 basically, uh if you want to speak on any topic or 00:01:23.469 --> 00:01:25.609 provide commentary, you don't need to raise your hand 00:01:25.620 --> 00:01:28.569 or whatever. Just come up to one of these front mics 00:01:28.579 --> 00:01:31.329 and we'll sort of call you in as best as we can 00:01:31.338 --> 00:01:34.418 the order that people came up. Um and I would also 00:01:34.430 --> 00:01:37.558 say that in the DER Workshops, we sort of developed 00:01:37.569 --> 00:01:39.870 an informal protocol of when we're going down the line. 00:01:41.159 --> 00:01:43.388 You know if in between speakers, if you're wanting 00:01:43.400 --> 00:01:45.969 to speak on the current topic. You know, you could 00:01:45.980 --> 00:01:47.519 hold up a 1. If you want to speak on and the 00:01:47.528 --> 00:01:50.180 2nd one, hold up a 2. Then we'll sort of know, like 00:01:50.189 --> 00:01:51.629 if you're waiting to speak on something else too. So 00:01:51.638 --> 00:01:54.138 we'll know who to call on next. And then there's the 00:01:54.150 --> 00:01:56.819 Ned Bonskowski protocol. Which is, if you just want to 00:01:56.829 --> 00:01:58.569 agree without slowing things down, you can just hold 00:01:58.579 --> 00:02:03.540 up a 3. Uh one other uh new protocol for this week. Is I 00:02:03.549 --> 00:02:06.159 think we do need some audience participation. So we're 00:02:06.168 --> 00:02:09.000 gonna do one test run. I'm gonna say hello and everyone's 00:02:09.008 --> 00:02:12.490 gonna repeat after me. Hello. That was the test run. Here's 00:02:12.500 --> 00:02:14.659 the important one. Happy Birthday, Rama. 00:02:18.419 --> 00:02:18.860 Happy Birthday, Rama. 00:02:22.729 --> 00:02:25.139 Well we, we got two hours and a lot to cover. So 00:02:25.149 --> 00:02:27.520 that is all I will, to will torture her uh on that. 00:02:27.800 --> 00:02:32.139 But um I guess we will start at the top, uh unless 00:02:32.149 --> 00:02:33.750 anyone has opening remarks. 00:02:39.899 --> 00:02:41.508 All right. So I don't know if, uh 00:02:43.240 --> 00:02:45.929 generally speaking, I mean. The task today is we have 00:02:46.439 --> 00:02:49.058 180 day implementation deadline for this rule. 00:02:49.069 --> 00:02:51.250 Which means we've got to get it on September 15th 00:02:51.439 --> 00:02:53.860 Open Meeting in PFP form. So we've got not a lot of 00:02:53.868 --> 00:02:56.659 time to do it. So if at any point you're thinking like 00:02:56.909 --> 00:02:59.270 maybe should I come up, maybe should I not now? Now 00:02:59.278 --> 00:03:00.719 is the best time to let us know what we need to 00:03:00.729 --> 00:03:04.758 be thinking about as we finish this draft. So um we'll 00:03:04.770 --> 00:03:07.770 weave in the discussion uh questions as we go. But I guess 00:03:08.050 --> 00:03:10.399 does anyone have anything to say about the purpose 00:03:10.409 --> 00:03:11.649 in applicability language? 00:03:17.308 --> 00:03:19.990 Okay. This is good. If, if this draft is just perfect 00:03:20.000 --> 00:03:23.129 that's gonna be easy for everybody. Um okay. So yeah 00:03:23.139 --> 00:03:27.449 and then there's the standard applicability. And, and 00:03:27.460 --> 00:03:29.330 I guess if, as we're moving on to the definitions, 00:03:29.338 --> 00:03:30.849 there are a lot of definitions here. So if you think 00:03:30.860 --> 00:03:33.778 you're gonna wanna discuss any of the provided definitions. 00:03:33.788 --> 00:03:36.338 Or whether or not you think the definitions are needed 00:03:37.689 --> 00:03:38.500 feel free. 00:03:41.490 --> 00:03:42.699 All right. 00:03:52.538 --> 00:03:54.629 And I'll go ahead and prompt, I'll go ahead and prompt. 00:03:55.149 --> 00:03:59.308 (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 00:03:59.319 --> 00:04:04.250 is like um the definitions that are here. Um is it 00:04:05.490 --> 00:04:09.808 should the rule be defining these definitions? Um or 00:04:09.819 --> 00:04:13.710 should we let the people who filed the plan define 00:04:13.719 --> 00:04:15.800 what these mean to them? 00:04:26.629 --> 00:04:28.699 Suspicious you guys, it's very suspicious. 00:04:36.769 --> 00:04:38.480 And I know you've been waiting for this forever. Um 00:04:38.488 --> 00:04:41.858 (item:1:Brian Lloyd with Oncor on rulemaking categories) Brian Lloyd with Oncor. I mean I, I think that the general sense 00:04:41.869 --> 00:04:45.269 is, is we thought it was helpful as the Commission considered 00:04:45.278 --> 00:04:48.600 this rulemaking. To have some idea of the types of 00:04:48.608 --> 00:04:51.488 things that, that are in these categories. You'll see 00:04:51.500 --> 00:04:55.040 all of these kind of have it included, but not limited 00:04:55.048 --> 00:04:58.829 to. So in recognition that there's, there's a tight 00:04:58.838 --> 00:05:01.939 time period on the rulemaking. There's a tight time 00:05:01.949 --> 00:05:04.108 period on the proceedings of six months as well. We 00:05:04.119 --> 00:05:05.829 thought it's somewhat helpful to say look, this is 00:05:06.019 --> 00:05:08.470 these are kind of some examples of the types of things 00:05:08.480 --> 00:05:10.439 that, that many of the utilities I think are starting 00:05:10.449 --> 00:05:13.600 to contemplate as part of these, these filings. Recognizing 00:05:13.608 --> 00:05:15.889 for every the other challenge being, every utility 00:05:15.899 --> 00:05:17.970 is gonna have kind of a different set of things. Even 00:05:17.980 --> 00:05:19.829 within a category, there may be a different set of 00:05:19.838 --> 00:05:22.108 things. So again, we thought it was helpful to flesh 00:05:22.119 --> 00:05:24.819 out a little bit of detail there. But recognize that 00:05:24.829 --> 00:05:26.738 that there may be other things that kind of come in. 00:05:26.750 --> 00:05:29.350 As well as come in over time for some of these technology 00:05:29.358 --> 00:05:30.738 advances and things like that. 00:05:37.949 --> 00:05:43.009 (item:1:Jessica Seuss with AEP Texas on definitions) Jessica Seuss with AEP Texas. Um I think we kind of 00:05:43.019 --> 00:05:46.439 echo Brian sentiments. I don't think having these in 00:05:46.449 --> 00:05:49.439 the definitions or having these definitions is strictly 00:05:49.449 --> 00:05:53.319 necessary. It might be slightly better to let these 00:05:53.329 --> 00:05:57.790 be defined by the utilities. Uh but this guidance is 00:05:57.798 --> 00:06:01.389 helpful and having something like this in the preamble 00:06:01.480 --> 00:06:05.129 um may be the appropriate place for that. Okay. 00:06:08.559 --> 00:06:11.689 (item:1:David Smeltzer on ) And so the, so the general sentiment seems to be, we 00:06:11.699 --> 00:06:15.009 need you know the, the applicants need flexibility 00:06:15.178 --> 00:06:18.358 uh to deal with the different topping. Uh you know 00:06:18.369 --> 00:06:21.238 but uh you know topographies of their system etcetera. 00:06:21.459 --> 00:06:24.660 But the guidance is helpful so that, you know, ALJs 00:06:24.670 --> 00:06:26.858 etcetera. People that aren't experts in this stuff. 00:06:27.040 --> 00:06:29.509 Have a general idea of what we're talking about. Is 00:06:29.519 --> 00:06:33.220 that uh, uh does anyone disagree with that being sort 00:06:33.230 --> 00:06:36.100 of the posture of where the draft should be on things 00:06:36.108 --> 00:06:36.699 like this? 00:06:39.959 --> 00:06:43.928 All right, this is going very smoothly. (item:1:Rama Rastogi, Commission Staff Rules & Projects with question on definition of resiliency) I did wanna 00:06:43.939 --> 00:06:47.088 ask uh or no uh you know, for you all to know 00:06:47.100 --> 00:06:49.778 that there is a definition of resiliency also in there. 00:06:49.790 --> 00:06:53.559 So is, should we take it that there is general consensus 00:06:53.569 --> 00:06:57.920 on what the, the definition of resiliency is here or 00:06:58.798 --> 00:06:59.928 are there thoughts? 00:07:05.189 --> 00:07:08.119 (item:1:David Smeltzer on defining resiliency) And to add to that? I know that defining resiliency 00:07:08.129 --> 00:07:11.480 generally speaking, is a, a national effort that is 00:07:11.910 --> 00:07:14.720 you know, has a lot of divergent thoughts on it. So 00:07:14.829 --> 00:07:17.259 there was some level of concern on staff's part about 00:07:18.059 --> 00:07:20.069 whether or not we wanted to have a definition of that 00:07:20.079 --> 00:07:23.059 anywhere. But I understand this would be contextual 00:07:23.838 --> 00:07:27.028 (item:1:Sam Chang with CenterPoint Energy on ) Yeah, Sam Chang with on, with CenterPoint Energy. Um 00:07:27.040 --> 00:07:30.230 we do believe having the definition of resilience or 00:07:30.238 --> 00:07:33.559 resiliency is helpful. And again, this is something 00:07:33.569 --> 00:07:37.009 that 8 utilities agree to from a language perspective. 00:07:37.019 --> 00:07:39.509 And if you look at the definition, it's very event 00:07:39.519 --> 00:07:44.678 based versus um approaches taken by NARUC and FERC. That 00:07:44.689 --> 00:07:48.629 are more concept based. And so we do think it's helpful 00:07:48.639 --> 00:07:49.869 to have that definition. 00:07:51.738 --> 00:07:56.329 (item:1:Ramya Ramaswamy with question on resiliency) So I have a question on that. Um so I, I can 00:07:56.338 --> 00:07:59.858 see with the event and especially if it is an event 00:07:59.869 --> 00:08:00.689 that is 00:08:02.420 --> 00:08:08.309 more um a large unique event. More than, you know, 00:08:08.319 --> 00:08:11.019 something that happens. Like Summer comes every year 00:08:11.028 --> 00:08:15.199 so, uh with that in mind. Um one of the things that 00:08:15.209 --> 00:08:18.470 I've been struggling with is also thinking of resiliency. 00:08:18.480 --> 00:08:24.309 More as a system based rather than infrastructure or 00:08:24.319 --> 00:08:29.889 specific to smaller ones. Because a lot of the individual 00:08:29.899 --> 00:08:34.168 components or individual, um the way we think of it. 00:08:34.178 --> 00:08:38.048 Can be also fall, fall into the reliability bucket. 00:08:38.178 --> 00:08:41.389 Compared to like resilience, which can be overarching 00:08:41.399 --> 00:08:45.340 of the system. And try and you know, going with the 00:08:45.349 --> 00:08:50.538 definition of um ability to prepare, adapt, respond 00:08:50.548 --> 00:08:57.048 and recover for the system as a whole. For unique or 00:08:57.058 --> 00:09:00.820 you know, larger events that occur not very frequently. 00:09:01.349 --> 00:09:03.729 (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 00:09:03.739 --> 00:09:07.330 distinction between resiliency and reliability. In 00:09:07.340 --> 00:09:11.048 our view, we view resiliency as how hard of a punch 00:09:11.058 --> 00:09:14.489 can you take? As far as high impact, low frequency events 00:09:14.500 --> 00:09:18.000 and how fast can you recover from that punch. Whereas 00:09:18.009 --> 00:09:21.408 reliability is more of a can you provide service on 00:09:21.418 --> 00:09:22.330 a blue sky day? 00:09:25.320 --> 00:09:29.538 (item:1:Micalah Spenrath with TAEBA on resiliency) Hi uh Micalah with TAEBA, just to kind of chime in. So 00:09:29.548 --> 00:09:32.428 I think TAEBA is in favor of a holistic understanding 00:09:32.440 --> 00:09:35.590 of resiliency and including like long term sustainability 00:09:35.599 --> 00:09:39.139 of the system. I think event based definitions are 00:09:39.149 --> 00:09:42.719 fine right now, but we might also want to consider 00:09:42.729 --> 00:09:45.879 just like growing demand and just encompassing stress 00:09:45.889 --> 00:09:49.750 on the system. It's not exactly an event. Um like you 00:09:49.759 --> 00:09:53.259 said, Summer occurs every year and demand spikes um 00:09:53.269 --> 00:09:57.139 which stresses the system. So resiliency can also be 00:09:57.149 --> 00:10:00.570 the ability to withstand changes in that demand and 00:10:00.580 --> 00:10:04.200 of course, come back from it. So I think, I think we 00:10:04.210 --> 00:10:06.918 don't have any language suggestions just yet on this 00:10:07.250 --> 00:10:09.969 and we don't have to move away from event based language 00:10:09.979 --> 00:10:13.168 but stress in general might also be captured under 00:10:13.178 --> 00:10:19.849 this. (item:1:Ramya Ramaswamy on reliability of the system) Um so, so this is something again I'm struggling 00:10:19.859 --> 00:10:22.090 with, especially, you know, because we are also trying 00:10:22.099 --> 00:10:25.989 to think of what is an emergency. And, you know, especially 00:10:26.000 --> 00:10:29.739 here in Texas with Summer being one of in the past 00:10:29.750 --> 00:10:33.389 has been our peak Load in our system and stress on 00:10:33.399 --> 00:10:38.090 the system. I agree, but that also becomes more reliability 00:10:38.099 --> 00:10:41.700 because that is what we are designing our system for 00:10:41.710 --> 00:10:45.190 for the everyday. Yes, we've had 40 days this Summer 00:10:45.200 --> 00:10:50.259 of peak, 100 plus degree days in Austin. But that is 00:10:50.269 --> 00:10:53.250 what we have to meet as a system and it's not a 00:10:53.259 --> 00:10:58.149 unique long term event, right? So that is what the 00:10:58.158 --> 00:11:02.250 between the reliable, reliable system and the resilient 00:11:02.349 --> 00:11:05.989 that we are building for um or planning for, you 00:11:06.000 --> 00:11:08.840 know, as the utility has to plan for, right. So that's 00:11:08.849 --> 00:11:11.808 that, that's what I was trying to touch upon. So, um 00:11:11.979 --> 00:11:14.269 I hope that clarifies. Yeah, thank you. 00:11:26.960 --> 00:11:31.859 (item:1:Cyrus Reed with Sierra Club on resiliency plan) Cyrus Reed, Sierra Club. Um to build on the uh previous 00:11:31.869 --> 00:11:37.408 commenters comments. Um I don't have any issue with 00:11:37.418 --> 00:11:40.830 these definitions, but you might want to make them 00:11:40.840 --> 00:11:43.700 a little wider to look at those other stresses. And 00:11:43.710 --> 00:11:47.519 as an example, the definition of resiliency plan very 00:11:47.529 --> 00:11:52.879 much follows HB2555, if I've got the number right. 00:11:52.889 --> 00:11:57.658 And list everything that was listed in that Legislation 00:11:57.668 --> 00:12:01.349 which is fine. But you might not want to limit it to 00:12:01.359 --> 00:12:05.500 those things. And I say that because um there are concepts 00:12:05.509 --> 00:12:10.840 like non wires alternative. There's the 2021 SB, can't 00:12:10.849 --> 00:12:13.908 remember the number, storage one which allows storage 00:12:13.918 --> 00:12:18.879 as a service. Those for, for help in the distribution 00:12:18.889 --> 00:12:24.090 grid. So there may be other things that a utility not 00:12:24.099 --> 00:12:26.928 required but might want to do as part of a resiliency 00:12:26.940 --> 00:12:31.548 plan um that could be incorporated. And I think we 00:12:31.558 --> 00:12:35.009 should allow that to happen by either saying not limited 00:12:35.019 --> 00:12:38.389 to or maybe adding something like non wires alternatives 00:12:38.399 --> 00:12:41.678 in this list. So that would be, and I don't have specific 00:12:41.690 --> 00:12:45.440 language today. But just having a wider definition 00:12:45.450 --> 00:12:50.359 obviously, when you guys get to the reviewing the plan 00:12:50.369 --> 00:12:53.320 and other stakeholders get to looking at the cost. 00:12:53.330 --> 00:12:55.580 There'll be debates about what should be included. 00:12:55.869 --> 00:12:58.969 But I think of the definitions, we should be probably 00:12:58.979 --> 00:13:02.849 wider than what, what's in this list. Okay, yeah. (item:1:David Smeltzer's question to Cyrus Reed) Because 00:13:02.859 --> 00:13:04.889 if, if you're measuring is something you might 00:13:04.899 --> 00:13:06.629 want to measure it against other measures that aren't 00:13:06.639 --> 00:13:08.879 there. I see what you mean, yeah. Um and you when 00:13:08.889 --> 00:13:11.158 you were saying that we, we might want it to be broader. 00:13:11.168 --> 00:13:13.889 You mean the actual resiliency plans themselves might 00:13:13.899 --> 00:13:17.840 include measures that are not on this list. (item:1:Cyrus Reed's follow-up to David Smeltzer) Exactly. 00:13:17.849 --> 00:13:22.048 And, and um even the way um, you know, separately 00:13:22.058 --> 00:13:25.609 the, the utilities have demand response programs which 00:13:25.619 --> 00:13:29.808 are not resiliency plans. Uh but when they're not 00:13:29.820 --> 00:13:34.489 being used for eea events maybe they help make 00:13:34.500 --> 00:13:37.038 the system more resilient. By the use of those demand 00:13:37.048 --> 00:13:39.690 response programs. So I, you know, I haven't thought 00:13:39.700 --> 00:13:42.538 through this but I. (item:1:David Smeltzer comments on resiliency) Yeah, no see what you mean. And I think that 00:13:42.548 --> 00:13:46.279 I'd had a uh, we got a three back here. Proper use 00:13:46.288 --> 00:13:49.690 of the Bonskowski protocol over here. Um, yeah. I, I've 00:13:49.700 --> 00:13:51.080 been thinking about that too. I mean there are other 00:13:51.090 --> 00:13:52.940 measures that resiliency can have. And the question 00:13:52.950 --> 00:13:55.788 is like, do they become a part of this? Or do they 00:13:55.798 --> 00:13:58.288 become something that if you want to do one of these 00:13:58.298 --> 00:14:00.019 you've got to prove that you shouldn't have done that 00:14:00.029 --> 00:14:02.308 other thing instead? You know, I mean so where the 00:14:02.320 --> 00:14:04.639 line is drawn. (item:1:Cyrus Reed's thoughts on David Smeltzer's comments) Or are they just a reference we have 00:14:04.649 --> 00:14:07.950 these other tools that we can use that also uh, allow 00:14:07.960 --> 00:14:10.779 for resiliency. But not, are not necessarily recovered 00:14:10.788 --> 00:14:13.840 through, you know, the cost on ratepayers. But at least 00:14:13.849 --> 00:14:16.950 they're, they're acknowledged. Yeah, that's 00:14:17.009 --> 00:14:20.940 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 00:14:20.950 --> 00:14:23.590 Texas Industrial Energy Consumers. Um we were just 00:14:23.599 --> 00:14:27.460 cautioned against confusing resiliency kind of blurring 00:14:27.469 --> 00:14:31.710 the line between resiliency and reliability. Um because 00:14:31.719 --> 00:14:34.529 I think event base is a very clear distinction as it 00:14:34.538 --> 00:14:38.489 was drafted. Um and I think that's a helpful way to 00:14:38.500 --> 00:14:41.940 distinguish the two. And once you start blurring that 00:14:41.950 --> 00:14:45.259 line, it gets just a little more complicated. And so 00:14:46.009 --> 00:14:47.389 we'd caution against that. 00:14:48.989 --> 00:14:54.239 And what's the, what's the fear? That there would be 00:14:54.389 --> 00:14:57.558 that it would end up costing consumers a lot more money. 00:14:57.849 --> 00:15:00.279 Because the. Liability measures would be pulled into 00:15:00.288 --> 00:15:00.379 the. 00:15:02.658 --> 00:15:06.450 Yes. (item:1:Ramya Ramaswamy question on definition of an event) So then would we also add a definition for an event? 00:15:09.200 --> 00:15:10.928 I haven't thought about that. 00:15:12.798 --> 00:15:15.658 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 00:15:15.668 --> 00:15:17.950 see an issue with how it's drafted without a definition 00:15:17.960 --> 00:15:22.190 for an event. Um and off the cuff, I can't think of 00:15:22.200 --> 00:15:24.048 a negative for including one. But 00:15:25.869 --> 00:15:28.989 thank you. Because it sounds like a fussy definition 00:15:29.000 --> 00:15:31.808 to write that's the next, it would be very fussy work. 00:15:32.080 --> 00:15:37.750 Um, okay. Anybody else want to comment on uh, resiliency 00:15:37.759 --> 00:15:38.279 definition? 00:15:40.408 --> 00:15:42.288 All right, let's keep on scrolling. 00:15:44.918 --> 00:15:47.889 (item:1:David Smeltzer opens floor for comments on Subsection D, Resiliency Plan Review & Approval Process) Resiliency plan, undergrounding, vegetation management. 00:15:49.928 --> 00:15:51.340 Anyone can holler at any point? 00:15:54.869 --> 00:16:00.340 Okay so making it through the definitions. Um uh Subsection 00:16:00.349 --> 00:16:03.139 D is about the resiliency plan, uh review and approval 00:16:03.149 --> 00:16:08.109 process. Um I guess I'll just because it's not a super 00:16:08.119 --> 00:16:10.788 chatty bunch today. I'll open up the, open up the floor 00:16:10.798 --> 00:16:14.149 for commentary on this Subsection. If anyone has thoughts 00:16:14.158 --> 00:16:17.918 on generally on the review and approval of these plans. 00:16:21.779 --> 00:16:21.808 Yes. 00:16:32.320 --> 00:16:35.250 (item:1:Zach Stevenson with TEC on denial/approval of a resiliency plan) Morning, Zach Stevenson for Texas Electric Cooperatives 00:16:35.259 --> 00:16:39.940 Uh our comment is limited to Subsection 6 within 00:16:39.950 --> 00:16:43.029 this section. I don't know if anyone else has anything 00:16:43.038 --> 00:16:43.750 before that? 00:16:46.629 --> 00:16:47.820 We can, we can skip around. 00:16:50.190 --> 00:16:52.629 And that's uh in particular 6C. 00:16:54.389 --> 00:16:57.808 Uh we know we recognize that this tracks the statutory 00:16:57.820 --> 00:17:00.719 language. However, this might be one of those areas 00:17:00.729 --> 00:17:02.639 where it might be appropriate for the Commission to 00:17:02.649 --> 00:17:07.337 read in uh the appropriate inverse. And just add in 00:17:07.347 --> 00:17:10.019 the denial or approval of a resiliency plan is not 00:17:10.028 --> 00:17:11.208 considered to be a finding. 00:17:13.358 --> 00:17:15.309 Yeah, to make sure the issues preserved for review 00:17:15.318 --> 00:17:18.890 to a rate case. Exactly. See what you mean. Does anyone 00:17:18.900 --> 00:17:22.519 want to have thoughts on that particular notion? I 00:17:22.528 --> 00:17:28.269 do. (item:1:George Hoyt with Entergy Texas on approving a plan) Um George Hoyt for Entergy Texas. So there has to be a 00:17:28.279 --> 00:17:31.380 meaning to approving a plan um and the measures in 00:17:31.390 --> 00:17:34.289 the plan. And so, while the utility will always be 00:17:34.719 --> 00:17:37.568 under an ongoing duty to prudently manage and implement 00:17:37.578 --> 00:17:39.949 the investment. You know, our view is that it does 00:17:39.959 --> 00:17:41.858 mean something when the Commission approves the plan 00:17:41.868 --> 00:17:44.838 and the measure in it. So to the extent that, you know 00:17:44.848 --> 00:17:47.019 there's not a change in material circumstances and 00:17:47.029 --> 00:17:50.578 the utility prudently implements the plan. Um, we don't 00:17:50.588 --> 00:17:53.459 think that the decision to, you know, undertake the 00:17:53.469 --> 00:17:55.979 the, the measure ordered by the Commission is subject 00:17:55.989 --> 00:17:56.729 to rereview 00:18:01.809 --> 00:18:02.838 Counter? 00:18:04.598 --> 00:18:07.578 (item:1:Zach Stevenson with TEC on rereview) Well, I think the rereview is contemplated with the 00:18:07.588 --> 00:18:13.309 um uh true up on the rate case. (item:1:George Hoyt with Entergy Texas follow-up on rereview) And so, yeah well 00:18:13.318 --> 00:18:15.680 just to be clear. The rereview is whether the utility 00:18:15.689 --> 00:18:19.618 has prudently incurred the actual cost. So what their 00:18:19.630 --> 00:18:22.559 wasted cost was there a cost overrun that wasn't justified. 00:18:22.568 --> 00:18:25.539 But the decision to build the project that was approved 00:18:25.549 --> 00:18:28.140 as part of a plan, absent change circumstances is not 00:18:28.150 --> 00:18:33.539 subject to review. Okay. Anyone else to speak on this 00:18:33.549 --> 00:18:34.699 narrower topic? 00:18:36.500 --> 00:18:38.910 Okay, Zach you got anything else? Nothing else. All 00:18:38.920 --> 00:18:42.078 right. Thank you very much. (item:1:Lauren Damen with NRG on REP notification) I'd like to back up quickly 00:18:42.088 --> 00:18:44.088 to 5 and hopefully this is not controversial. Uh 00:18:44.098 --> 00:18:47.289 Lauren Damen on behalf of NRG. I would just like to 00:18:47.299 --> 00:18:50.289 put a plug in, that y'all add a provision for REPs 00:18:50.299 --> 00:18:53.118 to get notice 45 days before the actual rider goes 00:18:53.130 --> 00:18:57.265 into effect. With this timing, I can see where we would 00:18:57.275 --> 00:18:59.493 definitely know 90 days from the filing, 90 days ahead 00:18:59.505 --> 00:19:01.265 of time. But it looks like there's some provisions 00:19:01.275 --> 00:19:04.144 where that is just not entirely clear. So regardless it 00:19:04.154 --> 00:19:06.015 would be great for REPs to get notice. So that we can 00:19:06.025 --> 00:19:08.713 update our EFLs and make system changes. To make sure 00:19:08.723 --> 00:19:11.104 that the customers can be apprised of the changes. 00:19:12.750 --> 00:19:13.719 Any objections? 00:19:18.939 --> 00:19:20.858 Seems reasonable for PFP purposes. 00:19:24.880 --> 00:19:26.828 (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 00:19:26.838 --> 00:19:31.130 of Houston. Um we have a comment on Section 4 in 00:19:31.140 --> 00:19:33.868 uh the language about what the Commission shall consider 00:19:34.348 --> 00:19:39.068 um Subsection A. There says that uh the Commission should 00:19:39.078 --> 00:19:42.189 consider whether the plan prioritizes areas of lower 00:19:42.199 --> 00:19:45.838 performance. Um we just didn't see any language in 00:19:45.848 --> 00:19:49.199 here that built on what that means? How the utilities 00:19:49.209 --> 00:19:51.920 should report on that? And, and how it exactly should 00:19:51.930 --> 00:19:54.588 be considered? So we, our recommendation is to build 00:19:54.598 --> 00:19:58.828 that out and um further specify what it means to prioritize 00:19:58.838 --> 00:20:01.500 an area of lower performance. And it could maybe go 00:20:01.509 --> 00:20:03.670 into the definition section of what an area of low 00:20:03.680 --> 00:20:04.449 performance is. 00:20:06.618 --> 00:20:10.229 That's an interesting notion. Does anyone wanna any 00:20:10.348 --> 00:20:11.180 thoughts on that? 00:20:14.709 --> 00:20:18.259 Yeah, that's worth worth thinking about. Um Do you 00:20:18.269 --> 00:20:21.769 have any suggestions on what you think of the uh what 00:20:21.779 --> 00:20:26.430 a low area of lower performance mean? It could be areas 00:20:26.439 --> 00:20:30.680 that experience a greater number of outages, circuits 00:20:30.689 --> 00:20:35.059 that are lower performance. Uh circuits areas that 00:20:35.068 --> 00:20:38.910 are affected by um you know circuits in flood plain, 00:20:38.920 --> 00:20:43.348 circuits in hazardous areas. (item:1:David Smeltzer's thoughts on areas of performance) Yeah, I understand. Yeah 00:20:43.358 --> 00:20:44.739 that's sort of an interesting one. Because 00:20:46.439 --> 00:20:49.449 you know, each type of event happens with different 00:20:49.459 --> 00:20:52.809 frequencies. So you'd almost measure what an area of 00:20:52.818 --> 00:20:55.170 performance is differently depending on what aspect 00:20:55.180 --> 00:20:57.500 of resiliency you're trying to address. So it's kind 00:20:57.509 --> 00:20:59.588 of a tricky wicket. But I think what you're saying 00:20:59.598 --> 00:21:03.848 is not and not crazy. Yeah. (item:1:Sean Meredith with Entergy on areas of performance) Hi. Yeah, Sean Meredith 00:21:03.858 --> 00:21:08.449 from uh Entergy. Um one of the concerns I have with, with 00:21:08.459 --> 00:21:10.939 trying to specify that on the front end is exactly 00:21:10.949 --> 00:21:13.680 what you were just alluding to. Depending on the part 00:21:13.689 --> 00:21:16.078 of the state you're in. One is if you're looking at 00:21:16.088 --> 00:21:18.479 low performing from a reliability perspective. That 00:21:18.489 --> 00:21:20.430 could be very different from a resilience perspective. 00:21:20.439 --> 00:21:23.608 You could have a circuit doesn't have poor performing 00:21:23.618 --> 00:21:26.900 reliability. But it could have a very high resilience 00:21:26.910 --> 00:21:29.239 impact. If a storm comes like on the coast, for instance. 00:21:29.250 --> 00:21:32.150 And the circuits built to 100 miles an hour, it may 00:21:32.160 --> 00:21:34.828 do fine day-to-day. The whole circuit may end up on 00:21:34.838 --> 00:21:38.019 the ground after an event. So you got to weigh those 00:21:38.029 --> 00:21:39.689 types of things. And I think the burden of proof is 00:21:39.699 --> 00:21:42.588 on us the beginning to say. Here's the highest likelihood 00:21:42.598 --> 00:21:44.890 of failure. Here's why we're attacking this from a 00:21:44.900 --> 00:21:48.959 resilience perspective. And if we specify that we could 00:21:48.969 --> 00:21:51.420 end up actually going in working on something that 00:21:51.430 --> 00:21:52.838 has less resilient benefit. 00:21:55.500 --> 00:21:57.410 I have a clarifying question. So are you trying to 00:21:57.420 --> 00:21:59.689 say that you are going in your resiliency plans. You 00:21:59.699 --> 00:22:02.709 are going to be defining what is the resiliency problem 00:22:02.719 --> 00:22:05.338 that you are solving to? (item:1: Sean Meredith's follow-up response to Rama Rastogi) That's absolutely it. The burden 00:22:05.348 --> 00:22:08.959 of proof is on us to define. Here's the benefits, here's 00:22:08.969 --> 00:22:12.078 the problem on each utility. Because each of us will 00:22:12.088 --> 00:22:14.989 have a, may have a very different challenge from a resilience 00:22:15.000 --> 00:22:17.049 perspective depending on where we are in the state 00:22:17.059 --> 00:22:19.519 or what type of infrastructure we have. So we will 00:22:19.529 --> 00:22:23.598 have to provide that and express the benefit that we're 00:22:23.608 --> 00:22:27.219 going to receive for the investment. So I think specifying 00:22:27.229 --> 00:22:30.269 that on the front end could really hamper the ability 00:22:30.279 --> 00:22:32.910 It may steer actually the utilities to go and invest 00:22:32.920 --> 00:22:36.189 in something to make for whatever the criteria set 00:22:36.199 --> 00:22:39.269 versus identifying the most beneficial to our customers 00:22:39.279 --> 00:22:42.019 and communities. (item:1:Rama Rastogi's follow-up question to Sean Meredith with Entergy) I do have a follow-up question which 00:22:42.029 --> 00:22:44.380 is actually coming from the one of the questions in 00:22:44.390 --> 00:22:48.660 the memo. That talks about alternatives for the problem 00:22:48.670 --> 00:22:52.180 that you are solving. So there may be one resiliency 00:22:52.279 --> 00:22:54.420 one solution to the resiliency problem that you've 00:22:54.430 --> 00:22:57.608 identified. And there could be, you know, more than 00:22:57.618 --> 00:23:01.140 one and there is a cost implication to the choice of 00:23:01.150 --> 00:23:04.439 the solution that you choose for solving that problem 00:23:04.890 --> 00:23:07.299 So that's a question, not just for you but for the 00:23:07.309 --> 00:23:10.650 floor as well. Like you know what is, what do you 00:23:10.660 --> 00:23:12.640 all think about that? Yeah, happy to address that. 00:23:12.650 --> 00:23:16.078 (item:1:Sean Meredith with Entergy on being most cost effective) So it's again, the burden of proof is on us to explain 00:23:16.088 --> 00:23:19.150 why the so the solution we have picked is the most 00:23:19.160 --> 00:23:21.868 cost effective for our customer. And we have to defend 00:23:21.880 --> 00:23:25.289 that and show that. And if there are questions around 00:23:25.299 --> 00:23:27.539 other alternatives, we need to explain why we're not 00:23:27.549 --> 00:23:31.729 utilizing that because of Xy and Z. Um But again, to 00:23:31.739 --> 00:23:35.769 the, the point of I think redefining that could steer 00:23:35.779 --> 00:23:39.000 utilities away from the right solution. So it's on 00:23:39.009 --> 00:23:43.588 us to show the most cost effective. Um but. Oh, not trying 00:23:43.598 --> 00:23:47.650 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 00:23:47.660 --> 00:23:53.180 of points. Um on the, um you know, defining areas of 00:23:53.189 --> 00:23:55.709 low performance. I think the unintended consequence 00:23:55.719 --> 00:23:58.719 could be that not only that you, some of these factors 00:23:58.729 --> 00:24:01.489 are focused on reliability, not resiliency. But also 00:24:01.500 --> 00:24:04.689 that you could inadvertently exclude areas of low performance 00:24:04.699 --> 00:24:08.049 say I don't know, a cyber security area. Um because 00:24:08.059 --> 00:24:10.969 you've, you've taken an arbitrary subset of areas that 00:24:10.979 --> 00:24:12.689 would be considered low performance. And then all of 00:24:12.699 --> 00:24:15.088 a sudden, you know, the utility is not addressing it. 00:24:15.098 --> 00:24:16.910 Even though it's a very cost effective and worthwhile 00:24:16.920 --> 00:24:21.009 measure. Um the other thing with on, on the alternatives 00:24:21.019 --> 00:24:23.858 whether you know, that should be a requirement to specify 00:24:23.868 --> 00:24:27.920 alternatives. Um I, I think as Sean said, the utility 00:24:27.930 --> 00:24:29.890 should have the latitude to do that where it makes 00:24:29.900 --> 00:24:32.309 sense and it's necessary to meet its burden of proof. 00:24:32.318 --> 00:24:35.358 But if we, if we insert a requirement that for every 00:24:35.368 --> 00:24:38.650 measure a utility proposes in a plan. It has to put 00:24:38.660 --> 00:24:42.680 forward some alternative. That may pollute these, these 00:24:42.689 --> 00:24:45.689 plans and cause a lot of unnecessary work and helpful 00:24:45.699 --> 00:24:48.848 information. There may be circumstances where, you 00:24:48.858 --> 00:24:52.209 know, there's an alternative that's technically feasible. 00:24:52.219 --> 00:24:56.709 But clearly um, you know, not practical or cost effective. 00:24:56.719 --> 00:24:59.949 (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 00:24:59.959 --> 00:25:02.118 be an easy paragraph of a plan to write? 00:25:03.729 --> 00:25:05.989 It would be like. You know, there's this other unfeasible 00:25:06.000 --> 00:25:11.430 alternative and, you know, in x area sure we could 00:25:12.400 --> 00:25:15.479 bulldoze through all like this 7 ft of granite to underground 00:25:15.489 --> 00:25:17.390 all these lines. But uh there's all granite in this 00:25:17.400 --> 00:25:20.180 area. So we I mean, it seems like that would not be. 00:25:20.588 --> 00:25:22.219 I understand what you're saying about like we don't 00:25:22.229 --> 00:25:25.170 want to set, we don't wanna affect. We want you guys 00:25:25.180 --> 00:25:26.729 to think about these in terms of what's going to achieve 00:25:26.739 --> 00:25:28.328 the maximum amount of resiliency, not what's gonna 00:25:28.338 --> 00:25:32.269 make the application easiest to fill out. Um but uh 00:25:34.630 --> 00:25:37.650 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. 00:25:37.660 --> 00:25:39.848 You're absolutely right. It's an easy paragraph to 00:25:39.858 --> 00:25:42.959 write. But it, it is not a particularly meaningful 00:25:42.969 --> 00:25:45.910 paragraph for anyone either, right. So to the extent 00:25:45.920 --> 00:25:48.259 it's easy that means it's obvious and, and it's, it's 00:25:48.269 --> 00:25:51.630 consuming resources. It, it you know making this 00:25:51.640 --> 00:25:54.338 take longer to review, harder to review. It's more voluminous. 00:25:54.348 --> 00:25:56.358 It's just, it doesn't appear to be providing meaningful 00:25:56.368 --> 00:25:58.098 information to the Commission. Now there it may very 00:25:58.108 --> 00:26:02.989 well be the case. That, um you know want to specify 00:26:03.000 --> 00:26:05.779 alternatives to demonstrate that a particular product 00:26:05.789 --> 00:26:08.309 or, or measure is the appropriate one in that situation. 00:26:08.318 --> 00:26:10.279 So I, I anticipate that you will see that quite a 00:26:10.289 --> 00:26:13.160 bit. Um, I just would caution against you know kind 00:26:13.170 --> 00:26:15.779 of prescriptive things in the rule to that effect where 00:26:15.789 --> 00:26:17.910 it might not make sense. Yeah, I'm trying to think 00:26:17.920 --> 00:26:21.250 from like a. We've only got 180 days to approve 00:26:21.259 --> 00:26:25.650 these plans. And so it almost seems like the strategic 00:26:25.660 --> 00:26:28.209 move from the plan writer would be to sort of immediately 00:26:28.219 --> 00:26:30.130 disavow all the things that are broken so that you're 00:26:30.140 --> 00:26:32.959 not hearing them from interveners perspective. But 00:26:33.059 --> 00:26:34.699 to your point whether or not that should be a requirement 00:26:34.709 --> 00:26:37.380 or something that just works its way through uh is 00:26:38.670 --> 00:26:42.529 (item:1:Ramya Ramaswamy on quantitative and qualitative language) So can I ask something? So the the words that come 00:26:42.539 --> 00:26:47.699 before the prioritize, prioritization is having qualitative 00:26:47.709 --> 00:26:50.509 and quantitative measures, right? Those basically are 00:26:50.519 --> 00:26:54.809 gonna drive the factors that drive this. So those can 00:26:54.818 --> 00:26:59.689 be um you can make those attribute based or performance 00:26:59.699 --> 00:27:04.049 based. And that can, I mean, that's how I am thinking 00:27:04.059 --> 00:27:06.130 about how these plans should be. That they are still 00:27:06.140 --> 00:27:09.459 going to be specific. It is a plan that addresses something. 00:27:09.469 --> 00:27:13.259 But because of those quantitative and qualitative, 00:27:13.269 --> 00:27:17.769 it should list the steps in the plans. That are the 00:27:17.779 --> 00:27:23.170 steps that a process that is planned. Am I? (item:1:Sean Meredith's follow-up to Ramya Ramaswamy's comments) You 00:27:23.180 --> 00:27:25.269 you think about that correctly. So it would uh just 00:27:25.279 --> 00:27:28.979 an example a hypothetical would be. Project A you 00:27:28.989 --> 00:27:32.189 expect to get these three benefits that are quantitative. 00:27:32.348 --> 00:27:34.328 That's absolutely what the plan is gonna encompass 00:27:34.338 --> 00:27:36.809 right? It's gonna be very specific to here's the benefits. 00:27:36.818 --> 00:27:40.500 Project A cost has these benefits associated with 00:27:40.509 --> 00:27:43.439 it. Right. That's, that's exactly how we, how I read 00:27:43.449 --> 00:27:47.838 that and how, what the intent is. But going back to 00:27:47.848 --> 00:27:54.318 the prioritization of the lower. Um how does that come 00:27:54.328 --> 00:27:58.059 with resiliency and not reliability is my struggle. 00:27:58.199 --> 00:28:01.818 Okay. So, um as I said earlier. I think it was an 00:28:01.828 --> 00:28:05.509 excellent definition is reliability is to provide the 00:28:05.519 --> 00:28:08.019 quantity and quality of power we want on a blue sky 00:28:08.029 --> 00:28:11.000 so day to day. So I hit the light switch, it's there. 00:28:11.009 --> 00:28:14.289 The way I want it resilience is, is very this high 00:28:14.299 --> 00:28:19.088 impact low frequency event based. So looking at it 00:28:19.098 --> 00:28:22.170 from a a day to day perspective is say to you say. 00:28:22.180 --> 00:28:24.068 We don't wanna, you don't wanna use those type of metrics 00:28:24.078 --> 00:28:27.519 because of the those impacts. What we have to look at 00:28:27.529 --> 00:28:30.630 It's got to be defined by what the event you're, you're 00:28:30.640 --> 00:28:33.769 being resilient to. So whether that's a wildfire, in 00:28:33.779 --> 00:28:36.390 our case we're a Coastal utility. Hurricanes is obviously 00:28:36.400 --> 00:28:39.368 one of the things we're very concerned with. Um So 00:28:39.380 --> 00:28:41.739 from our perspective, you know, those type of metrics 00:28:41.750 --> 00:28:44.199 are. How fast can you get the lights back on? It's 00:28:44.209 --> 00:28:45.759 not that the lights aren't going to go out. I said 00:28:45.769 --> 00:28:48.009 how fast are you going to get them back on? And what's 00:28:48.019 --> 00:28:51.029 the, what's the cost of the, uh for getting the lights 00:28:51.039 --> 00:28:53.509 back on? And that's really when you start measuring 00:28:53.519 --> 00:28:55.848 resilience, that's just one way to look at it. There's 00:28:56.019 --> 00:28:58.390 obviously depending on where you are in the state or 00:28:58.400 --> 00:29:02.469 what your event or threat is. Um, it will really drive 00:29:02.479 --> 00:29:05.890 that discussion. (item:1:Ramya Ramaswamy on details of the distribution system) So this is why it's like during the 00:29:05.900 --> 00:29:11.068 definition section, I had brought up the system rather 00:29:11.078 --> 00:29:13.809 than, you know, the smaller component. So it's like 00:29:13.880 --> 00:29:17.568 even when you're thinking about um, we most probably 00:29:17.578 --> 00:29:19.489 are talking of the same thing. But I just want to make 00:29:19.500 --> 00:29:22.239 it very clear here that at least my understanding 00:29:22.250 --> 00:29:25.239 right. That's what I'm trying to, to hone 00:29:25.250 --> 00:29:30.088 into. Is the resiliency plan should be thinking still 00:29:30.098 --> 00:29:34.390 of the system as a whole, the distribution system or 00:29:34.400 --> 00:29:37.890 the system that you guys are, the utility is focused 00:29:37.900 --> 00:29:41.559 as a whole. And not to say that okay, I'm just going 00:29:41.568 --> 00:29:45.529 to make sure that 78704 to pick a zip code is going 00:29:45.539 --> 00:29:48.529 to be my target resiliency. Is that a fair way to think 00:29:48.539 --> 00:29:51.390 about it? (item:1:Sean Meredith with Entergy on system perspective) Well you have to, you have to analyze it 00:29:51.400 --> 00:29:53.318 from a system perspective. But as you're putting your 00:29:53.328 --> 00:29:55.368 plan together, obviously it's very tactical. And you 00:29:55.380 --> 00:29:58.130 need to understand how those individual components 00:29:58.140 --> 00:30:00.789 impact the system. But you are looking at it from a 00:30:00.799 --> 00:30:05.108 system perspective that utilities perspective. Yes. 00:30:05.118 --> 00:30:07.459 But, but it is very tactical. And what you're going 00:30:07.469 --> 00:30:11.410 to do because some substations are more prone to flooding 00:30:11.420 --> 00:30:13.608 than others, right? Things like that. So you've 00:30:13.618 --> 00:30:15.009 got to look at it from that. And, but you have to 00:30:15.019 --> 00:30:18.338 understand the impact of that substation to the area. 00:30:19.509 --> 00:30:23.828 (item:1:Sam Chang with CenterPoint Energy's introduction of Eric Easton) So I have with me, Eric Easton, who's our VP of 00:30:23.838 --> 00:30:26.269 Grid Transformation and Investment. And also in his 00:30:26.279 --> 00:30:29.180 prior role, he oversaw high voltage operations. I think 00:30:29.189 --> 00:30:32.059 he can provide additional context to this discussion. Sure, 00:30:32.759 --> 00:30:36.539 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 00:30:36.549 --> 00:30:41.019 that Entergy had, uh just a few caveats. Um you know, you mentioned 00:30:41.029 --> 00:30:43.769 a little bit about the system perspective. I think 00:30:43.779 --> 00:30:46.160 we think about it not only from the electric system 00:30:46.170 --> 00:30:49.868 but also those critical loads that we have on our system. 00:30:49.880 --> 00:30:54.250 That are important during a disaster or public health 00:30:54.259 --> 00:30:57.500 situation, such as a hurricane or some other event. 00:30:57.709 --> 00:31:00.400 And so that's where I think there's a divergence between 00:31:00.410 --> 00:31:03.469 the performance based, which is more performance based 00:31:03.479 --> 00:31:07.130 on reliability versus the event based approach. Where 00:31:07.140 --> 00:31:10.608 we are planning for a specific event. And during that 00:31:10.618 --> 00:31:13.519 specific event, there may be other critical infrastructures 00:31:13.529 --> 00:31:16.618 that are important. That we would emphasize investment 00:31:16.630 --> 00:31:19.449 from a resiliency standpoint from the entire societal 00:31:19.459 --> 00:31:22.729 benefit, not only just the electric system. And then 00:31:22.739 --> 00:31:25.219 there's also things that are electric system based 00:31:25.229 --> 00:31:28.180 that we would want to put prioritization on. And so 00:31:28.189 --> 00:31:30.539 I think if we only looked at the performance of the 00:31:30.549 --> 00:31:34.479 electric system we may, as Entergy said. Have some misalignment 00:31:34.489 --> 00:31:37.868 between the investments that we would make from a reliability 00:31:37.880 --> 00:31:41.358 perspective and that of a resiliency perspective. So 00:31:41.368 --> 00:31:44.618 I didn't want that to be lost as well. That the electric 00:31:44.630 --> 00:31:48.608 system is one part of a broader system during an emergency. 00:31:48.880 --> 00:31:52.289 And because they are very event based, we might focus 00:31:52.299 --> 00:31:55.259 on specific parts of the system regardless of their 00:31:55.269 --> 00:31:58.598 day to day reliability. I think the other thing is 00:31:58.608 --> 00:32:01.809 that when we make resiliency investments and this kind 00:32:01.818 --> 00:32:04.828 of goes back to the optimization of those investments. 00:32:05.289 --> 00:32:08.650 that sometimes the same investment helps for multiple 00:32:08.660 --> 00:32:10.809 events. And so that's something else that utilities 00:32:10.818 --> 00:32:13.358 are going to look at. I would presume I know that center 00:32:13.368 --> 00:32:16.989 point will that if we make an investment, does it help 00:32:17.000 --> 00:32:20.608 us with multiple high impact low frequency events? 00:32:20.618 --> 00:32:23.858 And so if we start to have too much prescription in 00:32:23.868 --> 00:32:27.910 the steps that we need to take, it might avoid or impair 00:32:27.920 --> 00:32:29.959 our ability to do some of that optimization. 00:32:31.838 --> 00:32:34.650 (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 00:32:34.660 --> 00:32:37.039 you guys make what I think some pretty reasonable arguments. 00:32:37.289 --> 00:32:40.170 Um I still wonder kind of what we're supposed to do 00:32:40.189 --> 00:32:45.098 with this language about uh you know, areas on what 00:32:45.108 --> 00:32:48.449 prioritized areas of lower performance. And is maybe, 00:32:48.739 --> 00:32:50.618 is maybe the way we should think about it is, you know 00:32:50.630 --> 00:32:53.449 there's sort of different categories of action that 00:32:53.459 --> 00:32:56.939 you can take, you know. Um or different types of resiliency 00:32:56.949 --> 00:33:00.328 measures. And so just uh so elevated substations to 00:33:00.338 --> 00:33:02.989 avoid flooding versus vegetation management, to avoid 00:33:03.000 --> 00:33:05.640 those sorts of line outages. And is maybe the way to 00:33:05.650 --> 00:33:07.469 think about it. Is not that we should be, 00:33:09.338 --> 00:33:11.348 you know, if you guys have a plan that comes in with 00:33:11.358 --> 00:33:14.229 vegetation management. Maybe we shouldn't be asking 00:33:14.699 --> 00:33:17.019 whether or not vegetation management from a system 00:33:17.029 --> 00:33:20.588 perspective is a, a greater or lesser area of need 00:33:20.598 --> 00:33:23.719 like lower performance. But within each category, like 00:33:23.729 --> 00:33:26.368 if you're going to elevate substations or rather, you 00:33:26.380 --> 00:33:29.549 know, if you have an application to focus on. Uh one 00:33:29.559 --> 00:33:31.259 area and not the other, I don't know that we should 00:33:31.269 --> 00:33:34.078 be denying it because this isn't your most urgent need. 00:33:34.088 --> 00:33:36.559 But maybe if you're gonna start elevating substations 00:33:36.568 --> 00:33:41.660 uh you should start with the ones that are of areas 00:33:41.670 --> 00:33:43.608 most. You know, like to use it within each category 00:33:43.618 --> 00:33:46.279 rather than across categories. So I was trying to imagine 00:33:46.479 --> 00:33:48.568 sometimes you prioritize things that are lower hanging 00:33:48.578 --> 00:33:51.269 fruit rather than that are the most acute need. And 00:33:51.279 --> 00:33:54.858 so anyway, that's just a. I think that's. Another way 00:33:54.868 --> 00:33:57.578 to think about it. (item:1:Jessica Seuss with AEP Energy on language on prioritizing lower performance) I think that's a reasonable thought. 00:33:57.588 --> 00:34:01.509 And I think the biggest thing is we don't want to be 00:34:01.519 --> 00:34:04.430 as everyone has said, overly prescriptive in this rule. 00:34:04.509 --> 00:34:07.279 That language about prioritizing lower performance 00:34:07.289 --> 00:34:10.438 is in the statute. If we wanna just copy it from the 00:34:10.449 --> 00:34:12.489 statute and the rule or leave it out of the rule. I 00:34:12.500 --> 00:34:15.750 think that's a good plan. And then we can just leave 00:34:15.760 --> 00:34:19.550 it up to each utility to, in their applications explain 00:34:19.559 --> 00:34:22.780 how they're considering that factor. Yeah, because 00:34:22.789 --> 00:34:23.938 it's kind of interesting because it doesn't say we 00:34:23.949 --> 00:34:26.320 can't approve plans that don't do that, you know. But 00:34:26.329 --> 00:34:29.498 we, you know, it's there for some reason. 00:34:31.728 --> 00:34:34.429 (item:1:Eric Easton with CenterPoint Energy on priorities in the overall plan) Yeah, I think in some cases it's a supplemental benefit. 00:34:34.438 --> 00:34:39.500 So when we can align we do, we try to. But as 00:34:39.510 --> 00:34:41.679 you just mentioned, it's not a requirement. Because 00:34:41.688 --> 00:34:45.269 it's still based on the individual utilities perspective 00:34:45.280 --> 00:34:47.869 of what are the priorities in the overall plan. 00:34:50.019 --> 00:34:52.688 (item:1:George Hoyt with Entergy's thoughts resiliency vs. reliability) And I agree generally with what others have said. I 00:34:52.699 --> 00:34:54.679 would say, you know, you can also look at areas of 00:34:54.688 --> 00:34:57.168 lower performance in the context of what resiliency 00:34:57.179 --> 00:35:00.728 is as opposed to reliability, right? So, um an area 00:35:00.739 --> 00:35:02.949 of lower performance and a resiliency context can be 00:35:02.958 --> 00:35:07.228 thought of an area that's susceptible, right? So, um 00:35:07.239 --> 00:35:10.679 just offer that as well. (item:1:Micalah Spenrath with TAEBA on higher risk language) I actually wanted to chime 00:35:10.688 --> 00:35:12.898 in. And maybe we're getting hung up on the word performance 00:35:12.909 --> 00:35:16.289 but maybe it's like higher risk. So from a utility 00:35:16.300 --> 00:35:19.659 perspective, like maybe your areas that are more susceptible 00:35:19.668 --> 00:35:22.320 to these events, higher risk might be where you need 00:35:22.329 --> 00:35:25.039 to, to look at. But in terms of defining that I would 00:35:25.050 --> 00:35:27.989 defer to the utility community. Yeah, and I think for 00:35:28.000 --> 00:35:30.909 me, regardless of exactly how we take, take it. Just 00:35:30.918 --> 00:35:33.239 because you like maybe, just because the utility 00:35:33.250 --> 00:35:36.280 is most at risk of floods doesn't mean we don't also 00:35:36.289 --> 00:35:38.918 want them to be doing resiliency measures in other 00:35:38.929 --> 00:35:41.300 areas. Even maybe first because that's what they know 00:35:41.309 --> 00:35:42.449 how to solve in that moment. You know what I mean? 00:35:42.458 --> 00:35:45.128 I don't know. It's unclear. That's the, what. 00:35:46.929 --> 00:35:50.918 Uh. (item:1:Rama Rastogi on low hanging fruit vs. acute need) I think I have a follow up question about uh the 00:35:50.929 --> 00:35:55.159 low, the low hanging fruit versus the acute need. So 00:35:55.168 --> 00:35:58.378 in your resiliency plan what is, what is the general 00:35:58.389 --> 00:36:02.699 uh thought around. Would the resiliency plan be uh 00:36:03.389 --> 00:36:09.099 you know, bigger plan of uh you know, that consists 00:36:09.110 --> 00:36:14.438 of smaller sub plans? That kind of solve um you know 00:36:14.449 --> 00:36:18.619 specific resiliency problem in pockets of your service 00:36:18.628 --> 00:36:23.389 territory. How do you kind of? (item:1:Sean Meredith with Entergy on plan meeting multiple tenants) So, so I see it as 00:36:23.398 --> 00:36:27.208 being you have a plan that will meet multiple tenants 00:36:27.219 --> 00:36:31.280 that are listed there and I'll speak on ours. So when 00:36:31.289 --> 00:36:33.599 you look at it, obviously hardening is a huge component 00:36:33.610 --> 00:36:39.019 being a coastal utility. Also flood mitigation is another 00:36:39.030 --> 00:36:40.840 very large component for us. There are other things 00:36:40.849 --> 00:36:43.409 in there that we also have to consider. But it would 00:36:43.418 --> 00:36:46.668 it would be sections for each one of those explaining 00:36:46.679 --> 00:36:49.260 why these are the largest benefit to our customers 00:36:49.269 --> 00:36:51.878 for the cost associated with them. So for instance 00:36:51.889 --> 00:36:54.809 it would say, you know, feed or a harden this many 00:36:54.820 --> 00:36:58.079 poles basically to rebuild. Here's the cost, but here 00:36:58.090 --> 00:36:59.978 are the associated benefits for that. And it would really 00:36:59.989 --> 00:37:04.099 break it down to that level is how I foresee defending 00:37:04.188 --> 00:37:07.478 defending that. (item:1:Rama Rastogi with follow-up question to Sean Meredith with Entergy) I guess I'm kind of thinking from the 00:37:07.489 --> 00:37:11.148 staff's perspective of approvals. So like if you, if 00:37:11.159 --> 00:37:15.519 the plan is made up of like three subplans. Of kind 00:37:15.530 --> 00:37:19.438 of taking care of something on the coastal area, something 00:37:19.449 --> 00:37:24.760 on uh would we have an ability to kind of do uh 00:37:25.000 --> 00:37:28.489 you know, choose any two or would it be like something 00:37:28.500 --> 00:37:32.628 that this is the whole plan? And all three subparts 00:37:32.639 --> 00:37:35.300 are a part of the plan? So either the whole plan gets 00:37:35.309 --> 00:37:35.878 approved 00:37:38.148 --> 00:37:40.199 or. (item:1:David Smeltzer on comprehensive resiliency) And I think maybe some of the tension that she's referring 00:37:40.208 --> 00:37:43.309 to is when, when we hear from individual utilities 00:37:43.320 --> 00:37:46.188 or whatever about these. The, the real benefit of this 00:37:46.199 --> 00:37:49.199 statute is supposed to be. We can think about, we can 00:37:49.208 --> 00:37:51.628 think about our resiliency comprehensively like this. 00:37:51.639 --> 00:37:53.739 We, we can't we've previously not been able to think 00:37:53.750 --> 00:37:56.619 about it comprehensively. And like okay, comprehensively. 00:37:56.648 --> 00:37:58.418 But then when you actually start to think about the 00:37:58.429 --> 00:38:01.820 plans, the analysis breaks down. Because like what each 00:38:01.829 --> 00:38:03.619 individual measure is gonna have to be measured in 00:38:03.628 --> 00:38:05.010 different ways and they're gonna apply to different 00:38:05.019 --> 00:38:07.500 problems and you can't really compare across. And so 00:38:08.760 --> 00:38:11.599 is it, is it comprehensive or is it not you, you know 00:38:11.610 --> 00:38:13.648 what I mean? So it's just that there's a tension there 00:38:13.659 --> 00:38:15.610 between what level of analysis we're supposed to be. 00:38:16.708 --> 00:38:19.628 (item:1:Sam Chang with CenterPoint Energy on statutory language) Yeah, so I would refer to the statutory language that 00:38:19.639 --> 00:38:24.179 allows the PUC to approve as filed, modify or deny. 00:38:24.188 --> 00:38:27.139 So I think you have a wide range of options as far 00:38:27.148 --> 00:38:31.550 as what you wanna do uh come approval time. Sam is 00:38:31.559 --> 00:38:34.188 recommending denial, this is what I'm hearing. I'll 00:38:34.199 --> 00:38:38.329 hold on to it. (item:1:Rama Rastogi on alternatives) I, I do have uh, uh I'm gonna 00:38:38.340 --> 00:38:40.688 go back to, I want to be labor a little bit about the 00:38:40.699 --> 00:38:45.409 alternatives. Uh because uh I think uh from your previous 00:38:45.418 --> 00:38:48.688 comment, I'm talking to the Entergy comment. About that we 00:38:48.699 --> 00:38:53.239 don't have uh, we can't revisit uh the planned components 00:38:53.250 --> 00:38:56.079 once it's approved by the Commission. But the amount 00:38:56.090 --> 00:39:00.309 of time that we really do have uh is very limited. 00:39:00.789 --> 00:39:04.239 So in a scenario where Staff has very limited time 00:39:04.250 --> 00:39:10.128 to review the plan. Uh and it is a new thing, would 00:39:10.139 --> 00:39:13.289 it. I, I would personally feel that it would help the 00:39:13.300 --> 00:39:16.489 Staff also if there were, there was more hand holding 00:39:16.500 --> 00:39:21.780 in terms of you explaining. Uh why uh you know, the 00:39:21.789 --> 00:39:25.329 the entity chose a particular resiliency problem? Why 00:39:25.340 --> 00:39:28.329 you chose a solution? And why, you know, if vegetation 00:39:28.340 --> 00:39:32.539 management was there there less expensive alternative 00:39:32.550 --> 00:39:35.619 but you still went ahead with the, you know, lifting 00:39:35.628 --> 00:39:38.739 the substation up for a flood risk. What was the rationale 00:39:38.750 --> 00:39:41.320 for it? All I'm saying is that that's going to help 00:39:41.329 --> 00:39:46.409 the Staff kind of understand your position much better 00:39:46.418 --> 00:39:51.309 and I'll stop here. (item:1:George Hoyt with Entergy on alternatives) Yeah. I,I I understand what you're 00:39:51.320 --> 00:39:53.500 getting at and, and like I said. I, I think you're 00:39:53.510 --> 00:39:56.860 going to see a healthy discussion of alternatives in 00:39:56.869 --> 00:40:01.668 many cases. This was simply a point about not kind 00:40:01.679 --> 00:40:04.059 of requiring a box to be checked. That's going to pollute 00:40:04.070 --> 00:40:06.989 these plans and increase your work by describing a 00:40:07.000 --> 00:40:10.309 bunch of clearly implausible alternatives. So where 00:40:10.320 --> 00:40:13.099 an alternative needs to be discussed, to establish 00:40:13.110 --> 00:40:15.239 that it is the right thing to do for customers at the 00:40:15.250 --> 00:40:17.889 best, most effective at the least cost, that sort of 00:40:17.898 --> 00:40:22.659 thing, then we certainly intend to do that. (item:1:Jessica Seuss with AEP Energy on alternatives) And I think 00:40:22.668 --> 00:40:29.050 to echo those points. We can and intend to provide 00:40:29.059 --> 00:40:32.110 a lot of explanation on our decision making process. 00:40:32.119 --> 00:40:35.570 and plans. But that's not always going to be best achieved 00:40:35.579 --> 00:40:41.559 by discussing alternatives if none existed. Or if they're 00:40:41.570 --> 00:40:45.418 so out of the box that they're not really that helpful. 00:40:45.429 --> 00:40:48.728 And it's just going to increase the amount of things 00:40:48.739 --> 00:40:51.559 that Staff has to read. And increase the cost of preparing 00:40:51.570 --> 00:40:54.719 these plans. Um yeah. 00:41:01.159 --> 00:41:03.699 All right. This is uh feels like we've had a pretty 00:41:03.708 --> 00:41:06.628 robust discussion on this point. Are we uh 00:41:08.699 --> 00:41:09.478 all right, very good. 00:41:16.260 --> 00:41:16.280 Yeah. 00:41:19.429 --> 00:41:24.780 Um I have a thing on 4B. We have the estimated 00:41:24.789 --> 00:41:27.958 cost of implementing the measures proposed in the resiliency 00:41:27.969 --> 00:41:32.889 plan. Can we add timeline, estimated cost and timeline 00:41:33.360 --> 00:41:35.878 of implementing the measures proposed in the resiliency 00:41:35.889 --> 00:41:36.280 plan? 00:41:39.360 --> 00:41:43.030 So we got some, we got some threes over here. 00:41:45.159 --> 00:41:45.280 So 00:41:47.219 --> 00:41:49.530 Bill, do you have thoughts not on, not on this particular 00:41:49.539 --> 00:41:52.139 question? He's getting, you have another question for 00:41:52.148 --> 00:41:52.978 for the, for the crowd. 00:41:54.659 --> 00:41:56.918 Yeah, go for it. Um So I, I guess I have a 00:41:56.929 --> 00:42:00.570 question on uh on the riders on Part 5 basically. 00:42:00.898 --> 00:42:06.320 Um especially in light of the relative attractiveness 00:42:06.329 --> 00:42:13.168 of the big asset recovery. Um Would there be uh opposition 00:42:13.179 --> 00:42:18.860 to a requirement that the rider uh be limited to the 00:42:18.869 --> 00:42:23.909 DCRF or the TCRF for the non-ERCOT utilities? Or is 00:42:23.918 --> 00:42:28.438 there is a sense that we, we needed to establish, you 00:42:28.449 --> 00:42:33.070 know, the details of a new rider for this. (item:1:George Hoyt with Entergy on riders) George Hoyt on 00:42:33.079 --> 00:42:35.978 behalf of Entergy. Yeah, Bill. Um our point of view is that 00:42:35.989 --> 00:42:40.219 the rider, uh a new rider is, is specified. Is 00:42:40.228 --> 00:42:45.010 dictated by the statute. Um And it, in fact, the statute 00:42:45.019 --> 00:42:47.840 says that in approving or considering, you know, in 00:42:47.849 --> 00:42:49.648 approving a rider. The commission will determine the 00:42:49.659 --> 00:42:51.929 appropriate terms of the rider. And I can't make that 00:42:51.938 --> 00:42:56.898 read correctly if it's just the DCRF. Um So uh the 00:42:56.909 --> 00:43:00.938 DCRF may also have a different scope um of costs they're 00:43:00.949 --> 00:43:04.760 eligible for in this rider. So I, I think that um 00:43:04.909 --> 00:43:09.168 while it, it, you know, I would love for the deferral 00:43:09.179 --> 00:43:12.929 option to be as attractive as possible. Um I think 00:43:12.938 --> 00:43:18.389 that it's appropriate to, you know, allow the Commission 00:43:18.398 --> 00:43:24.128 um to uh adopt a new rider, consistent statue. Okay. 00:43:24.139 --> 00:43:26.659 And obviously, the statute does allow recovery through 00:43:26.668 --> 00:43:31.539 the DCRF or the non-ERCOT TCRF. How do you interpret the 00:43:31.550 --> 00:43:35.349 language requiring the Commission established that 00:43:35.360 --> 00:43:38.168 the terms of the rider and the plan. If the utility 00:43:38.179 --> 00:43:42.780 is not going to seek um, a rider outside the DCRF 00:43:42.789 --> 00:43:44.099 or, or TCRF? 00:43:46.898 --> 00:43:51.909 (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 00:43:51.918 --> 00:43:54.360 would determine the appropriate terms of the rider 00:43:54.369 --> 00:43:57.780 if the utility is not seeking one? Right. It would not 00:43:58.219 --> 00:44:01.110 like it. The utility would have the choice under the 00:44:01.119 --> 00:44:04.378 statute, whether to request a rider when it proposes 00:44:04.389 --> 00:44:07.280 its plan. And if it requests a rider and the Commission 00:44:07.639 --> 00:44:10.409 will then will then determine the appropriate terms 00:44:10.418 --> 00:44:13.579 of the rider, right? So if the utility says I'm not 00:44:13.590 --> 00:44:15.679 requesting a writer, then the Commission doesn't have 00:44:15.688 --> 00:44:17.860 work to do on that front. Yeah. Yeah, I mean, that 00:44:17.869 --> 00:44:20.030 was my interpretation as well. Which suggested, you 00:44:20.039 --> 00:44:25.280 know, maybe if everyone was okay with not requesting 00:44:25.289 --> 00:44:27.510 a separate rider, you know. The rule could specify 00:44:27.519 --> 00:44:30.039 that it, you know, has to be in the DCRF/TCRF. Obviously 00:44:30.050 --> 00:44:34.389 the statute doesn't limit it to that. But if you know 00:44:34.398 --> 00:44:36.199 no one was actually interested in having a separate 00:44:36.208 --> 00:44:38.878 rider that would definitely potentially make things 00:44:38.889 --> 00:44:41.409 a lot easier on drafting rider language on the rule. 00:44:41.418 --> 00:44:44.809 But you know if, if you know what I'm hearing is that 00:44:44.820 --> 00:44:48.110 you, you want, you want the rule to establish 00:44:48.119 --> 00:44:50.570 some stuff about uh an additional rider, resiliency 00:44:50.579 --> 00:44:53.159 rider. So okay, great. That's helpful. Thank you. 00:45:01.500 --> 00:45:04.760 Just a quick follow up. Good morning, everyone. Uh 00:45:04.769 --> 00:45:08.539 I'm just gonna ask a question. Uh is it the utilities 00:45:08.550 --> 00:45:12.929 view that the statute requires or at least contemplates 00:45:12.938 --> 00:45:14.019 a low growth adjustment? 00:45:26.478 --> 00:45:29.938 Brian Lloyd serving the public interest. Oh, wait. 00:45:30.570 --> 00:45:32.570 (item:2:Brian Lloyd with Oncor on DCRF option for distribution invested capital) Um I again Brian Lloyd for Oncor. Um, 00:45:34.099 --> 00:45:36.429 let's, let's kind of talk through that. I, I think 00:45:36.438 --> 00:45:43.639 where you, where a utility uses the DCRF option for 00:45:43.648 --> 00:45:47.619 distribution invested capital. There's already a low 00:45:47.628 --> 00:45:49.760 growth adjustment for that, right? So you're gonna 00:45:49.769 --> 00:45:53.619 kind of pick it up in that one. I think in the 00:45:53.628 --> 00:45:56.909 case where on the invested capital piece and I'll, 00:45:56.918 --> 00:46:00.369 I'll come back to, to another piece in a second. Where 00:46:00.378 --> 00:46:04.590 a utility uses a rider um for Oncor. It's not 00:46:04.599 --> 00:46:06.239 something we thought a lot about using. I think our 00:46:06.250 --> 00:46:09.929 preference is to, is to just use the DCRF. But as 00:46:09.938 --> 00:46:13.228 we thought about it, I think the way the formula works 00:46:13.239 --> 00:46:16.559 in the DCRF is you're effectively picking up all of 00:46:16.570 --> 00:46:20.079 the low growth there. And so if you have a separate 00:46:20.090 --> 00:46:23.760 rider and you want to do low growth on that too, you 00:46:23.769 --> 00:46:25.969 have to then start thinking about, well, how do I portion 00:46:25.978 --> 00:46:29.539 low growth between these two riders because of the 00:46:29.550 --> 00:46:34.019 way that formula works. So I think, I think my current 00:46:34.030 --> 00:46:36.019 thought is if a utility does a rider. You don't need 00:46:36.030 --> 00:46:39.309 to worry about low growth there. Because it's, the 00:46:39.320 --> 00:46:41.949 all of this is limited to distribution invested capital. 00:46:41.958 --> 00:46:45.918 And, and I guess the one caveat would be if a utility 00:46:45.929 --> 00:46:48.199 doesn't have a DCRF, then maybe you pick up something 00:46:48.208 --> 00:46:50.889 there. But assuming a utility is filing both DCRFs 00:46:51.280 --> 00:46:54.320 and a resiliency rider. I think you've already got 00:46:54.329 --> 00:46:58.530 all the low growth accounted for in the DCRFs. Um 00:46:58.739 --> 00:47:01.789 I think then the second piece is on the deferral. It 00:47:01.800 --> 00:47:05.059 is our view that, that section of the statute 00:47:05.070 --> 00:47:08.418 uses the term costs, which is inclusive of both invested 00:47:08.429 --> 00:47:13.289 capital as well as ONM. Then you get to the question 00:47:13.300 --> 00:47:15.688 of, do you need some kind of low growth adjustment 00:47:15.699 --> 00:47:17.610 for that? That one's a little bit harder for me to 00:47:17.619 --> 00:47:21.458 think about. Um I'm not sure you need that because 00:47:21.469 --> 00:47:24.929 you've got, let's say you use vegetation management 00:47:24.938 --> 00:47:27.478 maybe as, as an example. When the utilities rates are 00:47:27.489 --> 00:47:31.559 set, let's say we have $50 million of education management 00:47:31.619 --> 00:47:34.228 in rates. The utility of course, is going to spend 00:47:34.239 --> 00:47:36.708 above or below that every year. So it's a little bit 00:47:36.719 --> 00:47:40.418 different than invested capital. I think what's true 00:47:40.429 --> 00:47:42.909 with what the statute says as well. If you had $50 00:47:42.918 --> 00:47:46.418 million of VM in your base rates. You can't cut that 00:47:46.429 --> 00:47:50.159 to 45 spend 60 then get that whole delta. It would 00:47:50.168 --> 00:47:54.739 only be the increment above that. Um I think if you 00:47:54.750 --> 00:47:57.590 think of the other inflationary pressures that utilities 00:47:57.599 --> 00:48:00.539 have particularly right now. Interest rates, labor 00:48:00.550 --> 00:48:02.679 expenses, things like that. I think the intent of the 00:48:02.688 --> 00:48:05.809 statute is, is to incentivize and motivate these types 00:48:05.820 --> 00:48:10.010 of investments. Um again saying in a rate case that 00:48:10.019 --> 00:48:13.070 $50 million was gonna buy x number of miles of, of 00:48:13.079 --> 00:48:16.699 vegetation management. To, to it's just hard for me to 00:48:16.708 --> 00:48:20.418 think of a how a low growth adjustment to that individual 00:48:20.429 --> 00:48:24.019 component of the O and M cost of service really makes 00:48:24.030 --> 00:48:28.889 any sense in this context. So um so I I to to 00:48:28.898 --> 00:48:31.628 give you the shorter answer. I think, I think on invested 00:48:31.639 --> 00:48:33.739 capital, I think we argue is, I think it's taken care 00:48:33.750 --> 00:48:36.739 of in the DCRF piece on the deferral piece. And again 00:48:36.750 --> 00:48:39.989 we can maybe get to, when does the deferral get recovered. 00:48:40.000 --> 00:48:41.570 Does that have to wait to the rate case? Is there a 00:48:41.579 --> 00:48:44.659 component of DCRF that starts to recover that, that 00:48:44.668 --> 00:48:47.239 reg asset piece? I don't think we view that there's 00:48:47.250 --> 00:48:50.079 a low growth piece. That's there. The one other analogy 00:48:50.090 --> 00:48:53.389 I use is, is um kind of storm costs, right? When, when 00:48:53.398 --> 00:48:56.179 a utility books storm costs to its deferred account 00:48:56.688 --> 00:48:59.409 those costs just get booked. There's no, there's no 00:48:59.418 --> 00:49:02.909 offset to that for some, some calculation as to what 00:49:02.918 --> 00:49:05.179 the low growth looks like between your last rate case 00:49:05.188 --> 00:49:07.300 and when your storm occurred. And things like that 00:49:07.309 --> 00:49:09.458 It's kind of a fixed amount of dollars that then kind 00:49:09.469 --> 00:49:11.789 of rolls in. Now you do get the benefit of low growth 00:49:11.800 --> 00:49:14.019 right? Whenever you set the rate as you have low growth 00:49:14.030 --> 00:49:15.860 your billing units will grow. So that rate will get 00:49:15.869 --> 00:49:18.079 basically get bought down by those billing units. 00:49:18.090 --> 00:49:20.429 So I think that's, I think our view is it all kind 00:49:20.438 --> 00:49:23.119 of works without some kind of other explicit adjustment 00:49:23.128 --> 00:49:28.128 there. That makes sense? Yeah I, I mean, I think uh huh 00:49:29.449 --> 00:49:32.809 just speaking for myself. I mean, I think you identify 00:49:32.820 --> 00:49:38.800 and have addressed some of the potential nuanced complexities 00:49:38.809 --> 00:49:42.469 of trying to incorporate specific language in a rule. 00:49:42.760 --> 00:49:44.989 Um I just looked at some of these things this morning 00:49:45.000 --> 00:49:46.668 and I just looked a short while ago. I said language 00:49:46.679 --> 00:49:51.809 in 36.210 the DCRF legislation regarding Load growth. 00:49:51.820 --> 00:49:54.610 and the language, there is different from the language 00:49:54.619 --> 00:49:58.570 in this Bill. And it, it, that's why I kind of framed 00:49:58.579 --> 00:50:01.570 the question as is it, is it required? Or is does it 00:50:01.619 --> 00:50:05.760 does the statute at least contemplate the uh a growth 00:50:05.769 --> 00:50:08.119 adjustment? And I think, I think I heard you say the 00:50:08.128 --> 00:50:10.938 answer is kind of depends. (item:2:Brian Lloyd with Oncor on DCRF statute) Well I mean again, I mean 00:50:10.949 --> 00:50:13.289 one of the options for recovery then refers back to 00:50:13.300 --> 00:50:15.989 the DCRF statute, right? So again, you kind of pick 00:50:16.000 --> 00:50:19.438 it up there. And again, whether anybody at the capital 00:50:19.449 --> 00:50:22.648 thought about this or not. Because we're talking about 00:50:22.659 --> 00:50:25.938 just a potential different recovery mechanism for some 00:50:25.949 --> 00:50:28.929 distribution costs. And, and we have no doubt that if 00:50:28.938 --> 00:50:30.918 it's in DCRF, it can't be in some other rider right. 00:50:30.929 --> 00:50:33.378 I think the statute is clear on that as well. Something 00:50:33.389 --> 00:50:34.938 is in base rate. You can't kind of come and get it 00:50:34.949 --> 00:50:38.539 over here. I, I think when you go look at even if 00:50:38.550 --> 00:50:41.070 you do the right or how the low growth adjustment works 00:50:41.079 --> 00:50:43.938 in DC R, I think you pick it all up there already 00:50:44.320 --> 00:50:47.070 And, and again, maybe your one caveat is if the utility 00:50:47.079 --> 00:50:51.030 is not using the DCRF and is getting some distribution 00:50:51.039 --> 00:50:53.938 capital here. Do you think about maybe that's where 00:50:53.949 --> 00:50:56.550 that adjustment shows up? But then again, as you as 00:50:56.559 --> 00:50:58.639 a utility layers in these things, if they're using 00:50:58.648 --> 00:51:00.929 both mechanisms, you gotta, you gotta think about double 00:51:00.938 --> 00:51:05.539 counting of that adjustment. Uh Well, interesting cause 00:51:05.550 --> 00:51:08.820 cause uh uh I was talking with someone else this morning 00:51:08.829 --> 00:51:11.539 a bill. Um And uh we were talking about some of those 00:51:11.550 --> 00:51:15.250 very things, just the potential risk. I'll call it 00:51:15.269 --> 00:51:19.010 potential risk of some sort of double counting thing 00:51:19.019 --> 00:51:21.929 that that could inadvertently happen. And we just were 00:51:21.938 --> 00:51:24.159 trying to see, we're trying to think about whether 00:51:24.500 --> 00:51:26.590 there may be some sort of specific rule language that 00:51:26.599 --> 00:51:29.389 could make sure that that does not happen. (item:2:Brian Llyod with Oncor on low growth adjustment in multiple places) Yeah, I 00:51:29.398 --> 00:51:31.128 mean, I think, I think it's the case that you can't 00:51:31.139 --> 00:51:34.188 get the same thing in multiple places. I think it has 00:51:34.199 --> 00:51:37.519 to also be the case. You can't make the same low growth 00:51:37.530 --> 00:51:40.898 adjustment in multiple places as well. So I think that's 00:51:40.909 --> 00:51:44.469 the general principle. Again, I wrap my brain in knots 00:51:44.478 --> 00:51:46.199 around this when I first started thinking about how 00:51:46.208 --> 00:51:48.250 these things might work together. But that 00:51:48.260 --> 00:51:51.628 was kind of where, where our team kind of got on. We 00:51:51.639 --> 00:51:53.550 think it's all on the capital piece. We think it's 00:51:53.559 --> 00:51:56.489 all handled there on any kind of ONM pieces. In a, in 00:51:56.500 --> 00:51:59.148 a deferred asset. We don't think that, we don't think 00:51:59.159 --> 00:52:03.219 that's necessary. Thank you, Brian. You're welcome. I'm a 00:52:03.239 --> 00:52:03.849 (inaudible) 00:52:18.800 --> 00:52:21.478 And those last two speakers from Staff side were Bill 00:52:21.489 --> 00:52:23.539 Abbott and Darryl. They, they just started here. So 00:52:23.550 --> 00:52:24.978 they don't know about the convention of saying your 00:52:24.989 --> 00:52:27.349 name when you finished speaking. 00:52:27.360 --> 00:52:31.159 (item:2:John Ross Hubbard with TIEC on riders) John Ross Hubbard with TIEC. Um Darryl, to your question about whether 00:52:31.168 --> 00:52:33.708 or not the rider should include low growth. That 00:52:33.719 --> 00:52:37.438 we it's our position that it should. Um even though 00:52:37.449 --> 00:52:41.989 it is part of DCRF. It, a rider should include uh 00:52:42.000 --> 00:52:47.840 load growth adjustments. Uh George has a retort. 00:52:51.438 --> 00:52:54.500 (item:2:George Hoyt with Entergy on load growth adjustment) Darryl as you pointed out um you know, the DCRF statute 00:52:54.510 --> 00:52:57.030 expressly calls for load growth adjustment. The TCRF 00:52:57.039 --> 00:53:00.719 does not and it doesn't have one. The GCRR does not 00:53:00.728 --> 00:53:04.610 and it doesn't have one. Load growth adjustment is accounted 00:53:04.619 --> 00:53:07.878 for when you you know, factor in current building determinants 00:53:07.889 --> 00:53:11.429 and the rider. So it's going to take account as Oncor 00:53:11.809 --> 00:53:15.188 suggested for low growth already. We don't need a second 00:53:15.199 --> 00:53:16.519 adjustment for that in the rider. 00:53:25.679 --> 00:53:27.750 I need to think on that more. I just wanna make sure 00:53:27.760 --> 00:53:32.708 that it's uh that, that it's being accounted in some 00:53:32.719 --> 00:53:35.139 capacity. Uh 00:53:36.909 --> 00:53:37.320 Yeah. 00:53:40.530 --> 00:53:43.579 I'm sure our rates, folks might have something to put 00:53:43.590 --> 00:53:47.909 in the rule language. And comments will be considered on 00:53:47.918 --> 00:53:51.050 that at that point too. Ok. So we're having a lot of 00:53:51.059 --> 00:53:57.250 fun in um, paragraph five. Does anybody else, uh does 00:53:57.260 --> 00:53:59.708 anyone else have any questions that are either on this 00:53:59.719 --> 00:54:02.849 paragraph or the larger subsection that we're currently 00:54:02.860 --> 00:54:04.539 nuzzled into that? 00:54:11.019 --> 00:54:13.800 (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 00:54:13.809 --> 00:54:17.168 questions was what types of costs are gonna be eligible 00:54:17.179 --> 00:54:20.000 to be in different recovery mechanisms. I don't know 00:54:20.010 --> 00:54:23.228 if that's a discussion that people want have today 00:54:23.239 --> 00:54:27.280 or not? Or rate thinks they understand what they need 00:54:27.289 --> 00:54:28.070 for this sort of thing. 00:54:31.668 --> 00:54:33.929 All right. We're good. 00:54:35.449 --> 00:54:39.760 Yeah. Okay. See, I guess let's uh let's see what's next. 00:54:39.769 --> 00:54:40.639 Let's scroll a little bit. 00:54:50.789 --> 00:54:53.168 Approve, modifier or deny. I think that's interesting. 00:54:53.349 --> 00:54:53.918 Um 00:54:57.989 --> 00:55:00.070 the modification seems weird that we would modify it 00:55:00.079 --> 00:55:02.139 not through settlement agreement, but maybe the commissioners 00:55:02.148 --> 00:55:03.260 would order different things 00:55:05.139 --> 00:55:08.168 anyway. Uh there's not discussion on that. I'm just 00:55:08.179 --> 00:55:09.800 reflecting on how I could see it would put you guys 00:55:09.809 --> 00:55:11.969 in a weird position if we were ordering weird modifications 00:55:11.978 --> 00:55:15.739 to your plans. Um okay. Updated resiliency plans. Any 00:55:15.750 --> 00:55:18.260 thoughts on this subsection? 00:55:23.110 --> 00:55:25.280 Another perfect subsection. This is fantastic 00:55:29.050 --> 00:55:30.000 Costs. 00:55:31.938 --> 00:55:36.898 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 00:55:36.909 --> 00:55:41.320 was I had a question about the language in one, starting 00:55:41.329 --> 00:55:44.000 with an electric utility may calculate the incremental 00:55:44.010 --> 00:55:47.500 operations and maintenance costs. Is this referring 00:55:47.510 --> 00:55:54.019 to in a rider or in what context? I just 00:55:54.030 --> 00:55:56.280 wasn't sure of the purpose of this language. 00:56:00.389 --> 00:56:02.559 Again, this was an industry draft. So I, I wanna to 00:56:02.570 --> 00:56:03.820 pine on, yeah. 00:56:06.849 --> 00:56:09.458 (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 00:56:09.469 --> 00:56:11.918 our perspective, the way we were thinking of it. As 00:56:11.929 --> 00:56:15.719 as, as costs that would be booked to the deferred asset. 00:56:15.869 --> 00:56:18.648 And, you know, again I use VM as the example. It sort 00:56:18.659 --> 00:56:22.128 of called on specifically in the bill identifiable 00:56:22.139 --> 00:56:24.510 in the cost of service study. The, the language here 00:56:24.519 --> 00:56:26.699 we had sort of about kind of how you might calculate 00:56:26.708 --> 00:56:30.510 that was sort of one way of doing that. Where, you know 00:56:30.769 --> 00:56:33.059 as a utility that just got the pleasure of going through 00:56:33.070 --> 00:56:35.570 a fully litigated rate case. Um That's a rarely available 00:56:35.579 --> 00:56:37.728 kind of thing for us and was sort of an easy way 00:56:37.739 --> 00:56:40.929 to do the end. There was sort of a there might need 00:56:40.938 --> 00:56:43.110 to be another method where you've had some case, get 00:56:43.119 --> 00:56:46.039 settled in the past there. But at least from our perspective 00:56:46.050 --> 00:56:48.668 the idea was that this is, this is part of what is 00:56:48.679 --> 00:56:51.760 eligible for the deferred, deferred asset there. So 00:56:51.769 --> 00:56:55.179 it would take place in the rate case most likely. Um 00:56:55.188 --> 00:56:58.599 So again, I think we'll get to that later. I think 00:56:58.610 --> 00:57:01.610 ultimately, these costs all get reconciled in a rate 00:57:01.619 --> 00:57:06.949 case. Again, whether the deferred asset um starts to 00:57:06.958 --> 00:57:10.219 get recovered as part of a DCRF, including an OMN. 00:57:10.228 --> 00:57:14.329 That, that's booked there. We think the statute contemplates 00:57:14.340 --> 00:57:17.659 that and, and whether that, whether there's language 00:57:17.789 --> 00:57:20.829 about how that formula DCRF formula works. Or if there's 00:57:20.840 --> 00:57:23.469 a separate rider. Like we're doing a temporary gen 00:57:24.070 --> 00:57:27.550 whether that's in here or a DCRF amendment, I think 00:57:27.559 --> 00:57:29.510 we would probably kind of look at you all as to where 00:57:29.519 --> 00:57:32.260 you, where you might prefer that that happening. Um 00:57:33.019 --> 00:57:35.188 But I think there's no doubt that these costs ultimately 00:57:35.199 --> 00:57:38.030 get reconciled at the end of the day. And so again 00:57:38.039 --> 00:57:41.639 my example was, well, you had $50 million in your, 00:57:42.260 --> 00:57:44.909 in your residency plan, you had cut it and then increased 00:57:44.918 --> 00:57:47.030 it back a little bit. That would be fair game for people 00:57:47.039 --> 00:57:49.978 to say, well, no, there was, there was adequate money 00:57:49.989 --> 00:57:53.228 in your case. See, here's the line item and you didn't 00:57:53.239 --> 00:57:55.250 spend up to that. Therefore, there's nothing incremental 00:57:55.260 --> 00:57:57.090 there, but that would be fair. That that's of course 00:57:57.099 --> 00:57:59.000 fair game if it had come in through the rider at some 00:57:59.010 --> 00:57:59.289 point. 00:58:01.360 --> 00:58:03.449 (item:2:John Ross Hubbard with TIEC on language concerns) Uh I guess we're just struggling with the language 00:58:03.458 --> 00:58:05.530 a little bit because it seems like in a rate case, 00:58:05.539 --> 00:58:08.610 this would be automatic. And so why does this language 00:58:08.619 --> 00:58:09.260 need to exist? 00:58:10.958 --> 00:58:17.188 What's automatic that it would account for the like 00:58:17.199 --> 00:58:20.228 that? I would look at the ONM and it would 00:58:20.239 --> 00:58:22.289 be reference the amounts and it would reconcile the 00:58:22.300 --> 00:58:22.889 two. 00:58:24.510 --> 00:58:27.739 (item:2:Brian Lloyd with Oncor on reference clarification) Well, so yeah so let's again. Let's, let's take maybe 00:58:27.769 --> 00:58:31.059 Oncor as an example. We had a test year of 2021 for 00:58:31.070 --> 00:58:33.208 a rate case. Again, I'm just picking a number. It says 00:58:33.219 --> 00:58:36.208 it's $50 million in vegetation management. We file 00:58:36.219 --> 00:58:39.648 our resiliency plan next year. We say, hey, upping 00:58:39.659 --> 00:58:43.000 the vegetation management budget to $75 million really 00:58:43.010 --> 00:58:46.090 handles resiliency in this particular area of our, 00:58:46.099 --> 00:58:48.179 of our service territory Commission says absolutely 00:58:48.188 --> 00:58:51.289 we agree with you. Then that incremental 25 starts 00:58:51.300 --> 00:58:54.090 to get booked to the deferred asset. And again, whether 00:58:54.099 --> 00:58:57.550 recovery starts in the DCRF or whether recovery waits 00:58:57.559 --> 00:59:00.969 for the rate case in either event that gets reconciled 00:59:00.978 --> 00:59:03.280 and looked at in the rate case, did you in fact spend 00:59:03.289 --> 00:59:07.659 70 that incremental money on VM? That makes sense. 00:59:07.719 --> 00:59:09.369 Yeah, that makes sense. Yeah, thank you. 00:59:11.119 --> 00:59:12.878 And again, is the easy one to kind of think about. 00:59:12.889 --> 00:59:14.719 There may be other ONM things that are a little 00:59:14.728 --> 00:59:17.429 bit harder to suss out kind of what exactly that is. 00:59:17.438 --> 00:59:20.128 And again, that I think that obligation is on us as 00:59:20.139 --> 00:59:22.840 part of the resiliency plan to say. Okay, here's the 00:59:22.849 --> 00:59:25.599 incremental spend from what we think was in the right 00:59:25.610 --> 00:59:27.949 case. And again, that that would be fair game for folks 00:59:27.958 --> 00:59:30.570 or again, later in the reconciliation, I, I think we 00:59:30.579 --> 00:59:33.099 fully expect folks to kind of say we don't think you 00:59:33.110 --> 00:59:35.090 calculate that right. And we would have that, that 00:59:35.099 --> 00:59:36.289 discussion there. 00:59:39.510 --> 00:59:43.179 (item:2:George Hoyt with Entergy on rider in regard to capital & ONM) Same topic. Um George Hoyt again for Entergy. Um I 00:59:43.188 --> 00:59:46.478 think that the, the rider scope with regard to capital 00:59:46.550 --> 00:59:48.719 and ONM ought to be the same as the deferral. I can't 00:59:48.728 --> 00:59:52.110 see a reason why it wouldn't. Um But is with regard 00:59:52.119 --> 00:59:54.840 to the ONM incremental ONM expense. I mean 00:59:54.849 --> 00:59:57.809 I think this recognizes that you, you could begin a 00:59:57.820 --> 01:00:01.059 deferral in between rate cases because your plans approved 01:00:01.360 --> 01:00:04.099 So the Commission says go forth and do these measures 01:00:04.110 --> 01:00:06.978 They have ONM associated with them and then you 01:00:06.989 --> 01:00:09.148 are only recovering what was established in your rate 01:00:09.159 --> 01:00:11.469 case. This is incremental to it. And so that's the 01:00:11.478 --> 01:00:13.949 idea of a deferral is that you don't lose that expense 01:00:13.958 --> 01:00:16.789 you preserve it for future recovery. So this is, um 01:00:16.800 --> 01:00:19.500 I think part of this is designed to get at incremental 01:00:19.510 --> 01:00:20.769 costs in between rate cases. 01:00:23.918 --> 01:00:29.539 (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. 01:00:30.010 --> 01:00:38.389 PUC Staff for the last um, two weeks. Um And I apologize 01:00:38.398 --> 01:00:42.250 that this is sort of in the utilities draft rule. Uh 01:00:42.260 --> 01:00:45.789 Maybe I just need to read it more closely. I is it 01:00:46.728 --> 01:00:50.889 do the utilities believe that at the time they filed 01:00:50.898 --> 01:00:55.179 the plan that there is any sort of Commission discretion. 01:00:55.829 --> 01:00:58.168 or to what degree is there, Commission discretion with 01:00:58.179 --> 01:01:01.340 regard to the amount of the costs that are included 01:01:01.349 --> 01:01:05.469 in the plan stated in another way is, is during the 01:01:05.478 --> 01:01:07.389 Commission's consideration of the plan and all the 01:01:07.398 --> 01:01:11.239 party's consideration of the plan, is that a time where 01:01:11.250 --> 01:01:14.918 the, the cost amounts are contestable to any degree 01:01:14.929 --> 01:01:17.679 Or is that, is this kind of okay, here's the plan. It's 01:01:17.909 --> 01:01:22.809 $100 Commission approve it and we'll argue about the 01:01:22.820 --> 01:01:23.559 amounts later. 01:01:25.519 --> 01:01:28.139 To what degree is it contestable in the plan versus 01:01:28.148 --> 01:01:31.929 the final true review in a comprehensive rate case 01:01:32.019 --> 01:01:34.250 (item:2:Brian Lloyd with Oncor on general costs) Yeah I, I think I understand your question. Let me 01:01:34.260 --> 01:01:35.889 let me, let me sort of try it this way. I, I 01:01:35.898 --> 01:01:38.438 think our view is that the Commission is gonna want 01:01:38.449 --> 01:01:43.079 to know as it approves a plan and components of a plan 01:01:43.728 --> 01:01:47.489 What does everybody think that's gonna cost? So again 01:01:47.500 --> 01:01:51.128 let's say vegetation management. Um as, as one example 01:01:51.139 --> 01:01:54.148 us doing X number of more miles is gonna cost Y number 01:01:54.159 --> 01:01:57.030 of dollars now again, and they ultimately cost a different 01:01:57.039 --> 01:02:00.469 amount. But the Commission is saying, ok, yes, in concept 01:02:02.070 --> 01:02:05.550 this number of miles or this number of amount of incremental 01:02:05.559 --> 01:02:08.269 cost we think is a, is the correct thing to do as 01:02:08.280 --> 01:02:10.260 part of your resiliency plan. We think the Commission 01:02:10.269 --> 01:02:11.909 can change that. I mean, I think that goes back to 01:02:11.918 --> 01:02:14.148 the prior discussion on, on, maybe that's where modify 01:02:14.159 --> 01:02:16.889 comes in. You know, I really, I don't really want you 01:02:16.898 --> 01:02:18.878 to spend another $100 million. Maybe I want you to 01:02:18.889 --> 01:02:21.918 spend $75 million on this. Um, but again, the ultimate 01:02:21.929 --> 01:02:25.628 then expense gets reconciled later is I don't think 01:02:25.639 --> 01:02:27.320 we view and I think the statute is clear about this 01:02:27.329 --> 01:02:30.579 that you're fixing in necessarily the dollar spent 01:02:31.179 --> 01:02:33.550 You may, I mean, the utility may say I want to spend 01:02:33.559 --> 01:02:36.019 X dollars and the Commission may approve that utility 01:02:36.030 --> 01:02:39.188 may say I want to do vegetation management for X number 01:02:39.199 --> 01:02:41.668 of more miles. I think when you think of the capital 01:02:41.679 --> 01:02:45.320 piece, similarly, I'm gonna spend this amount of money 01:02:45.329 --> 01:02:48.349 to change out wood poles, the composite poles or, or 01:02:48.360 --> 01:02:51.280 something like that. I think the Commission is using 01:02:51.289 --> 01:02:54.978 at that point, the cost numbers as an assessment of 01:02:54.989 --> 01:02:56.929 what does this, does this feel like the right thing 01:02:56.938 --> 01:02:59.800 to do for the dollars? And, and what, what the utility 01:02:59.809 --> 01:03:01.889 has proposed or the Commission concludes is the benefit 01:03:01.898 --> 01:03:05.500 from that again, between a plan being approved and 01:03:05.510 --> 01:03:08.329 then the investment going into service and then the 01:03:08.340 --> 01:03:11.909 rate case, the cost of things may change. And I think 01:03:11.918 --> 01:03:13.478 the statute is clear that you're not, you're not sort 01:03:13.489 --> 01:03:16.500 of locking people into their forecast at the time again 01:03:16.510 --> 01:03:18.369 The utility still has the obligation to prove it was 01:03:18.378 --> 01:03:22.239 it was prudently incurred and all that. Um But, but 01:03:22.250 --> 01:03:24.469 I think that's, I think that's how you think about 01:03:24.478 --> 01:03:27.099 where the costs come into this. (item:2:Darryl Tietjen on costs being overstated) And, and I guess Brian 01:03:27.110 --> 01:03:30.418 my concern is just speaking for myself again, is that 01:03:30.938 --> 01:03:33.619 to the extent that part of you say, you know what this 01:03:33.628 --> 01:03:36.478 cost is way overstated or this estimated cost is way 01:03:36.489 --> 01:03:40.699 overstated, it essentially becomes what so often happens 01:03:40.708 --> 01:03:43.398 around here becomes essentially the equivalent of a 01:03:43.409 --> 01:03:46.378 comprehensive rate case. So the companies file their 01:03:46.389 --> 01:03:51.199 their plan TIEC, Staff, whomever said. You know what 01:03:51.208 --> 01:03:53.708 this is, you know, this is the way overstate it. It 01:03:53.719 --> 01:03:57.750 should be something less. Well, ok. Uh let's do a procedure 01:03:57.760 --> 01:04:00.179 schedule all these parties, file testimony, staff files 01:04:00.188 --> 01:04:04.139 testimony goes to hearing that's sort of my concern 01:04:04.148 --> 01:04:07.000 or my question. How does that process work or is that 01:04:07.010 --> 01:04:12.050 even contemplated as part of what the process is supposed 01:04:12.059 --> 01:04:14.500 to be or what it will inevitably? 01:04:17.929 --> 01:04:21.159 (item:2:Brian Lloyd with Oncor on structure of rider language) I mean let me, let me try, try this. I don't 01:04:21.168 --> 01:04:24.010 think you're setting a rate as part of these plans 01:04:24.708 --> 01:04:28.378 You may be approving a structure of a rider and the 01:04:28.389 --> 01:04:30.829 rider language has some suggestions on how that thing 01:04:30.840 --> 01:04:34.739 gets filed and updated for that process. I think, I 01:04:34.750 --> 01:04:37.110 think what the Commission is approving is elements 01:04:37.119 --> 01:04:39.909 of the plan. It is using potentially things like costs 01:04:39.918 --> 01:04:43.099 as its assessment is, is this in the public interest 01:04:43.110 --> 01:04:46.079 for me to approve or whatever languages there. But 01:04:46.090 --> 01:04:49.889 you're not setting a rate per se out of this with the 01:04:49.898 --> 01:04:53.699 recognition that later all of this gets reconciled 01:04:53.719 --> 01:04:56.030 in, in, I think at least the way we're thinking about 01:04:56.039 --> 01:04:58.590 it in the next comprehensive rate case, the way DCRF 01:04:58.599 --> 01:05:01.978 and interim T cost gets, gets reconciled. Does that help? 01:05:02.590 --> 01:05:05.809 (item:2:Liz Jones with Oncor on costs) So and, and I would add because sometimes more people 01:05:05.820 --> 01:05:10.750 from Oncor are better. Liz Jones with Oncor. Um So for 01:05:10.760 --> 01:05:14.590 instance, in a CCN proceeding, we talk about costs 01:05:14.599 --> 01:05:17.648 and their estimates and they may deviate in the end 01:05:17.878 --> 01:05:22.978 But the cost as the cost estimate helps the Commission 01:05:22.989 --> 01:05:26.878 evaluate its options under that proceeding. And I would 01:05:26.889 --> 01:05:30.030 envision something similar happening inside of a resiliency 01:05:30.039 --> 01:05:34.369 plan case. So, so you're saying the the sort of a reasonable 01:05:34.378 --> 01:05:38.780 comparison point are CNN is a CCN proceeding? I think 01:05:38.840 --> 01:05:42.648 so. (item:2:Brian Lloyd with Oncor's follow-up to costs) Yeah. And I think in the evaluation of the plan 01:05:42.659 --> 01:05:45.110 a utility that says, hey, me underground, this many 01:05:45.119 --> 01:05:48.250 miles is going to cost X. I think parties would be 01:05:48.260 --> 01:05:50.760 free to come in and say they are a low ball on 01:05:50.769 --> 01:05:52.809 that, don't you? If you approve that this thing is 01:05:52.820 --> 01:05:54.570 going to be way more expensive and, and again, that 01:05:54.579 --> 01:05:57.269 can be that the Commission can consider what everybody 01:05:57.280 --> 01:05:59.688 argues that evidence is in deciding whether to approve 01:05:59.699 --> 01:06:02.239 the plan. But, but I don't think you're locking in 01:06:02.250 --> 01:06:04.809 any of the costs in the same way as Liz said, you 01:06:04.820 --> 01:06:06.219 don't lock those in, in a CCN. 01:06:08.000 --> 01:06:11.188 (item:2:Sam Chang with CenterPoint Energy) Yeah, Darryl and just strategically, parties may choose 01:06:11.199 --> 01:06:14.128 to challenge costs during the resiliency plan review 01:06:14.139 --> 01:06:17.329 time just to preserve their ability to challenge it 01:06:17.570 --> 01:06:20.478 come reconciliation time. But practically that might 01:06:20.489 --> 01:06:20.929 happen. 01:06:23.418 --> 01:06:26.148 (item:2:Brian Lloyd with Oncor on cost locking) I think. So, I think one, one additional point, I think. On 01:06:26.159 --> 01:06:28.418 on the cost one and, and I think why we think it's 01:06:28.429 --> 01:06:31.309 very important that you, you're not locking the costs 01:06:31.628 --> 01:06:34.010 here is I, I think at least the way we view the 01:06:34.019 --> 01:06:37.789 statute is once the Commission approves a plan absent 01:06:37.800 --> 01:06:40.349 you getting a good cause exception, you're expected 01:06:41.110 --> 01:06:44.728 they may be required to do the plan. And so for a 01:06:44.739 --> 01:06:48.079 utility to say, look, we think it's going to cost if 01:06:48.090 --> 01:06:50.898 it ends up costing two acts and the utility comes in 01:06:50.909 --> 01:06:53.500 and says, I don't, we like a good cause exception to 01:06:53.510 --> 01:06:55.909 maybe not do this now. And the Commission says too 01:06:55.918 --> 01:06:58.320 bad, you got to do it. I don't think you can then 01:06:58.329 --> 01:07:02.090 say, ha ha gotcha. So I think that's why we think ultimately 01:07:02.099 --> 01:07:04.159 the, the ultimate rate proceeding and reconciliation 01:07:04.168 --> 01:07:06.349 is a place you look at where those reasonable costs 01:07:06.780 --> 01:07:09.208 And if, if again, a Commission thinks something is 01:07:09.219 --> 01:07:10.610 I'm sorry, if the utility, think something is blown 01:07:10.619 --> 01:07:13.469 out there is this good cause exception but absent that 01:07:13.478 --> 01:07:15.898 we, we think the expectation of the Commission is going 01:07:15.909 --> 01:07:18.989 to be, you go do everything we told you that we approved 01:07:19.000 --> 01:07:22.958 you doing. So, Brian, you're trying to use the burden 01:07:22.969 --> 01:07:26.059 is always on the utility argument. Well, I mean, what 01:07:26.070 --> 01:07:29.099 I'm saying is that there is a difference here from 01:07:29.110 --> 01:07:33.128 other things where the utility, where the Commission 01:07:33.139 --> 01:07:36.208 is, in essence buying into this plan and telling a 01:07:36.219 --> 01:07:39.519 utility. Yes, this is a good thing for you to go do 01:07:39.530 --> 01:07:41.300 and we believe it's in the public interest for the 01:07:41.309 --> 01:07:43.559 benefits that presumably the Commission is going to 01:07:43.570 --> 01:07:46.918 find in approving these plans. And that that's different 01:07:46.929 --> 01:07:48.958 than a lot of other things that's different than almost 01:07:48.969 --> 01:07:51.329 everything else we do. Maybe with the exception of 01:07:51.860 --> 01:07:54.148 even energy efficiency, I think there's some kind of 01:07:54.159 --> 01:07:57.050 bandwidth to move money around here. But again, depending 01:07:57.059 --> 01:07:59.119 on how these plans are presented and how the Commission 01:07:59.128 --> 01:08:02.148 approves it, we think that's a buy in from both the 01:08:02.159 --> 01:08:05.829 utility and the regulator that these are worthwhile 01:08:05.840 --> 01:08:10.309 efforts to do and you gotta come ask to not do them 01:08:10.320 --> 01:08:10.849 at that point. 01:08:15.918 --> 01:08:18.338 Cool, thank you, Brian. (item:2:David Smeltzer with Commission Staff on question on rate cases) So this, this is maybe just 01:08:18.350 --> 01:08:22.087 me not knowing a lot about how rate cases work and 01:08:22.099 --> 01:08:24.729 asking you to teach me in public. So that's fine. Um 01:08:25.958 --> 01:08:28.449 I, I get the idea that, you know, when we approve a 01:08:28.458 --> 01:08:30.649 measure, you don't have complete cost certainty. So 01:08:30.659 --> 01:08:33.619 on the tail end we're evaluating. Okay. But is the money 01:08:33.628 --> 01:08:35.439 that you did spend prudent? Like, you know, you're 01:08:35.449 --> 01:08:38.168 not over bidding, whatever. Uh when you talk about 01:08:38.180 --> 01:08:40.449 the idea that and I think this makes sense that in 01:08:40.458 --> 01:08:42.770 some cases, there might actually the plan might be 01:08:42.779 --> 01:08:44.560 a dollar figure, like, ok, we just want to spend X 01:08:44.569 --> 01:08:48.878 amount. And so then on the tail end prudency determination 01:08:49.140 --> 01:08:52.310 uh you wouldn't be able to guarantee just like before 01:08:52.319 --> 01:08:55.009 that X amount would, you know, the, the financial world 01:08:55.020 --> 01:08:57.298 might change and so would, would the prudency determination 01:08:57.310 --> 01:09:00.640 in the background be like? Well, did you do as much 01:09:00.649 --> 01:09:02.310 vegetation management as you should have been able 01:09:02.319 --> 01:09:04.279 to do with this much money? And if not, we're gonna 01:09:04.289 --> 01:09:07.079 take some of it back like, or is that, is that something 01:09:07.088 --> 01:09:09.168 that a rate case can handle if it's structured in that 01:09:09.180 --> 01:09:12.509 way or you get? That makes sense? (item:2:Brian Lloyd with Oncor on how are constructed) Yeah, I mean I, I 01:09:12.520 --> 01:09:14.759 I see the point there. I think um 01:09:16.600 --> 01:09:18.720 I again, I mean, it gets, it gets the kind of how 01:09:18.729 --> 01:09:21.770 the plans are constructed. I think we, we again where 01:09:21.779 --> 01:09:26.409 the metric or the, the plan is again, miles of em or 01:09:26.418 --> 01:09:29.640 or a general description of, of underground or, or 01:09:29.649 --> 01:09:32.640 some of the other resiliency kind of things that looks 01:09:32.649 --> 01:09:34.859 much more similar. I think if somebody does propose 01:09:34.869 --> 01:09:38.509 a, we're gonna spend X dollars and then the question 01:09:38.520 --> 01:09:40.939 is later is a, well, what, what did you get for the 01:09:40.949 --> 01:09:44.859 X dollars? Um I mean, my gut is, there's, there's still 01:09:44.869 --> 01:09:47.899 a prudency review there, right? I can't, I can't tell 01:09:47.909 --> 01:09:53.079 you $75 million is gonna buy you 1000 miles of additional 01:09:53.088 --> 01:09:55.958 vegetation management and then do two miles. I think 01:09:55.970 --> 01:09:58.378 there's got to be kind of a sanity check, right. So 01:09:58.390 --> 01:10:00.489 intellectual, I understand how you might do that analysis 01:10:00.500 --> 01:10:03.319 but I have not worked enough for, I have not worked 01:10:03.329 --> 01:10:06.798 rates cases. So I think is that sort of analysis achievable 01:10:06.810 --> 01:10:10.359 in the rate case context. And I will tell you our view 01:10:10.369 --> 01:10:13.909 is there um people have, have appeared to have more 01:10:13.918 --> 01:10:16.119 than adequate time to address a wide range of issues 01:10:16.128 --> 01:10:18.949 in rate cases. And I can't imagine this one adds much 01:10:18.958 --> 01:10:22.100 more to the colonoscopy that comes in that proceeding. 01:10:22.109 --> 01:10:23.819 So I'll take it. 01:10:25.680 --> 01:10:28.279 (item:2:George Hoyt with Entergy on cost effective measures) Yeah, I would just add. I think, you know, the utility 01:10:28.289 --> 01:10:30.399 having the burden approved to establish that the measures 01:10:30.409 --> 01:10:34.289 are cost effective. Um That may be a challenge if I 01:10:34.298 --> 01:10:38.810 say tell me $65 million is cost effective. Um The utilities 01:10:38.819 --> 01:10:41.619 I think are gonna do more than that. Um So I'm not 01:10:41.628 --> 01:10:45.270 too worried about that example. Um But where utility 01:10:45.279 --> 01:10:48.640 is outlining specific components of a plan measures 01:10:48.649 --> 01:10:51.458 this many poles in this places, this kind of stuff 01:10:51.470 --> 01:10:54.659 those projects are not the decision to proceed with 01:10:54.668 --> 01:10:57.708 that project is not subject to reconsideration once 01:10:57.720 --> 01:11:02.418 it's approved. Um the, the way your prudence determination 01:11:02.430 --> 01:11:04.489 at that point is how you implemented the project and 01:11:04.500 --> 01:11:07.680 whether you, you know, you you executed it prudently 01:11:07.890 --> 01:11:10.319 um, spent the costs prudently, that sort of thing. 01:11:11.659 --> 01:11:13.899 (item:2:Brian Lloyd with Oncor on elevation of substation) Yeah, I'm just, maybe to help you think about it. I 01:11:13.909 --> 01:11:15.850 mean, let's, let's take an elevation of a substation 01:11:15.859 --> 01:11:19.128 example. Right. Commission approves. Yes, I want you 01:11:19.140 --> 01:11:22.720 to elevate this substation in some urban area that's 01:11:22.810 --> 01:11:25.899 critical low. That is subject to flooding. This is 01:11:25.909 --> 01:11:28.159 great. I'm gonna go do that. They finished the project 01:11:28.168 --> 01:11:30.329 and realize they've done it wrong, tear it down and 01:11:30.338 --> 01:11:32.329 have to do it over again. I think there'd be no doubt 01:11:32.338 --> 01:11:35.009 at that point. That's gonna get a prudency question 01:11:35.020 --> 01:11:37.560 as to the total dollars or what of that? What did the 01:11:37.569 --> 01:11:40.729 utility do that that caused that or a contractor do 01:11:41.039 --> 01:11:43.659 And what's kind of the risk there? So I think that's 01:11:43.789 --> 01:11:46.569 that's clearly a case where, where you've said this 01:11:46.579 --> 01:11:49.750 thing, the cost of that thing is still kind of up for 01:11:49.759 --> 01:11:53.810 fair game. Um Now if I, if I said I'm gonna elevate 01:11:53.819 --> 01:11:56.319 that substation, it's gonna cost $50 million because 01:11:56.329 --> 01:11:59.588 of inflation. It cost $60 million. The utilities got 01:11:59.600 --> 01:12:02.509 approved. Well, why, why was that delta appropriate 01:12:02.619 --> 01:12:04.479 Oh, okay. Well, here's the cost, invoices, here's the 01:12:04.489 --> 01:12:06.970 materials cost, here's the labor cost. I think the 01:12:06.979 --> 01:12:10.128 view is you just don't get a ha ha $10 million. You're 01:12:10.140 --> 01:12:13.020 out. The utility has to kind of demonstrate that. But 01:12:13.029 --> 01:12:17.560 there's no, there's no just um, it was, it was X plus 01:12:17.569 --> 01:12:19.989 two and therefore you lose two, I think the statute 01:12:20.000 --> 01:12:21.560 and, and I think the draft we've given you is kind 01:12:21.569 --> 01:12:24.399 of meant meant to protect against that kind of that 01:12:24.409 --> 01:12:26.680 kind of situation because again, we're gonna follow 01:12:26.689 --> 01:12:29.759 these plans in year one. They may cover three years 01:12:29.779 --> 01:12:32.399 you may not be doing some of these projects until year 01:12:32.409 --> 01:12:35.100 four. And a lot of things can change that, that impacts 01:12:35.109 --> 01:12:37.829 cost between that. (item:2:David Smeltzer on conditional elements) Whichever envision. And I think, 01:12:39.418 --> 01:12:41.739 you know, I like what you're saying. Once, once the 01:12:41.750 --> 01:12:43.329 plan is approved, you're sort of expected to do it 01:12:43.338 --> 01:12:46.659 unless you come good cause exception. Would you, would 01:12:46.668 --> 01:12:51.359 you ever imagine a plan including conditional elements 01:12:51.378 --> 01:12:54.168 where you're sort of presetting up the conditions for 01:12:54.180 --> 01:12:55.520 a good cause exception. 01:12:58.168 --> 01:13:00.250 That's that question I don't need a off the cuff. 01:13:04.750 --> 01:13:08.509 I think I'd want to think through and I don't know 01:13:08.520 --> 01:13:09.979 that it needs to be in there. You know, people can 01:13:09.989 --> 01:13:11.909 settle on a lot of stuff. (item:2:Brian Lloyd on modifications) Yeah, I mean I, I again. 01:13:11.918 --> 01:13:14.770 I, I think modifies an expansive term. I think there's 01:13:14.779 --> 01:13:17.878 probably modification in some ways, maybe goes beyond 01:13:17.890 --> 01:13:19.729 what the commission can do, right? I mean, you guys 01:13:19.739 --> 01:13:22.548 are noticing some other kind of problems to just the 01:13:22.560 --> 01:13:24.779 Commission to kind of, you know, throw it out and say 01:13:24.789 --> 01:13:26.439 well, here's our plan, we just kind of made up for 01:13:26.449 --> 01:13:34.048 you. But I think conditional aspects of do this accept 01:13:34.060 --> 01:13:37.520 in these circumstances. I mean, my gut is, there's 01:13:37.529 --> 01:13:40.039 probably a way for the Commission to, to do that. If 01:13:40.048 --> 01:13:41.569 it, if it sees the need to do that. But I think 01:13:41.579 --> 01:13:44.180 I wanna think about that. Oh, and I was, I was not 01:13:44.189 --> 01:13:45.779 just whether or not we would do that but because you 01:13:45.890 --> 01:13:46.869 guys request that. 01:13:49.119 --> 01:13:51.159 And I don't know that it would need to be written into 01:13:51.168 --> 01:13:53.229 the rule. I'm just sort of thinking about stuff in 01:13:53.329 --> 01:13:55.470 real time. Here's, here's maybe an example where, where 01:13:55.479 --> 01:13:57.470 you could think of how and, and I'm not sure I would 01:13:57.479 --> 01:14:00.369 call it conditional, but, um, let's say there's a cyber 01:14:00.378 --> 01:14:03.259 project and it's, you know, we, at the time we filed 01:14:03.270 --> 01:14:05.680 the plan, this is the particular technology we're gonna 01:14:05.689 --> 01:14:09.470 use to address this particular cyber risk in that space 01:14:09.479 --> 01:14:12.949 Of course, technology changes fast and it could be 01:14:12.958 --> 01:14:16.029 a condition that I'm going to use this particular thing 01:14:16.039 --> 01:14:19.279 unless I find something better, better or cheaper or 01:14:19.289 --> 01:14:22.329 more efficient or address other problems. And then 01:14:22.338 --> 01:14:24.600 again, you may have been on the back end and in the 01:14:24.609 --> 01:14:27.039 prudency that, that utility has to demonstrate. Well 01:14:27.048 --> 01:14:30.180 why did you pick that new, new thing that came out 01:14:30.189 --> 01:14:32.029 over the thing that, that we had talked about three 01:14:32.039 --> 01:14:35.000 years ago in your case. And so I could see, I could 01:14:35.009 --> 01:14:36.869 see how we wouldn't like, the Commission wouldn't want 01:14:36.878 --> 01:14:39.329 you guys to feel like, oh, we gotta use this worse 01:14:39.338 --> 01:14:41.239 technology. So we don't have to go through the trouble 01:14:41.250 --> 01:14:43.869 of coming and applying again. Or, you know, uh coming 01:14:43.878 --> 01:14:46.470 in modifying. Yeah, we wouldn't want to lock you in. 01:14:46.479 --> 01:14:48.548 So, I mean, there is the challenge with the way the 01:14:48.560 --> 01:14:52.159 statute is written that to modify a plan, there's this 01:14:52.168 --> 01:14:54.520 language that says it can't take effect until kind 01:14:54.529 --> 01:14:57.899 of the end of your current plan. And so there again 01:14:57.909 --> 01:15:01.579 I don't, I, I can't imagine that, that for any component 01:15:01.588 --> 01:15:03.378 of, say our plan that's gonna address something like 01:15:03.390 --> 01:15:06.369 cyber, we're gonna walk into a particular solution 01:15:06.378 --> 01:15:09.079 again, just given the, the pace at which that technology 01:15:09.088 --> 01:15:12.430 changes. But that as, as an example of maybe where 01:15:12.439 --> 01:15:15.869 there'd be some conditionality. If people thought they 01:15:15.878 --> 01:15:18.168 needed to get that specific in these kind of plans 01:15:18.378 --> 01:15:20.378 may, maybe that's the way to think about it. But again 01:15:20.390 --> 01:15:24.539 I think that that this is all stuff that I think is 01:15:24.548 --> 01:15:27.399 on the utility to demonstrate within the plan and have 01:15:27.409 --> 01:15:29.909 that discussion with the stakeholders and the Commission 01:15:29.918 --> 01:15:33.850 during that. But I'll think I'll think more about that. 01:15:33.958 --> 01:15:38.569 Um Are you done? We're done. (item:2:Rama Rastogi with Commission Staff on plan effectiveness) I have a follow up question 01:15:38.579 --> 01:15:41.930 that what you said made me think about another issue 01:15:41.939 --> 01:15:44.899 that I want to tee up for discussion about the resiliency 01:15:44.909 --> 01:15:50.458 plan effectiveness. So, um I mean, there is, there 01:15:50.470 --> 01:15:52.668 is a point that, you know, you're building to something 01:15:54.020 --> 01:15:58.020 that event might not ever occur and there is an element 01:15:58.029 --> 01:16:00.810 of cyber security expenses that, you know, would need 01:16:00.819 --> 01:16:05.529 to be kind of, you want to look back, modify it and 01:16:05.539 --> 01:16:09.668 that would lead to incremental expenses. So how would 01:16:09.680 --> 01:16:15.970 you articulate your plans effectiveness in different 01:16:16.180 --> 01:16:17.838 you know, the different methods that you use in some 01:16:17.850 --> 01:16:21.909 cases? It might be not possible proof. (item:3:Brian Lloyd with Oncor on plan effectiveness) I mean I, I 01:16:21.918 --> 01:16:24.989 think it's so I, I think the, the general concept I 01:16:25.000 --> 01:16:27.520 think is difficult to do in, in the rule because depending 01:16:27.529 --> 01:16:29.909 on what component of a resiliency plan you're talking 01:16:29.918 --> 01:16:32.958 about, you may get different things. Um There may be 01:16:32.970 --> 01:16:35.989 certain things that one of your metrics might be. Is 01:16:36.000 --> 01:16:38.259 there an Ancillary safety and safety benefit? Right 01:16:38.270 --> 01:16:41.119 And, and some of these things, it is, it's, it's hard 01:16:41.128 --> 01:16:43.378 to prove the counterfactual of the avoidance of the 01:16:43.390 --> 01:16:46.119 thing that you avoided, right? So I elevated the substation 01:16:46.619 --> 01:16:49.229 there was some degree of flooding did I really need 01:16:49.239 --> 01:16:51.720 to elevate that substation for that particular thing 01:16:52.149 --> 01:16:54.229 I mean, that's going to be a very challenging thing 01:16:54.239 --> 01:16:56.229 to kind of do. Again, I think on the front end, there's 01:16:56.239 --> 01:16:58.060 this general concept of, are these the things that 01:16:58.069 --> 01:17:03.119 make sense um on, on things like some of the faster 01:17:03.128 --> 01:17:07.989 moving threats like cyber, I think similarly are at 01:17:08.000 --> 01:17:11.189 the and and again, thinking about a three year plan 01:17:12.060 --> 01:17:15.298 at the time, the Commission reviews the plan, it may 01:17:15.310 --> 01:17:18.270 be, these are the current threats in the spaces are 01:17:18.279 --> 01:17:21.239 rapidly changing. It may be well, somewhere in this 01:17:21.250 --> 01:17:24.180 process that was no longer the threat that didn't mean 01:17:24.189 --> 01:17:26.409 there's not a benefit to what we did from resiliency 01:17:26.418 --> 01:17:28.918 because that threat could reemerge at some point. But 01:17:28.930 --> 01:17:30.529 then here's this other threat that's happening. And 01:17:30.539 --> 01:17:33.020 again, whether that's encompassed in the plan or being 01:17:33.029 --> 01:17:36.649 in a subsequent plan. Um, you know, I think that that's 01:17:36.729 --> 01:17:38.418 that's the challenge of some of this. I don't know 01:17:38.430 --> 01:17:42.529 if that answered your question. Sort of, I'll take 01:17:42.539 --> 01:17:46.250 sort of that so. (item:3:Rama Rastogi on cyber security) At least with the cyber security bid 01:17:46.259 --> 01:17:49.220 and I'm kind of just thinking about it that because 01:17:49.229 --> 01:17:54.149 the technology changes so often getting into contracts 01:17:54.159 --> 01:17:58.168 that kind of build in or factor that aspect for long 01:17:58.180 --> 01:18:00.699 term. So there is some visibility of certainty about 01:18:00.708 --> 01:18:04.100 the costs that are going to be thrown at us rather 01:18:04.109 --> 01:18:07.239 than kind of going back and modifying it and adding 01:18:07.250 --> 01:18:09.859 the incremental cost part of it, at least like for 01:18:09.869 --> 01:18:12.079 the cyber security piece. (item:3:Brian Lloyd with Oncor on cyber security) Yeah. Well, and again, we 01:18:12.088 --> 01:18:15.539 have existing, of course, is not all new, we have existing 01:18:15.548 --> 01:18:18.838 programs on this within ray cases. We talk at length 01:18:18.850 --> 01:18:21.759 about what are the dollars associated with it and cyber 01:18:21.770 --> 01:18:25.140 and things like that to the extent this is an increment 01:18:25.149 --> 01:18:28.359 above that we would, I think do a similar explanation 01:18:28.369 --> 01:18:30.600 on the front end and then again, have the reconciliation 01:18:30.609 --> 01:18:33.119 on the back end as well. And then again, depending 01:18:33.128 --> 01:18:34.890 on what other components of the plan are. If there's 01:18:34.899 --> 01:18:38.350 other technology that you're adopting as part of a 01:18:38.359 --> 01:18:42.479 resiliency and hardening and a variety of things, there 01:18:42.489 --> 01:18:46.009 may be a cyber component to that, right? So I put switching 01:18:46.020 --> 01:18:49.239 devices in remote things that let me reroute power to be 01:18:49.250 --> 01:18:51.048 more resilient. I'm gonna want to make sure there's 01:18:51.060 --> 01:18:53.418 a cyber component to protect those as well to the extent 01:18:53.430 --> 01:18:54.789 that they're vulnerable to that. 01:18:59.359 --> 01:19:01.989 I want to kind of just ask uh if anyone has any 01:19:02.000 --> 01:19:05.878 other comments on the resiliency plan effectiveness 01:19:05.890 --> 01:19:09.798 That's a question that came from one of our Staff members. 01:19:17.458 --> 01:19:17.489 Okay. 01:19:22.890 --> 01:19:26.020 (item:3:Jessica Seuss with AEP Energy on resiliency plan effectiveness) Um I'm answering under the assumption, assumption that 01:19:26.029 --> 01:19:29.289 this is the question that was posed in the kind of 01:19:29.298 --> 01:19:33.180 pre questions in the agenda. So okay I thought of. 01:19:33.189 --> 01:19:35.699 Not, not exactly, but this just came up from one of 01:19:35.708 --> 01:19:41.699 the Staff members. Um Yeah, as far as effectiveness 01:19:41.708 --> 01:19:46.250 and metrics around that, you know, I think one of the 01:19:46.259 --> 01:19:50.890 difficulties around this is resiliency is typically 01:19:50.899 --> 01:19:54.810 measured as far as effectiveness, more on a terms of 01:19:54.819 --> 01:20:02.430 decades rather than years. Um And I think having that 01:20:03.020 --> 01:20:06.140 look back after these plans have been in place for 01:20:06.149 --> 01:20:08.449 a while, certainly makes sense and people will be able 01:20:08.458 --> 01:20:12.100 to get together that information on a shorter term 01:20:12.109 --> 01:20:15.640 basis as far as effectiveness. I think we'd be looking 01:20:15.649 --> 01:20:19.579 much more towards how effective have the utilities 01:20:19.588 --> 01:20:23.199 been in implementing the plans that they've presented 01:20:23.470 --> 01:20:26.878 Uh And for these things that they presented, can they 01:20:26.890 --> 01:20:31.109 say what benefit they are expected to provide? So if 01:20:31.119 --> 01:20:36.310 you're doing something like pole replacements for a 01:20:36.319 --> 01:20:41.020 different type of pull you can talk about, we've done 01:20:41.029 --> 01:20:44.319 X many replacements and now X percent of our system 01:20:44.369 --> 01:20:49.899 is when loaded to this amount. And I think that that's 01:20:49.909 --> 01:20:52.418 how we would be measuring effectiveness on a short 01:20:52.430 --> 01:20:53.399 term basis. 01:21:02.859 --> 01:21:05.930 Anyone else on this batch of topics I guess? 01:21:13.189 --> 01:21:15.909 (item:2:Bill Abbott with Commission Staff on distribution costs) I did have a question or two. This is Bill again. Um 01:21:15.989 --> 01:21:19.338 I did have a question or two um from both the non-ERCOT and, and 01:21:19.350 --> 01:21:23.970 um I guess the other utilities. Um So looking at subsection 01:21:23.979 --> 01:21:27.100 K of the statute, um first of all, I want, is it 01:21:27.109 --> 01:21:30.039 clear that it's only the distribution costs that can 01:21:30.048 --> 01:21:34.810 be booked as a direct asset? Is that in doubt or in 01:21:34.819 --> 01:21:35.409 dispute 01:21:37.890 --> 01:21:39.979 Bill, I think the subsection does say distribution 01:21:39.989 --> 01:21:43.079 related costs. Um and kind of in light of that, I guess 01:21:43.509 --> 01:21:50.609 and it um you know, uh allows that uh the use of 01:21:50.619 --> 01:21:54.649 uh you know, the DCRF and the non-ERCOT TCRF. So I 01:21:54.708 --> 01:21:58.149 guess part of my, one of my questions is, how do, so 01:21:58.159 --> 01:22:01.399 I assume that, that you'll interpret that as allowing 01:22:02.220 --> 01:22:05.140 you know, ONM cost booked the asset as recoverable 01:22:05.149 --> 01:22:07.649 under the DCRF. Is that correct? 01:22:16.289 --> 01:22:19.418 (item:2:Brian Lloyd with Oncor on distribution costs) I think the short answer is yes. Um and, and again 01:22:19.430 --> 01:22:21.298 I think there's um 01:22:23.168 --> 01:22:25.020 the kind of walk you through, I think the way we're 01:22:25.029 --> 01:22:28.789 thinking of it, let's say a resiliency investment comes 01:22:28.798 --> 01:22:30.970 let me do the capital piece first, a resiliency investment 01:22:30.979 --> 01:22:34.088 comes into service January 1. We start booking the 01:22:34.100 --> 01:22:38.729 depreciation and return. It comes into a DCRS, 01:22:38.739 --> 01:22:40.859 DCRF. That's effective say May 1. At that point, we 01:22:40.869 --> 01:22:43.680 stop any booking of that because the DCRF now keeps 01:22:43.689 --> 01:22:46.708 that. So now we've got a chunk of dollars here in deferred 01:22:46.720 --> 01:22:50.310 asset. We then have ONM components of the spend 01:22:50.319 --> 01:22:53.789 that are incremental to what's in rates today as those 01:22:53.798 --> 01:22:56.128 get incurred, get booked to the right asset. I think 01:22:56.140 --> 01:22:59.039 our view is, is the efficient thing to do is in the 01:22:59.048 --> 01:23:02.649 rate, sorry, in the DCRF, then you start recovering 01:23:02.659 --> 01:23:05.418 the asset as well. So this does not build up over time 01:23:05.430 --> 01:23:08.779 and over time and over time. Um And, and you sort of 01:23:08.789 --> 01:23:11.199 have this rolling recovery of this asset as you're 01:23:11.208 --> 01:23:13.449 incurring the cost you'll always be behind. Of course 01:23:13.458 --> 01:23:15.838 there's still gonna be some lag there. But again, we 01:23:15.850 --> 01:23:18.479 think we think the intent of the statute was to, to 01:23:18.489 --> 01:23:20.958 foster these investments and, and kind of do that. 01:23:21.779 --> 01:23:23.649 (item:2:Bill Abbott follow-up comments on distribution costs) Yeah. Yeah. And I guess the, the more general question 01:23:23.659 --> 01:23:27.048 is to what degree did the current limitations in the 01:23:27.060 --> 01:23:31.989 DCRF and non-ERCOT TCRF constrain? Because like typically 01:23:32.000 --> 01:23:34.560 you wouldn't allow, I mean, oh, and costs that are 01:23:34.569 --> 01:23:39.789 not normally um uh both, you know. Uh So what's the 01:23:39.798 --> 01:23:43.750 word capitalized? Yes. Um uh capitalized wouldn't be 01:23:43.759 --> 01:23:46.699 include in a DCRF. But I guess your view is that 01:23:46.708 --> 01:23:50.479 this, the statute allows that and similarly, normally 01:23:50.489 --> 01:23:52.819 distribution costs wouldn't be include in a non-ERCOT 01:23:52.899 --> 01:23:57.759 TCRF. Um so, so I have the pleasure of not having 01:23:57.770 --> 01:24:01.640 to think about non-ERCOT TCRFs. Very fortunate. (item:3:Brian Lloyd with Oncor on deferred ONM) I, I, 01:24:01.649 --> 01:24:05.208 I'll, I'll say yes. I mean, I think, I think the analogy 01:24:05.220 --> 01:24:06.810 you can think of and again, the Commissions kind of 01:24:06.819 --> 01:24:09.569 split it a little bit differently, but the, the temporary 01:24:09.579 --> 01:24:13.949 generation piece has a deferred ONM piece to it, of that 01:24:14.079 --> 01:24:16.579 asset that again the Commission has decided to split 01:24:16.588 --> 01:24:19.100 into a different thing. But you, you just, you can 01:24:19.109 --> 01:24:20.899 kind of do it in that proceeding. I think what was 01:24:20.909 --> 01:24:23.029 contemplated. I think the same thing is true here that 01:24:23.039 --> 01:24:26.239 the resiliency statute talks about the costs that are 01:24:26.250 --> 01:24:29.418 allowed to be recovered. And then the DCRF is one 01:24:29.430 --> 01:24:32.350 of the mechanisms to do that. And again, our, I think 01:24:32.359 --> 01:24:35.418 hopefully nobody here understands the Staff challenges 01:24:35.430 --> 01:24:38.338 of, of labor as much as I do. Our view is to 01:24:38.350 --> 01:24:41.449 try to make us efficient and utilize the DCRF for 01:24:41.458 --> 01:24:44.619 that. And I think, I think a little whether you do 01:24:44.628 --> 01:24:46.939 it as a a on the DC RF, whether you do it 01:24:46.949 --> 01:24:49.439 as a separate component, sort of a separate charge 01:24:49.449 --> 01:24:52.918 that gets done in the DCRF proceeding, I think is 01:24:52.930 --> 01:24:55.159 a little bit immaterial to the, to the idea that you 01:24:55.168 --> 01:24:58.689 start the recovery there. Again, it all gets reconciled 01:24:58.699 --> 01:25:01.918 in, in your next base rate case anyway. Yeah. Okay. Yeah 01:25:01.930 --> 01:25:05.829 Yeah. So, yeah, that's helpful. I get it not clear 01:25:05.838 --> 01:25:08.619 to me how much to what degree this override the existing 01:25:09.069 --> 01:25:13.338 restrictions and the rules. But, you know, I'm sure 01:25:13.350 --> 01:25:15.390 I'm sure the attorneys and other parties will have 01:25:15.399 --> 01:25:16.750 a lot of opinions on that. So, thanks. 01:25:21.859 --> 01:25:24.720 (item:2:Rama Rastogi with question concerning costs) While we are all here, I did have a question about 01:25:24.729 --> 01:25:27.378 cost and it's, it's really just a curiosity question 01:25:27.390 --> 01:25:31.470 at this stage for the resiliency plans or you know 01:25:31.479 --> 01:25:31.949 the 01:25:33.560 --> 01:25:36.418 the plan that you, that you make, are you able to kind 01:25:36.430 --> 01:25:39.609 of monetize that cost in some way? Like do your insurance 01:25:39.619 --> 01:25:43.319 costs go down or anything else that it has a positive 01:25:43.329 --> 01:25:47.750 impact on in terms of reducing your costs because you 01:25:47.759 --> 01:25:52.798 are now planning for taking care of risk. So there's 01:25:52.810 --> 01:25:56.000 a level of risk that goes down. Are you able to kind 01:25:56.009 --> 01:25:57.378 of monetize it somewhere 01:26:07.239 --> 01:26:10.699 (item:2:Sean Meredith with Entergy in response costs question) Sean Meredith from Entergy. Um So yeah, we're talking about 01:26:10.708 --> 01:26:13.199 the cost, there's a couple of aspects there. So I would 01:26:13.208 --> 01:26:15.779 I would say that the first one is we're looking at 01:26:15.789 --> 01:26:18.909 the impact of, of how that implementation of those 01:26:18.918 --> 01:26:22.079 projects is impacting the restoration costs. So that's 01:26:22.088 --> 01:26:23.289 that's piece one. So it's 01:26:24.970 --> 01:26:27.529 in those high vulnerable or high consequence areas 01:26:27.539 --> 01:26:30.119 It's how are we reducing that impact to what it's going 01:26:30.128 --> 01:26:33.500 to cost to rest, to restore and ultimately will impact 01:26:33.509 --> 01:26:35.810 our customers and communities so that there's a piece 01:26:35.819 --> 01:26:38.259 to that there's also a piece that when you start looking 01:26:38.270 --> 01:26:41.270 at the, the duration and the customer and it's interrupted 01:26:41.279 --> 01:26:44.079 those types of things. It's also looking at what's 01:26:44.088 --> 01:26:46.619 the societal impact with that? That's an important 01:26:46.628 --> 01:26:49.759 aspect of it from whether it's a large industrial or 01:26:49.770 --> 01:26:52.750 commercial residential, there's that impact also of 01:26:52.759 --> 01:26:56.369 costs that we need to really understand and show how 01:26:56.378 --> 01:27:00.390 those projects and whatever it is from the resilience 01:27:00.399 --> 01:27:03.069 how you're doing it, how that is also having a positive 01:27:03.079 --> 01:27:08.729 impact on, on that part of the equation so. (item:2:Rama Rastogi with question on cost risk) I, I guess 01:27:08.739 --> 01:27:12.930 um I wanna probably clarify. I'm not talking about 01:27:12.939 --> 01:27:17.329 the economic impact or the society benefit. That is 01:27:17.338 --> 01:27:19.958 that is something that is going to happen and that 01:27:19.970 --> 01:27:23.449 is the intent of the plan. But does it kind of impact 01:27:23.458 --> 01:27:25.970 your books in any way that your costs come down because 01:27:25.979 --> 01:27:29.909 your risk at some level is also kind of getting addressed 01:27:29.918 --> 01:27:31.239 with these plans, 01:27:33.489 --> 01:27:36.949 (item:2:Eric Easton with CenterPoint Energy on cost risks) Eric Easton, CenterPoint. So, so I think one of the things 01:27:36.958 --> 01:27:40.060 that we anticipate is that as we make those investments 01:27:40.069 --> 01:27:44.020 in resiliency, we have some avo avoided cost from the 01:27:44.029 --> 01:27:47.140 damages that would have happened to the assets if we 01:27:47.149 --> 01:27:49.729 didn't make those investments. So if you think about 01:27:49.739 --> 01:27:53.048 a flood scenario, if we were to go ahead and elevate 01:27:53.060 --> 01:27:56.399 that substation prior to it flooding, then the cost 01:27:56.409 --> 01:27:59.798 to rebuild it will be different than the investment 01:27:59.810 --> 01:28:02.770 to actually do the mitigation. There's a couple of 01:28:02.779 --> 01:28:04.939 reasons for that one is that we would incorporate it 01:28:04.949 --> 01:28:08.970 into the design. And then two, once we've had a disaster 01:28:08.979 --> 01:28:12.109 type of event, we're typically doing things on an expedited 01:28:12.119 --> 01:28:15.279 time frame. And so once we start to have to expedite 01:28:15.289 --> 01:28:18.520 that project, the costs go up incrementally. So if 01:28:18.529 --> 01:28:21.958 we're able to do that on a more uh planned basis as 01:28:21.970 --> 01:28:24.569 opposed to an expedited basis, then there's a cost 01:28:24.579 --> 01:28:26.789 savings not only to the utility but to the customer 01:28:26.798 --> 01:28:27.208 as well. 01:28:34.708 --> 01:28:35.600 More on this? 01:28:39.689 --> 01:28:40.180 All right, 01:28:47.699 --> 01:28:50.829 we've been sort of addressing cost resiliency, cost 01:28:50.838 --> 01:28:53.750 plan, review and reconciliation as we've gone. But 01:28:53.759 --> 01:28:56.918 as we formally get to Subsection G. Is there anyone who 01:28:56.930 --> 01:28:58.689 wants to opine on this topic further? 01:29:02.350 --> 01:29:04.789 Is there anyone who would like to opine on any topic 01:29:04.819 --> 01:29:07.239 uh, related to this discussion further as we reach 01:29:07.250 --> 01:29:11.470 the bottom of the, of the page here? Have we done it, 01:29:11.479 --> 01:29:12.739 have we solved all the problems? 01:29:16.579 --> 01:29:20.048 (item:3:Cyrus Reed with Sierra Club on SB415) Cyrus Reed, Lone Star Chapter Sierra Club. The, the Bill I 01:29:20.060 --> 01:29:24.128 mentioned earlier was SB415 from the 21 Session. Which 01:29:24.140 --> 01:29:27.899 includes the potential for contracts. So just making 01:29:27.909 --> 01:29:30.329 that clear, I don't know if any utility would want 01:29:30.338 --> 01:29:33.159 to use it for resiliency, but to the extent they wanted 01:29:33.168 --> 01:29:35.069 to, that language does exist. 01:29:36.689 --> 01:29:40.079 And I think that's being taken up with the, it's being 01:29:40.088 --> 01:29:42.600 bundled in with the mobile general making. We are gonna 01:29:42.609 --> 01:29:45.259 try and do a double feature today. But uh, of this 01:29:45.270 --> 01:29:48.529 and that. But Maria is in the Northwest and so that 01:29:49.548 --> 01:29:56.128 critical staffing failure. Um okay so I think uh ,uh 01:29:56.310 --> 01:30:00.350 yeah, me too. (item:3:David Smeltzer on reporting mechanisms) Uh So I think that we, we've been sort 01:30:00.359 --> 01:30:03.259 of addressed it tangentially a little bit, but Rama 01:30:03.270 --> 01:30:05.859 reminded me that one of our post questions is where 01:30:06.140 --> 01:30:09.680 um you know, we're perpetually thinking about like 01:30:09.689 --> 01:30:11.970 reporting mechanisms at the tail end. And I think that 01:30:12.199 --> 01:30:14.250 it's been addressed to some extent today, but since 01:30:14.259 --> 01:30:16.569 it was a posed question, if there's anyone else that 01:30:16.579 --> 01:30:21.168 wants to talk about reporting mechanisms on the effectiveness 01:30:21.180 --> 01:30:23.789 of the plans and whether or not that's a good idea 01:30:23.798 --> 01:30:27.739 and uh what we would use that for, um I guess we'll 01:30:27.750 --> 01:30:29.239 create a little bit of space for that now, before 01:30:29.250 --> 01:30:29.989 we wrap up. 01:30:39.069 --> 01:30:41.259 In some of these discussions we've had behind closed 01:30:41.270 --> 01:30:43.418 doors, but, you know, Commissioners and others are 01:30:43.430 --> 01:30:46.739 watching now. So it's the, it's the time. (item:3:Sean Meredith with Entergy on reporting mechanisms) Sean Meredith 01:30:46.750 --> 01:30:49.979 from Entergy. Um I think it's important to report on the, the 01:30:49.989 --> 01:30:52.270 effectiveness of how we've implemented the plan. So 01:30:52.279 --> 01:30:56.399 as we said earlier, um we committed to putting 100 01:30:56.409 --> 01:30:58.569 distribution poles in the ground of this wind loading 01:30:59.009 --> 01:31:02.520 at this cost. We've executed that because we've already 01:31:02.628 --> 01:31:04.878 the burden of proof party met for this was a good plan 01:31:04.890 --> 01:31:08.180 to go execute. It's on us to prudently execute that 01:31:08.189 --> 01:31:11.798 now. So I think that's 100% especially in the short 01:31:11.810 --> 01:31:13.859 term when we're talking resilience because it is a 01:31:13.869 --> 01:31:16.708 broader topic. Um There was something that was said 01:31:16.720 --> 01:31:20.088 earlier that I just, I also wanted to address. So looking 01:31:20.100 --> 01:31:23.418 at Sadie safety to measure the effectiveness of this 01:31:23.430 --> 01:31:26.588 I would, I would caution against for a couple, a couple 01:31:26.600 --> 01:31:30.680 of reasons. Um So is obviously we're looking at duration 01:31:31.338 --> 01:31:34.399 and when you, we're talking duration, there are so 01:31:34.409 --> 01:31:37.699 many variables in, in these major events. So we we'll 01:31:37.708 --> 01:31:41.579 just take a Hurricane Harvey as an example. Um when 01:31:41.588 --> 01:31:44.140 you're talking duration, there is areas you can't get 01:31:44.149 --> 01:31:47.250 to potentially in a storm like that for days, which 01:31:47.259 --> 01:31:51.569 has a drastic impact on the Sadie. So the Sadie one excludes 01:31:51.579 --> 01:31:53.899 major events to begin with. So if you were to back 01:31:53.909 --> 01:31:56.109 up and take pure Sadie, that's not excluding the major 01:31:56.119 --> 01:31:59.909 events, even that's drastically impacted by the type 01:31:59.918 --> 01:32:02.418 of event, or you could have a very fast moving storm 01:32:02.430 --> 01:32:04.149 where you could get there immediately. So it's very 01:32:04.159 --> 01:32:06.569 hard to compare apples to apples and normalize that 01:32:06.819 --> 01:32:10.289 similar with frequency. So safety, you could have years 01:32:10.298 --> 01:32:12.609 where you have maybe one event. So your frequency starts 01:32:12.619 --> 01:32:14.378 to go down. But on the flip side of that, you could 01:32:14.390 --> 01:32:16.930 have a year like some people have experienced where 01:32:16.939 --> 01:32:20.829 you have 6, 7, 8, 10 events. So it's a, it's a very it's 01:32:20.838 --> 01:32:22.859 hard to normalize that for these major events. So I 01:32:22.869 --> 01:32:25.560 would really, those are very strong reliability metrics 01:32:25.569 --> 01:32:28.298 But from a resilience perspective, I don't, I don't 01:32:28.310 --> 01:32:30.418 think we'll effectively measure the effectiveness of 01:32:30.430 --> 01:32:31.600 your resilience investment. 01:32:35.000 --> 01:32:37.128 (item:3: Sam Chang with CenterPoint Energy on reporting mechanisms) We'd agree with that. We don't think Sadie safety 01:32:37.140 --> 01:32:41.949 is a good proxy on resiliency as it relates to reporting 01:32:41.958 --> 01:32:44.958 We think it's a good idea. It gives you guys visibility 01:32:44.970 --> 01:32:47.729 as far as what we've done, what we plan to do, how 01:32:47.739 --> 01:32:51.918 much we've incurred. Um We did discuss in previous 01:32:51.930 --> 01:32:54.479 meetings kind of Florida's regime. We think that's 01:32:54.489 --> 01:32:57.909 a little too robust and it's too much as far as information 01:32:58.359 --> 01:33:01.390 Um But something along the lines of an annual report 01:33:01.399 --> 01:33:04.009 um similar to how we file monthly construction reports 01:33:04.250 --> 01:33:07.088 uh we think that's a good format to give you guys visibility. 01:33:12.239 --> 01:33:15.500 And then there and then to responding to questions 01:33:15.509 --> 01:33:18.359 that other people are pinging. (item:3:David Smeltzer's question on metrics) Um I think you guys 01:33:18.369 --> 01:33:22.009 are it, it sounds like you guys would want to have 01:33:22.020 --> 01:33:25.509 individual metrics for based on the different types 01:33:25.520 --> 01:33:27.409 of measures that would be just as part of the plan 01:33:27.418 --> 01:33:33.378 or are there external known metrics that uh are expected 01:33:33.390 --> 01:33:35.680 to be utilized at that we know of at this point? 01:33:37.199 --> 01:33:40.378 So, so at this point, so if not Sadie safety, is 01:33:40.390 --> 01:33:42.890 there another answer to that question? (item:3:Sean Meredith with Entergy on metrics) So at this point 01:33:42.899 --> 01:33:46.729 there's not a uh an industry standard how to measure 01:33:46.739 --> 01:33:49.149 resilience because as we've already addressed, there's 01:33:49.159 --> 01:33:51.520 a lot of different things that go into resiliency. 01:33:51.958 --> 01:33:55.390 So that's we do not have a proposal on how it would 01:33:55.399 --> 01:33:57.199 be on how we're implementing the plan and how we've 01:33:57.208 --> 01:33:59.529 shown that, that's gonna provide that resilient benefit 01:33:59.539 --> 01:34:03.009 just our effectiveness to implement that. (item:3:Rama Rastogi on metrics) I guess that 01:34:03.020 --> 01:34:06.390 that's a fair point. Uh But can we do something, for 01:34:06.399 --> 01:34:10.338 example, if you replace the, the wood poles with concrete 01:34:10.350 --> 01:34:13.909 and there is an existing uh example of something like 01:34:13.918 --> 01:34:16.140 this in Florida happening and they kind of ahead of 01:34:16.149 --> 01:34:19.159 us in a few years by how they've done it and there 01:34:19.168 --> 01:34:23.668 are, you know, results or some data available about 01:34:23.680 --> 01:34:27.909 if, if it's helped at all. So is there a is that 01:34:27.918 --> 01:34:32.109 fair to ask you all to kind of provide any comparatives 01:34:32.319 --> 01:34:36.548 if not within the state? But you know, there is data 01:34:37.168 --> 01:34:40.699 to hold on to the analysis to compare because it is 01:34:40.708 --> 01:34:45.289 a new territory for all of us. I I think it would 01:34:45.298 --> 01:34:48.390 be fair to say if you've completed these projects, 01:34:49.378 --> 01:34:52.000 can we receive data on the back end of the after the 01:34:52.009 --> 01:34:55.119 event to see how that, how those assets perform? So 01:34:55.128 --> 01:34:57.479 for instance, if we put concrete poles in the ground 01:34:57.739 --> 01:35:00.668 or those concrete poles all still standing, that doesn't 01:35:00.680 --> 01:35:02.520 mean something is not wrapped in the wire, right? Because 01:35:02.529 --> 01:35:05.250 there's some things that come out of our control. So 01:35:05.640 --> 01:35:07.338 you know, but the key is that the poles are in the 01:35:07.350 --> 01:35:09.729 air that significantly reduces the work we need to 01:35:09.739 --> 01:35:11.649 go after the event. And that's the key is to get back 01:35:11.659 --> 01:35:14.208 faster. So I think it's very fair to say, hey, you've 01:35:14.220 --> 01:35:17.449 completed. All these projects are the, are the assets 01:35:17.458 --> 01:35:20.789 doing what they need to do and have us say yes. And 01:35:20.798 --> 01:35:23.958 here's our data to support that. Um But as far as a 01:35:23.970 --> 01:35:26.069 metric that would identify and really point to, to 01:35:26.079 --> 01:35:29.548 go, you know, to drive that home, I don't, I think 01:35:29.560 --> 01:35:31.668 that would, is a, is a significant challenge just because 01:35:31.680 --> 01:35:35.600 of the variability at this point. I know this is a 01:35:35.789 --> 01:35:37.899 this is in the, the industry knows that we are, we 01:35:37.909 --> 01:35:40.958 are, oh, we got a lot of smart people previously trying 01:35:40.970 --> 01:35:43.119 to understand how to put a metric around this. And 01:35:43.699 --> 01:35:45.600 I'll say there's a lot of smart folks that are struggling 01:35:45.609 --> 01:35:48.399 with this right now. So much smarter than me is up 01:35:48.409 --> 01:35:52.579 here trying to explain it. (item:3:Liz Jones with Oncor on metrics) So I would ask Liz Jones 01:35:52.588 --> 01:35:58.539 for Oncor. I would ask that you all focus on including 01:35:58.548 --> 01:36:02.739 as an element of the plan proposal, the metrics that 01:36:02.750 --> 01:36:07.168 the utility intends to use rather than in the rule 01:36:07.180 --> 01:36:11.609 trying to establish sort of generalized performance 01:36:11.619 --> 01:36:16.310 metrics. I think the plan, I think so, Oncor has a 01:36:16.319 --> 01:36:20.529 wide variety of service area. You know, we got Sandy 01:36:20.539 --> 01:36:23.458 we got Woody, we got urban, we got rural depending 01:36:23.470 --> 01:36:27.149 on what kind of plan and what area of our system we 01:36:27.159 --> 01:36:32.319 were addressing. You might find uh that we would recommend 01:36:32.329 --> 01:36:36.180 very different kinds of metrics and much like our earlier 01:36:36.189 --> 01:36:42.109 discussion on areas of lower. I can't remember the 01:36:42.119 --> 01:36:46.310 term that was used lower performance. Thank you. Um 01:36:46.659 --> 01:36:50.829 I think this is something that is better worked through 01:36:50.838 --> 01:36:52.949 in a case than in the rule. 01:36:56.500 --> 01:36:58.918 I'm just happy to hear you identified woody as a resiliency 01:36:58.930 --> 01:37:00.729 risk. He'll be thrilled to hear that. 01:37:02.890 --> 01:37:04.548 Sometimes it's capitalized sometimes. 01:37:09.100 --> 01:37:11.489 All right. So I guess we're, we're reaching the end 01:37:11.500 --> 01:37:13.708 of our time. Does anyone else have any other, um, 01:37:15.479 --> 01:37:16.649 anything else I want to talk about? 01:37:20.500 --> 01:37:23.729 All right. Well, I guess, I guess our final piece of 01:37:23.739 --> 01:37:25.588 business, which is the final piece of business in the 01:37:25.600 --> 01:37:29.270 DER world. Um is, you know, is it Staffs ongoing efforts 01:37:29.279 --> 01:37:31.720 to make these things uh more casual and fun and 01:37:31.729 --> 01:37:36.289 DER workshops. We, we always uh uh awarded 01:37:36.319 --> 01:37:39.189 a, a jacket of the a jacket of the workshop for the 01:37:39.199 --> 01:37:40.619 person who was wearing the most interesting stuff. 01:37:40.628 --> 01:37:42.390 And I think people started responding to that this 01:37:42.399 --> 01:37:44.479 group wasn't broken into that, but I think Theresa 01:37:44.489 --> 01:37:45.509 is the winner today. 01:37:47.798 --> 01:37:50.449 Our first, our first Staff winner of the, of the Jacket 01:37:50.458 --> 01:37:52.270 contest with a lovely blue number. Good job. 01:37:54.838 --> 01:37:58.770 So, so next time you're all on notice. Uh you know 01:37:58.779 --> 01:38:02.250 I let's see, competition. (item:3:David Smeltzer's final information for workshop attendees) Thanks everybody for coming 01:38:02.259 --> 01:38:04.918 to the resiliency workshop. We anticipate the proposal 01:38:04.930 --> 01:38:08.838 for publication being on the, you know, the mid September 01:38:09.060 --> 01:38:13.779 um the mid September open meeting. And I would say 01:38:13.789 --> 01:38:16.310 that, you know, our internal review process is usually 01:38:16.319 --> 01:38:19.199 we have to get drafts to the hallway two weeks in advance 01:38:19.208 --> 01:38:21.789 And so if anyone has any last minute ideas, getting 01:38:21.798 --> 01:38:26.600 them to us this month, uh would be the optimal time 01:38:26.609 --> 01:38:29.069 for staff's workload. So reach out, you know how to 01:38:29.079 --> 01:38:32.579 get us. Uh and hopefully we'll come up with a good 01:38:32.588 --> 01:38:34.088 product. (item:3:David Smeltzer closes workshop) This was really helpful today. Thank you. 01:38:34.619 --> 01:38:35.649 Thank you very much. 01:38:37.890 --> 01:38:37.979 (inaudible)