 like to introduce to you some of our environmental heavyweights from Alliant Energy and I am an Alliant Energy Employee, I might add, full disclosure. So we have Steve Jackson, we have Michelle Pluta, and Joe Hock. The topic they're going to be speaking to you about today is connecting environmental compliance to responsible resources. Thank you, Mark, and thanks to everybody for the invite. We appreciate it very much. We don't often get out and and give a lot of detail on some of the things that we're working on but again we appreciate it. We were thinking originally of getting like working out here and walking around but this seems to work okay. Everybody hear me alright? Okay good. We hope to give you a little insight of some of the major environmental rules that we're following and how they fit into how we do strategic planning and work through our resource plan. Mark introduced me, I'm Steve Jackson. I manage the environmental services group that is responsible for planning. We look at emerging rules, we put together strategic plans, budgets, and as we like to joke our work is done in decades because a rule starts 20 years ago and through litigation and all that it takes place in rulemaking. Here we are 20 years later actually doing something like constructing pollution control equipment or reaching some new compliance goal requirements. So I've been with Alain for 20 years so I can kind of say our work is done in decades. I've actually seen it and we'll introduce ourselves Joe or Michelle would you like to introduce yourself at this time? Sure thanks Steve. Steve is our boss at the Alliance. We were in the planning group there, Michelle and I. Before I came to Alliance I spent five years at the Wisconsin DNR and probably know so many in the audience some of the work I did with that agency and I've been with Alain now for the past two and a half years and it really is a great place to work and you know the company has a really good commitment to the environment and looking out for its customers so we're happy to talk about some of the environmental rules we're looking at today and happy to answer any questions so you know we want to keep this open so if there's something you don't understand or you have a question on just raise your hand we'll try to stop as we go through this that take questions as well. Good afternoon I'm Michelle Pleta and I've been with Alliance since about 2001 prior to working at Alliance. I worked mostly in the Wisconsin area at a consulting company working for a lot of the industries in this area and throughout the state so I'm not sure what else anybody would like to know. I have some roots in the shabuagan area, shabuagan sausage so. I've had shabuagan sausage as well so but no roots so oops like there we go. As Joe mentioned we'd like to keep this open so we are willing to answer any questions you have we'll do our best I should say to answer any questions you have. We like I mentioned earlier we want to kind of talk about our strategy and talk about how we do environmental planning and how we make things happen within the generation what we call our generation resource but we are now calling responsible resources because as we'll talk what used to be a lot of coal fire generation is changing quite a bit so we'll talk a little bit about that in one of the slides but we plan to talk about the clean power plan ozone national ambient air quality standards the coal combustion residuals rule effluent limitation guidelines and water quality standards kind of in general we do talk a lot in excuse me in acronyms so we'll try our best not to do that for you because we're kind of technical nerds in that way with the acronyms and it may not be familiar to you so and if you are a technical nerd great let me know you know raise your hand if you're a technical nerd and you know what NAX means and you know we'll talk try to talk in those terms for you so like I said we're prepared to answer any questions you have but we're not prepared to like dive deep into some of the regulations we want to kind of keep a high level to keep it more interesting otherwise it can be long and tedious and and you just ate lunch so is there at this time I'd like to ask is there anything specific that you didn't see up here that you might like us to cover should we have the time yes I'm not going to answer that right now but we'll help we'll preserve it for later it's a good question any others now you see where I'm going we're just getting the information but I'm not going to answer the question right now all right I'm going to turn this over to Michelle she's going to hit the next slide okay so we wanted to talk a little bit about how we go about environmental planning and as I mentioned I'll maybe start with just an example I've been with the company since 2001 and when I started one of the issues I began working on and we're not talking about today really because it's a success story is mercury and mercury emissions reductions and and really it's a good example of how we we think about you know in the long term how we can go about managing environmental compliance when we look at environmental planning and in our perspective we kind of take a very long-term approach but we also we make sure to balance it make sure it's pragmatic and we take our time to make sure whatever we're doing will make sense both in the short term and in the long term so for an example when we we started working on our mercury reductions we did a lot of testing and pilots some of those pilots were done at our Edgewater generation station here and just understanding technology and so by doing those types of things we can figure out how to leverage the results which results in which types of technologies might work well at the same time for example in mercury we had a state mercury rule there was also a federal rule that actually finally took compliance this year we have to make sure that we can expand upon those technologies so we started with kind of a dual approach looking at both kind of smaller scale technologies but those that would work with larger scale technologies so kind of in the long run what we ended up is a federal rule that replaced a state rule and kind of a group of technologies we're using together now that has over 90% mercury reductions so that's an example of you know taking that bigger picture review when we implement a rule and throughout that process I would say even the rules change several times and we actually just are getting some some closure on the mercury rule from the legal standpoint but needless to say you know we we focused on kind of the long-term objective and so I think that's just a good example of how we kind of plan for the future we don't we don't wait to the last minute but we also don't put the cart before the horse and try to over design so so kind of looking at that bigger picture and knowing things may kind of be in flux the other thing I would say is that we're continuing to monitor rules and regulations and trends and as those change over time and that helps us to kind of look at what might be coming down the pike how we can look at things not only from an air mission stand standard but also looking at water and the solid waste impacts so we're looking at it from a broader multimedia perspective as well so that we also don't create another challenge down the road when we're we're putting in some type of a control or putting some measures into place so so that's kind of in a nutshell kind of the bigger picture of how we look at things as we see new rules coming down we work pretty diligently to provide comments to our regulators on ways to help inform them on what will be feasible technically what will help reduce costs and more than anything else we're trying to make sure we have some level of planning certainty which is kind of hard to come by these days so we've been pretty diligent in offering comments to our regulators the Environmental Protection Agency Wisconsin Department of Natural Resources and others on the bigger picture of you know you you're gonna ask us to do this but this is what we need to do and if you do it this way that helps us to have some flexibility and some certainty and balance and reduce the cost for our customers so that's that's a very important thing for us when we look at all of these any questions oh yes absolutely so we work quite closely as well with our trade groups and for example the Electric Power Research Institute is one national organization that helps us with many of the studies that we do on the technology to help us understand you know what will will work effectively and so we leverage those partnerships also with trade groups Edison Electric Institute and others to help kind of make sure nationally and also at the state level that when we have things come come together that we are able to inform our regulators of the best solutions okay and next Joe is going to talk a little bit all right so Steve had mentioned you know times they're changing that includes our fleet you know we we used to have you know a lot of coal generation we still see that as a piece of the puzzle moving well into the future there definitely is a place for that but our fleet has been in a state of transition you know you brought up the question on nuclear you know we can get back to you and see if we've taken a formal company position on it but nuclear has always been that kind of a piece of our pie as well we've always tried to have a balanced portfolio if you will and we always look at what's in the best interest of our customer and meeting our demand while meeting our environmental commitments and this just shows over time at least back to 2007 looking into the future how our fleet is changing and this is based on the size of the units not necessarily how they operate but what we call nameplate capacity to give you an idea of kind of the scope of these these pies so the the new the nuclear police there is a nuclear facility which we have a purchase power agreement agreement to purchase the power from Dwayne Arnold energy center in Iowa we used to have one with Kiwani here in Wisconsin until recently that nuclear piece is about half the size of the Edgewater generating station which I would note you know we have the plant manager here and a couple others from the plant so you know they've great team there and any question specifically about the plant more than happy to drag them up here but just to give you a set an idea of you know what these pies are showing that nuclear piece about the half this size of what's over at Edgewater there so we do use this term responsible resources because we're I think we've done a really good job of making reductions transforming our fleet positioning ourself well so when various rules come along whether it be the mercury and air tactics rule or DNR knocks nitrogen oxide rules come along or even clean power plan we're pretty well positioned to meet some of these rules and engaged with some of the agencies as Michelle has noted and one of things I really like about the company is at least I found that we're really respected out there on all sides of the aisle and we try to make informative comments on these rules and that that helps as well I believe so I'm going in the future you can see our plan is any coal that we have to keep it but focus on our biggest most efficient units improve efficiency at those units we recognize that if they're gonna stick around for the long term they're gonna have to be fully controlled and we've made a lot of investments and we continue to do so as an example just over at Edgewater just this year will be finishing up another major air pollution project there and as a company we're looking at some of these key pollutants reducing them anywhere from 80 to 90 percent just dating back over the last 10 years so really really impressive emission reductions while maintaining costs at a reasonable level for our customers yeah so we're really you kind of think about three or four type major pollutants nitrogen oxides NOx being one SO2 sulfur dioxide mercury and then particulate matter so those are some of the four major pollutants that we're looking at so when we say partially controlled coal we're thinking maybe we have a box for one or two of the pollutants whereas fully we're controlling the whole fleet at all now for the set of pollutants so yeah really it kind of exciting times and we're in the process of building a new state-of-the-art combined cycle natural gas plant in Iowa we've and we've proposed to expand our Riverside Center down in Beloit and our combined cycle natural gas plant there and so our fleet is really changing and we're also getting involved more in renewables you know we're expanding our wind in Iowa with their purchase power agreements and we're also getting more involved in solar we're doing a lot of exciting things with solar putting solar on some of our old coal landfills we're putting solar at our corporate headquarters we're doing pilot projects with different nature centers and schools so just really exciting times for for the company any questions on how the fleet's changing this is the last chance before we start getting into some of these rules and I think I'm going to take the next one which are notes actually a clean power plan which no shortage of stuff to talk about so Michelle's gonna walk us through that actually I'd like to just ask if people in mind a show of hands of anybody here who's at least heard of or read about the clean power plan good pretty much everybody almost yeah okay good that's helpful just to know it's carbon reductions in the clean power plan is probably the the one on the forefront for us right now as as we've discussed we're working through a lot of our other emissions reductions and successfully doing so under that fully controlled coal block and so now we're looking at something that's focusing on our carbon dioxide emissions carbon dioxide emissions will come from our fossil fuel power plants and the one thing I would say about that is that with CO2 carbon dioxide being CO2 making sure I'm good about that it's different it does not have that we have different control technologies that we can work into our plants and effectively reduce those other emissions with carbon dioxide it's not that easy there really isn't a great commercial technology out there that's been proven to help us achieve those reductions and so what we have that came out this year is the clean power plan and the clean power plan essentially it's going to be a statewide goal that will affect us our fossil fuel power plants and those in the state and nationally and what those guidelines will do is to ask us to reduce our carbon dioxide emissions across the state and so it will be a national but requirement that will affect each of our our fossil fuel units and that's essentially our coal fired units and certain of our combined cycle natural gas units with the guidelines what we'll need to do is look broadly on how we can make reductions in terms of timing the development of these plans to achieve these goals will be due in fall of 2018 there's a variety of step periods in the planning process that occur before that and the reductions will need to occur starting from 2022 through 2030 and then they step down for a final goal that begins in 2030 and beyond in terms of overall reductions these goals are going to have a 30 to 40 percent reduction from a baseline level that EPA proposed which was the year 2012 as I mentioned a little bit in terms of carbon dioxide it's different and we can't just decide to add this technology and so when we talk about the clean power plan what you have is a rule that we call something that goes beyond the fence line literally meaning beyond our power plant fence line because how we will get these reductions will be some actions at the plants but it will also be in changing how we operate and then different employing different types of energy resources such as renewables to help kind of reduce the carbon footprint of our fossil plant so it's going to be kind of an array of measures that we will work together to make sure that we have a lower co2 footprint at the same time we have to make sure we balance out those actions to make sure that we're providing you with a reliable source of power because not all of the technologies are there like Edgewater is a base load power source more broadly so what we're doing in terms of achieving these reductions as I mentioned there are some things we can do at our plant and to a large extent there are things we do anyways and that's improving the efficiency of our fleet and we've worked very diligently to do that and we continue to improve it and essentially what we're doing there is making sure just like your car you try to have an efficient car more miles per gallon we're trying to run our units the same way so we get more energy produced for each unit of fuel that we're burning we're also retiring as we talked about with the responsible resource strategy a lot of the smaller less efficient plants that are pretty old and we're due for replacement anyways we have actually since 2005 over 2000 megawatts that has been retired or will be fuel switch to natural gas we're also increasing the amount of energy we will have from highly efficient gas fired units many of you are aware that we are moving forward with building a new state-of-the-art gas plant here in Wisconsin so that will help us to meet some of the changes we have in the fleet with the retirements we're also increasing the energy produced as we mentioned with renewable resources if you look today at our distributed generation for example compiled all the small solar and wind units that we have that's approximately 65 megawatts right now and it's growing exponentially we have over 450 megawatts of wind purchased power agreements and we own over 568 megawatts of owned wind sites including the Cedar Ridge wind farm which is right here near Fond du Lac and then we are also continuing to do energy efficiency energy energy efficiency makes sense no matter what and we're continuing to make sure we support the focus on energy program is the main program here in Wisconsin so I'll all said and done those are all you know things we're we've been doing for a while and actually in terms of reductions of CO2 to date since about 2005 we've reduced CO2 by over 15 percent but there's going to be a lot of work to get to the 30 to 40 percent bubbles that you see in the rule and it's going to take some time for that transition but we think we're in a pretty good spot as as you see with our responsible resource strategy that's part of that planning approach that we like to use to try to kind of prepare for what we see as a future and making sure we have a flexible strategy that we can have a variety of options to help us to comply so questions I see one in the back well that's not necessarily an issue we we get into in terms of ourselves as a company it's not part of our operations I know there's a lot of study going on with that and oversight in terms of the regulations but we really I would say we really don't have a hard and fast position on it right because we don't have oil resources here the closest carbon potential carbon capture and storage location is in southern Illinois Illinois yeah it's not really cost it's cost prohibitive right right for the most part it's going to be a change in the nature of how your power is being produced and and that's really what these goals are aimed at not so much trying to have a kind of a back-end control any other questions well I would love to say that we have have the dollar figure for you today because I am everybody in our company is getting this question a lot so not getting too far down the road the good news is that as we talked about our responsible resource strategy we are pretty well positioned here with our balance portfolio in terms of the things we've already done so we will have flexibility to comply with this final rule the challenge is that we are not quite sure what those state plans will be in the specifics so there's a lot of flexibility in this final rule which is good but it's almost so much flexibility it's hard to know how we will develop a state plan because there's many options and I just kind of say at the highest level not getting into the technical details there's one pathway that kind of focuses they call it a mass-based approach another one is the rate-based approach and there's a lot of levels of detail for each of those and so right now we are working very closely with different agencies with different every the trade group on modeling as are all the states looking at how we we can put together a state plan and what are the best options so until we have the details of the state plans which really won't be due until September of 2018 it's hard for us to really know the the actual costs what I would feel comfortable telling you is that the cost for us will be incremental to things we've already gotten place and we we do think that we can keep them within a reasonable amount but that's going to be contingent on our state plans including certain things that we want and making sure we get credit for all the good things we've been doing and so we're working very diligently to to make sure people are aware of the things we need in that state plan to make it effective for our customers would just like to add that there without getting into the details of this there's an option for a federal plan if the state doesn't pursue its own plan and we are strongly promoting that the state develop its own plan otherwise you would be subject to the federal plan doesn't offer the state as much flexibility if you go with the federal plan so we're other utilities as well and maybe some of you feel that the state should be moving forward with the state plan they're not quite there yet that's in the works okay any other questions okay and next I think we have always a little bit about ozone might be familiar topic for some of you keep moving along here so yeah ozone and I know that's a kind of a big topic here and shaboy again it's kind of the thing it never ends there's there's six pollutants that EPA set standards for and one of them is ozone now ozone's not something that's even directly emitted by our plants or any year industries or cars it's something that's formed in the atmosphere typically in the summertime and having a lake next door enhances it so EPA set standards for these six pollutants which they call criteria pollutants ozone's one of them and they're supposed to look at them every five years they they often miss that but they eventually get to it and sometimes they do it on their own sometimes they're forced by a court but they've they've done it in 1997 they did it in 2008 and they just did it a few weeks ago in October of 2015 and each time not surprisingly the standard goes lower and lower and lower so you know we're tracking we're tracking this as we are all environmental rules we feel that our our company's pretty well positioned for these rules however this is one that we'd like to keep tabs on because we know it can impact a lot of our customers so we do try to stay engaged on it there's really two pollutants that come together to form ozone it's this NOx nitrogen oxide and then also volatile organic compounds VOCs and there's a lot of industries that emit those types of pollutants so it can be pretty far-reaching in terms of what this standard can impact and then motor vehicles as well and transportation plays a big part and the tricky thing with ozone is it's known as a regional pollutant so it can travel far distances and as is well known here in Sheboygan you can be impacted by not only your own emissions by but your neighbors and from other places far away there's a group out of Chicago that does some modeling and Lideco is the acronym like Michigan Air Directors Consortium they look at you know who's responsible for what and their latest modeling that I had seen from their director was all of Wisconsin's emissions taken in whole is about 9% of the ozone in Sheboygan not not just yours but all of Wisconsin and when you look at like Illinois and Indiana which is primarily Chicago type region you're talking roughly around 20% so a lot of it comes from out of state and the regulators know that but if you get flagged as a non-attainment area which means you're not meeting EPA's standard then there's requirements that are put on you for being in non-attainment that that apply to businesses in the area so it's important to try and keep tabs of this and as I said EPA just lowered the standard the latest level of 70 parts per billion Sheboygan has been really proactive of work working with EPA regional headquarters and also Wisconsin and our on getting some extra ozone monitors in this county and you know we're supportive of that the one that was there historically and still is is south of the city and it sticks way out into the lake there was one a few years ago now that was put north of the city so you know hypothetically would capture more accurately Sheboygan emissions and also a mile or two inland and just this year that monitor has been 17% lower huge difference EPA typically looks at the fourth highest value over the ozone season which is summer the monitor the south was 81 parts per billion that monitor to the north 67 you know and the standard that EPA just lowered the level to is 70 so it's a huge difference you know just moving a mile or two inland you know maybe a farther north it shows you Sheboygan it's questionable how much impact the Sheboygan is having so now with this new standard EPA is gonna they've already started a process where they're gonna try and define areas that are meeting and not meeting the standard so I encourage you to be proactive with the WDNR and we will as well typically the states have about a year to make recommendations on what areas they think should be classified as non-attainment versus attainment meeting these standards and then EPA will turn that around and finalize it within the next year so we have some time here in the next year or two to engage DNR and I think we want to point out some of the things we're seeing with the monitor and we'll be doing that and I encourage you to do that as well so one other way that these ozone standards impact us is not only are you dealing with potential non-attainment issues and you get increased permitting stringency in the area but for utilities we get the added bonus of EPA looks and says well we want to try and do something about this transport of ozone so if your impact if your emissions your utility emissions are impacting another state more than 1% that's what they they model and say if you're modeling more than 1% we're gonna set caps on your your fleet emissions basically your state and then divvy up it's a cap and trade program so they'll they'll divvy out allocations to try and address this interstate transport now my new utilities aren't at all the only ones responsible for ozone but they're kind of the easiest to set these programs on so it cross-state air pollution rule is one of the ways they've got about doing this and they just actually released a proposal to kind of make that more stringent so we're looking at that we're planning on developing comments and you know I'm sure other companies are as well so like I said we're in pretty good shape nox we've reduced almost 60% already and we have a goal of about 80 so you know we're making big reductions that are helpful but we're also keeping tabs on this for our customers any questions on ozone yeah the fourth high yeah yeah I mean they look to EPA typically looks at three year average of fourth highs but the fourth high for at least preliminarily for 2015 is 67 at that northern minor so Joe question came in about how will these new rules affect our local businesses you kind of hit on that real quick on the clean power plan there's not a real direct connection between the clean power plan and local businesses from a compliance perspective however you know there's things that we could possibly do together in partnership that could be beneficial so I don't that's helpful as an answer whoever had the question but maybe on this one yeah I mean ozone is one of those that really does have a direct impact and that's why we try to keep tabs on it if not for us for our customers as well you know Edgewater we've put some state-of-the-art technology on one of our the biggest unit there and it often wins awards about being the best one of the best in the country so we're happy really happy with that question back there oh yeah it definitely does yeah there's no doubt about it and it's really interesting kind of chemistry mixed because in the summertime the lake is a little cooler it takes the lake longer to warm up so it actually kind of traps some of those pollutants that come up from the south from Chicago and then they sit out there and then in the summer you know sometimes they get a lake breeze come in and they'll cool things down but not only is it bringing cooler air it's bringing some of that elevated ozone that was sitting over the lake and cooking some some years you see some of the highest ozone up in Dorr County which you know I mean there's no huge industries up there but yet they get a lot of ozone so this is something that's transported really far so yeah we do see that but the important thing to keep in mind though is if areas get fly does not meeting this there's permitting restrictions that come to specifically those areas so that's why it's important to track this yeah yeah they should yeah yeah it has three years now I believe this last year would have been the third year so well to so far okay okay well that'll be enough time for this next standard and I think they will you know when I was at DNR we worked with EPA down in Kenosha and what they did in Kenosha was they had two monitors and they really limited the size they said we're still gonna designate you not attain it but we'll we'll scale it back a little bit so that's something that I would hope to see up here as well so other questions or we'll move along some of Steve's gonna talk a little bit about some water and wastes rules and then you know other questions come up we can get them at the end too somehow I get to talk about waste no it's actually a subject that I enjoy so one of the things another rule that we're following is the coal combustion residuals rule actually brought baggy two baggies one full of fly ash and one full of bottom ash so if you've never seen it they're actually here yeah so for utility when you burn coal you're generating ash and actually when you burn wood when you burn pretty much anything you generate some kind of byproduct the byproduct for coal is flash which is very light you'll see it's a kind of a talcum powdery material and the other is bottom ash a lot of companies handle that material wet we do we handle our bottom ash wet we also generate slag at one of our units at here at Edgewater we handle it wet there's constituents in the in the flash and bottom ash that can leach out and get into the water so actually I'm talking about a different rule this is cold okay so this is why it's confusing because the next rule I'm going to talk about is the related rule and it kind of gets to the last bullet on this slide there's multiple rules that come out and affect pollutants and media in different ways so we try to take this as Michelle indicated earlier this kind of long-term pragmatic holistic approach when we look at solutions we're not creating one that you know we're not solving one and creating another okay so with the coal combustion residuals rule where I was actually on track was how we have to manage the coal combustion residuals once they're generated so this rule came out in April of this year highly anticipated lot lot of discussion around what it what's gonna you know what are the impacts gonna be so one of the things is when you generate coal combustion residuals they have to go somewhere most of our flash we sell for cement or concrete cement concrete we also do take some of our bottom ash and it's utilized for road projects foundation projects and things like that everything else has to be disposed so one of the things about the coal combustion residuals rule was to make it so there's a standard across the country of how people manage this material if it goes in a landfill it's meeting certain engineering requirements if it's being utilized it's meeting certain specifications for beneficial use in addition if you're disposing of coal combustion residuals wet and into ponds are the ponds meeting performance requirements do they have a liner do you have groundwater contamination is it stable is it safe these are the kind of things that the rule addresses and again universally across all states fortunately we have a great program in Wisconsin for handling coal combustion residuals and so we've when this rule came out we you know there's some impacts but they're not as severe as maybe other cities but it does impact potentially impact our active ponds we will be monitoring groundwater we also have to do certain studies and if some of those studies end up showing instability of our ponds or the ponds not safe then we may have to close those out and that's what we are identifying here in the second bullet as a trigger event trigger events may lead to early closure of landfill or a pond also any new landfills being installed or constructed have to meet certain design requirements and fortunately for us we've taken that long-term approach again and we've we've put in those more stringent design requirements and construction requirements several years ago so again not as impactful as it might be to others one thing that's very interesting about this rule I'll point out the little box there we have our own CCR website so everybody's welcome to go on your spare time of course go look at all the documents that we have related to our CCR compliance program this rule went into effect October 19th of this year and we had to have a website up and running so that we can inform the public how we're meeting our compliance obligations we're not alone every utility in the country has to do this so it's a new weird kind of thing instead of filling out a piece of paper and sending it to the agency we don't have to do that we have to fill out the paper posted on to our website and now everybody gets to look at whether or not we're complying so it's a very interesting aspect yes yes yes yes the other question I've had as I showed these is where where does this come out of the process the process so this is fly ash and it's actually not water sorry Eric it's Columbia's but fly ash comes it's the lighter particle that passes through the boiler passages and gets collected in either electrostatic precipitator and now we have a bag house so there are pollution controls that collect this material it's gathered into hoppers and then it's loaded out to silos taken in trucks for beneficial use or for disposal the bottom ash so so this is handled dry so this is a good thing we have dry fly ash handling and you'll see why I say it's a good thing because the next rule talks about water the bottom ash which looks kind of like a lava stone of sort is handled wet it comes it's the heavier portion of you guys in the plant correct me if I'm wrong here but this is the heavier portion of the coal combustion residual and it drops to the bottom of the boiler and it goes through some crushers and then it's transported wet out to ponds generally at Edgewater it's we have a device called a hydrobin so it's a mechanical separator tanks and things where the water goes in and it separates out the bottom ash from the water and we try to reuse as much of that water as possible but most people just sluice it out to a pond and then dig it up and then dispose of it or beneficially use it was that helpful to those as far as process first person with the hand up right there yes Eric you want to talk about Edge yeah and generally I if it's about a 70 I don't know we 70 30% 70 okay so 70% flash 80% 400,000 tons of byproduct you reused which was a 70% roughly 70% rate so we generate a lot and when we put in dry scrubbers to control SO2 we generated a whole new we created a whole new byproduct which we're working on trying to find a better source yeah it's a great believe it or not we're and we're doing studies so this is interesting and I know we might be pushing time here but we actually are doing studies with UW on utilizing that material as an ag product because it has as a liming agent it's really good and it's also has a sulfur component which the farmers like so it's the the beauty of our process is when you remove this material from that lime scrubber solids waste you now have a good scrubber solids material that you could market potentially and use as an ag product if you have fly ash mixed in with that not as good so we remove the fly ash first a very small amount carries through it doesn't affect the quality or the reusability I guess is a good word alright let me try to stay on track here five minutes thanks so what are we doing with CCR rule we're evaluating how we handle our ash systems we're looking at landfill options and like I said we are redesigning or re really we've already designed our landfill so we're really just building our landfills with that solid highly engineered design already in place we continue to utilize our byproduct as much as possible and then again we try to keep multiple rules in mind so let's go to the to the next one just because of time that fluid limitation guidelines rule it came out this year it really addresses waste waters from utility processes wet scrubbers ash transport water so like the bottom ash transport water wastewater from mercury control gasification so if you take coal and gasify it you may have a wastewater and then leachate from landfills so we we don't have wet scrubbers we have dry scrubbers so when we talked about how we plan for the future we planned for dry scrubbers thinking that in the future if we had wet scrubbers we'd have to treat or manage that wastewater from the wet scrubber so we don't have that we have ash transport water and we have leachate even though we have mercury control systems we don't have any wastewater from those systems and we're not gasifying coal into into a natural gas we used to do that years and years and years ago and we don't do that anymore so what happens here is the requirements from the ELG rule they they get incorporated into our wastewater permits and the wastewater permits are on a five-year cycle so with that in mind the rule requires that we comply by November 1st 2018 but no later than so between November 1st 2018 and no later than the end of 2023 so we have some time to comply with that but I'm going to talk again about a connection here because at our Edgewater facility and the next area I'm going to talk about is water quality standards the next slide there are other factors that might make you do something sooner here but you have to look at this holistically at Edgewater specifically they've received a wastewater permit with an arsenic limit that's very very low it's extremely less 0.2 parts per billion it's really low so when we look at the CCR rule when we look at the ELG rule and we look at the wastewater permit limits that are coming in that permit all separate rules all with separate timings we try to take that holistic approach and we say what solution is going to work best so at Edgewater for example we're going to be getting rid of the wet ash solution it is a major source of arsenic that's a great solution it solves two or three of these rule problems and the timing of that work will be contingent on whatever that first driver is in this case it's the wastewater permit and the water quality standards so we are migrating to dry ash handling across the fleet and we continue to look at you know what is the most cost-effective way to minimize discharges that could trigger non-compliance with these limits okay real quick water quality standards I kind of just touched on that are we still okay Jane with time I think it's like maybe right on pushing it okay I'll go fast I kind of already touched on this that we're getting lower limits in pretty much every single one of our wastewater permits anybody here have wastewater discharge from your process are you in the same boat yes feels good doesn't it so we again take this pragmatic long-term holistic approach to solving these problems as you can see multiple rules solutions can fit and cover for multiple rules that's really what we're doing here I kind of leave it at that and and Edgewater is kind of our our classic story here in Wisconsin for how we deal with water quality standards ELG coal combustion residuals rule it's it's a nice package and the solution is that holistic solution so we'll move into this last thank you slide and point out that we have an annual report an annual environmental report and it just recently got published we put postcards out on the table out front we don't in the in a solid sustainability effort we don't print this so you can get it electronically on our website and you can find the information out about this you'll see lots of information on things we just talked about how much our pollutants have reduced what our fuel portfolio looks like how much coal combustion residuals we use water consumption there's a whole bunch and a lot of good stories like peregrine falcon nests osprey nests and things like that that we're doing all across our fleet so we certainly appreciate the time and if you have any questions or want to stay we'd be happy to answer those I will be honest we didn't think we we thought maybe we have 30 minutes to talk but we fill up that hour really easy Steve Michelle Joel thank you very much for coming up here and speaking with us today we really appreciate it I'd like to make a couple of announcements about other upcoming events we have a focal point the topic will be well at work really that's Wednesday the 20th of June 20th of January 7 30 p.m. Jean Cole well the wellness advocate speaker coach and owner of well by choice will help us kick off a healthier and more productive 2016 our next first Friday forum Governor Walker has been invited and has accepted the invitation he will be here in Sheboygan he'll be joining us to speak at the first Friday forum I see Jane looks a little uncomfortable because you never know how things will go with the governor if something else comes up if something else comes up and the governor can't make it we have another excellent program in the bag just in case the governor can't make it but because we anticipate a much larger audience for the governor we will have a change of venue next for next first Friday forum folks from the Elks Club aren't in here room so I can say this it'll be at the Blue Harbor so watch for the invitation for that and do watch for that change of venue one other thing I'd like to mention and my apologies to Greg because I'm not a financial advisor but I'd like to offer you all an opportunity to save some money and help your own personal finances if you would like to you can sign up to come to all the first Friday forums for the entire year and by signing up in one shot you'll actually save about 20% on a cost of joining us everyone for our first Friday forums so do consider that at the Sheboygan County Chamber of Commerce's website and with that I believe that's all the announcements we have I'd like to thank you for joining us today and thank you again to our speakers