WEBVTT 00:00:03.508 --> 00:00:06.139 (item:1:Welcome/Introductions by Dave Gordon, PUC Executive Counsel) Everyone, my name is Dave Gordon. I'm Executive Counsel 00:00:06.150 --> 00:00:08.560 here at the PUC. I'm joined with David Smeltzer, who's 00:00:08.569 --> 00:00:11.198 the Director of Rules and Projects. I want to thank 00:00:11.210 --> 00:00:14.579 all of you for coming to this Texas Energy Fund Workshop. 00:00:14.589 --> 00:00:18.519 I want to thank everyone also who submitted comments. Those 00:00:18.530 --> 00:00:21.289 are very helpful to us as we're working through this 00:00:21.478 --> 00:00:25.208 project that's new for us. Uh A couple of logistical 00:00:25.219 --> 00:00:27.850 notes just to start off. (item:1:Dave Gordon lays out instructions for comments and overview of workshop) Uh First of all, this is going 00:00:27.859 --> 00:00:30.309 to be broadcast on Texas Admin and available through 00:00:30.318 --> 00:00:33.658 our website. Um If you come up to speak, just please 00:00:33.668 --> 00:00:36.990 uh let everyone know who you are and who you're affiliated 00:00:37.000 --> 00:00:40.819 with. Um I also want to note that the aim of this 00:00:40.829 --> 00:00:44.908 workshop is for us, the PUC Staff to get information 00:00:44.918 --> 00:00:49.079 from all of you. On how these programs should work, 00:00:49.090 --> 00:00:53.029 how they can work efficiently and fairly. Um We are 00:00:53.179 --> 00:00:56.149 new at running programs like this. So we are going 00:00:56.158 --> 00:00:59.048 to depend on the input from all of you. I'm gonna let 00:00:59.060 --> 00:01:02.840 David take over with a few logistics uh about how to run the 00:01:03.029 --> 00:01:06.819 meeting too. (item:1:David Smeltzer, PUC Director of Rules & Projects, lays out how the workshop will proceed) Hi everybody. Um We've, we've started doing 00:01:06.829 --> 00:01:09.299 these workshops again, And if you have been to one, 00:01:09.308 --> 00:01:12.448 you know the drill. But, um as we get to each, I 00:01:12.459 --> 00:01:15.168 think the way we're gonna proceed uh on the Agenda. 00:01:15.180 --> 00:01:19.058 We've got more topics than time. And so if you see 00:01:19.069 --> 00:01:21.778 the, the second organizational level. Which are the 00:01:21.790 --> 00:01:23.969 open bullets, the white open bullets. I think we're 00:01:23.980 --> 00:01:26.659 going to pull those up, sort of a chunk at a time. 00:01:26.668 --> 00:01:29.010 So we'll go white bullet by white bullet. And if you 00:01:29.019 --> 00:01:33.540 have anything to say on that cluster of topics. That's 00:01:33.549 --> 00:01:36.338 sort of how we'll proceed. Um You don't have to be 00:01:36.349 --> 00:01:38.448 invited up to speak. Just go ahead and come on up and 00:01:38.459 --> 00:01:41.948 we'll call on you in the order that we see you as 00:01:41.959 --> 00:01:44.620 best as we can. (item:1:David Smeltzer lays out informal workshop protocols) And if you recall, if you've been to 00:01:44.629 --> 00:01:47.338 any of our recent workshops. Um we sort of have some 00:01:47.349 --> 00:01:50.370 informal protocols for being up here. Which is, you 00:01:50.379 --> 00:01:53.409 know, if you are wanting to talk on the same topic 00:01:53.418 --> 00:01:55.808 when we're looking across. Flash, just a little one. 00:01:55.819 --> 00:01:58.790 If you're waiting to speak on something else and you're 00:01:58.799 --> 00:02:01.629 just occupying a chair. Two means we'll call on you 00:02:01.638 --> 00:02:03.719 when we're done with the ones. And then if you just 00:02:03.730 --> 00:02:06.948 want to agree with what's being said, but not say it 00:02:06.959 --> 00:02:10.919 again. Um For the sake of brevity, uh you can use the 00:02:10.929 --> 00:02:13.750 Ned Bonskowski protocol of holding up a three. So these 00:02:13.758 --> 00:02:17.949 are the rules of engagement for the workshop. Um And 00:02:17.960 --> 00:02:20.118 uh we have a lot of topics and a lot of people. 00:02:20.129 --> 00:02:24.069 So let's be as succinct as we can. But uh you know 00:02:24.080 --> 00:02:27.699 like Dave had said. We've not done, we've not run a program 00:02:27.710 --> 00:02:30.569 like this before. So if you are sitting on your hands 00:02:30.580 --> 00:02:33.838 trying to decide. Should I come say the thing or not. 00:02:33.860 --> 00:02:36.330 Come say the thing. Like we want the input, we need 00:02:36.338 --> 00:02:38.360 to be able to plan and get this stuff right. So that's 00:02:38.368 --> 00:02:41.389 that's why we're here. Um Just a couple of other quick 00:02:41.399 --> 00:02:45.960 opening notes. (item:1:Dave Gordon introduces from Gena Minjares TX Treasury Safekeeping Trust Co.) Um I want to thank Gena Minjares for coming today. 00:02:45.969 --> 00:02:49.758 Gina is the CFO of the TX Treasury Safekeeping Trust 00:02:49.770 --> 00:02:52.399 Company. If you all have questions about logistics 00:02:52.409 --> 00:02:55.469 for funds administration. She may be available to answer 00:02:55.479 --> 00:03:01.729 those um and uh post workshop. Um We will allow folks 00:03:01.740 --> 00:03:06.618 to file comments in this Docket uh or Project 54999. 00:03:07.179 --> 00:03:09.689 (item:1:Dave Gordon lays instructions on comments) We're gonna ask for comments on any of the questions 00:03:09.699 --> 00:03:12.538 that are here. Um And we ask that you have those in 00:03:12.550 --> 00:03:16.300 by October 13. So as you ruminate over what gets 00:03:16.308 --> 00:03:19.979 discussed today, feel free to put those plans down 00:03:19.990 --> 00:03:22.669 and those thoughts down in paper and send them our 00:03:22.679 --> 00:03:25.139 way. And we'll consider them as we work through the 00:03:25.149 --> 00:03:29.389 rules. So with all of that said. (item:2:Dave Gordon with PUC Staff opens discussion on Grant Program for Outside of ERCOT Facilities) I think we're gonna 00:03:29.399 --> 00:03:33.800 start things off with our Program for Grants Outside 00:03:33.808 --> 00:03:39.800 of ERCOT. So who's here to raise issues associated 00:03:39.808 --> 00:03:44.139 with the Grant Program for Outside of ERCOT Facilities 00:03:47.379 --> 00:03:48.710 I see some movement, so. 00:03:53.159 --> 00:03:55.050 Thanks very much. And again, just state your name and 00:03:55.058 --> 00:03:57.599 who you're with. So everybody at home can follow along 00:04:01.159 --> 00:04:04.610 (item:2.3:Julia Harvey with Texas Electric Cooperatives on Facility Modernization) All right. Thank you Mr. Seltzer, Mr. Gordon. Um I'm 00:04:04.618 --> 00:04:07.819 Julia Harvey with Texas Electric Cooperatives. Appreciate 00:04:07.830 --> 00:04:10.729 the opportunity to participate today. Just had a, a 00:04:10.740 --> 00:04:15.860 couple of comments around the Out of ERCOT Fund. Um 00:04:15.960 --> 00:04:20.059 there's a question around facility modernization. And 00:04:20.069 --> 00:04:23.619 kind of what types of programs or measures should qualify 00:04:23.629 --> 00:04:26.858 for that. Um So what is modernization basically, it's 00:04:27.048 --> 00:04:29.778 it's adapting to something new. And so when we've talked 00:04:29.790 --> 00:04:33.139 to our members about what potential projects might 00:04:33.149 --> 00:04:35.730 qualify under that criteria. They bring up things like 00:04:35.738 --> 00:04:40.778 a grid automation projects or communications upgrades. 00:04:40.790 --> 00:04:44.699 Uh things to enable the minimization of outages. They've 00:04:44.709 --> 00:04:48.040 also brought up looping circuits to enable back feed 00:04:48.048 --> 00:04:52.100 of facilities. Or even upgrading wooden poles to concrete 00:04:52.108 --> 00:04:54.798 poles. Do want to note that pretty much everything 00:04:54.809 --> 00:04:58.858 I mentioned would also probably qualify under the reliability 00:04:58.869 --> 00:05:02.889 and resiliency enhancements category. And so you may 00:05:02.899 --> 00:05:06.338 get um measures or programs that qualify under more 00:05:06.350 --> 00:05:09.769 than one criteria under the statute. And so that's 00:05:09.778 --> 00:05:12.699 kind of my comment on facility modernization. Great, 00:05:12.730 --> 00:05:13.028 thanks. 00:05:15.720 --> 00:05:18.170 (item:2.2:Taylor Kilroy with TPPA on Eligibility) Uh Taylor Kilroy, on behalf of the Texas Public Power 00:05:18.178 --> 00:05:21.399 Association. Uh 100% agree with what Julia said. What 00:05:21.410 --> 00:05:23.619 I wanted to talk about for a second was eligibility. 00:05:23.920 --> 00:05:26.149 There are several MOUs that operate outside of ERCOT. 00:05:26.220 --> 00:05:28.790 Nine or 10 depending on how you count the, the one 00:05:28.798 --> 00:05:31.559 in transition. We did want to flag that, you know, 00:05:31.569 --> 00:05:35.559 when the DOE is processing its uh GRIP Program through 00:05:35.569 --> 00:05:38.129 the IIJA. It's three acronyms in one sentence, new 00:05:38.139 --> 00:05:42.660 record. Um They did uh implement small utilities set 00:05:42.670 --> 00:05:45.230 asides. Where for certain programs, they'd allocate 00:05:45.238 --> 00:05:49.500 up to 30% for small utilities. In other programs for 00:05:49.509 --> 00:05:53.959 kind of the smaller utilities. (item:2.1:Taylor Kilroy with TPPA on Streamlined Application Process and Simpler Reporting Requirements) They would do um a streamlined 00:05:53.970 --> 00:05:56.028 application process kind of like the Commission does 00:05:56.040 --> 00:06:01.028 for C and D water utilities. And kind of uh simpler 00:06:01.040 --> 00:06:03.428 reporting requirements to make sure that this is open 00:06:03.439 --> 00:06:05.678 for kind of the small utilities. That you don't have 00:06:05.689 --> 00:06:07.829 to have, you know, an in-house grant writer to be able 00:06:07.838 --> 00:06:09.988 to apply for these and maintain compliance with these. 00:06:10.298 --> 00:06:11.939 And we'd encourage the Commission to do the same. You 00:06:11.949 --> 00:06:14.928 know, make sure that some of our small utilities, rural 00:06:14.939 --> 00:06:17.790 and small town Texans uh maintain eligibility for them. 00:06:17.798 --> 00:06:20.548 Thank you. Thanks Taylor. (item:2.1:Dave Gordon, PUC Executive Counsel's question on what is essential) In line with that you know 00:06:20.559 --> 00:06:23.290 one of our big questions. Here is what are the essential 00:06:23.298 --> 00:06:26.250 components of a rule to implement this program? And 00:06:26.319 --> 00:06:29.278 that'll be a recurring question throughout these. Uh 00:06:29.290 --> 00:06:31.369 Taylor, you mentioned that this one should be easy 00:06:31.379 --> 00:06:33.689 for people to apply to. Are there any other considerations 00:06:33.699 --> 00:06:37.209 associated with what we need to do to simply establish 00:06:37.220 --> 00:06:40.000 this program in a rule? Um What it, what it needs to 00:06:40.009 --> 00:06:41.939 look like? What the parameter should be? Anything like 00:06:41.949 --> 00:06:44.980 that. (item:2.1:Taylor Kilroy on Communication) Um I, I'd say communication is key. Honestly 00:06:44.988 --> 00:06:47.480 it's some of these folks don't pay a lot of attention 00:06:47.488 --> 00:06:51.519 to PUC. Just because PUC and, and ERCOT are kind of 00:06:51.528 --> 00:06:54.439 one. And while the Commission does do a lot of work 00:06:54.449 --> 00:06:57.069 with SVP and MISO. It can be harder to figure out what's 00:06:57.079 --> 00:06:59.230 happening in Austin. So communication is absolutely 00:06:59.238 --> 00:07:03.778 key. (item:2.1:Julia Harvey with TEC on Broadband Grant program) And then if I could add um kind of at a 00:07:03.790 --> 00:07:06.629 higher level. The, the question around what are the 00:07:06.639 --> 00:07:10.108 essential components of the rule. Um You know, you 00:07:10.119 --> 00:07:11.980 you may want to look at and you may already have looked 00:07:11.988 --> 00:07:14.790 at. What the the Comptroller's Office did with the Broadband 00:07:14.798 --> 00:07:18.189 Development Office, Broadband Grant Program. That's 00:07:18.199 --> 00:07:22.108 a competitive grant program for private entities. And 00:07:22.119 --> 00:07:25.028 so in their rulemaking, they have um details around 00:07:25.040 --> 00:07:29.420 eligibility application requirements, uh evaluation 00:07:29.428 --> 00:07:33.059 criteria. I think that will be very important uh reporting 00:07:33.069 --> 00:07:35.949 and records retention and failure to perform things 00:07:35.959 --> 00:07:38.649 like that. And so just kind of uh you know, at a 00:07:38.660 --> 00:07:41.269 high level, a recommendation could be maybe. Looking 00:07:41.278 --> 00:07:44.100 there for a framework that y'all could borrow from 00:07:44.108 --> 00:07:45.500 as you develop these rules. 00:07:47.040 --> 00:07:50.569 (item:2.1:David Smeltzer, PUC Director of Rules & Projects on a dedicated Workshop website) And Taylor to your point and to whoever else would say it. 00:07:50.660 --> 00:07:53.119 I know that uh Gleeson said at the last open meeting 00:07:53.129 --> 00:07:55.220 that we have working on a web page. It's just gonna 00:07:55.230 --> 00:07:58.439 be dedicated to this program. And so as that gets fleshed 00:07:58.449 --> 00:08:01.410 out, as you know. You guys are working with different 00:08:01.420 --> 00:08:05.519 size groups and things. So if it becomes apparent to 00:08:05.528 --> 00:08:07.238 you. (item:2.1:David Smeltzer on gaining helpful information from Workshop attendees) That like, hey, it would be really helpful if there 00:08:07.250 --> 00:08:09.879 was more content on X? Or if there was a guide on 00:08:09.910 --> 00:08:13.819 why? Um we might not always think of that. And so helping 00:08:13.829 --> 00:08:17.379 us know what information is missing so that we can 00:08:17.769 --> 00:08:20.100 provide more resources is something that you should 00:08:20.189 --> 00:08:22.189 feel free to do at any time. Yeah, we'll take you up 00:08:22.199 --> 00:08:22.660 on that. 00:08:24.428 --> 00:08:26.250 So we have someone else at the table. Go ahead. Yeah 00:08:26.259 --> 00:08:30.790 Thank you for the opportunity. Zoe Lees, is this on? Yep. 00:08:30.829 --> 00:08:34.320 Yep. Okay. (item:2.1:Zoë Lees, Regional VP with Xcel Energy SPS on Streamlined & Simple application and reporting requirements) Zoë Lees, uh Regional Vice President with 00:08:34.330 --> 00:08:40.719 Xcel Energy SPS. Um Just want to echo the sentiment that 00:08:40.859 --> 00:08:44.678 uh there needs to be a streamlined and simple application 00:08:44.690 --> 00:08:48.599 process, also with reporting requirements. I think 00:08:48.609 --> 00:08:51.779 we need to look at what is material and provides the 00:08:51.788 --> 00:08:56.529 Commission good information but maybe not too onerous 00:08:56.538 --> 00:08:59.979 for the utility as well. That is uh applying for these 00:08:59.989 --> 00:09:05.418 funds. (item:2.1:Zoë Lees with Xcel Energy SPS on impact cost of replacements for ratepayers) I just want to also speak to the impact that 00:09:05.428 --> 00:09:10.950 grants could have for ratepayers. As SPS looks at an 00:09:10.960 --> 00:09:16.058 aging generation fleet. And having to replace that generation 00:09:16.070 --> 00:09:19.038 and has large replacement plans in the future. We see 00:09:19.048 --> 00:09:24.379 grant projects like this as possibly having a material 00:09:24.389 --> 00:09:27.779 impact on the cost of those replacements for ratepayers. 00:09:27.788 --> 00:09:31.279 So I would encourage the Commission when it's looking 00:09:31.288 --> 00:09:35.168 at grant applications. To be making material grants 00:09:35.428 --> 00:09:40.649 um of a size that, that rate payers and customers will 00:09:40.658 --> 00:09:48.330 see the impacts of. Um and also to um to avoid turning 00:09:48.340 --> 00:09:50.509 it into a program that becomes more of an evolving 00:09:50.519 --> 00:09:54.538 loan program. I think that's problematic would encourage 00:09:54.548 --> 00:09:58.788 the Commission to keep it a grant program. Great. Thank 00:09:58.798 --> 00:09:58.969 you. 00:10:01.529 --> 00:10:04.279 (item:2.5:Dave Gordon, PUC Executive Director on priorities associated with timing and other objectives) Sort of moving down. And anyone at the table or anyone 00:10:04.288 --> 00:10:07.298 else have any thoughts about timing of when we ought 00:10:07.308 --> 00:10:09.808 to have this rule in place. Is there any priorities 00:10:09.820 --> 00:10:12.418 associated with these objectives? 00:10:15.969 --> 00:10:20.609 (item:2.5:Zoë Lees with Xcel Energy SPS on funds availability) SPS think would uh if funds were available next year 00:10:20.619 --> 00:10:24.129 would be applying for those funds. Right. (item:2.5:Julia Harvey with TEC on funds availability) And I think 00:10:24.139 --> 00:10:28.538 ideally, you know, the three programs would be stood 00:10:28.548 --> 00:10:32.048 up simultaneously. But I know there's prioritization 00:10:32.058 --> 00:10:35.349 that has to happen around the, you know, loans in ERCOT. 00:10:35.479 --> 00:10:38.450 But, you know, our members Electric Cooperatives. Would 00:10:38.690 --> 00:10:40.340 you know, as soon as these funds are available are 00:10:40.349 --> 00:10:45.450 looking forward to taking advantage. Great. (item:2.5:David Smeltzer with PUC Staff on standing up programs) When you say the 00:10:45.460 --> 00:10:47.609 reason you'd want them all stood up is because people 00:10:47.619 --> 00:10:50.538 are interested in all three. Not because of some necessary 00:10:50.548 --> 00:10:53.889 interrelationship between how applicants might choose 00:10:53.899 --> 00:10:56.519 between them. Or I mean it was there, is there any 00:10:56.529 --> 00:10:59.200 nuance there that I? (item:2.5:Julia Harvey on overlapping programs) A little bit of both. Yeah, interested 00:10:59.210 --> 00:11:01.190 in all three, but there is some overlap. I think with 00:11:01.200 --> 00:11:04.259 loans and grants and uh potentially so. 00:11:06.629 --> 00:11:10.369 Agree. (item:2.6:Dave Gordon with PUC Staff with question on Program Functionality) And then I think our last piece on this one 00:11:10.379 --> 00:11:13.168 was uh Program Functionality. And I think just as a 00:11:13.178 --> 00:11:16.869 preview for any of the other discussion topics. I was 00:11:16.879 --> 00:11:18.710 curious to know, and I think I may have an indication 00:11:18.719 --> 00:11:22.590 based on the comments. Is sort of what pieces uh around 00:11:22.599 --> 00:11:27.058 instruction or application materials do you need? Do 00:11:27.070 --> 00:11:31.548 should we have a, you know uh, uh sessions where we 00:11:31.558 --> 00:11:33.779 can teach the potential applicants how to use these 00:11:33.788 --> 00:11:36.538 programs, online features? Are there any 00:11:38.320 --> 00:11:41.408 considerations around those pieces that you all may 00:11:41.879 --> 00:11:43.928 want to add for this program? 00:11:47.009 --> 00:11:49.619 And sorry, I do not mean to put anyone on the spot. 00:11:49.629 --> 00:11:52.779 You if you don't have any, that is totally fine. (item:2.6:Zoë Lees with Xcel Energy SPS on clear expectations in the application process) I 00:11:52.788 --> 00:11:55.469 certainly think that clear expectations of what you're 00:11:55.479 --> 00:11:58.788 looking for in the application process is very 00:11:58.798 --> 00:12:02.129 helpful to the applicant. So whatever that ends up 00:12:02.139 --> 00:12:06.200 looking like from the Commission. Um it's helpful for 00:12:06.210 --> 00:12:08.769 the applicant to know what, what the expectations are. 00:12:08.779 --> 00:12:11.690 And what thresholds they need to be able to demonstrate 00:12:11.700 --> 00:12:14.340 in that application process. Yeah. 00:12:17.678 --> 00:12:19.538 Does anyone else in the room have any thoughts about 00:12:19.548 --> 00:12:23.288 Outside of ERCOT Grant Program administration and implementation? 00:12:25.500 --> 00:12:29.428 Going once? Great. Thank you very much for starting 00:12:29.440 --> 00:12:31.538 us off and appreciate your thoughts. 00:12:38.460 --> 00:12:40.558 If anyone does cobble together a sentence with more 00:12:40.570 --> 00:12:44.558 than three acronyms. Taylor has the, the current title 00:12:44.570 --> 00:12:46.830 now. But we're looking for, for more. 00:12:48.450 --> 00:12:52.750 Great. Well, I think this uh sets us up for the next 00:12:52.759 --> 00:12:56.259 uh program that's part of SB 2627. (item:3:Dave Gordon with PUC Staff opens discussion on Loan Program for Facilities Inside ERCOT) Which is the, the 00:12:56.269 --> 00:13:01.048 Loan Program for Facilities Inside ERCOT. So I will 00:13:01.058 --> 00:13:03.080 let folks think about whether they like to come up. 00:13:03.090 --> 00:13:06.298 There are a few who are eager. If the table fills up 00:13:06.308 --> 00:13:08.460 we can do multiple rounds. Um and also if you're at 00:13:08.469 --> 00:13:11.070 the table, you know, be mindful of others who may want 00:13:11.080 --> 00:13:12.759 to jump in behind you. 00:13:18.658 --> 00:13:19.460 Okay. That's it. 00:13:21.710 --> 00:13:23.798 I, I don't I'm happy to just dive in and we'll see 00:13:23.808 --> 00:13:26.548 what they. Great well, thanks. So we'll start again 00:13:26.558 --> 00:13:30.029 in the same format. (item:3.1:Dave Gordon with PUC Staff's question on necessary components of rule to implement) So we'll be first seeking y'all's 00:13:30.038 --> 00:13:32.609 input on the, you know, what are the necessary components 00:13:32.619 --> 00:13:35.200 of a rule to implement this program? Uh keeping in 00:13:35.210 --> 00:13:37.570 mind that you may want to address some of those subtopics 00:13:37.580 --> 00:13:41.658 in the square bullets. And I am just going to go from 00:13:41.668 --> 00:13:44.979 my left to the right of the table. So please go ahead 00:13:44.989 --> 00:13:48.210 and begin. All right, hello. (item:3.5:Monica Batra-Shrader with Enchanted Rock on addressing regional and reliability needs) I'm Monica Batra-Shrader on behalf 00:13:48.219 --> 00:13:51.879 of Enchanted Rock. I will say that we submitted comments 00:13:51.889 --> 00:13:54.158 through our broader coalition grid, uh Grid Resilience 00:13:54.168 --> 00:13:57.349 in Texas. That has a little bit more details um that 00:13:57.359 --> 00:14:00.658 I'm gonna go in here. But um we first would like to 00:14:00.668 --> 00:14:04.639 address uh the sub bullet. How should the PUC evaluate 00:14:04.899 --> 00:14:08.019 the ability to address regional and reliability needs. 00:14:08.418 --> 00:14:12.779 Um so we have a few thoughts. (item:3.1:Monica Batra-Shrader on ranking projects and unit availability) Um we would like to 00:14:12.788 --> 00:14:16.969 rank projects by physical performance criteria. Ramp 00:14:16.979 --> 00:14:21.619 rate for example, for flexibility. Um historical availability 00:14:21.629 --> 00:14:26.259 for technology types. Um You know, our unit availability 00:14:26.269 --> 00:14:29.889 was approximately 97% from June 1st through August 00:14:29.899 --> 00:14:34.849 30th. And um would like to point out that 100 megawatts 00:14:34.859 --> 00:14:38.918 from a distributed set of generation has a higher availability 00:14:38.928 --> 00:14:43.178 rate than a single generator. And um thus will provide 00:14:43.190 --> 00:14:48.200 more reliability to the grid. (item:3.1:Monica Batra-Shrader on aggregating a portfolio of generators) Um I would also like 00:14:48.210 --> 00:14:51.320 to point out um that applicants should be permitted 00:14:51.330 --> 00:14:54.908 to aggregate a portfolio of generators to be collectively 00:14:54.918 --> 00:14:58.989 defined as a facility. Because there isn't a, a facility 00:14:59.000 --> 00:15:02.369 that is defined yet. For meeting the minimum 100 Megawatt 00:15:02.379 --> 00:15:06.330 capacity thresh, threshold. Um we actually Enchanted 00:15:06.340 --> 00:15:10.119 Rock has done some work to internally um to flush out 00:15:10.129 --> 00:15:14.269 the scale of this opportunity. And we are able to bring 00:15:14.279 --> 00:15:17.500 about 500 megawatts to the grid within 3 years. 00:15:17.509 --> 00:15:20.719 With distributed front of the meter deployments. Um 00:15:20.729 --> 00:15:23.918 So straight up dispatchable capacity if aggregations 00:15:23.928 --> 00:15:29.840 are allowed to participate in this program. Um we believe 00:15:29.849 --> 00:15:33.229 that this portfolio of generators would enhance geographic 00:15:33.239 --> 00:15:36.149 diversity of generation and more effectively target 00:15:36.158 --> 00:15:40.408 local and regional reliability needs. Just a quick 00:15:40.418 --> 00:15:42.649 follow up on that. Sure. You may not have the answer if you 00:15:42.658 --> 00:15:45.048 don't, that's fine. Okay. (item:3.1:Dave Gordon with PUC Staff's question on aggregation) When you talk about aggregation. 00:15:45.058 --> 00:15:48.250 I mean, how closely together would these facilities 00:15:48.259 --> 00:15:51.788 be if they were aggregated for allowance? That's a 00:15:51.798 --> 00:15:54.080 good question and I will get back to you. All right. 00:15:56.099 --> 00:15:59.269 Thank you, Mr. Gordon and Mr. Smeltzer. (item:3:Bill Barnes with NRG introduction of Tom Atkins) Bill Barnes for 00:15:59.279 --> 00:16:03.048 NRG. Appreciate the opportunity to provide comments 00:16:03.058 --> 00:16:05.389 and early feedback on the development of the loan program. 00:16:06.139 --> 00:16:09.340 Developing generation projects is extraordinarily complicated 00:16:09.349 --> 00:16:11.599 and undoubtedly the loan program is gonna have a lot 00:16:11.609 --> 00:16:13.719 of moving parts and details. So we really appreciate 00:16:13.729 --> 00:16:16.369 this opportunity to be here. My limited role here is 00:16:16.379 --> 00:16:19.070 to introduce uh our Vice President of Development, Mr. 00:16:19.080 --> 00:16:23.019 Tom Atkins. Who has some extensive feedback on really 00:16:23.029 --> 00:16:25.019 each of the bullet items. We will be following the 00:16:25.029 --> 00:16:28.440 details of those in comments. Um but he'll be providing 00:16:28.450 --> 00:16:30.859 a high level overview of each of the components that 00:16:30.869 --> 00:16:33.099 we feel are are necessary for the implementation of 00:16:33.109 --> 00:16:36.450 the program. So thanks again. Thank you. Thank you. 00:16:36.460 --> 00:16:38.840 (item:3:Tom Atkins, Vice President of Development with NRG on ) Good afternoon. I appreciate the opportunity to address 00:16:38.849 --> 00:16:42.609 you. And again, it's an ambitious program. I would 00:16:42.619 --> 00:16:45.928 say that I have over 25 years experience bringing IPP 00:16:45.940 --> 00:16:50.129 projects through a project finance mechanism to market. 00:16:50.139 --> 00:16:53.440 Successfully constructing and operating them. So I 00:16:53.450 --> 00:16:55.788 think there are a lot of lessons that can be learned 00:16:55.798 --> 00:16:58.298 from that. That hopefully we can, we can provide some 00:16:58.308 --> 00:17:01.158 thoughts to you on it. And as an introduction, I will 00:17:01.168 --> 00:17:03.710 as you go through each of the open bullets. Have, have 00:17:03.719 --> 00:17:06.380 some specific thoughts for you. But the three main 00:17:06.390 --> 00:17:09.299 things I want to sort of lead with. (item:3.1:Tom Atkins with NRG on quality) It's important 00:17:09.309 --> 00:17:12.858 I believe for the Commission to look at the quality 00:17:12.868 --> 00:17:15.739 of the projects that it receives. The goal of the program 00:17:15.750 --> 00:17:19.400 is to add new, reliable dispatchable generation to 00:17:19.410 --> 00:17:23.670 the to the fleet. And at the end of the day, the 00:17:23.680 --> 00:17:27.068 collateral for the loan is going to be the asset itself. 00:17:27.078 --> 00:17:31.338 And it will be there for its lifetime if it gets constructed. 00:17:31.449 --> 00:17:35.750 And so I think it's really important to look at the 00:17:36.189 --> 00:17:40.380 value of that asset to the reliability of the system 00:17:40.390 --> 00:17:42.578 and make sure it makes sense on a long term basis. 00:17:42.799 --> 00:17:45.529 (item:3.9.1:Tom Atkins on applicants having 40% equity available) The second thing I think is important to do when evaluating 00:17:45.539 --> 00:17:48.410 loan applications is to make sure that the applicant 00:17:48.420 --> 00:17:53.118 actually has the 40% equity lined up that goes against 00:17:53.130 --> 00:17:58.868 the 60% loan because it would be a bad outcome. To the 00:17:58.880 --> 00:18:01.959 extent that you were to approve a loan have 60% ready. 00:18:02.029 --> 00:18:05.348 And the sponsor not actually have the 40% to actually 00:18:05.358 --> 00:18:08.289 build the project. Because the win comes for the state 00:18:08.299 --> 00:18:11.439 when the project gets built, and started up and operating. 00:18:11.449 --> 00:18:13.939 Because then you have an asset, it will be there forever. 00:18:14.358 --> 00:18:17.358 The sponsor may come and go, but the asset will be 00:18:17.368 --> 00:18:19.660 there for, for Texas. So I think that's important. 00:18:20.000 --> 00:18:22.750 (item:3.1:Tom Atkins on applicant experience) And third along the same lines, it's important that 00:18:22.759 --> 00:18:28.180 the sponsor have the experience to actually and wherewithal 00:18:28.189 --> 00:18:30.199 to pull this off. To know what to develop, know what 00:18:30.209 --> 00:18:33.358 permits they need. Know how to actually go about building 00:18:33.368 --> 00:18:35.818 a project. Getting the contracts together so that there 00:18:35.828 --> 00:18:39.299 are guarantees for performance and schedule and price. 00:18:39.309 --> 00:18:41.269 And all the things that are important to make sure 00:18:41.279 --> 00:18:43.789 a project doesn't just start, but it actually gets 00:18:43.799 --> 00:18:46.809 to the finish line. And I'll have more comments as we 00:18:46.818 --> 00:18:52.500 go through other specific uh bullets. Great, Mr. Sams? 00:18:52.799 --> 00:18:56.509 (item:3:Brian Sams with Calpine Energy and TCPA on questions from TCPA) Hey uh Brian Sams. I'm kind of doing double duty today. 00:18:56.529 --> 00:18:59.949 Um I'm here on behalf of Calpine, my employer of course. 00:18:59.959 --> 00:19:04.029 But then also on behalf of TCPA as the Board President. 00:19:04.039 --> 00:19:06.098 Our Executive Director is feeling a little under the 00:19:06.108 --> 00:19:08.868 weather and wanted to not share that with the rest 00:19:08.880 --> 00:19:12.309 of the group. So here I am for, for TCPA. Um 00:19:12.618 --> 00:19:16.000 uh I'm here to respond to any questions you guys have 00:19:16.009 --> 00:19:20.189 about our TCPA questions. Uh We really appreciate 00:19:20.199 --> 00:19:23.809 the opportunity to provide supplemental briefing as 00:19:23.818 --> 00:19:25.750 some of these things come out. (item:3.1:Brian Sams with Calpine Energy & TCPA on aggregation) I did have my finger 00:19:25.759 --> 00:19:28.689 raised for the aggregation discussion though. I just 00:19:28.699 --> 00:19:31.229 I wanna highlight that that might be a controversial 00:19:31.239 --> 00:19:38.900 issue. Just because of the way that 34.0104 is written. 00:19:38.910 --> 00:19:41.670 That it needs to be a net increase of at least 100 00:19:41.680 --> 00:19:46.469 megawatts of capacity for each facility. Um So that 00:19:46.479 --> 00:19:49.078 you know if, if that if aggregations are something 00:19:49.088 --> 00:19:51.199 that we need to explore. Maybe y'all want to receive 00:19:51.209 --> 00:19:53.660 additional briefing on, on that before we make any 00:19:53.670 --> 00:19:57.338 policy cuts. Great. Thank you. (item:3.1:Dave Gordon on policy cuts and open line of questions) I will say that we are 00:19:57.348 --> 00:19:59.729 not ready to dive in and make those cuts at this time. 00:19:59.739 --> 00:20:02.828 But uh so the, the comments and the brainstorming around 00:20:02.838 --> 00:20:05.328 it are really useful. Um But as we get down the road 00:20:05.338 --> 00:20:08.890 we may be holding additional workshops. Or having opportunities 00:20:08.900 --> 00:20:12.489 for everyone to answer questions um that are a little 00:20:12.500 --> 00:20:16.209 bit more pointed. Um But please do feel free to respond 00:20:16.219 --> 00:20:18.670 to any of your colleagues who are up here or who have 00:20:18.680 --> 00:20:21.529 mentioned anything. Um This is supposed to be a free 00:20:21.539 --> 00:20:26.160 discussion. And there's no penalties for us if uh you 00:20:26.170 --> 00:20:30.068 said something that um you know, anything you say is 00:20:30.078 --> 00:20:33.618 is, is fair game. We apologize for missing the one 00:20:33.630 --> 00:20:36.529 we'll, we'll look better. And, and Brian, I hope you're 00:20:36.539 --> 00:20:38.618 getting two paychecks today for your double duty. Uh, 00:20:38.630 --> 00:20:39.699 no. 00:20:42.838 --> 00:20:46.209 Miss Coleman? (item:3.3:Diana Coleman with CPS Energy on evaluating creditworthiness) Good afternoon. Diana Coleman with CPS 00:20:46.219 --> 00:20:49.170 Energy. We did file comments. We appreciate the opportunity 00:20:49.189 --> 00:20:52.130 to be here and be able to file those comments. The 00:20:52.140 --> 00:20:56.068 first portion that we wanted to talk about was on that 00:20:56.150 --> 00:20:59.400 sub bullet for the first is regarding the evaluating the 00:20:59.410 --> 00:21:03.729 creditworthiness. That is one area that we were looking 00:21:03.739 --> 00:21:07.555 into and seeing if we could get more details. On exactly 00:21:07.564 --> 00:21:12.045 what that counter party risk threshold would look like 00:21:12.324 --> 00:21:15.354 and what some of the repayment provisions for either 00:21:15.364 --> 00:21:18.305 stalled or unsuccessful project delivery. What that 00:21:18.314 --> 00:21:22.015 would look like? In case that, you know, event occurs. 00:21:22.213 --> 00:21:24.953 (item:3.1:Diana Coleman with CPS Energy on reallocation of grants and loans) And then also the reallocation of grants and loans 00:21:24.963 --> 00:21:27.463 if that should occur to other projects. And what the 00:21:27.473 --> 00:21:31.144 Commission's thought processes were on those kinds 00:21:31.154 --> 00:21:37.848 of issues. (item:3.6:Diana Coleman with CPS Energy on reliability performance standards) And then the only other thing um was as 00:21:37.858 --> 00:21:42.719 far as the reliability performance standards. What 00:21:42.729 --> 00:21:45.390 are you all thinking? Is it, would the program have 00:21:45.400 --> 00:21:49.858 like milestone based metrics? How would that look like? 00:21:49.868 --> 00:21:53.250 And just a little bit more information on exactly what 00:21:53.259 --> 00:21:55.979 each of the entities would have to meet. In order to 00:21:55.989 --> 00:21:59.549 move forward. (item:3.6:Dave Gordon with PUC Staff on CPS comments) Great. It sounds like you are also in 00:21:59.559 --> 00:22:02.328 a similar position to us for trying to figure out information 00:22:02.338 --> 00:22:05.459 about the programs. And so we will try to develop that 00:22:05.469 --> 00:22:08.750 as we go along. But if CPS as a public power entity 00:22:08.759 --> 00:22:11.150 um in the space. Has, has thoughts about how those should 00:22:11.160 --> 00:22:14.818 go uh feel free and, and let us know um either here 00:22:14.828 --> 00:22:16.750 or in responses of comments. 00:22:18.989 --> 00:22:20.939 (item:3.1:David Smeltzer's comments on reliability performance standards and quality) Yeah, on that point in terms of comments that would 00:22:20.949 --> 00:22:24.180 be filed on things like that. Or things like how we 00:22:24.189 --> 00:22:26.199 would ensure that the projects are quality or that 00:22:26.209 --> 00:22:29.299 people have necessary information. I am never going 00:22:29.309 --> 00:22:32.539 to turn my nose up at recommended language that gets 00:22:32.549 --> 00:22:35.019 filed. Or you know bolted like these might be the 00:22:35.029 --> 00:22:37.309 consideration so that it's always good to have stuff 00:22:37.318 --> 00:22:41.150 to pull into the brainstorming process. So specific 00:22:41.160 --> 00:22:43.828 is always more helpful than general. (item:3.6:Brian Sams with Calpine Energy on quality) On that, I think 00:22:43.838 --> 00:22:47.809 there's probably a lot of um federal programs that 00:22:47.818 --> 00:22:50.939 have some of the same criteria. For, you know, quality 00:22:50.949 --> 00:22:55.358 of management, the uh you know, the project itself. 00:22:55.368 --> 00:22:58.650 That uh we could share that would potentially be helpful 00:22:58.660 --> 00:23:01.969 for you all. Yeah, we would definitely look to those 00:23:01.979 --> 00:23:05.088 as, as templates for what we want to do if they're 00:23:05.098 --> 00:23:08.848 useful in borrowing from those. So thank you. Miss Griffiths? 00:23:09.229 --> 00:23:11.549 Yeah. Uh (item:3.7:Megan Griffiths, Law Firm of Jackson Walker behalf of Targa Resources on term primarily) Good afternoon, Megan Griffiths with the Law 00:23:11.559 --> 00:23:13.828 Firm of Jackson Walker. And I'm here today on behalf 00:23:13.838 --> 00:23:17.449 of Targa Resources. Um Targa filed comments and, and 00:23:17.459 --> 00:23:20.759 we appreciate the opportunity to do so. Um I'm here 00:23:20.769 --> 00:23:23.759 today on the, the final bullet. Under the subheading 00:23:23.769 --> 00:23:26.189 which was listed as how should the PUC interpret the 00:23:26.199 --> 00:23:31.118 term primarily in PURA Section 34.016(b), Subsection 1. 00:23:31.578 --> 00:23:34.170 Which is under the loan restrictions provision of 00:23:34.180 --> 00:23:38.199 the statute. Um Targa is a critical gas supplier and 00:23:38.209 --> 00:23:40.910 and critical customer under the Railroad Commission 00:23:40.920 --> 00:23:44.650 rules. Um It has gas processing plants that are integral 00:23:44.660 --> 00:23:48.670 to the reliability of the system. And that, that serve 00:23:48.680 --> 00:23:52.170 um utilities in Texas and ultimately benefit retail 00:23:52.180 --> 00:23:55.650 customers. Um And so, what we're seeking is to clarify 00:23:55.660 --> 00:23:57.920 and understand the rules of the road with respect to 00:23:57.930 --> 00:24:02.118 that particular restriction. And um as you're aware 00:24:02.130 --> 00:24:05.088 uh utility delays in the Permian Basin are a significant 00:24:05.098 --> 00:24:08.189 issue for critical customers and critical gas suppliers 00:24:08.199 --> 00:24:11.660 that have uh facilities out there. And a House Bill 00:24:11.670 --> 00:24:15.890 5066 was recently enacted um in recognition of those 00:24:15.900 --> 00:24:20.449 particular issues. And so, uh Targa and I assume others are also 00:24:20.459 --> 00:24:24.289 looking at whether this loan is an opportunity to build 00:24:24.299 --> 00:24:28.598 reliable dispatchable generation. That can serve um 00:24:28.930 --> 00:24:32.118 critical customers in private use networks. But we 00:24:32.130 --> 00:24:36.108 need some um basically some clarification. And what 00:24:36.118 --> 00:24:38.809 we would request is that there would be a rule clarification 00:24:38.818 --> 00:24:41.858 that generation that's otherwise eligible. That's in 00:24:41.868 --> 00:24:44.299 a pond that serves a critical customer and provides 00:24:44.309 --> 00:24:47.410 grid reliabilities would not be a facility that would 00:24:47.420 --> 00:24:51.900 fall under that particular loan restriction. (item:3.7:Dave Gordon with PUC Staff on question of dedicated facilities) Some other 00:24:51.910 --> 00:24:55.039 commenters have raised the similar issue and I have 00:24:55.049 --> 00:24:59.009 a question about those facilities. That might be dedicated 00:24:59.019 --> 00:25:01.430 to a private use network or an industrial load. Do 00:25:01.439 --> 00:25:04.338 you have a position on whether we have to consider 00:25:04.348 --> 00:25:07.630 the size of the facility compared to the Load associated 00:25:07.640 --> 00:25:10.259 with it? Or is it something more along the lines of 00:25:10.269 --> 00:25:14.449 how much energy is dispatched into ERCOT versus the private 00:25:14.729 --> 00:25:17.920 user? (item:3.7:Megan Griffiths on behalf of Targa on generation meeting statute requirements) I think what you need to look at is effectively 00:25:17.930 --> 00:25:20.809 does the generation meet the requirements under the 00:25:20.818 --> 00:25:23.588 statute. Which is effectively the 100 megawatts. Now 00:25:23.608 --> 00:25:27.118 Load has to be served from anywhere right. From generation 00:25:27.130 --> 00:25:29.559 within a private use network or from outside the grid. 00:25:29.848 --> 00:25:32.799 And so, um you know, one of the things that we think 00:25:32.809 --> 00:25:35.009 the Commission could look at. Is, you know, it's going 00:25:35.019 --> 00:25:37.818 to have to be served for a critical customer, but then 00:25:37.828 --> 00:25:41.709 excess energy can then be provided into the grid. And 00:25:41.719 --> 00:25:45.299 so we have to come up with, you know, some language 00:25:45.309 --> 00:25:46.170 to address that. 00:25:48.400 --> 00:25:50.529 (item:3.7:Dave Gordon's follow-up to Targa's suggestions) I'll go ahead and piggyback off of David's suggestion. 00:25:50.539 --> 00:25:53.848 Once we get into this process a little bit more, we'll 00:25:53.858 --> 00:25:56.890 be welcoming language. That is associated not only with 00:25:56.900 --> 00:26:00.920 the primary um use portion of this. But also the other 00:26:00.930 --> 00:26:05.209 portions of the, the rules. So, thank you. All right. (item:3.7:John Ross Hubbard, behalf of TIEC on primarily term) John 00:26:05.219 --> 00:26:08.729 Ross Hubbard on behalf of TIEC. Um we have a similar, a 00:26:08.739 --> 00:26:13.000 similar issue as Ms. Griffiths described. Um and would 00:26:13.009 --> 00:26:16.219 like more clarification on what primarily means. 00:26:16.229 --> 00:26:19.239 And to your question, we're still considering it. 00:26:19.250 --> 00:26:21.930 (item:3.7:John Ross Hubbard with TIEC on nameplate capacity) I think an initial cut would be to look at the nameplate 00:26:21.939 --> 00:26:26.170 capacity of uh the facility and the nameplate capacity 00:26:26.180 --> 00:26:28.969 of the generation. And if that nameplate capacity 00:26:28.979 --> 00:26:34.299 exceeds the industrial Load, then it might be considered 00:26:34.309 --> 00:26:37.598 as primarily. Not primarily serving the industrial loads. 00:26:37.608 --> 00:26:43.430 So then the ability to qualify for a loan. One clarification 00:26:43.439 --> 00:26:45.900 on that though. (item:3.7:Megan Griffiths behalf of Targa on industrial loads and privacy use networks) Is that industrial loads and privacy 00:26:45.910 --> 00:26:48.189 use networks, they do have flexibility to back down. 00:26:48.199 --> 00:26:50.068 But to the extent that they're a critical customer 00:26:50.078 --> 00:26:53.000 and the grid needs them. They don't have necessarily 00:26:53.009 --> 00:26:55.868 that flexibility. So that's why we think it's important. 00:26:56.140 --> 00:26:59.189 You know that if, if it's a customer that's not a critical 00:26:59.199 --> 00:27:02.750 customer. Then that sort of clarification may work 00:27:02.759 --> 00:27:04.828 but you need to look at the characteristics of the 00:27:04.838 --> 00:27:07.500 Load. And I think those can be spelled out in a rule 00:27:07.509 --> 00:27:10.650 making. That's a good point. We had a one over here. 00:27:10.858 --> 00:27:14.088 (item:3.7:Monica Batra-Shrader with Enchanted Rock on primarily) Hi Monica Batra-Shrader, Enchanted Rock again. Um 00:27:14.098 --> 00:27:17.170 We also have some thoughts on this bullet point. Um 00:27:17.410 --> 00:27:19.660 I would like to point out that there are deployment 00:27:19.670 --> 00:27:22.289 models in which relatively large behind the meter gen. 00:27:22.680 --> 00:27:26.529 Can be deployed via a third party investor or operator 00:27:26.539 --> 00:27:30.868 ownership. And that collocated Load only pays a contribution 00:27:30.880 --> 00:27:34.729 towards the asset for use during grid outages. And 00:27:34.739 --> 00:27:37.479 that type of behind the meter gen. Would only run for 00:27:37.489 --> 00:27:40.828 on-site backup power purposes 1% of kilowatt hours 00:27:40.838 --> 00:27:44.549 annually. While the remaining 99% would be used for 00:27:44.559 --> 00:27:47.338 the provision of grid services like Entergy or ancillary 00:27:47.348 --> 00:27:51.809 services. Um we currently don't have generation registered 00:27:51.818 --> 00:27:55.500 as a capital R resource. The split is based on our 00:27:55.509 --> 00:27:58.489 personal outage hours covered versus the rest of our 00:27:58.500 --> 00:28:01.608 operations at Enchanted Rock. But we believe it's a good 00:28:01.618 --> 00:28:05.390 representation of the split um with a market integrated 00:28:05.400 --> 00:28:09.900 capital R resource. Great. Thanks for that. (item:3.1:Dave Gordon confirming any further questions on essential components) Does anyone 00:28:09.910 --> 00:28:12.368 have any other thoughts about this particular piece 00:28:12.380 --> 00:28:15.650 of it the, the primary association of the resource? 00:28:17.439 --> 00:28:20.680 Or anything else that is associated with the sort of 00:28:20.689 --> 00:28:24.689 the nuts and bolts rules components? See we've got 00:28:24.699 --> 00:28:28.160 somebody. Monica, you can share your microphone with him. That'd 00:28:28.170 --> 00:28:32.068 be great. Thank you. Uh (item:3.1:Russell Weeks with Wärtsilä on quality assets) Thank you Russell, Russell Weeks, 00:28:33.420 --> 00:28:36.818 Wärtsilä. Um I just want to kind of build off of what NRG 00:28:36.828 --> 00:28:40.489 has said about the quality of assets. Uh when it comes 00:28:40.500 --> 00:28:43.640 to, you know, prioritization of some of these loans 00:28:43.650 --> 00:28:45.959 and when the Commission is looking at them. Definitely 00:28:45.969 --> 00:28:48.868 ready to fund assets, which could be a number of things. 00:28:48.880 --> 00:28:52.880 To, you know, get ready to uh fund a project. As well 00:28:52.890 --> 00:28:57.568 as a secondary half a prioritization of physical attributes. 00:28:57.989 --> 00:29:00.279 Just a thought for you since we're having a workshop 00:29:00.289 --> 00:29:04.078 and throwing some ideas out there. Um there is aged, 00:29:04.088 --> 00:29:08.719 aged um assets in the grid currently roughly 26,000 00:29:08.729 --> 00:29:14.318 megawatts over 30 plus years. You could uh assess what 00:29:14.328 --> 00:29:17.689 is is coming into your queue by looking at those resource 00:29:17.699 --> 00:29:21.209 asset registration forms. And seeing how much better 00:29:21.239 --> 00:29:24.348 um whatever is being applied. Whatever is being applied 00:29:24.358 --> 00:29:29.689 for um reg uh qualifies for the the resources. Just 00:29:29.699 --> 00:29:33.328 just a thought there. Um (item:3.7:Russell Weeks with Wärtsilä on term primarily) My only other comment is we'd 00:29:33.338 --> 00:29:37.088 like to understand more what primarily means. When it 00:29:37.098 --> 00:29:40.680 comes to Wärtsilä and our modular resources on the grid. It's 00:29:40.689 --> 00:29:45.098 much easier for us to deploy larger assets when we 00:29:45.108 --> 00:29:48.500 have infrastructure already in place. You know, industrials 00:29:48.509 --> 00:29:51.348 that want to oversize their generators and push that 00:29:51.358 --> 00:29:54.568 excess out into the market. So understanding what primarily 00:29:54.578 --> 00:29:57.858 is and, and if these resources would qualify for those 00:29:57.868 --> 00:30:01.140 loans is of great interest as well. Thank you. Great 00:30:01.150 --> 00:30:01.529 Thank you. 00:30:04.108 --> 00:30:06.439 (item:3.5:Diana Coleman with CPS Energy on addressing regional and reliability needs) The only other item we wanted to raise was the second 00:30:06.449 --> 00:30:09.519 bullet that's up there. Is how the PUC should evaluate 00:30:09.680 --> 00:30:12.469 an applicant's ability to address regional and reliability 00:30:12.479 --> 00:30:17.509 needs. Would that look like market participants within 00:30:18.949 --> 00:30:21.368 ERCOT? You know what, what that process would look like? 00:30:21.410 --> 00:30:24.689 Um also a process to qualify and to participate in 00:30:24.699 --> 00:30:27.160 the program. That way it's, it's clearly laid out, so 00:30:27.170 --> 00:30:30.838 expectations are known. Um and then same thing with 00:30:30.848 --> 00:30:32.959 the reliability standards. I think that's just a common 00:30:32.969 --> 00:30:37.479 theme. If the expectations are known and the parameters 00:30:37.489 --> 00:30:40.250 are set. I think it would be easier for folks to know 00:30:40.259 --> 00:30:43.279 exactly, you know, what bucket they would fit in. Or 00:30:43.289 --> 00:30:45.439 they would need to fit in in order to be able to 00:30:45.449 --> 00:30:46.608 participate in the program. 00:30:48.160 --> 00:30:51.170 Great. On, on that point. Uh, and hopefully we'll be able 00:30:51.180 --> 00:30:53.430 to bounce around between the bullets here. Absolutely. So stay 00:30:53.439 --> 00:30:57.289 on that point. (item:3.5:Tom Atkins with NRG on applicant reliability) We did have some thoughts on reliability 00:30:57.299 --> 00:31:01.469 and uh how, how applicant would demonstrate that. 00:31:01.479 --> 00:31:04.439 So we think it's incumbent upon the applicant to provide 00:31:04.449 --> 00:31:07.618 you information that they are in fact reliable and 00:31:07.630 --> 00:31:10.439 address the regional need. And one of the ways to do 00:31:10.449 --> 00:31:13.068 that is through the screening study that's done by 00:31:13.108 --> 00:31:16.160 the local transmission organization through the ERCOT 00:31:16.439 --> 00:31:19.880 interconnection process. To demonstrate deliverability 00:31:19.890 --> 00:31:22.910 and proximity to Load. (item:3.5:Tom Atkins with NRG on requirement of an applicant requirements) So that's one thing that I think 00:31:22.920 --> 00:31:25.939 could be a requirement of an application. Is that show 00:31:25.949 --> 00:31:29.088 us that there's been a study by the transmission organization 00:31:29.299 --> 00:31:32.229 that you're deliverable. So that if you built this project 00:31:32.239 --> 00:31:34.630 in this spot. You're not going to be constrained by 00:31:34.640 --> 00:31:37.309 transmission limitations. So that's certainly one. 00:31:37.318 --> 00:31:41.400 So asking the applicant show us how you are actually 00:31:41.410 --> 00:31:45.019 reliable and contribute to the, you know, overall uh 00:31:45.039 --> 00:31:49.229 regional benefit, that makes sense. And there's a perfect 00:31:49.239 --> 00:31:52.029 example of third party report from the transmission 00:31:52.039 --> 00:31:54.219 organization through the interconnection process. Yeah 00:31:54.229 --> 00:31:56.789 that's great. A reference to the screening study that 00:31:57.078 --> 00:31:58.439 makes good sense. 00:32:01.160 --> 00:32:03.420 Are there any threes from our TO friends on that? Do 00:32:03.430 --> 00:32:07.078 we like the, do we like the screening study as a tool 00:32:07.549 --> 00:32:08.828 as part of the application process? 00:32:10.618 --> 00:32:11.390 We'll talk later. 00:32:14.920 --> 00:32:19.160 (item:3.5:Diana Coleman with CPS Energy on applicant's ability to participate) One last thing on the applicant's ability to participate. 00:32:19.219 --> 00:32:24.719 Would one question we had is. Would the participants 00:32:24.729 --> 00:32:27.868 for this program, could they be participating in any 00:32:27.880 --> 00:32:30.088 other market enhancements? Would this be something 00:32:30.098 --> 00:32:33.939 that this would be, you know, just for this particular 00:32:33.949 --> 00:32:36.789 program? Or could they do something like PCM? Or is there 00:32:36.799 --> 00:32:40.578 any guidelines or restrictions that would? For the purposes 00:32:40.588 --> 00:32:43.019 of this. (item:3.5:Dave Gordon's follow-up to question of being screened out) We're, you know. I've only read through Chapter 00:32:43.029 --> 00:32:47.078 34 and the limitations associated with it are the, 00:32:47.088 --> 00:32:50.348 you know, the definitional ones. Okay. Um So I don't have 00:32:50.358 --> 00:32:52.769 any comment about how you might be screened out by 00:32:52.779 --> 00:32:55.689 virtue of participation in another program. But based 00:32:55.699 --> 00:32:58.939 on just this statute I, I don't. Not seeing that. 00:33:00.568 --> 00:33:03.989 I think uh if I, if I may. Um I'm loving what 00:33:04.000 --> 00:33:07.670 NRG is saying this morning. (item:3.5:Russell Weeks with Wärtsilä on RARF) But um the, I agree the 00:33:07.680 --> 00:33:10.539 screening study is definitely a good place to start. 00:33:10.660 --> 00:33:13.400 And one thing I, I did mention was some of those attributes 00:33:13.410 --> 00:33:16.199 that are in the RARF or the resource asset registration 00:33:16.209 --> 00:33:18.930 form. Which would be around like fuel flexibility, 00:33:18.939 --> 00:33:22.920 like heat rates, um thermal derate, historical availability, 00:33:23.259 --> 00:33:25.910 um water consumption. There's a number of different 00:33:25.920 --> 00:33:28.858 things, these are just illustrative. So you, you can 00:33:28.959 --> 00:33:32.108 gauge how much better the new piece of equipment would 00:33:32.118 --> 00:33:35.519 be versus what you already have in the system. Got 00:33:35.529 --> 00:33:38.989 you. I, I'll jump to some, uh I'm gonna go back to 00:33:39.000 --> 00:33:40.818 the beginning here. And maybe walk through a little 00:33:40.828 --> 00:33:44.019 bit with some, some thoughts. (item:3.3:Tom Atkins with NRG on creditworthiness) What should the applicant 00:33:44.029 --> 00:33:47.459 provide is one of the, one of the questions. And, and 00:33:47.469 --> 00:33:50.500 also creditworthiness. You know, our suggestion is 00:33:50.509 --> 00:33:52.868 the creditworthiness comes from the quality of the 00:33:52.880 --> 00:33:55.479 project. And that the project can actually generate 00:33:55.489 --> 00:33:58.299 revenue streams to pay back the debt. Which is traditional 00:33:58.309 --> 00:34:00.868 project finance. And so we're strong advocates for 00:34:00.880 --> 00:34:03.799 that. And also that the equity as I mentioned before 00:34:03.809 --> 00:34:06.380 that there's hard commitments for the equity. So that's 00:34:06.390 --> 00:34:08.378 you know, that that's on the table and ready to go 00:34:08.389 --> 00:34:11.559 if the loan is approved. (item:3.2:Tom Atkins with NRG on what applicants will need to provide) But in order for you to make 00:34:11.570 --> 00:34:13.878 a judgment as the Commission that a project has this 00:34:13.889 --> 00:34:16.898 level of quality and can provide this level of revenue 00:34:16.909 --> 00:34:21.340 to pay back the loan. It does require that the applicant 00:34:21.349 --> 00:34:23.869 submit a considerable amount of information for you 00:34:23.878 --> 00:34:26.590 to evaluate. Which includes the contracts behind the 00:34:26.599 --> 00:34:29.539 project. That the permits are in place and an economic 00:34:29.550 --> 00:34:32.793 model that demonstrates that the project will actually 00:34:32.802 --> 00:34:35.614 generate cash flow. Sufficient to pay back the loan 00:34:35.623 --> 00:34:38.552 pretty straight forward. But one of the suggestions 00:34:38.563 --> 00:34:41.974 that we have. (item:3.5:Tom Atkins with NRG on 3rd party consultant) Is that there is a whole industry out 00:34:41.983 --> 00:34:45.342 there that does this kind of work. And it might make 00:34:45.353 --> 00:34:48.842 sense for the Commission to retain a third party consultant. 00:34:48.864 --> 00:34:53.043 To help evaluate applications that come in from a traditional 00:34:53.052 --> 00:34:56.518 project finance standpoint. Including potentially an 00:34:56.528 --> 00:35:00.838 independent engineer. Which is an applicant for a third 00:35:00.849 --> 00:35:04.677 party IPP, goes to the finance community generally have 00:35:04.688 --> 00:35:08.099 to get a lender to do a review and do an underwriting. 00:35:08.108 --> 00:35:11.018 That says that this assets quality like a home mortgage. 00:35:11.028 --> 00:35:15.068 You get an assessment of a home's value before the 00:35:15.079 --> 00:35:17.603 bank lends. Because at the end of the day, the bank 00:35:17.612 --> 00:35:19.972 in a home mortgage gets the home, if something goes 00:35:19.981 --> 00:35:22.652 wrong. It doesn't get to get somebody else's boat or 00:35:22.663 --> 00:35:25.643 another house, they get just that house. So it's important 00:35:25.652 --> 00:35:28.771 to evaluate the value of the project and having third 00:35:28.782 --> 00:35:31.472 parties do that. I think could be very helpful. Because 00:35:31.481 --> 00:35:35.172 that's a standard process that's done in the industry. 00:35:36.766 --> 00:35:39.235 I will mention associated with uh hiring a third party. 00:35:39.246 --> 00:35:43.436 (item:3.5:Dave Gordon with PUC Staff on pre-solicitation notice) For that is we have issued a pre-solicitation notice. 00:35:43.445 --> 00:35:46.574 Um identifying that we are in the process of seeking 00:35:46.585 --> 00:35:49.476 somebody who may be able to administer the programs 00:35:49.485 --> 00:35:53.295 associated with this. So we have not issued a solicitation 00:35:53.304 --> 00:35:55.976 yet, but that pre-solicitation notice is available 00:35:55.985 --> 00:36:00.054 for review. And um we give an indication of the sort 00:36:00.065 --> 00:36:04.519 of the outlines of what we may be seeking. Great and 00:36:04.530 --> 00:36:06.869 I'll continue. And I, I don't wanna dominate. Please go ahead. 00:36:06.878 --> 00:36:09.599 So actually others jump in. (item:3.4:Tom Atkins with NRG on estimated cost) But I want to talk about 00:36:09.610 --> 00:36:11.590 estimated cost. One of the, one of the questions is. 00:36:11.599 --> 00:36:14.679 How should the PUC determine estimated cost for the 00:36:14.688 --> 00:36:17.760 purposes of determining loan caps? And, and we want 00:36:17.769 --> 00:36:21.414 to make a couple of points here. Um We think that an 00:36:21.425 --> 00:36:24.264 applicant should be supplying you enough information 00:36:24.273 --> 00:36:27.063 to understand what the actual cost of a project is 00:36:27.074 --> 00:36:29.695 And we want to emphasize some costs that aren't necessarily 00:36:29.704 --> 00:36:32.125 always considered, but there are soft costs involved 00:36:32.135 --> 00:36:35.103 in developing any project. All the work that goes into 00:36:35.114 --> 00:36:38.655 getting those contracts in shape up front. Getting 00:36:38.664 --> 00:36:40.474 land if you need to, you know, if you're acquiring 00:36:40.485 --> 00:36:45.514 land as part of the project. Uh securing water, all 00:36:45.523 --> 00:36:48.244 the permitting cost. And then two in particular, I 00:36:48.253 --> 00:36:50.239 want to talk about. (item:3.4:Tom Atkins on loan fees) I don't know that there'll be any 00:36:50.250 --> 00:36:52.889 loan fees. But in a third party transaction, there 00:36:52.898 --> 00:36:56.090 are sometimes loan fees. Those are generally counted 00:36:56.099 --> 00:36:58.929 as capital cost because it's a cost to get the project 00:36:58.938 --> 00:37:02.300 in the ground. (item:3.4:Tom Atkins on interest during construction) And, and secondly, uh if there's any 00:37:02.349 --> 00:37:04.849 interest during construction. So to the extent that 00:37:04.860 --> 00:37:08.320 the the state loans money during construction before 00:37:08.329 --> 00:37:10.639 there's a revenue stream. Because the project is being 00:37:10.648 --> 00:37:13.500 built. That interest during construction has to be 00:37:13.510 --> 00:37:16.728 paid that adds to the capital cost. And it's important 00:37:16.739 --> 00:37:20.023 that, that be considered part of the total capital cost 00:37:20.083 --> 00:37:23.014 uh sort of window. So qualifying capital costs are 00:37:23.023 --> 00:37:26.155 important and we'd be happy to provide specific details 00:37:26.164 --> 00:37:28.695 of that in a, in a subsequent filing. Brian, I'll get 00:37:28.704 --> 00:37:31.074 to you in just a sec. To follow on that. Which you 00:37:31.083 --> 00:37:34.155 mentioned the estimated cost for the loan cap portion. 00:37:34.164 --> 00:37:36.934 Would you recommend the same calculation for the deposit 00:37:36.945 --> 00:37:40.250 amount? (item:3.4:Tom Atkins on collateral deposit amounts) Yes. Yes, we would. And that deposit is an 00:37:40.260 --> 00:37:42.320 important collateral item as well. Certainly during 00:37:42.329 --> 00:37:45.409 construction that 3%. Absolutely we would say that 00:37:45.418 --> 00:37:47.978 that's there to make sure that there's skin in the 00:37:47.989 --> 00:37:50.489 game. More skin in the game in case there's a problem. 00:37:50.500 --> 00:37:53.389 So we do. And the last point I'll make for yielding 00:37:53.398 --> 00:37:56.719 here. (item:3.4:Tom Atkins on contingency) Contingency, contingency is a big item too. When 00:37:56.728 --> 00:38:00.010 when someone plans to build a project of this size 00:38:00.019 --> 00:38:03.619 and nature. You think, you know everything. But we're 00:38:03.628 --> 00:38:05.780 smart enough to know, we don't know everything. And 00:38:05.789 --> 00:38:07.860 something is going to happened during construction 00:38:07.869 --> 00:38:11.760 that we did not expect. So it's typical to have a contingency 00:38:11.769 --> 00:38:14.969 level of at least 5% of the capital cost. So if it's 00:38:14.978 --> 00:38:18.239 a $100 million project, you would want to have at least 00:38:18.250 --> 00:38:22.550 $5 million. It's not targeted against a specific expense. 00:38:22.559 --> 00:38:27.398 But it's a contingency item that any commercial lender 00:38:27.409 --> 00:38:30.739 would require you to have in your project budget. To 00:38:30.750 --> 00:38:33.228 take care of things that might come up. Because what 00:38:33.239 --> 00:38:35.478 you don't want to have happen is somebody is so tight 00:38:35.708 --> 00:38:38.398 to the, you know, letter of what they applied for. 00:38:38.418 --> 00:38:40.648 Something happened, something cost a little more than 00:38:40.659 --> 00:38:43.820 they thought. Something changed and now there's no money 00:38:43.829 --> 00:38:46.659 to pay for it. So the contingency is another item that 00:38:46.668 --> 00:38:49.579 we would strongly suggest should be included within 00:38:49.590 --> 00:38:53.679 that capital cost qualifying. Brian, you had a comment on that. 00:38:53.688 --> 00:38:56.878 Yeah, this is I'm speaking on behalf of Calpine now. 00:38:56.889 --> 00:39:00.168 (item:3.4:Brian Sams with Calpine on estimated costs and finance language) Uh we had all of these exact same questions. I feel 00:39:00.179 --> 00:39:02.228 like you could have been in, in the meeting in, in 00:39:02.239 --> 00:39:05.000 my house and we were talking about these things. Uh 00:39:05.010 --> 00:39:08.360 So I just, I wanna reiterate how important all of that 00:39:08.369 --> 00:39:13.320 clarity on what that is. Um And also I've just learned 00:39:13.329 --> 00:39:15.610 that the finance people have their own kind of language. 00:39:15.619 --> 00:39:19.010 And so making sure that you know how we define this 00:39:19.019 --> 00:39:22.739 is consistent with that kind of finance language when 00:39:22.750 --> 00:39:25.829 these materials come out. Great. 00:39:28.909 --> 00:39:31.050 I, I guess what is it? Uh I want to go on 00:39:31.059 --> 00:39:36.369 to another subject. New topic. Okay. Um there, there's 00:39:36.378 --> 00:39:41.110 a question in here uh related to. I'm sorry, let's get 00:39:41.119 --> 00:39:46.610 to the right place here. (item:3.6:Tom Atkins with NRG on debt covenant regarding reliability) Oh, debt covenant regarding reliability. 00:39:46.619 --> 00:39:49.148 That there would be some minimum performance level 00:39:49.159 --> 00:39:52.110 that would be a debt covenant. Now, debt covenant means 00:39:52.119 --> 00:39:54.269 if you, if you don't meet that covenant, you're in 00:39:54.280 --> 00:39:57.148 default of a loan, it's a big deal. Okay. And anybody 00:39:57.159 --> 00:39:59.789 who's looking at this, any equity providers. They're 00:39:59.800 --> 00:40:01.909 going to look and say, whoa I have to read that very 00:40:01.918 --> 00:40:04.898 carefully. Because being in default of a loan, especially 00:40:04.909 --> 00:40:06.519 a loan like this is going to be a big trouble. Because 00:40:06.530 --> 00:40:09.019 to replace this loan, it's going to be very expensive. 00:40:09.039 --> 00:40:12.824 So be very, very important that any debt that would 00:40:12.833 --> 00:40:16.175 result in a default be thought through carefully. And 00:40:16.184 --> 00:40:19.353 what we would suggest on a performance basis is that 00:40:19.414 --> 00:40:22.333 the standard be something that's reasonably achievable 00:40:22.344 --> 00:40:24.764 with due diligence of operation and maintenance. (item:3.6:Tom Atkins with NRG on high performance standard) In 00:40:24.773 --> 00:40:26.405 other words, it shouldn't be a high standard. Because 00:40:26.414 --> 00:40:28.534 if it's a high standard, people are going to be afraid 00:40:28.543 --> 00:40:30.494 the loan is going to default. You know, something could 00:40:30.503 --> 00:40:34.489 happen in any year, an unexpected outage. And all of 00:40:34.500 --> 00:40:37.039 a sudden, you know, you're three months fixing something. 00:40:37.119 --> 00:40:40.168 And you drop below the standard for the, for the 00:40:40.179 --> 00:40:42.500 covenant, you're in default to your loan. It's, it's 00:40:42.510 --> 00:40:45.728 a bad situation. (item:3.6:Tom Atkins on defaults) So wanna make sure that things that 00:40:45.739 --> 00:40:49.019 result, result potentially in defaults are carefully 00:40:49.030 --> 00:40:52.000 thought through. There's an opportunity for an applicant 00:40:52.010 --> 00:40:54.489 to cure default like you're in default. Now you have 00:40:54.500 --> 00:40:57.728 so many days to cure this default. And that it not be 00:40:57.739 --> 00:41:00.849 a standard that, that's so high. As to all of a sudden 00:41:00.860 --> 00:41:03.780 all the loans are defaulting. So be very careful and 00:41:04.039 --> 00:41:08.070 anything that results in a, a covenant. That could result 00:41:08.079 --> 00:41:08.610 in the default. 00:41:10.228 --> 00:41:13.708 That's helpful. Okay, to do. 00:41:15.228 --> 00:41:18.668 We can talk about timing too if you want. Well, before 00:41:18.679 --> 00:41:21.510 we do timing. Is are there any, is there anyone else 00:41:21.519 --> 00:41:23.878 who would like to speak on some of the. You know, the 00:41:23.889 --> 00:41:25.849 the nuts and bolts of what ought to be included in 00:41:25.860 --> 00:41:27.280 the rule or how we have to think about them? 00:41:37.429 --> 00:41:40.769 Mr. Reed? (item:3.1:Cyrus Reed with The Sierra Club on Legislation stating other factors) Yes uh Cyrus Reed, Sierra Club. Um if you go 00:41:40.780 --> 00:41:43.019 back to the Legislation, there's something that says 00:41:43.030 --> 00:41:45.688 other factors that you guys should look at. And I just 00:41:45.699 --> 00:41:49.809 wanted to mention that. (item:3.2:Cyrus Reed with The Sierra Club on meeting environmental permitting) Um obviously, as part of the 00:41:49.820 --> 00:41:54.110 application, you would want to be assured that the 00:41:54.119 --> 00:41:57.610 folks applying can meet any environmental permitting 00:41:57.619 --> 00:42:01.699 requirements. So as an example, um if they're gonna 00:42:01.708 --> 00:42:04.570 locate in the Greater Houston area and are subject 00:42:04.579 --> 00:42:07.688 to tighter restrictions on nuts. You would want to know 00:42:07.699 --> 00:42:09.579 that and you would want to make sure that they could 00:42:09.590 --> 00:42:12.329 meet those criteria. So you didn't give a loan and 00:42:12.340 --> 00:42:14.099 then discover they couldn't get the permit they need 00:42:14.110 --> 00:42:17.389 from TCEQ. So there's a number of those issues. But just 00:42:17.610 --> 00:42:20.769 somewhere in the application making sure they demonstrate 00:42:20.780 --> 00:42:22.688 that they're gonna be able to meet those criteria is 00:42:22.699 --> 00:42:25.659 is important. And of course, those criteria change all 00:42:25.668 --> 00:42:28.079 the time. Um thanks to The Sierra Club. 00:42:30.010 --> 00:42:32.438 Thanks for that and I'm seeing some agreement too. 00:42:36.079 --> 00:42:39.369 Any other pieces of the necessary components for this 00:42:39.378 --> 00:42:42.489 rulemaking before we get to the next big chunk? 00:42:44.679 --> 00:42:48.250 The next item uh I might have some guesses about you. 00:42:48.260 --> 00:42:51.739 (item:3.9:Dave Gordon with PUC Staff opens the floor with question on timing) What you all might say about timing? But I, I will 00:42:51.750 --> 00:42:54.478 wait to hear it from you instead. And this, this really 00:42:54.489 --> 00:42:59.300 deals with um the timing of the programs. Um one thing 00:42:59.309 --> 00:43:02.530 I just want to note for this one in particular. Is if 00:43:02.539 --> 00:43:05.559 you think that um the timing should be interrelated 00:43:05.570 --> 00:43:08.579 with any of the other programs? Uh please do speak 00:43:08.590 --> 00:43:10.820 up on that. Because that will help our prioritization 00:43:10.829 --> 00:43:14.559 for how we move forward with these uh various programs. 00:43:17.269 --> 00:43:22.679 Mr. Atkins? Thank you. First of all, let me thank the Commission's 00:43:22.688 --> 00:43:25.148 forethought in being here today for a workshop right 00:43:25.159 --> 00:43:27.610 now to talk about this. Even though we know we have 00:43:27.619 --> 00:43:30.989 you know, a November election. That is required to enable 00:43:31.099 --> 00:43:33.628 the Legislation. So it's important to get a jump start 00:43:33.639 --> 00:43:36.063 and we've seen some deadlines that are already in place 00:43:36.074 --> 00:43:38.844 and we encourage that. And I think that is important. 00:43:39.063 --> 00:43:41.655 (item:3.9.2:Tom Atkins with NRG on Completion Bonus Grant Program deadline) One of the deadlines in the Completion Bonus Grant 00:43:41.664 --> 00:43:45.695 Program is Summer 2026. Having a facility online Summer 00:43:45.704 --> 00:43:49.364 2026 gets you the max Completion Bonus. So there's 00:43:49.375 --> 00:43:53.204 a big incentive to hit that date. I would suggest that 00:43:53.344 --> 00:43:58.945 this program of funding loans. Would need to actually 00:43:59.375 --> 00:44:02.985 be funding by the end of 2024 in order for anyone to 00:44:02.994 --> 00:44:08.050 have a chance to hit that 2026 Summer. So to the extent 00:44:08.059 --> 00:44:10.559 that that remains important, and I suggest it does. 00:44:11.019 --> 00:44:14.648 (item:3.9:Tom Atkins on loan proceeds availability) Having loans, loan proceeds available by the end of 00:44:14.659 --> 00:44:17.619 next year. Would be important and then one could back 00:44:17.628 --> 00:44:20.039 up from that date. And say okay well, when does the 00:44:20.050 --> 00:44:21.958 rule have to come out? When would applications have 00:44:21.969 --> 00:44:23.878 to go in? How much time does the Commission need to 00:44:23.889 --> 00:44:27.949 evaluate the applications to award loans? I haven't 00:44:27.958 --> 00:44:31.079 done that calculation backwards. But if you start with 00:44:31.469 --> 00:44:34.159 actually funding loans by the end of next year in order 00:44:34.168 --> 00:44:37.610 to get some projects online for Summer 2026. I think 00:44:37.619 --> 00:44:40.599 is a good, a good starting point. I'll ask a follow 00:44:40.610 --> 00:44:42.688 up on that and you may not have an answer, Mr. Atkins. 00:44:42.699 --> 00:44:47.019 But uh, anyone may um do you have a sense of whether 00:44:47.030 --> 00:44:50.039 somebody must be a borrower under the loan program 00:44:50.050 --> 00:44:52.300 to also be a performance grant recipient? 00:44:55.188 --> 00:44:57.360 I, I haven't, I haven't thought about that. Certainly 00:44:57.369 --> 00:44:59.260 in our case we we've, we've put them together in 00:44:59.269 --> 00:45:01.530 our minds. And when it comes to timing, you did ask 00:45:01.539 --> 00:45:03.570 about whether things are connected and I would say 00:45:03.579 --> 00:45:08.250 that they are connected. (item:3.9.2:Tom Atkins on understanding the Completion Bonus Grant) Because um the Completion Bonus 00:45:08.260 --> 00:45:11.559 Grant is something that people will look at as part 00:45:11.570 --> 00:45:14.969 of the economic package that we are presenting under 00:45:14.978 --> 00:45:18.599 a loan application. And so understanding the rules 00:45:18.610 --> 00:45:21.648 for that Completion Bonus Grant. Will be important to 00:45:21.659 --> 00:45:25.050 get approvals. And NRG internal approvals will be, well 00:45:25.059 --> 00:45:27.519 can we count on revenues from the Completion Bonus 00:45:27.530 --> 00:45:29.949 Grant or not? I don't know because they haven't been 00:45:29.958 --> 00:45:32.559 published the rules yet that's going. So I would suggest 00:45:32.570 --> 00:45:35.949 that those two are hand in hand. (item:3.9.3:Tom Atkins with NRG on interconnection to ERCOT) I don't think someone 00:45:35.958 --> 00:45:38.969 should be able to apply for a Completion Bonus Grant 00:45:39.179 --> 00:45:41.989 until they're complete. I mean that's you know, you 00:45:42.000 --> 00:45:44.119 you, get interconnected. That the Legislation 00:45:44.128 --> 00:45:46.809 talks about interconnected to ERCOT. So once you're 00:45:46.820 --> 00:45:49.148 interconnected to ERCOT. I think at that point, you could 00:45:49.159 --> 00:45:53.000 apply for the Grant. (item:3.9.4:Tom Atkins on rules outlined in advance of loan application deadline) But knowing what the rules are 00:45:53.010 --> 00:45:55.829 at least at a high level is gonna be important before 00:45:55.840 --> 00:45:59.244 loan applications go in. So people know okay, I think 00:45:59.253 --> 00:46:03.195 I can qualify for the $120,000 instead of the $80,000. 00:46:03.204 --> 00:46:06.675 Or here, here are the performance requirements and 00:46:06.684 --> 00:46:08.474 I know I'm not going to get all of it. So I'm 00:46:08.485 --> 00:46:11.135 only, I'm only going to assume I'm going to get half 00:46:11.144 --> 00:46:13.784 of it or something like that. So yes, I think it is 00:46:13.793 --> 00:46:16.445 important that the rules for the Completion Bonus Grant 00:46:16.454 --> 00:46:22.103 Program be outlined in advance of loan application 00:46:22.114 --> 00:46:22.554 deadline. 00:46:26.159 --> 00:46:30.039 I think I saw Wärtsilä trying to. I mean, I can certainly add 00:46:30.050 --> 00:46:33.489 to that. Um just building off of what's being said. 00:46:33.500 --> 00:46:38.208 So just so the Commission is a, is aware um in your 00:46:38.559 --> 00:46:41.648 various talks with different market participants. (item:3.9.3:Russell Weeks with Wärtsilä on prioritization queues) Is 00:46:42.519 --> 00:46:46.280 will there be any sort of prioritization through the 00:46:46.289 --> 00:46:48.519 queues through the, you know, the transmission and 00:46:48.530 --> 00:46:51.688 distribution studies, some sort of priority for Grant. 00:46:51.699 --> 00:46:55.769 Like people that are awarded grants. Currently, you 00:46:55.780 --> 00:46:58.760 know, if you had a Greenfield project. I couldn't see 00:46:58.769 --> 00:47:01.320 it going online before 2027. So you're immediately 00:47:01.329 --> 00:47:05.628 going to miss the $120,000 and that's not even due 00:47:05.639 --> 00:47:09.909 to process. That's due to supply constraints with breakers 00:47:10.289 --> 00:47:13.070 um depending on which high voltage uh set up that you 00:47:13.079 --> 00:47:17.760 go with, what you need. Um so that's, that's something 00:47:17.769 --> 00:47:20.648 that's been on our mind when it comes to projects. Is 00:47:20.659 --> 00:47:25.228 uh what sort of uh funding by 2024 will certainly help 00:47:25.239 --> 00:47:29.148 people that are ready to go like today. Um but nothing 00:47:29.159 --> 00:47:33.289 nothing new beyond that, that's Greenfield. Great. Taylor 00:47:33.300 --> 00:47:35.369 you came up too. Did you have something to add on this 00:47:35.378 --> 00:47:41.760 piece? Sure. (item:3.9.2:Taylor Kilroy with TPPA on cap on loans and completion bonuses) I did want to flag that. Um 0104(d) does 00:47:41.769 --> 00:47:44.550 set a 10,000 Megawatt cap on the amount of money that 00:47:44.559 --> 00:47:48.469 can be spent on both the loans and the Completion Bonuses. 00:47:49.059 --> 00:47:50.918 And so at some point, the Commission is going to need 00:47:50.929 --> 00:47:53.280 to link up. To make sure that they haven't exceeded 00:47:53.289 --> 00:47:56.829 the cap. (item:3.9.6:Taylor Kilroy, TPPA on when a facility get a Completion Bonus & Loan) I think there's an open question as to whether 00:47:56.840 --> 00:48:00.639 or not as they're counting that if a facility gets 00:48:00.648 --> 00:48:02.909 both the completion bonus and that. Whether that should 00:48:02.918 --> 00:48:06.949 count as one Megawatt for both programs or two Megawatts. 00:48:06.958 --> 00:48:09.139 Because they're getting a Megawatt through each program. 00:48:09.458 --> 00:48:11.619 You know, if you build 100 Megawatt facility, is that 00:48:11.929 --> 00:48:14.260 100 megawatts from the completion bonus is 100 Megawatt 00:48:14.269 --> 00:48:16.739 from the loan. So it's 200 towards the cap or 100. 00:48:17.119 --> 00:48:19.300 I think that's an open question. I do not have a position 00:48:19.309 --> 00:48:22.760 on that today. But uh I think it would be helpful to 00:48:22.769 --> 00:48:26.090 have those programs. Uh The rules for those programs 00:48:26.099 --> 00:48:28.918 adopted at relatively at the same time. Just to make 00:48:28.929 --> 00:48:32.989 sure that we don't actually bust that cap. Great. I've 00:48:33.000 --> 00:48:35.918 heard this before too. Relatively the same time. Do 00:48:35.929 --> 00:48:38.949 you are, are you all advocating for concurrently. Meaning 00:48:39.309 --> 00:48:43.668 same day or sort of within a season or a quarter kind 00:48:43.679 --> 00:48:48.519 kind of thing? Any, any thoughts? Not, not understanding 00:48:48.530 --> 00:48:51.539 the question, sorry. Uh I mean do, do these things. 00:48:51.550 --> 00:48:55.449 I guess what I'm trying to ask is. To apply for 00:48:55.458 --> 00:48:58.570 a loan under this program. Would a Performance Bonus 00:48:58.579 --> 00:49:00.849 Grant rule need to be adopted? 00:49:04.559 --> 00:49:07.139 Well, I again. (item:3.9.4:Tom Atkins with NRG on applicant understanding the rules) I, I would think that the the rule should 00:49:07.148 --> 00:49:10.128 be known. So an applicant making the application should 00:49:10.139 --> 00:49:11.909 have an understanding of whether they believe that 00:49:11.918 --> 00:49:14.500 they'll be qualifying for the, the grant or not. Because 00:49:14.510 --> 00:49:17.260 if you don't qualify for the grant, it changes your 00:49:17.269 --> 00:49:20.679 loan application and your whole economics. So understanding 00:49:20.688 --> 00:49:25.090 that the what it takes to get that grant is important 00:49:25.909 --> 00:49:29.869 before the deadline for the application. Okay, you won't 00:49:29.878 --> 00:49:32.469 I don't think you'll see applications for the grant 00:49:32.478 --> 00:49:35.280 for some time. But understanding what the rules around 00:49:35.289 --> 00:49:38.039 it will be. I think is important before the deadline 00:49:38.050 --> 00:49:41.340 for, you know, the the initial application. So it it's, 00:49:41.349 --> 00:49:44.938 it's understood. And I would say just on the point 00:49:44.949 --> 00:49:48.179 we just heard. (item:3.9.2:Tom Atkins with NRG on Megawatt combinations) We would certainly take the position. 00:49:48.188 --> 00:49:51.789 that a Megawatt for the loan program, plus a Megawatt 00:49:51.800 --> 00:49:54.628 for the Completion Bonus Program equals one Megawatt. 00:49:54.639 --> 00:49:56.918 Because otherwise you just cut the program in half 00:49:56.929 --> 00:50:00.320 potentially. So that would be our position on that. 00:50:01.418 --> 00:50:04.369 And then I did want to follow up on something that 00:50:04.378 --> 00:50:07.969 my colleague from Wärtsilä said. (item:3.9.3:Tom Atkins with NRG on procuring equipment) Which there are issues 00:50:07.978 --> 00:50:10.708 right now procuring equipment. Okay. They're very, they're 00:50:10.719 --> 00:50:13.780 caused by a lot of global conditions. But I just found 00:50:13.789 --> 00:50:16.019 out that buying a new high voltage circuit breaker 00:50:16.030 --> 00:50:18.750 takes two years right now. Okay. It used to take less 00:50:18.760 --> 00:50:21.469 than a year, it's two years now. What that means is 00:50:21.478 --> 00:50:25.099 some people who are looking to, you know, implement 00:50:25.110 --> 00:50:28.219 the program quickly and get steel on the ground. May 00:50:28.228 --> 00:50:31.800 spend money before they have certainty on the loan 00:50:31.809 --> 00:50:35.039 application. In fact, anyone who's developing a project 00:50:35.050 --> 00:50:37.429 is spending soft costs right now to get ready. Whether 00:50:37.438 --> 00:50:40.360 it's permitting or otherwise. Just want to make the 00:50:40.369 --> 00:50:44.059 point on timing. (item:3.9:5:Tom Atkins with NRG on 60/40 availability) When funds become available from the 00:50:44.070 --> 00:50:48.550 loan program, it's 60/40. So our impression was that 00:50:48.849 --> 00:50:51.398 all things equal, if nothing had been spent at the 00:50:51.409 --> 00:50:55.619 very start. As money as bills came in, 60% would come 00:50:55.628 --> 00:50:58.128 from the loan, 40% would come from the equity. And that 00:50:58.139 --> 00:51:01.010 would go all the way to the end. But if let's say 00:51:01.019 --> 00:51:05.688 $10 million has been spent before the loan funds. We 00:51:05.699 --> 00:51:08.889 do think that on a timing basis that the, when the 00:51:08.898 --> 00:51:12.418 loan closes. The sponsor should be made whole if you 00:51:12.429 --> 00:51:14.708 will for the 60% that they already spent. So we spent 00:51:14.719 --> 00:51:18.219 $10 million should be able to get 6 of that back when 00:51:18.228 --> 00:51:22.079 the loan initially funds. It's already spent its historic 00:51:22.090 --> 00:51:25.659 expense, but it's qualifying capital cost. And we think 00:51:25.668 --> 00:51:29.199 that the loan should be able to fund that from the 00:51:29.208 --> 00:51:32.639 beginning. And then it would go, our suggestion is. 00:51:32.929 --> 00:51:35.829 That we go 60/40 going forward. So every month, this 00:51:35.840 --> 00:51:37.929 is how much money we spent to build the project. This 00:51:37.938 --> 00:51:42.679 month, 60% of that would come from the loan program. 00:51:42.688 --> 00:51:45.320 And then the sponsor would be providing the other 40. 00:51:45.760 --> 00:51:48.668 Okay. (item:3.9.5:Tom Atkins on guarantee from sponsors) And as I mentioned earlier, you would have had a guarantee 00:51:48.679 --> 00:51:51.909 from the sponsor that the equity is already there. 00:51:51.918 --> 00:51:54.349 So you don't have to worry in month 7, all of a 00:51:54.360 --> 00:51:57.239 sudden the 40% is not there. You have a guarantee for 00:51:57.250 --> 00:52:00.438 that money that, that 40% is already guaranteed, so. 00:52:01.039 --> 00:52:03.329 So should I, as I listen to all these comments. Should 00:52:03.340 --> 00:52:06.938 I be worried about the, the combination of these statements, 00:52:06.949 --> 00:52:10.550 right. (item:3.9.3:David Smeltzer's thoughts on approval of projects) Um we shouldn't approve projects for the loan 00:52:10.559 --> 00:52:12.300 unless we know that they're going to have all their 00:52:12.309 --> 00:52:16.610 financials in line. Um part of the way you add up to 00:52:16.619 --> 00:52:18.719 get all your financials in line. Is you plan for the 00:52:18.728 --> 00:52:20.869 fact that you might be able to get a performance bonus. 00:52:21.110 --> 00:52:24.269 That performance bonus is based on implementation timelines. 00:52:24.429 --> 00:52:27.449 They are extreme unknown implementation timeline 00:52:27.458 --> 00:52:30.250 variable goals that are beyond our control. And we 00:52:30.260 --> 00:52:33.949 shouldn't let you apply for a performance bonus until 00:52:33.958 --> 00:52:37.050 you've completed it. So it feels like are we setting 00:52:37.059 --> 00:52:40.389 ourselves up to approve projects that depend upon a 00:52:40.398 --> 00:52:43.958 performance bonus. That we are not saying that they're 00:52:43.969 --> 00:52:46.099 gonna get until later and/or would we be tying our 00:52:46.110 --> 00:52:49.280 hands in the performance bonus award process. If we're 00:52:49.289 --> 00:52:52.719 approving these marginal products that depend upon 00:52:52.728 --> 00:52:56.039 it? I mean is there a counter to that? (item:3.9.3:Tom Atkins follow-up to David Smeltzer's comments) I think the 00:52:56.050 --> 00:53:00.280 answer to that is. The project sponsor takes certain 00:53:00.289 --> 00:53:03.668 risks. Okay. (item:3.9.3:Tom Atkins with NRG on project risk) Getting a project done on time is a project 00:53:03.679 --> 00:53:07.208 sponsor risk. Okay. And we mitigate that risk by working 00:53:07.219 --> 00:53:10.000 with contractors who sign up for fixed price contracts, 00:53:10.010 --> 00:53:12.668 and fixed timing and liquidated damages. If they're 00:53:12.679 --> 00:53:15.409 not done on time. And things that help us make sure 00:53:15.418 --> 00:53:18.099 a project gets done on time. So we'll make certain 00:53:18.110 --> 00:53:21.458 assumptions about the Completion Bonus Grant. But the 00:53:21.469 --> 00:53:24.398 way the Legislation is set up that gets paid off over 00:53:24.409 --> 00:53:28.860 10 years. So that's 10 years in the future. Okay. Again 00:53:28.869 --> 00:53:31.750 I'm going to put myself in the State's position. I 00:53:31.760 --> 00:53:33.760 don't care if you earn that 10 years later because 00:53:33.769 --> 00:53:36.099 the steel is in the ground. What I have to focus on 00:53:36.110 --> 00:53:38.438 is get the steel in the ground. And then if you have 00:53:38.449 --> 00:53:42.909 trouble after that. Well you know, the State can foreclose 00:53:42.918 --> 00:53:45.628 on the asset and sell it to somebody else, you know. 00:53:45.639 --> 00:53:48.978 And so the steel is there and the asset is there. So 00:53:48.989 --> 00:53:51.739 I don't think that in my mind it is a problem. That 00:53:51.750 --> 00:53:55.099 that's a project risk. That a project sponsor has to 00:53:55.110 --> 00:53:58.289 evaluate and determine how much they're gonna depend 00:53:58.300 --> 00:54:01.099 on that Completion Bonus Grant coming in. Do I really 00:54:01.110 --> 00:54:03.280 how much do I think of that I am really gonna earn? 00:54:03.478 --> 00:54:07.269 And, and so that's a project risk. And I, I don't think 00:54:07.280 --> 00:54:10.510 it's gonna stop people from proceeding with their projects. 00:54:10.550 --> 00:54:12.958 (item:3.9.3:Bill Barnes with NRG on guarantees) And the Completion Bonus isn't guaranteed because it's 00:54:12.969 --> 00:54:15.409 based on performance, right. So that's the whole point. 00:54:15.769 --> 00:54:18.519 No, none of that is, is guaranteed up front. You have 00:54:18.530 --> 00:54:20.519 to actually perform and have an asset that's high quality 00:54:20.530 --> 00:54:22.369 to get that. That's right. I was just, I was just 00:54:22.378 --> 00:54:26.559 responding to the seeming consensus. That there would 00:54:26.570 --> 00:54:29.260 be plan. That people would be incorporating that bonus 00:54:29.269 --> 00:54:31.030 into their planning. And that was the reason why the 00:54:31.039 --> 00:54:32.128 rules. I mean, I 00:54:33.648 --> 00:54:36.148 mean. (item:3.9.3:Brian Sams with Calpine on planning and modeling) I think people will be incorporating that into 00:54:36.159 --> 00:54:38.579 their planning and their modeling for sure. And you 00:54:38.590 --> 00:54:41.438 know for that reason, the rules around the criteria 00:54:41.449 --> 00:54:44.449 need to be super clear at the outset. Because people 00:54:44.458 --> 00:54:48.429 will indeed, you know, book that money somehow or the 00:54:48.438 --> 00:54:52.719 absence of it somehow. Um and on that point. (item:3.9.3:Brian Sams on discretion of the up to amount) One the questions 00:54:52.728 --> 00:54:56.539 we had internally was um, it's up to amount. Like what 00:54:56.550 --> 00:54:58.918 kind of discretion is there? You know, within that 00:54:58.929 --> 00:55:04.030 10 year period uh to change the, the the bonus payout. 00:55:04.039 --> 00:55:07.070 If someone is eligible for it? And just, you know, clarity 00:55:07.079 --> 00:55:09.188 around what that looks like is, is helpful. Because 00:55:09.199 --> 00:55:12.648 otherwise it gets discounted in uh your, you know 00:55:12.659 --> 00:55:16.070 your performer for the project. And I see the TIAC 00:55:16.079 --> 00:55:22.110 came up and. (item:3.9.John Ross Hubbard with TIAC on formatting rules) John Ross Hubbard, TIAC. Um I, I think while 00:55:22.119 --> 00:55:26.050 companies may factor that factor the bonus in as they're 00:55:26.059 --> 00:55:29.590 applying for the loan. I think formatting the rule 00:55:29.599 --> 00:55:32.269 in a way that they're distinct is also important. Because 00:55:32.280 --> 00:55:35.800 I could see and it is wanting to apply only for the 00:55:35.809 --> 00:55:39.550 completion bonus and not for the loan. Um and so having 00:55:39.559 --> 00:55:42.438 that flexibility, I think is important. And I think 00:55:42.449 --> 00:55:46.668 in terms of um figuring out whether or not companies 00:55:46.679 --> 00:55:50.050 are factoring that in that could be part of the material 00:55:50.059 --> 00:55:54.340 submitted as you're evaluating the candidates. (item:3.9.3:Megan Griffiths with Targa on modeling factors) This 00:55:54.349 --> 00:55:57.179 is Megan Griffiths with Targa. I would echo what John 00:55:57.188 --> 00:55:59.349 said. I think each project is going to be different. 00:55:59.360 --> 00:56:02.639 And so NRG and Calpine, you know, may have a view on 00:56:02.648 --> 00:56:05.539 how they factor that into their model. Whereas a different 00:56:05.550 --> 00:56:08.469 type of project may or may not be factoring that as 00:56:08.478 --> 00:56:10.869 heavily into their model. The rules of the road do 00:56:10.878 --> 00:56:13.030 need to be laid out for everybody. And I, so I agree 00:56:13.039 --> 00:56:15.728 with that sentiment. But there will be different types 00:56:15.739 --> 00:56:19.119 of projects. Great, thank you. Taylor? Um totally different 00:56:19.128 --> 00:56:20.679 topic. What's your password? 00:56:22.989 --> 00:56:23.019 Yeah, 00:56:25.699 --> 00:56:26.739 That's it. You don't know it Dave? 00:56:28.699 --> 00:56:33.648 It's, it's PUC number two David. His password is number two David. I heard 00:56:33.659 --> 00:56:35.159 undersign number one pick. 00:56:45.610 --> 00:56:48.110 Great. I think that's some useful context about sort 00:56:48.119 --> 00:56:51.500 of the timing related to those two pieces. And, and 00:56:51.510 --> 00:56:54.500 thanks to everybody for speaking up on that, on that 00:56:54.510 --> 00:56:58.820 piece of it. Um obviously, it's gonna be difficult 00:56:58.829 --> 00:57:03.070 to manage um in that order. But I would be remiss to 00:57:03.079 --> 00:57:06.389 just not add this to timing challenges. (item:3.9:Brian Sams with Calpine on market design) That applicants 00:57:06.398 --> 00:57:09.340 are encounter when applying for a loan. Like market 00:57:09.349 --> 00:57:12.469 design is super important to having an insight into 00:57:12.739 --> 00:57:16.590 I know. Uh into, into like what your expectations can 00:57:16.599 --> 00:57:19.860 be about the future. Uh and that's probably a TCPA 00:57:19.869 --> 00:57:20.409 comment. 00:57:22.610 --> 00:57:25.300 Thank you. And on that note, we are one half done with 00:57:25.309 --> 00:57:26.938 our allotted time. So I hope you feel you've gotten 00:57:26.949 --> 00:57:31.039 one half of your, your comments given. So, yeah 00:57:31.050 --> 00:57:33.280 we're good. I wanted to make sure that we're not sending 00:57:33.289 --> 00:57:36.918 people out into 4:30 Austin traffic. So we'll, we'll 00:57:36.929 --> 00:57:39.260 shoot for another hour or so. If, if the time takes 00:57:39.269 --> 00:57:45.000 up that uh that much. Um one other piece that we touched 00:57:45.010 --> 00:57:49.059 on for the Outside of ERCOT Grants. (item:2.6:Dave Gordon with PUC Staff opens the floor on program functionality) Was the um uh necessary 00:57:49.070 --> 00:57:52.300 functionality of the program. Um and I'll ask sort 00:57:52.309 --> 00:57:55.110 of a similar question is what kind of assistance might 00:57:55.119 --> 00:57:58.659 applicants need on this side? Um and um 00:58:01.019 --> 00:58:05.050 if you had a thought? Or, or envisioned a particular 00:58:05.059 --> 00:58:07.889 process for how somebody is going to go about applying 00:58:07.898 --> 00:58:12.579 for these loans. I'd love to hear what has worked in 00:58:12.590 --> 00:58:15.409 the past? You know, what kind of models are useful, 00:58:15.418 --> 00:58:18.530 so. Anybody is welcome to chime in on this as well. 00:58:22.648 --> 00:58:25.489 (item:2.6:Tom Atkins with NGR on program functionality) Well we, we would think that the rule would come out 00:58:25.500 --> 00:58:29.820 and it would include an application process. And that 00:58:29.829 --> 00:58:32.519 would include sort of timing of the process. When, when 00:58:32.530 --> 00:58:35.619 the PUC would be ready to receive applications. And 00:58:35.628 --> 00:58:39.059 what as a minimum would be required as part of an application 00:58:39.070 --> 00:58:41.889 package? And we'll be happy to respond in writing as 00:58:41.898 --> 00:58:43.849 to the kinds of things that we think would be appropriate 00:58:43.860 --> 00:58:48.280 for that. So happy to do that. And, and that's uh I 00:58:48.289 --> 00:58:50.728 think that's the correct guidance. Here's the timing 00:58:50.739 --> 00:58:52.750 for the program. Here are the things that you need 00:58:52.760 --> 00:58:58.789 to include to apply for a loan. And in some sense, some 00:58:58.800 --> 00:59:01.878 target as to how long it would take to evaluate loan 00:59:01.889 --> 00:59:05.659 applications before making a decision? Right. That 00:59:05.668 --> 00:59:08.938 is another thing. So we do have the deadline for beginning 00:59:08.949 --> 00:59:11.659 to accept those applications if there's an appropriate 00:59:11.668 --> 00:59:13.619 time period for which we should have the application 00:59:13.628 --> 00:59:17.128 window open? Those thoughts would be useful in any 00:59:17.139 --> 00:59:19.139 comments that anyone would like to follow up with. 00:59:20.519 --> 00:59:24.090 Um another component of this group of questions is 00:59:24.099 --> 00:59:29.079 deals with disbursement of funds. (item:3.9.5:Dave Gordon with PUC Staff opens floor for comments on disbursement) Um I'd be interested 00:59:29.090 --> 00:59:33.289 to know from the people who like to borrow. How might 00:59:33.449 --> 00:59:37.860 the PUC make manageable dispersement of, of these funds 00:59:37.869 --> 00:59:40.019 during the construction process? If you all have any 00:59:40.030 --> 00:59:40.610 thoughts there? 00:59:44.728 --> 00:59:47.079 (item:3.9.5:Tom Atkins with NRG on disbursing loan funds) I, I think I, I had addressed that before. But just a quick 00:59:47.090 --> 00:59:51.519 summary. Um when a loan funds, so when it closes. You're 00:59:51.530 --> 00:59:54.119 approved. Now we're ready, we have the funds available. 00:59:54.269 --> 00:59:56.898 There should be, you know, a draw package which is 00:59:56.909 --> 01:00:00.969 it's incumbent on the sponsor. To now submit to the 01:00:00.978 --> 01:00:05.898 Texas Energy Fund. Here is this month's bill at closing 01:00:05.989 --> 01:00:09.260 we spent $10 million getting to this point. So we're 01:00:09.269 --> 01:00:13.000 asking for $6 million. Now, next month we spent $2 million 01:00:13.010 --> 01:00:17.909 more. So we're asking for 1.2 and we'll put up 800. 01:00:17.918 --> 01:00:21.458 So get it on a monthly basis going forward. And there 01:00:21.469 --> 01:00:23.539 was a question again, trying to save time here. (item:3.9.5:Tom Atkins with NRG on communication and administrative agents) But 01:00:23.550 --> 01:00:26.418 you asked, you know what, what could the could help 01:00:26.429 --> 01:00:28.519 the Commission in communications and things like that. 01:00:29.139 --> 01:00:32.269 There are administrative agents who do this, their 01:00:32.280 --> 01:00:36.039 job to like administer loans. So that's something again 01:00:36.050 --> 01:00:39.398 on a third party basis. The fund could consider retaining 01:00:39.409 --> 01:00:42.628 an administrative agent. To make everyone's life easy. 01:00:42.639 --> 01:00:45.929 And keep track of all right, this project submitted this 01:00:45.938 --> 01:00:48.628 draw package and they, they checked all the boxes. 01:00:48.639 --> 01:00:51.300 So I'm dispersing money. And, and they would be sort 01:00:51.309 --> 01:00:54.300 of the guardian for when does the money actually get 01:00:54.309 --> 01:00:57.188 wired and how much? David, he thinks we can't do it. 01:00:57.199 --> 01:00:58.179 Just the two of us. 01:00:59.918 --> 01:01:03.039 No. Okay, well. That's going in the application. Noted. 01:01:06.228 --> 01:01:08.958 All right. Well, are there any other thoughts about 01:01:08.969 --> 01:01:12.909 the uh Loan Inside ERCOT program before we move on? 01:01:12.918 --> 01:01:16.119 Bill? I did have. This is more of an administrative 01:01:16.128 --> 01:01:20.148 question. Can I ask you guys a question? (item:3:Bill Barnes with NRG on the Texas Energy Fund Advisory Committee) Uh this has 01:01:20.159 --> 01:01:23.699 to do within Senate Bill 2627. Uh one of the requirements 01:01:23.708 --> 01:01:26.849 is the establishment of the Texas Energy Fund Advisory 01:01:26.860 --> 01:01:29.579 Committee. Obviously, we're going through the process 01:01:29.590 --> 01:01:32.860 now of developing rules for the program. This Advisory 01:01:32.869 --> 01:01:37.148 Committee also has responsibility over reviewing and 01:01:37.159 --> 01:01:39.829 providing comments and recommendations on the rules 01:01:39.840 --> 01:01:42.199 regarding the use of the funds. Right. My question 01:01:42.208 --> 01:01:45.269 to you is how do you foresee the Advisory Committee 01:01:45.280 --> 01:01:48.000 interacting with the Commission and timing of such? 01:01:48.628 --> 01:01:53.849 (item:3:Dave Gordon with PUC Staff on Texas Energy Fund Advisory Commitee) Um I think our timelines are really driven by that 01:01:53.860 --> 01:01:57.889 for right now that June 1st application date. Um the, 01:01:57.909 --> 01:02:00.309 the Committee that you're referencing is a Legislatively 01:02:00.320 --> 01:02:03.668 impaneled committee. Um and we are going to take 01:02:03.679 --> 01:02:07.918 the recommendations that they have made. Um but uh 01:02:09.090 --> 01:02:11.570 I don't wanna say anything. (item:3:David Smeltzer with PUC Staff on Texas Energy Fund Advisory Committee) It's not clear to us that 01:02:11.579 --> 01:02:14.340 we can afford to wait. And we don't have any control 01:02:14.349 --> 01:02:17.809 over when that will be impaneled. And so uh when 01:02:17.820 --> 01:02:20.188 when they get here, we'll see how they want to interact 01:02:20.199 --> 01:02:22.590 with us, I guess. Will you wait? We, we have we, I 01:02:22.599 --> 01:02:24.418 don't have any more insight on this than I do about 01:02:24.429 --> 01:02:27.320 when we'll get a new Chairman. I mean, do you think 01:02:27.329 --> 01:02:29.110 you'll wait to adopt a rule until the Committee is 01:02:29.119 --> 01:02:32.128 established? No I, I anticipate that we will move 01:02:32.139 --> 01:02:35.878 forward um in the extent that we can. Um because 01:02:37.449 --> 01:02:39.840 we don't know, we can't control for that variable. 01:02:39.889 --> 01:02:43.309 (item:3:David Smeltzer on waiting for Committee to be impaneled) And I think that the, when the Legislation was going 01:02:43.320 --> 01:02:45.019 through, there were prior versions of the draft that 01:02:45.030 --> 01:02:48.050 required us to take their advice into account. And 01:02:48.059 --> 01:02:50.148 now I think the language is often to consider something 01:02:50.159 --> 01:02:52.898 like that. And I think that's something that our GR 01:02:52.909 --> 01:02:55.289 Team helped work on. Because of exactly the concern 01:02:55.300 --> 01:02:58.559 that you're raising. If we've got deadlines and we, we have 01:02:58.570 --> 01:03:00.530 no control over some of the inputs. That's a problem. 01:03:00.539 --> 01:03:03.519 (item:3:Dave Gordon on waiting for Committee to be impaneled) Yeah. And we, and we fully anticipate um receiving 01:03:03.530 --> 01:03:06.139 the comments and input from that Committee once it's 01:03:06.148 --> 01:03:09.969 impaneled. Um but I think that we can accomplish the 01:03:09.978 --> 01:03:14.949 work that's envisioned in the Bill. Uh without them 01:03:14.958 --> 01:03:18.760 if, if we have to do that. Thanks. Yeah. 01:03:23.079 --> 01:03:28.168 All right. I think that takes care of our Inside ERCOT 01:03:28.179 --> 01:03:32.000 Loan Program. (item:4:Dave Gordon with PUC Staff opens up the floor for discussion on the Completion Bonus Grant) And we have touched on a bit of the Completion 01:03:32.010 --> 01:03:34.789 Bonus Grant stuff. But I, I do want to open this section 01:03:34.800 --> 01:03:37.878 up particularly for the, the Performance Bonus Grant. 01:03:38.360 --> 01:03:42.599 Um and I'll, I'll start again with uh you know what 01:03:42.610 --> 01:03:45.628 you all think the essential components of a rule need 01:03:45.639 --> 01:03:50.489 to be for this program. And so anybody who would like 01:03:50.500 --> 01:03:53.719 to speak on this? Mr. Atkins? 01:03:56.898 --> 01:03:59.938 Popular today. Not shy, and happy to share. So you did ask the question of, you 01:03:59.949 --> 01:04:02.809 know what metric? (item:4.1:Tom Atkins with NRG on hours and reserve) I think the Legislation talks about 01:04:02.820 --> 01:04:05.378 the 100 hours, the top 100 hours. The lowest reserve 01:04:05.389 --> 01:04:07.769 requirement in, in the, in the pool if you will in 01:04:08.478 --> 01:04:11.148 ERCOT. Look back and see how did you perform during those 01:04:11.159 --> 01:04:14.708 100 hours. (item:4.1:Tom Atkins on EAF) We would suggest that the, the performance 01:04:14.719 --> 01:04:19.329 factor for that should be the equivalent availability, EAF. Which 01:04:19.340 --> 01:04:23.469 is the n gas. And that, that's a combination of, at 01:04:23.478 --> 01:04:26.079 what capacity did you operate at and for how long? 01:04:26.090 --> 01:04:27.739 So you're probably familiar with this, but if there 01:04:27.750 --> 01:04:31.449 was 100 hours and you operated for all 100 hours. But 01:04:31.458 --> 01:04:34.978 at just one Megawatt out of 100. That's, that's a EAF 01:04:34.989 --> 01:04:37.360 of 1% you know. Yeah, it was there all the whole time 01:04:37.369 --> 01:04:39.885 but only one Megawatt. If you were there for 50 megawatts 01:04:39.894 --> 01:04:44.655 50%. If you're all 100 hours for all 100 megawatts, 01:04:44.664 --> 01:04:48.014 then you're 100%. So we think equivalent availability 01:04:48.023 --> 01:04:51.974 is what, you know, really reveals how much contribution 01:04:51.985 --> 01:04:56.215 you had to reliability on those 100 hours. (item:4.1:Tom Atkins on median performance) And then 01:04:56.550 --> 01:05:00.719 uh as far as it's a graduating scale. Of you know, 01:05:00.728 --> 01:05:03.619 I forget the exact I know optimum is, is the top and 01:05:03.628 --> 01:05:07.610 median is the bottom. So median performance, if you 01:05:07.619 --> 01:05:10.079 just had the median performance, as I understand it. 01:05:10.148 --> 01:05:14.079 It sets the floor. You get like no, you get no Completion 01:05:14.090 --> 01:05:17.280 Bonus Grant for that period of time. And I would suggest 01:05:17.289 --> 01:05:20.039 that this be done on perhaps an annual basis, 100 hours. 01:05:20.050 --> 01:05:21.969 So every, every year is gonna be different. So it's 01:05:21.978 --> 01:05:26.478 an annual look back. And so I would suggest that the median 01:05:26.489 --> 01:05:29.889 performance since it sets the floor should not be too 01:05:29.898 --> 01:05:31.909 high. Otherwise again, people are going to say well 01:05:31.918 --> 01:05:35.139 not getting any of that money. So what that should 01:05:35.148 --> 01:05:39.599 be hard to tell. (item:4.1:Tom Atkins on what is the optimum) We throw out their number 50% as a 01:05:39.610 --> 01:05:42.280 starting point. Where you get, if you're not there, 01:05:42.289 --> 01:05:44.938 at least half the time and half your capacity, you 01:05:44.949 --> 01:05:47.938 get nothing. And then it graduates up to what's the, 01:05:47.949 --> 01:05:52.010 what's the optimum? And the optimum should be achievable 01:05:52.019 --> 01:05:54.329 if everything goes well. It should be, shouldn't be 01:05:54.340 --> 01:05:56.829 impossible. It should be achievable. And so what we 01:05:56.840 --> 01:06:00.449 would suggest there is what people expect to do. Which 01:06:00.469 --> 01:06:05.530 a little nuance here, 95% is a reasonable expectation 01:06:05.539 --> 01:06:08.969 for a mature plant. We would say in its first year 01:06:08.978 --> 01:06:12.610 we would look for a little bit less 92%. Because of 01:06:13.010 --> 01:06:16.030 first year, it can be some issues. (item:4.1:Tom Atkins on graduating scale) So and then there's 01:06:16.039 --> 01:06:18.648 a graduated scale in between that. If you, if you're 01:06:18.659 --> 01:06:22.458 at 50% you get nothing. If you're at 95% you get 100%. 01:06:22.469 --> 01:06:24.668 And there should be some sort of graduated scale in 01:06:24.679 --> 01:06:28.909 between. That's, you know, a very rough concept for 01:06:28.918 --> 01:06:31.789 how you might think about it. But again, the floor 01:06:31.800 --> 01:06:34.780 shouldn't be you know too high. So people aren't 01:06:34.789 --> 01:06:36.860 gonna, you know something happens you get nothing. 01:06:37.148 --> 01:06:41.199 And again, optimum should be achievable. But achievable 01:06:41.208 --> 01:06:44.668 meaning you did as well as you'd hoped to do. That's 01:06:44.750 --> 01:06:47.228 our input. One follow up I have on that. And I think I 01:06:47.239 --> 01:06:49.559 know what your answer will be. But I'll, I'll let you provide 01:06:49.570 --> 01:06:51.918 it again. Um do you think there should be any relationship 01:06:51.929 --> 01:06:54.208 between this performance standard even at like the 01:06:54.219 --> 01:06:57.208 median level and the debt covenant reliability performance 01:06:57.219 --> 01:07:01.250 standard? (item:4.1:Tom Atkins on performance standard & debt covenant reliability performance) No. Okay. I don't. I think they, you know, 01:07:01.260 --> 01:07:03.760 one is, you know, the debt covenant is for reasons 01:07:03.769 --> 01:07:07.688 I mentioned before. That's sort of like a fatal outcome. 01:07:07.699 --> 01:07:10.809 Whereas this, this year, this year I gave up my Completion 01:07:10.820 --> 01:07:13.800 Bonus Grant payment. That's a lot less than I have 01:07:13.809 --> 01:07:14.840 a default on my loan. 01:07:22.949 --> 01:07:23.398 Great. 01:07:38.449 --> 01:07:41.550 Moving down just on the list. I was curious enough 01:07:41.559 --> 01:07:43.938 that anyone in the room has a thought. (item:4.4:Dave Gordon with PUC Staff opens for discussion on existing facilities vs. new construction) About whether 01:07:43.949 --> 01:07:47.829 or not the Performance Grant Program was designed specifically 01:07:47.840 --> 01:07:50.619 for new construction versus upgrades to existing facilities? 01:07:50.628 --> 01:07:54.760 If there is a viewpoint on that? Is there any thoughts 01:07:54.769 --> 01:07:56.898 there? Should one be eligible and one not? 01:08:02.039 --> 01:08:04.918 If you don't chime in, then we'll decide. I'm kidding. 01:08:05.918 --> 01:08:11.079 Um and then one of the comments that we got, uh at 01:08:11.090 --> 01:08:13.590 least one of the comments. (item:4.5:Dave Gordon with PUC Staff's opens floor for discussion what an extenuating circumstance is to extend deadlines) Is there's an allowance for 01:08:13.599 --> 01:08:16.009 extending the deadlines for the Performance Bonus Grant. 01:08:16.020 --> 01:08:20.430 And um it is based on the, the Commission finding that 01:08:20.439 --> 01:08:23.640 extenuating circumstances support extension of a deadline. 01:08:23.989 --> 01:08:26.560 I wondering if anybody has thoughts on what might constitute 01:08:26.569 --> 01:08:30.609 extenuating circumstance in this context? Mr. Atkins? 01:08:31.128 --> 01:08:33.798 I, I do have some thoughts on that. (item:4.5:Tom Atkins with NRG on what an extenuating circumstance is to extend deadlines) And I think the 01:08:34.199 --> 01:08:36.500 the guiding principle, the guiding principle should 01:08:36.509 --> 01:08:41.039 be. Something that's beyond the reasonable control of 01:08:41.048 --> 01:08:44.350 the project. So something happens that could not be 01:08:44.359 --> 01:08:48.708 prevented by reasonable operation and maintenance practices. 01:08:48.720 --> 01:08:50.539 Like I didn't spend enough money on maintenance and 01:08:50.548 --> 01:08:53.579 and a pump broke. Well, sorry to hear that. You know, 01:08:53.588 --> 01:08:56.548 you should have spent more on maintenance. But a hurricane 01:08:56.560 --> 01:08:59.239 came through and, and caused flooding. Whatever that 01:08:59.250 --> 01:09:01.560 you know that's, that's an act of God. Those type 01:09:01.569 --> 01:09:04.628 of things. So our suggestion would be the standard 01:09:04.640 --> 01:09:08.699 should be beyond the reasonable control of the project. 01:09:12.028 --> 01:09:15.457 Hi Dave. (item:4.4:Emily Jolly with LCRA on existing facilities and CDRs) Um Emily Jolly with LCRA. Uh I wanted to go back 01:09:15.469 --> 01:09:19.587 to your last question. Um and, and, and it's not something 01:09:19.599 --> 01:09:22.988 that we've necessarily contemplated. Um but I'm curious 01:09:22.998 --> 01:09:26.188 how y'all are looking at the um the idea of existing 01:09:26.198 --> 01:09:29.979 facilities under the, the grant program. In light of 01:09:29.988 --> 01:09:35.028 the provision. Uh that talks about the eligibility based 01:09:35.038 --> 01:09:39.698 on when the facility is included in the, the June CDR. 01:09:39.707 --> 01:09:43.168 requirement. Right. Can you help us understand how y'all 01:09:43.180 --> 01:09:45.720 are reconciling those? (item:4.4:Dave Gordon on existing facilities CDRs) So I reached out initially to 01:09:45.729 --> 01:09:49.270 ERCOT about this. And um they have mentioned that if 01:09:49.279 --> 01:09:51.689 there would be an upgrade to a facility. That it would 01:09:51.699 --> 01:09:54.619 get reflected in the CDR. So at least that's a starting 01:09:54.628 --> 01:09:58.009 point. Is that the incremental increase would be something 01:09:58.020 --> 01:10:02.720 that is captured in a, in a CDR going forward. Um 01:10:02.729 --> 01:10:05.869 that's the basis on which we have begun to analyze 01:10:05.878 --> 01:10:09.689 this. But uh and, and upgrades of 100 megawatts are 01:10:09.699 --> 01:10:12.338 greater. Right. Right. And that would, that would be 01:10:12.350 --> 01:10:15.239 the, the statutory requirement. But I think if I'm 01:10:15.250 --> 01:10:17.829 to understand ERCOT correctly. Which definitely could 01:10:17.838 --> 01:10:22.259 be the, the wrong approach. Um those incremental upgrades 01:10:22.270 --> 01:10:27.750 would appear in forward looking CDRs. Okay, thank you. And 01:10:27.759 --> 01:10:30.149 then I actually agree with the comments from Mr. Atkins 01:10:30.159 --> 01:10:32.109 on the second piece. I think that's a good standard 01:10:32.119 --> 01:10:34.619 and consistent with rule language. That's, you know 01:10:34.628 --> 01:10:37.750 otherwise in, in the Commission rules. Great. Thanks 01:10:37.759 --> 01:10:37.838 so much. 01:10:42.109 --> 01:10:47.168 Um unless there are any other thoughts on sort of this 01:10:47.180 --> 01:10:49.259 piece of the discussion. We can move on to our next 01:10:49.270 --> 01:10:53.220 chunk, which is the functionality portion of this. 01:10:53.689 --> 01:10:55.770 Yeah, but before we move on to that. (item:3:David Smeltzer's follow-up comments on Advisory Committee) I think that we 01:10:55.779 --> 01:10:57.739 had a, we had a really good question a little bit ago. 01:10:57.750 --> 01:11:00.899 About how we would interact with the Advisory Committee. 01:11:00.909 --> 01:11:02.779 And I think that David and I are sometimes responding 01:11:02.789 --> 01:11:06.279 without having uh the language right in front of us. 01:11:06.289 --> 01:11:09.220 And, you know, consistent with the language of the 01:11:09.229 --> 01:11:11.199 statute. You know, the Advisory Committee when it 01:11:11.208 --> 01:11:13.680 is appointed by the Legislature. The Bill is clear 01:11:13.689 --> 01:11:16.390 that it may give recommendations and it may provide 01:11:16.399 --> 01:11:20.628 it may adopt rules. And so when we talk about Staff 01:11:20.640 --> 01:11:24.009 planning on moving forward. That, you know, as of now 01:11:24.020 --> 01:11:26.109 without the Committee Members. We don't, we don't know 01:11:26.119 --> 01:11:28.029 whether or not they will choose to give recommendations. 01:11:28.039 --> 01:11:31.029 But as the Bill clarifies, we certainly shall give 01:11:31.039 --> 01:11:33.918 those recommendations full consideration. And we would 01:11:33.930 --> 01:11:37.229 expect our bosses here up at the dais to do that as well. 01:11:37.239 --> 01:11:39.239 And so I didn't uh I wanted to make sure that that 01:11:39.250 --> 01:11:41.479 was our comments were understood appropriately. So 01:11:41.489 --> 01:11:43.259 we, we don't have any certainty over whether or not 01:11:43.270 --> 01:11:46.859 we will receive recommendations. But should we receive 01:11:46.869 --> 01:11:49.939 them, obviously we shall consider them. Thanks, thanks 01:11:49.949 --> 01:11:53.119 for clarifying that. I appreciate it. And there was 01:11:53.128 --> 01:11:55.430 one question before you move on. (item:4.3:Tom Atkins with NRG on reliability metrics) It had to do with 01:11:55.720 --> 01:11:59.819 um should the reliability of metrics apply to all facilities 01:11:59.829 --> 01:12:02.470 the same? And the answer that I think is yes, no matter 01:12:02.479 --> 01:12:06.739 the technology. I think all dispatchable you know, 01:12:06.750 --> 01:12:10.529 flexible resources should be measured by the same measure. 01:12:10.539 --> 01:12:13.509 And you, you mentioned that uh a way to do that there 01:12:13.520 --> 01:12:17.789 is a. EAF. But, yeah. Yes, I would suggest that. They would all fall within that. The standard, all 01:12:17.798 --> 01:12:20.619 projects meet the same standard. Different technologies, 01:12:20.628 --> 01:12:22.810 and all included. Great. 01:12:25.310 --> 01:12:27.539 So like I said. I'll move, I'll move on to this next 01:12:27.548 --> 01:12:31.539 batch of questions and um it deals with program functionality. 01:12:31.548 --> 01:12:34.909 (item:4.6:Dave Gordon with PUC Staff opens the floor on program functionality) And I am curious about the thoughts about from the 01:12:34.918 --> 01:12:38.560 room. On um early state that facility could be eligible, 01:12:38.579 --> 01:12:39.079 so. 01:12:40.699 --> 01:12:44.149 How, how should this may link into our discussion about 01:12:44.239 --> 01:12:48.378 you know, the the need to develop rules concurrently. 01:12:48.390 --> 01:12:50.270 Um but any thoughts about when someone is going to 01:12:50.279 --> 01:12:54.000 be eligible for this and should be able to apply? I 01:12:54.009 --> 01:12:56.640 think just reiterating what I said previously. (item:4.7:Tom Atkins with NRG on having clear rules) Rules 01:12:56.649 --> 01:12:59.930 are really important before the application deadline. 01:12:59.939 --> 01:13:02.759 But I don't believe someone should apply, be able to 01:13:02.770 --> 01:13:05.279 apply for the grant until they meet the conditions 01:13:05.289 --> 01:13:08.189 of the grant. Which are they're interconnected to the 01:13:10.109 --> 01:13:10.640 ERCOT grid. Great. 01:13:15.729 --> 01:13:19.048 (item:4.6:Brian Sams with Calpine on what interconnection means) We, we had a question about what interconnection means? 01:13:19.060 --> 01:13:21.359 Um and this is an important one because you can be 01:13:21.369 --> 01:13:26.409 interconnected on test um or you could have uh you 01:13:26.418 --> 01:13:30.220 know, uh commercial operation. And so just having clarity 01:13:30.229 --> 01:13:33.140 around that. For when you develop that kind of criteria 01:13:33.149 --> 01:13:35.628 is important too. I caught that. (item:4.6:Dave Gordon on interconnection impacts) And thanks for mentioning 01:13:35.640 --> 01:13:40.029 the fact that you may be totally ready to go. But something 01:13:40.039 --> 01:13:44.220 beyond your control could impact your interconnection. 01:13:44.229 --> 01:13:47.220 So I think that those would be suitable comments to 01:13:47.229 --> 01:13:49.119 make when we get into the rulemaking. Absolutely. 01:13:53.279 --> 01:13:58.259 Any other pieces on uh functionality around the Performance 01:13:58.270 --> 01:13:59.918 Grant Program, um? 01:14:03.039 --> 01:14:08.520 Any systems issues? These are my last comment. It's 01:14:08.529 --> 01:14:13.649 useful honestly. Well, thank you. They are well taken so. (item:4.8:Tom Atkins with NRG on taking a look back) Um so we think again, there 01:14:13.659 --> 01:14:15.449 should be a look back at, at the end of the year. 01:14:15.458 --> 01:14:18.208 You got to go back and what were the 100 hours that 01:14:18.220 --> 01:14:21.159 counted. You don't know them until the year is over. 01:14:21.168 --> 01:14:24.470 Because you know it could happen at any time. So that 01:14:24.479 --> 01:14:28.020 you there would be a certified, the project would submit 01:14:28.029 --> 01:14:32.689 a certified sort of accounting. For what its equivalent 01:14:32.699 --> 01:14:36.079 availability was during those 100 hours. And we would 01:14:36.088 --> 01:14:39.609 suggest that a copy of that would go to ERCOT. Who could 01:14:39.619 --> 01:14:43.220 potentially be in a position to, you know, say that's 01:14:43.229 --> 01:14:46.329 accurate or otherwise. Based on the data that they get 01:14:46.338 --> 01:14:49.569 from all the generating resources in the, in the pool. 01:14:50.789 --> 01:14:52.878 Going the other way is there any information that 01:14:52.890 --> 01:14:55.279 the potential program participants might need from 01:14:55.350 --> 01:14:58.378 ERCOT to administer this? (item:4.9:Tom Atkins with NRG on 100 hours) Certainly it needs to be 01:14:58.390 --> 01:15:01.418 public. What those 100 hours were? You wouldn't want 01:15:01.619 --> 01:15:04.500 you know, different projects using different hours. 01:15:04.509 --> 01:15:07.409 What are those 100 hours? I think ERCOT would be in 01:15:07.418 --> 01:15:11.109 the best position to at the end of the year. Say, okay 01:15:11.119 --> 01:15:12.359 it was these 100 hours. 01:15:14.989 --> 01:15:15.298 Right. 01:15:19.619 --> 01:15:23.259 I, I will just. (tem:4.9:Tom Atkins on different projects) Again, there's different kinds of projects. 01:15:23.270 --> 01:15:28.359 And so a project that is operating. So say it's operating 01:15:28.369 --> 01:15:32.430 most of the time and those those 100 hours it operated 01:15:32.439 --> 01:15:35.680 through the 100 hours all good. But what about a peaking 01:15:35.689 --> 01:15:40.369 plant that only operates when it, it's called on by 01:15:40.378 --> 01:15:43.439 ERCOT because of pricing. One of those 100 hours, maybe 01:15:43.449 --> 01:15:46.850 it was held back as a reserve unit. As long as it 01:15:46.859 --> 01:15:50.829 was available to operate, it should get full credit. 01:15:51.048 --> 01:15:54.520 If it wasn't dispatched for some reason. That doesn't 01:15:54.529 --> 01:15:57.000 mean it wasn't ready to go and provide the support. 01:15:57.009 --> 01:15:59.180 It may have been held back as an emergency reserve 01:15:59.189 --> 01:16:04.039 or some other reason. (item:4.9:Tom Atkins on equivalent availability) So the standard for equivalent 01:16:04.048 --> 01:16:07.409 availability. Should be either you are operating and 01:16:07.418 --> 01:16:11.000 met the need or you were available to operate but not 01:16:11.009 --> 01:16:14.128 called on. In which case, you should still, you know 01:16:14.140 --> 01:16:16.250 you're standing by on a 10 minute unit. I'm held 01:16:16.259 --> 01:16:19.109 back because, you know, 10 minute units are special 01:16:19.119 --> 01:16:21.458 to the pool. And they need them to reset the system 01:16:21.470 --> 01:16:24.168 after contingencies. You need to hold back a certain 01:16:24.180 --> 01:16:26.739 amount of 10 minute reserve in case something else 01:16:26.750 --> 01:16:30.770 happens. If I got held back, I shouldn't be penalized. 01:16:30.779 --> 01:16:34.069 So it's important either you were operating or you 01:16:34.079 --> 01:16:36.548 could have operated but we're not dispatched. Makes 01:16:36.560 --> 01:16:37.009 sense. 01:16:40.708 --> 01:16:44.600 Any other thoughts around the Performance Grant Program 01:16:44.609 --> 01:16:49.208 before we move forward into Backup Power? I see one. 01:16:55.720 --> 01:17:00.878 Hello. In my view, if you look at the Legislative on 01:17:00.890 --> 01:17:04.279 the entire program is to develop more power and more 01:17:04.289 --> 01:17:07.759 capacity. Can you say who you are real quick? My name's Mike Neary 01:17:07.789 --> 01:17:12.298 and I'm from Dallas, Texas. Great. And uh you know, the Legislative 01:17:12.310 --> 01:17:16.079 intent is to provide for more capacity through the 01:17:16.088 --> 01:17:22.168 incentives. And if you look at any new projects and 01:17:22.180 --> 01:17:25.239 you look at your lead time to accept applications to 01:17:25.250 --> 01:17:29.909 make decisions, we've been in discussions with vendors 01:17:29.918 --> 01:17:33.739 on turbans and equipment and there's not any way on 01:17:33.750 --> 01:17:37.739 a new project in my view that anybody's gonna be able 01:17:37.750 --> 01:17:41.119 to qualify for that higher number because the equipment 01:17:41.128 --> 01:17:44.798 can't be delivered. You just can't get it on a timely 01:17:44.810 --> 01:17:52.149 basis. And either in my view, it would be in the state's 01:17:52.159 --> 01:17:57.180 best interest to extend those deadlines to qualify 01:17:58.509 --> 01:18:01.878 provided, you know, that people are working diligently 01:18:01.890 --> 01:18:05.520 to get the equipment and maybe that has to be addressed 01:18:05.529 --> 01:18:08.430 in the Legislation because those deadlines were set 01:18:08.439 --> 01:18:13.649 in Legislation. So you might have to address it going 01:18:13.659 --> 01:18:19.378 back to the Legislature. But if with a recommendation 01:18:19.659 --> 01:18:24.270 from your group that the equipment can't be bought 01:18:24.279 --> 01:18:27.850 and delivered on a time frame that would allow anybody 01:18:27.859 --> 01:18:32.600 to qualify on that first tranche. So you're effectively 01:18:32.609 --> 01:18:36.239 taking that first tranche off the table for any new 01:18:36.250 --> 01:18:40.029 project and the equipment. And I, I think the state's 01:18:40.039 --> 01:18:45.048 intent is to bring more capacity to the table. And 01:18:45.539 --> 01:18:49.750 I, I'd suggest the rules which would incentivize new 01:18:49.759 --> 01:18:54.699 capacity should be put in place. And I don't think 01:18:54.708 --> 01:18:58.189 there is any bad intent. Nobody was trying to set that 01:18:58.199 --> 01:19:02.520 up, set people up for failure on that. But the world 01:19:02.529 --> 01:19:06.289 has changed in the lead times on equipment. So I think 01:19:06.298 --> 01:19:09.640 that needs to be taken into consideration on how you 01:19:09.649 --> 01:19:13.659 could possibly deal with that. And one other thing 01:19:13.668 --> 01:19:17.399 from the application process and the approval process 01:19:18.140 --> 01:19:22.619 people are going to be spending a lot of soft costs 01:19:23.239 --> 01:19:27.869 in anticipation of doing this thinking they can qualify. 01:19:27.878 --> 01:19:34.649 So the sooner the rules are set forth and with the 01:19:34.659 --> 01:19:38.140 best clarity that they're set forth, people will be 01:19:38.149 --> 01:19:42.859 inclined to risk more predevelopment money sooner. 01:19:43.649 --> 01:19:48.009 Uh if you know, it's a calculated risk but it's a 01:19:48.020 --> 01:19:50.479 lot of money. Right. That sounds like a global comment 01:19:50.489 --> 01:19:54.659 too for both. So in our case, we're looking at investing 01:19:54.668 --> 01:19:58.020 our own money. And I can assure you we're cautious 01:19:58.310 --> 01:20:02.039 you know, with what it is. So that's, you know, I think 01:20:02.048 --> 01:20:04.918 it's a great program. I think it's gonna help Texas 01:20:04.930 --> 01:20:09.729 and we meet with the migration and the growth in demand. 01:20:09.739 --> 01:20:12.369 You know, we absolutely have to have it. So I think 01:20:12.378 --> 01:20:15.319 it's a great Legislative initiative. But it needs to 01:20:15.329 --> 01:20:17.739 work. Great. Thanks for that, Mr. Neary. 01:20:22.668 --> 01:20:26.819 So with that, um I think I'll move on to the Texas 01:20:26.829 --> 01:20:30.088 Backup Power Package Program segment of our Agenda 01:20:30.100 --> 01:20:33.958 today. I want to say also this is not last. Because 01:20:34.378 --> 01:20:37.279 for any other reason that it appears last in the order 01:20:37.289 --> 01:20:40.208 of the statutes. That's why we're here on that. Um 01:20:40.628 --> 01:20:43.659 I, and, and I will clarify. (item:3:David Smeltzer with PUC Staff on open rulemaking on Advisory Committee) That we have an open rule 01:20:43.668 --> 01:20:47.850 making on the Advisory Committee. And uh I'm not, I 01:20:47.859 --> 01:20:51.628 am not considering testimony that you say today as 01:20:51.640 --> 01:20:55.279 a comment on that rulemaking. So it will not be summarized 01:20:55.289 --> 01:20:57.859 and included in that proposal for adoption. So if you 01:20:57.869 --> 01:21:00.239 have comments on that rulemaking. Make them in, in 01:21:00.250 --> 01:21:03.239 the, in the rule. That rulemaking really deals with 01:21:03.250 --> 01:21:06.750 the um creating that Backup Power Advisory Committee. 01:21:06.759 --> 01:21:10.270 Um So everything else should be fair game too. But 01:21:10.798 --> 01:21:11.319 um. 01:21:14.229 --> 01:21:17.119 (item:5.1:Dave Gordon with PUC Staff opens up floor on essential components for rules) Again, we'll start off with uh what are the essential 01:21:17.128 --> 01:21:20.759 components for, for establishing rules for this program. 01:21:23.789 --> 01:21:27.899 Monica? (item:5.1:Monica Batra-Shrader with Enchanted Rock on 2.5 Megawatt threshold language) All right, Monica Enchanted Rock. Um essentially 01:21:27.909 --> 01:21:31.560 we are looking for clarification on the 2.5 Megawatt 01:21:31.569 --> 01:21:35.029 threshold language. Um we want to make sure that this 01:21:35.039 --> 01:21:38.390 language doesn't prevent an otherwise eligible project. 01:21:38.399 --> 01:21:40.970 That may have loads greater than 2.5 megawatts from 01:21:40.979 --> 01:21:45.560 receiving a grant. And um I just can provide a few 01:21:45.569 --> 01:21:49.520 examples. Um many facilities on which communities rely 01:21:49.529 --> 01:21:52.989 for health safety and well-being. Can easily exceed 01:21:53.000 --> 01:21:58.009 that 2.5 Megawatt threshold. Um this limit will introduce 01:21:58.020 --> 01:22:01.509 a lot of boundary cases. And so we believe there should 01:22:01.520 --> 01:22:04.298 be room for this incentive to help customers that don't 01:22:04.310 --> 01:22:07.989 fall neatly within that threshold. Um For example, 01:22:08.000 --> 01:22:11.909 if the facility's Load is below that limit. A customer 01:22:11.918 --> 01:22:14.930 might have an interest in procuring excess capacity 01:22:14.939 --> 01:22:18.970 to achieve that additional on-site resiliency. Um For 01:22:18.979 --> 01:22:22.989 example, Enchanted Rock uses an N minus one model. Um 01:22:23.128 --> 01:22:26.310 where we can lose an engine or some capacity and still 01:22:26.319 --> 01:22:31.569 power that full facility. Um Another example is blocks 01:22:31.579 --> 01:22:35.989 of capacity. So a 2.2 Megawatt facility might be seeking 01:22:36.000 --> 01:22:40.060 backup power for its full Load with one Megawatt packages 01:22:40.069 --> 01:22:43.350 and thus would have to procure three megawatts of deployed 01:22:43.359 --> 01:22:46.979 capacity under that program. And so we just want to 01:22:46.989 --> 01:22:51.659 make sure that um eligible facilities under that 2.5 01:22:51.668 --> 01:22:55.789 Megawatt limit. Are uh you know, given uh the time of 01:22:55.798 --> 01:22:59.640 day with that threshold. Out of pure curiosity, I mean. 01:22:59.649 --> 01:23:02.189 What's the facility that's gonna be over 2.5 megawatts? 01:23:02.199 --> 01:23:07.668 A big hospital or? Um like well, just in terms of that 01:23:07.680 --> 01:23:11.489 like excess capacity. Could be a grocery store, a nursing 01:23:11.500 --> 01:23:15.739 home, hospital. But for the ones that have Load over 01:23:15.750 --> 01:23:18.619 2.5 megawatts. What, what do you know, do you have 01:23:18.668 --> 01:23:20.750 offhand examples of what those are? It's ok, if you 01:23:20.759 --> 01:23:24.079 don't. I, I do not. No problem at all. I'm just curious. 01:23:26.140 --> 01:23:28.569 Other thoughts? A food bank would be an example. 01:23:30.409 --> 01:23:34.720 Thank you. (item:5.1:Christina Rollins, Assistant General Counsel for NRG on essential components) Christina Rollins, Assistant General Counsel 01:23:34.729 --> 01:23:38.409 for NRG. Um So as far as the essential components of 01:23:38.418 --> 01:23:42.859 a rule um implementing these provisions had three thoughts. 01:23:42.869 --> 01:23:45.529 Um so the first one would be defining the who like 01:23:45.539 --> 01:23:48.489 who is an eligible entity and there the statute provides 01:23:48.500 --> 01:23:50.699 us with some guidance, right? It's facilities on which 01:23:50.708 --> 01:23:52.890 the communities rely on for health safety and well 01:23:52.899 --> 01:23:56.668 being. So non-exclusive list, right? Um It also tells 01:23:56.680 --> 01:24:00.359 you who is not um certain for profit entities, private 01:24:00.369 --> 01:24:02.859 schools that don't serve the public. But to the extent 01:24:02.869 --> 01:24:05.890 there are categories of facilities that are definitely 01:24:05.899 --> 01:24:09.560 eligible, such as a hospital, police station, fire 01:24:09.569 --> 01:24:11.958 station. It'd be nice to define those in the rule. 01:24:12.418 --> 01:24:15.680 And then when you have to make a judgment call on whether 01:24:15.689 --> 01:24:17.708 or not you meet the criteria. How will you make that 01:24:17.720 --> 01:24:19.899 judgment call? Um You know, what's the process used 01:24:19.909 --> 01:24:23.399 to decide whether or not a facility is or is not eligible? 01:24:24.159 --> 01:24:27.029 (item:5.1:Christina Rollins on minimizing operation costs) The second one is the statute provides that the facilities 01:24:27.039 --> 01:24:30.119 need to be engineered to minimize operation costs. 01:24:30.418 --> 01:24:34.939 Um So in looking at that, some consideration probably 01:24:34.949 --> 01:24:37.449 needs to be given to you. How will um providing certain 01:24:37.458 --> 01:24:40.569 environmental controls on some of those backup facilities. 01:24:40.609 --> 01:24:44.128 Contribute to whether or not, you find or that a facility 01:24:44.140 --> 01:24:47.069 is minimizing operational costs or not? Because in theory 01:24:47.079 --> 01:24:49.529 it would be more expensive to operate. So, does that 01:24:49.539 --> 01:24:52.399 automatically mean that it's not um minimizing those 01:24:52.409 --> 01:24:56.819 costs? (item:5.4:Christina Rollins on facilities providing energy or ancillary services) And then finally, the statute does provide and 01:24:56.829 --> 01:24:59.350 and you've listed it here. That you can't use these 01:24:59.359 --> 01:25:02.319 facilities to provide energy or ancillary services. 01:25:02.329 --> 01:25:05.128 Right? And so there, there's some indication that the 01:25:05.140 --> 01:25:08.229 facilities are truly meant for backup power. And shouldn't 01:25:08.239 --> 01:25:11.149 be used as a revenue stream for the entity that attains 01:25:11.159 --> 01:25:13.989 funding for them. But then that raises the other questions 01:25:14.000 --> 01:25:16.759 about what are the other permissible use cases for 01:25:16.770 --> 01:25:20.259 a backup facility? For example, could the facility 01:25:20.270 --> 01:25:23.819 choose to economically island itself to minimize its 01:25:23.829 --> 01:25:27.430 exposure to wholesale power prices? So we're not opining 01:25:27.439 --> 01:25:30.319 one way or the other. But to provide clarity up front 01:25:30.329 --> 01:25:33.390 when individuals or in facilities are going to obtain 01:25:33.399 --> 01:25:35.708 these packages and these loans and these grants. To 01:25:35.720 --> 01:25:37.859 give them a really clear idea of what they can use 01:25:37.869 --> 01:25:39.979 the facility for and what they can't use it for. 01:25:41.979 --> 01:25:43.628 Great. Thanks Christina. I'll come back to you in a moment and I'll get through 01:25:43.640 --> 01:25:48.509 the first. Yeah, Diana? (item:5.1:Diana Coleman with CPS Energy on essential components for rules) Diana Coleman, CPS Energy. A 01:25:48.520 --> 01:25:50.739 lot of the comments that Christina just had, we had 01:25:50.750 --> 01:25:54.918 a lot of questions on clarity as well. Um is specifically 01:25:54.930 --> 01:25:58.220 on what types of facilities these could be? What kind 01:25:58.229 --> 01:26:01.680 of entities that these would look like? Um as a municipally 01:26:01.689 --> 01:26:04.378 owned utility, could we partner with these types of 01:26:04.390 --> 01:26:07.509 facilities? In order to participate or receive those 01:26:07.520 --> 01:26:10.899 types of fundings? What are the, what are the limitations? 01:26:10.909 --> 01:26:14.798 And what are the prerequisites or the components that 01:26:15.088 --> 01:26:18.829 would be necessary for eligibility? And so that was 01:26:18.838 --> 01:26:21.819 one of the questions on um that Christina raised that 01:26:21.829 --> 01:26:23.850 you know, that we're also looking at too. Like where 01:26:23.859 --> 01:26:27.000 does it fit? And would there be a partnership availability? 01:26:27.009 --> 01:26:30.520 Or that would be a free standing, you know, facility 01:26:30.529 --> 01:26:33.759 on its own? And then I guess lastly, you know, just 01:26:33.770 --> 01:26:36.759 any type of limitations on what these facilities or 01:26:36.770 --> 01:26:38.680 resources would look like would be helpful. 01:26:40.199 --> 01:26:40.689 Great 01:26:44.069 --> 01:26:46.890 (item:5.2:Zach Stevenson behalf of TEC on projects eligible for loans vs. grants) Zach Stevenson, on behalf of Texas Electric Cooperatives. 01:26:47.199 --> 01:26:50.548 Uh we had uh some questions regarding uh you know, 01:26:50.560 --> 01:26:53.869 the first two bullet points. Uh between projects eligible 01:26:53.878 --> 01:26:56.909 for loans versus grants and terms established for the 01:26:56.918 --> 01:27:01.020 program. Uh Our, our reading of the uh statute as it 01:27:01.029 --> 01:27:04.189 passed is a lot of that would be deferred to the Advisory 01:27:04.199 --> 01:27:06.319 Committee that's to be established. And so we're just 01:27:06.329 --> 01:27:08.350 kind of curious as to how much do y'all plan on putting 01:27:08.359 --> 01:27:10.458 in the rule versus how much is gonna be deferred to 01:27:10.470 --> 01:27:12.859 the committee? And what, what impact the Committee will 01:27:12.869 --> 01:27:17.708 have on those decisions? (item:5.4:Zach Stevenson with TEC on facilities participating in energy and ancillary services) And then uh on the backup power 01:27:17.720 --> 01:27:20.609 facilities uh participating in energy and ancillary 01:27:20.619 --> 01:27:24.970 services. Uh one idea we had was to potentially require 01:27:24.979 --> 01:27:30.239 an annual attestation. For um that uh no sales of energy 01:27:30.250 --> 01:27:32.489 and ancillary services took place over the prior 01:27:32.500 --> 01:27:37.289 year. And that was just uh one thing we had. Great. 01:27:37.298 --> 01:27:40.009 Thanks for that recommendation. (item:5.2:Dave Gordon with PUC Staff on Advisory Committee providing recommendations) I will note also, not 01:27:40.020 --> 01:27:43.208 only is there at the Advisory Committee that's gonna 01:27:43.220 --> 01:27:47.958 be um providing recommendations on the, the loans versus 01:27:47.970 --> 01:27:51.500 grants uh component of this program. But we'll also 01:27:51.509 --> 01:27:54.970 have a research entity that is engaged to uh recommend 01:27:54.979 --> 01:27:58.048 certain technology types. So that's another portion 01:27:58.060 --> 01:28:00.199 that we'll be taking into consideration as the program 01:28:00.208 --> 01:28:03.128 goes forward. And Monica, you had a follow up on. Uh 01:28:03.149 --> 01:28:06.350 (item:5.4:Monica Batra-Shrader with Enchanted Rock on sale of energy and ancillary services) Yes, I had to follow up on the sale of energy and 01:28:06.369 --> 01:28:10.548 ancillary services topic. Um there are several behind 01:28:10.560 --> 01:28:14.128 the meter services uh that these backup power packages 01:28:14.140 --> 01:28:16.899 can provide. Host facilities that are not the sale of 01:28:16.909 --> 01:28:20.180 energy or ancillary services. Um but help ensure the 01:28:20.189 --> 01:28:23.708 reliability of the grid. Such as demand response 01:28:23.720 --> 01:28:28.259 and peak shaving. Um and curtailing Load via behind 01:28:28.270 --> 01:28:31.229 the meter generation also does not constitute the sale 01:28:31.239 --> 01:28:34.159 of energy or ancillary services. But it does provide 01:28:34.168 --> 01:28:37.220 a service that aligns with the goal of this program. 01:28:37.878 --> 01:28:41.819 Um and I would also like to point point out that installed 01:28:41.829 --> 01:28:46.319 capacity above that 2.5 Megawatt threshold. 01:28:46.409 --> 01:28:50.039 Um should not be subject to the criteria um in the 01:28:50.048 --> 01:28:52.109 package. Great. Thanks for that. 01:28:54.060 --> 01:28:56.680 And just to add on to what Enchanted Rock was saying. 01:28:56.689 --> 01:28:59.000 (item:5.1:Christina Rollins with NRG on rule for power packages) Is that to the extent that you can clarify that up 01:28:59.009 --> 01:29:01.079 front in a rule. That, you know, you could use these 01:29:01.088 --> 01:29:04.159 power packages to do things like people trading or 01:29:04.168 --> 01:29:06.838 demand response that would be helpful. So we don't 01:29:06.850 --> 01:29:09.168 get into a situation years on down the line. Where you 01:29:09.739 --> 01:29:12.619 face no, you can't use that facility in that manner. 01:29:12.628 --> 01:29:14.810 So everyone's clear from the get go. That's a very 01:29:14.819 --> 01:29:16.119 good point. Yeah. Thank you, Christina. 01:29:21.259 --> 01:29:24.569 Any other thoughts about the components of a rule? 01:29:25.199 --> 01:29:28.298 Um obviously keeping in mind that we'll be waiting 01:29:28.310 --> 01:29:30.369 to hear from our Advisory Committee on this one too. 01:29:33.779 --> 01:29:38.789 Um and then finally, our last item here. (item:5.6:Dave Gordon opens the floor on program functionality) Is uh any kind 01:29:38.798 --> 01:29:42.149 of program functionality that might be necessary with 01:29:42.159 --> 01:29:45.659 this program? Do you, does the community need guidance 01:29:45.668 --> 01:29:47.189 instruction on how this will work? 01:29:49.708 --> 01:29:52.220 Think everybody fleeing from the table indicates that 01:29:52.588 --> 01:29:55.708 it will be instinctual. You will, you will apply based 01:29:55.720 --> 01:29:56.588 on vibes. 01:29:58.970 --> 01:29:59.659 Um 01:30:01.949 --> 01:30:06.100 any other thoughts from people if we're through the 01:30:06.109 --> 01:30:08.588 the question portion of the Agenda? But um if anyone 01:30:08.600 --> 01:30:11.020 wants to add something before we close? Or is that a 01:30:11.029 --> 01:30:14.399 dangerous technique that I? No, we're entering the rant portion 01:30:14.509 --> 01:30:18.619 of? Well, before we enter the rant portion. I do wanna 01:30:18.628 --> 01:30:21.489 thank Gena Minjares again for being here from the Trust Company. 01:30:21.689 --> 01:30:24.529 Um if you would like to introduce yourself to her, 01:30:24.539 --> 01:30:30.069 you can find her. (item:5:Dave Gordon with PUC Staff lays out final instructions to workshop attendees) Um and uh I'll note again, we will 01:30:30.079 --> 01:30:34.189 be accepting any comments for the questions and items 01:30:34.199 --> 01:30:36.399 that we've discussed today. So if your thoughts coalesce 01:30:36.409 --> 01:30:40.798 around something um in the next day or over the weekend 01:30:40.890 --> 01:30:45.250 Please feel free to file those in Project 54999 by 01:30:45.259 --> 01:30:49.779 October 13. David, do you have any other thoughts? 01:30:53.409 --> 01:30:56.918 No, I was trying to vet the PUC tradition of, of uh 01:30:56.930 --> 01:30:59.668 awarding a most colorful jacket award at the end of 01:30:59.680 --> 01:31:01.739 a workshop. But I you know, I don't know it. Christina 01:31:01.829 --> 01:31:03.119 might have it. Christina I think maybe 01:31:05.529 --> 01:31:08.020 has it. This is, this is colorful. But this is not our flashiest, this is not our 01:31:08.029 --> 01:31:11.509 flashiest winner in this category in the past. So we'll 01:31:11.520 --> 01:31:13.930 see some more polka dots in the future. Um well, thanks 01:31:13.939 --> 01:31:16.918 very much to everyone. Like I said, it's very helpful 01:31:16.930 --> 01:31:20.560 for us to receive your input. Um and I imagine it will 01:31:20.569 --> 01:31:23.699 be an ongoing process. Um we may have more of these 01:31:23.708 --> 01:31:25.739 we will definitely solicit your comments on the rule 01:31:25.750 --> 01:31:30.619 making and um help us out. Uh David mentioned that 01:31:30.628 --> 01:31:33.789 providing sample language is a useful tool for us um 01:31:33.798 --> 01:31:37.859 as a starting point. And we are grateful for any work 01:31:37.869 --> 01:31:41.279 that you want to help us out with. (item:5:Dave Gordon concludes workshop) So thanks again 01:31:41.289 --> 01:31:42.939 Um and I appreciate all of you.