 Good morning everyone Welcome to this morning's briefing the environmental and energy study Institute is very proud to be bringing this briefing To you this morning on the toll topic of how can states comply with the clean power plan? State officials working together to identify options Over the course of the last year there has been much discussion with regard to the administration's proposed clean power plan administration proposal to reduce greenhouse emissions in the electricity power sector and That has led to many many white papers to all kinds of analyses to webinars to briefings across the country and Certainly across Washington and even this week. I saw many many more analyses and white papers that were being released and All of this I think has been accelerated because it is Anticipated that the administration after having received in excess of four million comments will be issuing a revised Final clean power plan later this summer either in July or August I Think one of the most important things for us to Recognize and we're going to hear much more about that this morning Is that over the course also of the last year year and a half is that? There have been three organizations that have our national and scope that have been working together sharing information questions concerns and Looking for possible options solutions that make sense for their states And they have been all about trying to identify ways forward How do it how does one best address this whole issue of reducing emissions in this? Obviously critical critical sector of our economy that powers our economy and that they have been joining together in terms of looking at How their various roles in responsibilities at the state and local level Can make a difference in terms of their coordination their cooperation their collaboration their understanding of each other's perspectives Those three Organizations and we're going to hear from their leaders this morning are the national association of clean air agencies the national association of state energy officials and The national association of regulatory utility commissioners They each have very very important roles in terms of environment and energy regulatory research energy assurance responsibilities at the state and local level and therefore the proposed rule Represents another very very interesting challenge for these very important Officials upon whom we rely with regard to looking at so much implementation of federal state and local legislation and rules and the proposed EPA Clean power plan is particularly unique in that this is the first time that There has been a proposed rule That is so reliant upon looking at flexibility Looking at ways that states can put together plans that look at a whole variety of options Technologies resources in which to do that. So we're going to hear much more about that the perspectives that come from these different areas of responsibility by state and local officials So to kick off our discussion this morning is bill becker who is the executive director of the national association of clean air agencies NACA Is an organization that has the responsibility for I should say it's its members have the responsibility working at the state and local level in terms of implementation of the clean air act and have for years bill is Is He founded this organization has been with NACA since 1980 is Very much the go-to person has won awards with regard to his work in this whole area and The association of clean air agencies is an association of state and local air pollution control agencies in 43 states the district of Columbia a Hundred and sixteen metropolitan areas across the country as well as for territories And as I said NACA's members have the primary responsibility under the clean air act for implementing our country's air pollution control problems and so you can see that this is a rather formidable task and To talk about it and this whole both the menu of options that NACA has put forward And that is one more Resource in the toolbox for state and local officials what is really very very important driver behind all of this is again the shared perspectives and really looking at how these policies and potential options really affect any to draw from the expertise and the shared and differing responsibilities of state and local officials Good morning So thank you Carol for that nice introduction in this very kind invitation to be here today When I speak before a group like this, I can't help but think about my brother My brother is a very famous scientist In fact, he is so famous. He has a chauffeur who takes him to all of his speaking engagements And my brother was asked to speak before a group not unlike this to talk about climate change and He had given this speech many many times and he says to his chauffeur Joe. He says Joe you've heard this speech a hundred times Why don't you give it? This group doesn't know what I look like I'll sit in the back of the room and read a newspaper and no one will be wiser and Joe said this is great. My brother said Joe However under no circumstances should you ask for questions because if you do they're gonna find out you're a fraud and Joe was really excited about this. My brother gave him the 10 pages of speech Joe put it aside he gave a wonderful speech got a standing ovation and Was feeling so cocky that he did the unforgivable. He asked for questions Well, wouldn't you know someone in the first row Asked the most complicated question one could imagine and Joe looked into the eye and he said mister That was really a stupid question That question was so simple-minded that I'm gonna have my chauffeur who's sitting in the back of the room answering So so if there's anyone here including in the front row that asked a question I need help and I have my team with me okay, so As Carol said we are an association of state and local air pollution control agencies Here's what I will cover today. Here's here's what I've been asked to cover I will make a few general observations Give you some context about President Obama's clean power plan Talk to you about some of the implementation issues that state and local agencies are Experiencing and then talk about some of the implementation tools that we have Published recently and will be publishing soon after the rule is promulgated and then closed with some observations After discussing our relationship with the two associations that Carol mentioned So we are an association of state and local air pollution control agencies our office is on the other side of the capital We've been there since 1980 We have 41 states We have a hundred and sixteen of a hundred and seventeen local air pollution control agencies Washington DC in the territories Two important points about state and local air pollution control agencies One is on page one of the Clean Air Act It gives state and local air agencies the quote primary Responsibility of implementing our nation's laws So our mission is to clean up the air and to implement the Federal Clean Air Act at the state and local level and the second part of this related is Under EPA's clean power plan, which I will get into in a little while We are the ones that will be developing the plans Submitting the plans and responsible for implementing the plan. So the responsibility falls on us Even though we will be working very closely with the utility commissioners energy officials and many many other stakeholders So a couple general observations just to Move things along first, you know, I represent almost every state and local air pollution control agency in the country I'm not stupid. We understand the politics that is is going on in the states And in communities and there are there are governors who aren't as enamored with this program as others There are members of Congress who are actively fighting this But perhaps one of the most important things I want you to understand from our perspective is Until or unless this program is curtailed in any manner this is the law and our folks are going to be implementing this program as Effectively as we can and as expeditiously as we can unless we're told to stand down and for the time being almost without exception We're not being told to stand down The a few other things with regard to some of the rhetoric and with regard to some of the threats of litigation This is a proposal This is not a final rule and while much of the Criticism against this program is focused on some very legitimate issues It's a proposal and we expect that some of those concerns will be ameliorated when the rule is finalized Second I will predict with certainty that there will be some hiccups There will be some bumps at the outset of implementation of this program. This is not new no one should be worried about this This is something that goes along with the territory, especially in implementing the cleaner act We've seen this with vehicle emissions testing programs with reform reformulated gasoline and many other programs and we'll expect it here And I know we're not going to panic and stakeholders shouldn't as well. We'll work together and we'll work through these issues and finally with the last observation many of you are from congressional offices and You can help immensely in making this program work should your bosses wanted to work and there are Authorizing provisions in the cleaner act under section 105 that provides Funding grants to state and local agencies to implement clean air programs. This is a very important one the president recommended a Significant increase in grants the states and Congress will be marking up the EPA budget bill next week And we hope that you Take a close look at that Okay, so EPA's clean power plan is is Being derived from the existing clean air act I think it's safe to say that If if proponents of reducing greenhouse gases had their way They would prefer federal legislation I think even the regulated community would prefer federal late legislation But we are not going to see federal legislation in this Congress and I don't know about the next Congress and this is exactly why EPA has decided to use existing authority under the clean air act to regulate greenhouse gases and There are two provisions that are really important for you to understand There's a provision under section 111 B that Requires EPA to regulate new and modified and Reconstruction power plants and rules have been proposed and there is the provision under section 111 D That addresses the regulation of existing power plants and it's that Section under 111 D that we're talking about today, but importantly unless EPA is successful In regular and issuing rules for section 111 B 111 D can't move forward. So these things are intertwined and and one depends upon the other EPA's clean power plan Requires from electric generating units power the power sector, you know Very significant reductions a 30% reduction in carbon dioxide emissions from 2005 levels by 2030 And so you look at that you think that's 15 years or so for Utilities to comply. It's a pretty significant lead time to comply but another part of this is that EPA has set an interim goal That requires a chunk a large chunk of these emissions reductions to take place not in 2030 but 10 years earlier in 2020 and so this has been referred to as the cliff because many are concerned that that Utilities and states will have a difficult time meeting this interim deadline of 2020 10 years before the final deadline and this has been Really the core of a lot of the criticism of this proposal And that's why I said at the outset that we shouldn't panic over a proposal We should be thoughtful about what happens after finalization and I am pretty sure that this cliff this interim Deadline will be changed when EPA finalizes its role Another very important part of this is that each state gets an emissions target goal Under the clean power plan so every state's goal is going to be different and it's going to be a rate-based goal Which can be translated into a mass-based equation When EPA developed the goal for each state it looked at four relatively general Building blocks and they refer to them as building block one two three and four and I've listed them and The first one is what can be done within the facility to improve efficiencies? The second one is how can we shift to? Cleaner generating sources The third is how can we build low-emitting energy sources and finally? How can we pursue demand side energy efficiency? You know there's a common denominator of this and it's doing things better and more efficiently One of the most important things I will leave you with today is notwithstanding how EPA has set the state's targets The states are fully Flexible and able to decide on their own Which strategy whether it's in any of the four building blocks or not it can include in its Plan so the states are not bound by Picking strategies just within these four building blocks They can pick anything they think is appropriate so long as it passes muster with EPA and that's a very important point Here are the timelines for submitting plans This rule will be finalized probably in August States will have a little over a year to develop Their plan that they have to submit to EPA and the EPA has to review it and either approve it or reject it or negotiate If the state is having trouble and many will find this challenging States will be given an additional year to submit their plan And if the state decides and a lot of states are thinking of this To engage with other states in more of a multi-state program the state will have an additional year So the submittal of plans by state and local regulatory agencies will take from one to three years beginning from this August Now I'd love to tell you that states are you know almost there in developing a plan But that's a bit ludicrous because we haven't even seen the final rule But I will tell you It's been almost an unprecedented effort in terms of the level of effort and the energy expended in the year and a half proceeding this rule where our members have been meeting with almost every possible constituency in their states and with their state utility counterpart and their state energy counterpart in trying to understand the consequences and the impacts of this rule and That's really important because this is unlike any rule. We've ever implemented This is not your typical EPA rule that state and local agencies adopt we are looking at activities and processes and stakeholders that have never really been affected or engaged much in implementation under the Clean Air Act There are two basic questions that states are going to be Asking and and addressing and this gets to the meat of the presentation one is What strategies not only included in the four building blocks, but beyond the four building blocks should states consider in meeting their target and meeting their compliance plan obligations and I'll be talking in a second about the menu of options that identifies anything we could possibly think of The second equally important strategy is once you've identified a strategy an option of technology That strategy has to be incorporated into a plan. It has to address enforceability it has to address Verification it has to ensure that we're going to achieve the emissions reductions It has to meet each of the 11 criteria that EPA has set out in its rule to Let states know what is acceptable to the agency if we don't demonstrate to EPA satisfaction that our plan Passes muster they will reject it and then there are consequences to it So the first question what's involved is our menu of options we published this two weeks ago I think we had handouts for the table of contents outside and what it does is it identifies It has 25 chapters. It's 465 pages and it identifies literally Everything we and our contractor could think of that could possibly go into a state plan Whether it's part of the building blocks or not and for each strategy. We have described it We have identified the potential greenhouse gas reductions. We've identified the cost the cost effectiveness where that strategy has been employed and and Equally important we identified not just the greenhouse gas reductions But we tried to identify the collateral non greenhouse gas air quality benefits that could accrue You know if your congressman or governor or senator or stakeholder Does not agree that this program is going to reduce greenhouse gases the way you want There's still reason to consider this program seriously because you will get huge Reductions in small-forming emissions and fine particulates which are killing people and in other air pollutants Which are causing a lot of significant health problems throughout the country So there is a lot more than just greenhouse gases that could come from this program this is what it looks like and As I mentioned we are looking at options I won't get into them too much now. We can wait for the Q&A period, but we have chapters that address not only those strategies within the building blocks, but also Chapters that we have included strategies that are outside of the building blocks So things that EPA has not really focused on in their building blocks But we have are for example improving the quality of of the fuel you're using of the coal You're using a lot of the coal is high sulfur fuel and has a lot of ash and it's not as efficient as as other fuels We could be switching fuels at existing sites and there's a lot of electricity lost and greenhouse gas reductions lost in transmission lines and going from the power plant to the actual residential Community the second question that we addressed I'm shifting from the menu now to something else. That's really important is a model that we are coming out with about 30 days After the rule is finalized and this model. It's kind of a misnomer. It's actually a menu of models It's a it's a series of regulatory pathways So that once a state has adopted a strategy We then have to take that strategy and put it into our plan and we will be taking For each major strategy and for each potential scenario that a state chooses that strategy adopting regulatory language for it Having preamble language that describes it and we will be providing this for literally every state and local agency in the country and Stakeholders so that states won't have to start from scratch in developing regulatory language that appeases EPA Rather, they'll have it at their disposal and this is not really a one-size-fits-all Model because we know in the states there are as administrator McCarthy likes to say There are 50 different state plans that will come in all requiring something different But we are trying to identify The types of strategies that we think states will adopt and then provide them Within a month after this rule is promulgated enough specificity that they can really implement this quickly because we want to meet the deadlines and Our goal is to Do this? Quickly enough that we've also taken advantage of the changes that EPA has made from proposal to final rule so that it's a timely and beneficial product So let me let me wind down and and and just conclude with one other very important point I'm proud to be up here with with Chuck and David from Nay Rook and Nassio because These are organizations that we work very closely with we hadn't worked years ago Together, but it's only been recent years and recent activities under the Clean Air Act that has necessitated our groups coming together And we have worked, you know really well when trying to figure out Collectively it's part of good government. I think To understand the needs of these groups Nay Rook will tell you that they're interested in reliability and we get it and there will be nothing in our plans that will adversely affect Reliability and David will tell you representing the state energy officials that their concerns is Providing opportunities for energy efficiency, and we think that is a very important of strategy To consider and we are all over that issue because we think it's a it's smart public policy So let me conclude with a few observations I Don't want to leave the impression that implementation of the clean power plan is a slam dunk. It's not it's going to be challenging We understand this But we are going to be working very very hard at the state and local level to try to make it work And we think the two documents the two tools I described Will help accelerate Effective implementation of that We've already been working really hard laying the groundwork for compliance. We've been meeting our members have been meeting with stakeholders they've been meeting with Intra intrastate all the governmental entities so they can understand fully what's expected And those discussions have been very very worthwhile even within states who are suing EPA over this rule. There's been very good discussions I should say a word about EPA's involvement. They've been Really really great listeners. They've met with the states almost anywhere anytime They've sought our input and we are hopeful that they're going to carry out that leadership and Incorporate Many of the concerns and the legitimate issues that states around the country have been offering and we're confident that they will and then finally I need to say a word about an effort that has been being promoted Not just by the Senate majority leader, but by others For states to stand down There's been this effort to try to persuade states to stand down and to ignore The implementation of this program and while you know, I said earlier not every state likes this program If the law is not changed, this is the law and the consequence of standing down and not implementing this program is severe a Federal plan will be imposed and by definition. It will be less flexible and more costly for stakeholders secondly It will lead to It will just show a total disregard For the tens of thousands of hours that state governmental officials have been used to meeting with Stakeholders and others and trying to make this work and it just sends the wrong signal in light of the fact that we Think greenhouse gases and climate change are real problems and must be addressed. So with that, I thank you for this imitation I thank you for your attention Thanks very very much, Bill And now we will turn to another of these important energy-based organizations To David Terry who is executive director for the National Association of State Energy Officials David brings Over 27 years of experience working on energy for a variety of entities Everything from being a researcher for the Washington Post to being an analyst with the National Academy of Sciences working with the governor's Wind Energy Coalition, but he worked for Nassio beginning clearback in 2004 and worked with Nassio from from 1996 through 2004 and then became Nassio's executive director in 2008 What is important? I think to particularly understand about the National Association of State Energy officials is that This embraces 56 state and territory energy offices Nassio communicates state policy views on virtually all national energy issues Which cover everything from natural gas and electricity to buildings energy efficiency Renewable energy industrial energy efficiency energy emergency response and assurance and reliability as well as energy technology Innovation and of course all of this is is almost always tied to also being very concerned about how this affects states economic development David Thank You Carol. I appreciate the introduction and I have to thank ESI Carol's organization for hosting today's briefing and always for their excellent work I am somewhat biased as a board member of ESI, but I think you all know their excellent work. Well, so thank you very much Carol covered I think a little bit about these state energy offices. I won't be labored that I would point out though For those of you not familiar The energy offices are typically appointed by their governors. They focus on policy is distinct from regulation So where the utility commissioners are certainly focused on regulation of economic regulation of the Electric utilities the energy offices are more focused on policy advising their legislators advising their governors across a range of energy issues Much as Carol described We also have a number of private sector affiliate members as that are a part of our organization They're non-voting members, but they provide good market input and a good ground check We always are concerned with economic development impacts associated with energy So that's a helpful part of our organization and I think a good way of understanding where we come from With regard to the clean power plan a few things. I think about our approach that differ from the other Organizations NACA and Nehru in some ways Nazio does not have a position on 111 D or the clean power plan There's obviously a great diversity of views among the states among the governors as you all know and as Bill pointed out But we do want to ensure that states have options flexibility in The plan Shouldn't move forward. We want to make sure that reliability Affordability sustainability are protected as a part of that plan. I think we all share those goals And the other piece of this that's important. You'll see as a theme in my comments Going forward. We see efficiency certainly is a great compliance option both demand side and supply side So transmission distribution System efficiency as well as end-use energy efficiency But also we frequently think of energy efficiency in the context of investor-owned utility rate pair programs typically overseen by the commissions That's a huge important part of the compliance Solution set that we see but the other part are all the non So-called non rate pair programs So if you think about the amount of money spent on energy efficiency each year in the United States It's on the order of $50 billion that includes private sector investment consumers Utility investments a whole range of things and and the bulk of that investment is happening outside of those rate pair programs And we want to make sure that states have the opportunity to capture those benefits Take credit for them and also that we get the most cost-effective option moving forward a few examples of those I'll go into them in a moment But certainly the rate pair programs, but also energy savings performance contracting in the public building sector building energy codes commercial pace industrial efficiency investments and a range of other activities Some of the key takeaways that I would I would Keep in mind as you consider the clean power plan and how it moves forward the electricity system As many of you know was already undergoing dramatic change Certainly a shift in natural gas Generation was underway. We have dramatic improvements in energy efficiency in many sectors Ranging from those kinds of things that we all know about LEDs and so forth for lighting But also emerging building technologies I we just did a congressional briefing yesterday on zero net energy buildings And you'd be amazed to know although there are a small number the number of buildings that are emerging that produces much energy As they use a school just down the road in Arlington, Virginia Just opened that does that the first three elementary schools in the country built in Kentucky several years ago do that So there those issues certainly the integration of the internet and controls around how we use energy in the electric system Is also come to bear so utilities already have a great deal to deal with and certainly the commissions and the state energy offices In how they work with them and yet at the same time. I think we all expect reliable affordable environmentally sensible Power to be delivered. So it's quite a challenge. It was going along and that's I think that's an important thing to keep in mind In how complex it is to deal with all of these issues The other take away and I mentioned it just a moment ago, but it's thinking about truly cost approach and by that I don't mean anything very inflammatory, but rather just a reminder that we have a wide range of options I think that's really embodied in NACA's Menu approach, which is a great document certainly includes many of the ideas that Nazio has and And I would really encourage you to take a look at that and consider it as you as you look at the clean power plan and what the states are doing also ensuring that Evaluation measurement and verification around efficiency programs are streamlined. It's a balancing act We have probably a habit in the in the energy community of Measuring to a great degree of accuracy and while that's important This is serious business keeping air quality meeting air requirements a serious business We also don't want to make it so difficult that it's virtually impossible for states to move forward So finding that balance is a very tricky detail And the focus of a lot of our work and a number of other organizations at least in this particular space Certainly assisting states with ongoing no regrets Programs and activities and I'm going to spend a little time on that a moment and continuing the kind of dialogue We've had not only among the so-called 3n groups Nazio, Nehru, NACA, but also our members on the ground And I think that's a healthy and very positive Thing going on not only in this area, but in other areas of energy regulation and environmental regulation a few things about our ongoing Activities we've as bill mentioned we've been involved with working with both of their organizations for some time We've had a number of meetings. They're noted here some agreement on principles in 2014 that we submitted to EPA That I would encourage you to take a look at but places where we found common agreement around energy efficiency as compliance As a compliance measure certainly around reliability And a number of other issues and and I think those are worth noting We've also been working on At Nazio on compliance case studies So looking at various energy efficiency areas again typically beyond the rate payer efficiency program So working with the energy services industry companies like Johnson controls and Amoresco I in the state energy offices about how they implement energy efficiency in public buildings So by way of comparison There's about a seven billion dollar a year market in investment in energy efficiency in public buildings That's almost all privately financed. So it's an amazing opportunity. We need to capture that There's additional funds going in at the federal level and many other examples I'm certainly planning sessions that we have coming up at our meetings As I mentioned we're working very closely with the energy offices on no regrets options and also with the private sector Associated with the clean power plan, but broadly to help meet state energy and air goals I think one in particular worth noting we have a multi-state tracking project going on in the public building investment area Trying to see where we can streamline activities in that space both in terms of measuring the emissions that are saved associated with projects the amount of investment Return the amount of benefit to the taxpayer and energy savings and so forth We also have a similar project with the state of Texas and a number of other organizations Looking at building energy code compliance. So existing codes that are on the books What kind of energy savings are they producing and how are we verifying that and what kind of emissions reductions come from that? So these are capturing and existing Programs that are cost-effective in many cases on their own on their own merit And we're not capturing the emissions benefits in the way we can and we want to make sure we do that Similarly in the industrial space. There are great opportunities there largely Private sector voluntary activities in this space. We see that over and over again There are a number of state energy offices that operate assistance and financing programs for their small and large industrial industrial Partners and stakeholders on the ground the amount of savings that can be generated. There is enormous It is generally unless it's inside of a utility program is generally not captured from an emissions perspective at the state level So again another opportunity, and I think you kind of get the get the flavor here It's just a little chart that gives you a sense of the level of Private investment just in the public building sector at the state and local level. So right now we're at about six billion dollars a year That's escalating over time. It's estimated to be nearly 20 billion dollars a few years down the road And again, these are largely private sector investments the savings from the project pay for the project over time The emissions associated with it are well documented generally verified by contract. It's really an extraordinary process It's a great example in one of the areas that we focused in particular at Nassio. There's a the text just came up I guess a number of ongoing activities in addition to our coordination with Neyruka and NACA I mentioned we are working on compliance studies in about Seven or eight areas They're not all listed here But they include use of combined heat and power by the private sector whether that's at a hospital or a university or an industrial plant As a much more efficient way to provide power in some cases again capturing the emissions from that So we're developing case studies for state for states to consider about how that works at the state level And how they could capture those savings how they might EM and via and also draft plan language So that maybe something a state can consider plugging into their plan And we're certainly coordinating closely with Bill's group on that They are the experts on the plan element But we're trying to provide as much as we can packaged options states can use to the plan move forward We're also doing that in other areas. I mentioned building energy codes, but also retrofit of residential Properties existing federal programs. There's a well-known program in the residential sector energy star new homes Those savings are very well documented and put out by EPA They are generally not captured at the state level for a for compliance Purposes under Environmental rules and so we think there's an option there clearly EPA is satisfied with that program in the way that they operate The states find it a very advantageous program as well as do the private sector builders So all of these activities are really leading up to that Initial takeaway that I mentioned which are to really capture the least cost approaches the truest least cost approaches if I were In an energy office trying to advise my governor work with my Partner agencies at the state level we want to find a way to get to the least cost approach to compliance So picking up on these private investments the voluntary programs existing state policies are just sort of logical Places to begin the trick of course is how we quantify that doing it in a in an economic and reasonably simple format and also making sure we do have verifiable savings they clearly the Meeting compliance requires that as it should Just some next steps on where we're headed We will complete the efficiency Pathways or case studies that I mentioned over the course of the next couple of months We'll be submitting those to the Environmental Protection Agency After our states have had an opportunity to comment on them. We've been working closely with them Those will be Submitted as options for EPA to consider they'll certainly be shared with all of our state members with NACA and Neighborhood as options as they consider state-level discussions with their members We also are working in another important area that has a benefit for Potential clean power plan compliance, but it has a benefit that's broader in the area of energy and air coordination And that's a national energy efficiency registry So one of the challenges as many of these private sector and voluntary programs are implemented around energy efficiency is who owns the Efficiency credit who owns the associated emissions reduction Is it verifiable? Is it transparent? So a registry a voluntary registry gives the opportunity for companies for states for local governments to enter those projects Meet certain criteria and have a means of verifying that so it may promote The ability of a state to count whether they're getting toward a particular energy goal certainly toward the clean power plan There's an obvious linkage there, but generally I think it's helpful with state activities, and that's an important one to watch I think it's a valuable a valuable approach We are working with about seven states on the compliance or excuse me on the governance rules Around that private sector organization the climate registry is working on some of the substance and would actually operate such a registry if it moves forward And lastly and and certainly most importantly working directly with not only our energy offices But with the EPA regional offices and presumably the Department of Energy as we as we move forward if the plan moves forward Starting in September. We have a number of regional meetings planned With the regional EPA offices and our members and certainly support in-state work across our three organizations representative members Just some contacts at Nazio at the end here for a takeaway. I do want to reiterate what Bill said I think the cooperation among Nehru, NACA, Nazio certainly among our members, but particularly Bill and Chuck has been exceptional Not only on this area, but over the years as we try to act in the best interest of the states and and find least-cost approaches to meet really what our Interlinked goals and challenges. Thank you Thank You David and Now we will turn to the third leg of this stool Charles Gray who is the executive director of the National Association of Regulatory Utility Commissioners or as we all say Nehruk and Chuck has been While he was named executive director in 1999 he has been involved with Nehruk since 1979 serving in various capacities and one of the things that I think is also important with regard to Looking at this key role of state commissions across the country are the wide variety of issues that they must deal with On a regulatory basis that ranges from yes energy, but it's Electricity it's gas they also in terms of many states in terms of water Telecommunications and transportation, so it varies across the country, but but covers a number of sectors and So this again Obviously requires a lot of skill a lot of knowledge a lot of wisdom in terms of being able to Work across all of these sectors and then a and across all of these states With different concerns priorities resources in each of these states, and so we are very glad to welcome Chuck Gray I have one slide and that's it So hopefully this will go quickly I thanks Carol for the very kind introduction and for inviting me here today To follow up on these very glib speakers here, so this will be a little disappointing, but I Start with the standard disclaimer that the remarks are you're about to hear my words only and should not be attributed to any Nehruk members, especially since we're on C-spin. They're probably watching so I Get that out there. I also have a second disclaimer, which is similar to what David said Concerning the merits of the EPA proposal one under 111d I want to make clear that Nehruk has taken no position for or against whether the the EPA should be moving forward with this However, we have members commissions who are very strongly opposing The proposal as well as very strongly supporting that and I think you'll see that Continued as we get near the final rule Thanks for describing Nehruk. Nehruk is a national organization. I'll just Repeat 50 state commissions plus the District of Columbia and they always make sure that we Acknowledge that the District of Columbia is not a state and it has a public service commission And importantly our members regulate retail electric utility services with which is at the heart of this discussion Including generation services provided to retail customers that are the focus of the Clean Power Plan They also regulate natural gas Distribution and purchases by retail customers as well, which are clearly implicated by by the Clean Power Plan as it now stands and In the at the EPA proposal Importantly what that means really is many of the options that bill has described or that are in the the menu Falls squarely within the regulatory jurisdiction of one or more state commissions and in many in other cases in the Jurisdiction of the Federal Energy Regulatory Commission in the areas of Transmission and wholesale market compliance options Just as an example in I think it's chapter three of bills menu. There's a Section on combined heat and power And Combined heat and power is a long-standing issue before the state public utility commissions dating back to actually before I started working at Neighborhood in 1978 when Congress passed perpa that it was called cogeneration at that time now It's called combined heat and power, but that empowers the public utility commissions essentially two big issues interconnection of the of the of the plant to the grid and then buy back Prices that the utility would pay to the or the to the owner of the CHP facility Those things will have those decisions is as a compliance option will have to be vetted by the State Utility Commission as it as it's added to the to the state plan another example is On retiring aging power plants those power plants have been certificated by public utility commissions if they're in retail rates and if they're If there's if they're closed before their useful life life is over there may be stranded cost recovery issues that the state Commissions will have to address if the plant hasn't been fully depreciated Also, just the decision itself to shut down the plant may be required to be approved by the Public Service Commission I guess my point is while the need for three-end coordination here in Washington has been important and I think very very Necessary Close coordination between the commissions the air regulators and the energy offices out in the states is crucial and it's indispensable Really there needs to be this dialogue going forward As just talking about the relationship arc the coordination between the three associations has been Continuous and beneficial over the last three or so years and I think from speaking from Nayruv's perspective That's been a very rewarding relationship throughout as David mentioned we Most of our work in the last year and a half has been on energy efficiency Both utilities and third-party energy efficiency program, but I think now with the final rule It's gone to OMB and it's going to be coming out soon I think we'll have to broaden our relationship now and look at other issues as well as the is the energy efficiency Questions that we've that we've worked on on before I know from from Nayruv's perspective We will be eager to participate in a broadened discussion with with the three ends As we go forward When the rule is out what role will Nayruv members play in efforts to develop state compliance plans? Well, I think David mentioned it quite accurately our watchwords of our members are going to be focused on two issues reliability and affordability As economic regulators of electric services The state commissions and the Federal Energy Regulatory Commission are responsible for ensuring that wholesale and retail services Meet these two goals affordability and reliability our members have been working closely with FERC on reliability issues over the last few months Resulting in the letter that FERC sent to the EPA on May 15 suggesting that EPA consider Adopting a reliability safety valve We have not taken a position as an organization on that proposal, but There's strong support among our members that that FERC suggestion to EPA be accepted and in that there be a Some kind of a contingency in case the the compliance plans do raise Reliability issues In addition to the work that NAC is doing on the compliance plan, and this is where my slide comes in Nayruv has been developing white papers and reports in response to what appears to be a growing interest in Assessing what a regional compliance plan looks like or a multi-state compliance plan would look like As reported and actually just this week and inside climate news 41 states are now in regional groups exploring this Multi-state option including states that strongly oppose the the CPP. I think Bill's Suggesting that even if you don't like it you should do it and rather than have the feds do it It is really working in a lot of in a lot of states that are not wild about the the proposal For our for our part. We released a report last month On behalf of the Eastern interconnection State Planning Council, some of you may know what that is We call it ice pick and it's Issued about a process for how you would get states together to think about putting together a regional plan The white paper that the link is right there was funded by the Department of Energy through some of our grant grant Assistance and it's really based on two premises first that except for Texas The grid is interstate the markets are interstate but compliance plans under section 111 D at least on its face our state Specific so there needs to be a connection there and I think the second premise that drives this discussion is that Multi-state there's been a lot of studies recently that multi-state compliant compliance plans reduce compliance costs Improve operational efficiency and strengthen reliability So I think there's a lot of growing interest in in trying to see how how far this goes I think the quote one of the questions is will the states have enough time to put something together that requires a lot of work The are the white paper that we've issued provide steps in a process for states to get together to initiate a multi-state approach It contains a sample MOU that states can look at and if they want to Agree to as they come together the MOU is there for their benefit while our paper focuses mostly on process issues, there are some Proposals and many proposals out out out in the firmament if you will on what a compliance plan like this might look like The probably the best known regional Compliance plan is Reggie the regional greenhouse gas initiative, which is operates primarily New England in the in the mid Atlantic states there was a story today an E&E that now Pennsylvania and Virginia are thinking about joining Reggie as well So I think we're likely to see that as at least a model. It's a cap and trade based system Which may be? States may seek to join the existing Reggie or set up a similar kind of Project in other states our friends at the regional transmission organization the RTOs that run the run the grids and the Power markets have also proposed some a regional compliance plan that they would help Implement through the through their control over the wholesale power markets not quite clear To me how it's actually going to work But they're they're working on it and then just recently the the Georgetown climate Center released a paper outlining a system of single-state compliance approaches with interstate elements a sort of a hybrid between a single-state plan and a regional plan and That's going forward as well many of the the the Interstate elements are likely to be the compliance options that the NACA menu recommends Well, they would believe that is not our role to tell the states that they should do a regional plan Is clearly an option that if chosen will require the close coordination among air regulators energy officers and utility Commissions like we haven't seen before not only as we as we look at multiple Jurisdictional authority, I'll stop there. Thank you for your attention and I look forward to the questions Thank you very much Chuck and I might mention to that we hope in the fall in September or Hopefully to once again work with our colleagues here to put together another form that really looks at The next steps forward and looking at model plans and what this might represent once that the EPA Rule for the clean power plan is is finally released So let's open it up for your questions And I would just ask you to go to the microphone here in the aisle and please identify yourself with your question Do we have any? Okay back here Could you just please? William Yeatman the competitive enterprise Institute just a quick question. Mr. Becker you seem to assert categorical jurisdiction over implementation of the clean power plan for The air quality regulators and that seemingly that was conflicted by what Mr. Gray said and I was just wondering is that a decision for state legislatures or has that already been decided in your mind? So I think we're saying the same thing, but I'll let Chuck speak for himself under the Clean Air Act and under section 111d State air regulators have the legal responsibility of developing a plan and implementing the plan We of course will be working with state utility regulators and state energy officials in Pursuing the kinds of programs that they both outlined and it may be that the state will have to take actions with Utility commissioners concerns and energy officials concerns in mind as part of the plan, but the ultimate responsibility Lies with the state environmental agency and and till we're told differently. That's our responsibility Yeah, I don't disagree. I clearly the the law is the law in the states and as Bill says the air regulators are responsible for Dealing with the environmental impacts, but that doesn't Obviate the op-poss of the requirement that the states actually approve what their the state commissions approve what they're Legally bound and bound to do but I think they'll be constructive dialogue on how that all works So when you go forward, you're not going to have the air regulars and I'm going to put a Element in a plan that they know that the commissions wouldn't improve and vice versa that the states will be the commissions will be Constructive and try and give as much flexibility to the to the plan writers as possible Great. Any other questions? Angela crooks from the Department of Energy and I had a question for Nassio Just wondered if you're looking at distributed generation as part of the overall energy efficiency strategy Yes, we are and renewables certainly specifically as well as Micro grids combined heat and power both but in the renewable area We've been working with a number of states and the renewable trade associations to see where that fits in I think I think some of the challenges in in that area are Extremely dependent upon the state and the region you're in and a couple of examples about issues We have to work through in the West the a great deal of the renewable resource Opportunity sits on federal lands it has traditionally been very difficult to develop renewables on federal lands as an example And there are a number of states that if you look at the Calculation of the renewable opportunity contained in the clean power plan draft rule much of that opportunity sits on federal lands I think that's an example of that's a huge barrier that has to be worked through as an option There are also I think More technical barriers in terms of states that produce a great deal of renewable power But perhaps don't consume as much maybe they export a great deal of it How does that credit fall? The clean power plan draft rule to my mind was a little bit unclear on that I think there are issues on both sides, but the short answer is yes, and I think there's a lot to do in that space And I might mention and you might want to address this bill that there are there's a whole chapter In the menu of options document if you want to talk about that a little bit We can talk about distributed generation and there is a chapter But I I wanted to make a broader point if I can a couple points and the common denominator of the two points I want to make is There are opportunities That this rule presents there are there are certainly costs, and it's clear that some of the opposition Is focused on the cost of implementation But we should not forget for one second that there are opportunities in this rule for power facilities for energy companies for other stakeholders to benefit and I can only tell you this through anecdote when we were developing our menu We must have had 30 meetings with regulated industries Including renewable industries who wanted to be part of that menu who wanted to Communicate as widely as possible the kinds of things that their products could provide state regulators to Be embodied in a plan Financially and economically they benefit from states pursuing some of these things, so it's not just An adverse impact on economic development in the state. There are efficiencies. There are other other tremendous Opportunities that this program for the smart folks for the industries that really care can take advantage of and we've seen that and I I think we're going to see that even more once the final rule is implemented and then a second quick point I'll tell you a little story about Something similar to this program in January of 2011 EPA proposed regulating states and Power facilities and other manufacturing facilities with respect to greenhouse gases and they required at the time that All major facilities obtain a permit that would Require the installation of best available control technology and at the same time like today there were a dozen governors who were suing EPA and Notwithstanding the fact that those governors were suing and they had you know legitimate concerns about this just like today's governors do The state at the same time was developing the legislative and regulatory infrastructure to comply So that they were not only playing both sides responsibly, but they were hearing from their industries that They wouldn't be able to expand they wouldn't be able to take advantage of Opportunities in economic development if they didn't have the regulatory infrastructure in place To do so notwithstanding general opposition to the program and that was smart of them and in the end every state but one actually adopted the program and went ahead because industry was telling them to and Complied and the last day Texas eventually came came along So there are opportunities if you seek them out in this program to take advantage of a lot of things that can be done Great. Thanks very much. Bell. Are there other questions or comments? That one one Issued that I wanted to just raise that builds upon what you were just saying Bill is in terms of looking at the different chapters, and I think that there's also one that talks about innovation and And that pursuant to the original enactment of the clean The Clean Air Act and the Clean Air Act amendments It struck me that one of the things that we saw there was that there was a lot of innovation a lot of costs that were much Much lower than what people anticipated that a lot of things were driven forward that were not necessarily Anticipated so I was just curious whether each of you could comment about that What your experience is and what you are seeing and if there are any particular States or or other industries that you think are are looking at that Happy to happy to comment Carol. I think that's a great question and it's one because most of the energy offices Report to their governors. They have a particular focus on economic development So technology innovation generally and this in supporting businesses development of those innovations is is incredibly important and I think We have Repeatedly been surprised by the kind of innovation that takes place I think back about the kinds of electricity loads at least in this space that we anticipated 10 years ago that haven't materialized and Independent of the financial downturn that we've had You know loads are low demand is lower in many places because of that everything from the obvious Like LED light bulbs that also things that frankly only a few of us energy nerds know about how building systems work together I mentioned some of those things in my remarks and I guess one thing I would add to that And I think maybe it it emphasizes or builds on what bill just said with regard to benefits 39 of the states are Have formal energy plans that they do in a policy context We call them comprehensive energy plans the state energy offices generally lead those It's being responsive to their governor typically when a new governor comes in sometimes It's legislatively mandated, but they look across the entire energy spectrum not just electricity But technologies companies that are in their states Research capabilities in their states natural resources They try to figure out where they can support particular pathways and part of that process much like the the regulatory framework Bill mentioned really helps to drive innovation and economic development. So there is another side to this that's That is important to look at and I think traditionally as we've seen new rules whether they're environmental rules or state implemented goals or past legislation That really does drive innovation. It drives the cost down. We need to make sure though that the regulatory process or Or plans such as the clean power plan allow for the kind of flexibility and private investment that's needed to make that happen Because that's where it will come from Yeah, just to add a few points You know the Cleaner Act probably like other Important domestic legislation is a wonderful case study in regulatory development When a rule is proposed before it's finally adopted, you know all interest most interest groups Come up with the worst case scenarios the highest costs And we could all hear write the playbook of the rhetoric that is dispensed once a rule is proposed and This it's almost as if the sky is falling once the rule is finalized The industries and this is a huge compliment to them the industries have immense an immense amount of talent and they shift their focus from Rhetoric to now they have to comply and what do they do they find innovative ways of Addressing these national goals that they hadn't particularly shared I don't want to paint too wide a brush here, but I could they hadn't shared during the rule-making process and I'll give you a couple examples during the acid rain debate in the leading up to the 1990 Cleaner Act The estimates for allowances to reduce sulfur dioxide Were ten times higher than what the actual allowances sold for after implementation when reformulated gasoline was debated in in Congress and Congress eventually adopted a law and EPA eventually adopted regulations leading up to that You can look this up. It's it's public information There were there was talk of long lines of gas stations the cost of gasoline would be you know between 10 cents and 25 cents higher and in reality The cost of reformulated gasoline was a fraction of a penny wasn't even noticeable and again the oil companies learned how to Reduce pollutants in their gasoline when they were required to so there is a huge Opportunity for technical advancement. It may not be shared now, but once the rule is promulgated You can almost guarantee That the impacts and the costs that have been projected will be reduced and I mean that as a compliment to the industry Who has to comply? Yeah, I would just observe there's a lot of innovation going on right now, which is Related to but in some sense separate from what's going on with the clean power plan I Go to many conferences where utility of the future is debated about we're going to distributed to a distributed model Well with storage and rooftop solar has become a big issue I think a lot of the innovation is already Underway in some respects what's happening for example up in with the New York Commission up in Albany as they try to prepare for the for the new business model and Prepare the commissions for a new regulatory model and This is an industry that moves very has moved very slowly over time And they make long-term investments for assets and infrastructure. That's built to be there for a while And I think that innovation is probably Not as fast as maybe in the telephone as we saw on the telephone side, but Clearly it's it's underway, and I think it will benefit the the compliance plan process a great deal So a lot of that is going to happen even without the clean power plan Okay, could you go okay? Could you just get in line over there great? Go ahead? Hi another question. I'm Angela crooks department of energy Who is leading the charge right now in terms of starting on the compliance plan work? Is it the air regulators? Is it utilities who want to make sure their interests are protected? Who do you see you being most actively involved at this stage? You should probably all answer that. Yeah, I think that's an excellent question and I want to just jump out and say the environmental agencies, but I will I will temper You know that that response and say We are being deluged in a good way With with requests for meetings we meeting my members we request for meetings and discussions with all affected stakeholders and so while the the environmental agencies as I mentioned to the gentlemen earlier have the responsibility Stake affected stakeholders both government and industry are not being shy about Seeking out meetings and trying to weigh in so it's it's a collaborative effort in some strategies This will be a utility only Strategy and the state will have you know less responsibility or little responsibility It'll be up to the utilities so the smart utilities are going in and making their case in other strategies It will be you know partly State driven and partly utility driven or you know other common elements and other Stakeholders will be engaged so I think it's it's a shared responsibility Yeah, we get again you talk about anecdotes. We're getting a lot of anecdotal reports that a lot of states have workshops that they put together with all the regulatory bodies as well as the stakeholders to try and Thread their way through this discussion You know you're also see legislation in some states where the governor is going to have to finally sign off on the on the plan Which is is is out there as well. So I think it's going to vary from state to state But ultimately I think just under the law under the Clean Air Act It's the air regulators that are legally responsible for submitting the plan I think that basically Chuck's comments exactly right from an energy office perspective We I think does there's a lot of variation from state to state certainly the air agency Leadership on the plan development and submission. I think there is What I would say is surprising is the level of coordination across the three agencies at the state level and in many states Where many of you might be surprised where that's occurring and I think it's it's reflective of them being thoughtful and doing the right thing for For their constituents and and thinking about the future. So I I don't I think you can point to particular examples where Governor may have charged a particular agency to take the lead in in some regard, but I think generally it's much more collaborative And that is actually really really good news. That's terrific news Go ahead Thank you. I'm a Khalil Shahid with the Natural Resources Defense Council And so my question is concerning So we've been hearing a lot of messages and you know, we can argue about the reliability of the data or the messages That's a completely different argument, but we've we've been hearing a lot of arguments about, you know the threat to the clean power plan on on on low income rate payers in terms of, you know In terms of rising rates, but then at the same time when we hear about The compliance options particularly for energy efficiency There is always an emphasis on the industrial sector commercial sectors in public buildings And so my question for you all is, you know through this is through the stakeholder process, you know What inputs need to be provided in order to ensure that energy efficiency investments actually reach low-income Consumers so that these threats about rate hikes, you know, don't actually Pan out. I think you all should take a pass at that too What's to start? I'll start. Okay so very good point and One that I know my members are very sensitive with I'll make two comments. One is in our report We don't have a specific chapter on Environmental justice issues or The poor or Those adversely affected, but there are examples throughout the chapter whether it's low you know weatherization programs or or other types of Energy efficiency programs that will that will help the poor that will help those that all live in Impoverished areas the second point is We are involved in discussions with EPA on assessing environmental justice problems around the country and We've been working with them. There are permitting requirements that affect our business and we are Throughout the country having to deal with these issues not just in climate Strategies, but in regular implementation of the cleaner act So we are we are sensitive to it and we're doing our best to try to address these issues head on Well, low and low-income impacts are a major concern among among the state commissions Clearly the consumer advocate organizations in the states are raising those questions It's we we've supported for years. Lieheap is a is an important way to to deal with that problem Low-income, right and actually now is it getting back to the innovation questions some of the Disruptive technologies that are now being talked about Actually could result in and shifting of cost from one customer class to another So that's something that people are looking at to see that that doesn't happen And I just would observe the Qer that the Department of Energy issued one of their proposals has to do with a related Issue with just methane emissions and they would actually provide billions of dollars for low-income To reimburse low-income people who have to pay for for more Expensive pipeline in the ground to keep the emissions down So I think there's a lot of different pieces to this puzzle, but it's still out there Sure a terrific question. I'm glad you brought it up. Actually, we have several things going on in this area Through nazi I guess first and foremost I'd say we are developing I mentioned we have case studies and compliance plan language We're working on one of those is in the low-income sector for retrofit of low-income homes and the energy offices as a group are always concerned about affordability, but certainly for low-income households in particular and 26 of the offices around weatherization retrofit programs most of that is federally supported part of it is Utility supported and also private sector engagement as well So there are hundreds of millions of dollars a year invested in the retrofit side of that for low-income households Across the country every year that many the energy offices are engaged in those programs are very well monitored measured verified the public dollars are guarded very carefully the benefits to the To the resident are multiple certainly comfort health safety But also because many of their electric bills are supplemented with either federal state or private funds It lowers those costs. So there's a win-win there So that's another important piece to that. I would also say the There's a you know enormous private voluntary efforts that aren't being captured I think of habitat for humanity for example There's a North Carolina program supported by a state-related entity with habitat for humanity that have Done over 4,000 new efficient homes and they've guaranteed the energy bills to be $24 or less per month heating and cooling So the efficiency gains that are there should be rolled up and captured Hopefully, there's a way to monetize that and and benefit that sector as a part of this so that they Don't feel as much of an impact to the degree that rates do increase or bills increase Yeah, just one quick follow-up first, you know as it relates to whether it's LIHEAP or other federal state subsidies We know that those subsidies are being reduced You know and so and and when it comes to low-income weatherization in most cases Whether it's through the utility or through some other program You know those programs are typically limited to direct installs. They'll change a light bulb. They'll change a refrigerator But they're not really getting to you know much more deeper retrofits particularly for low-income multifamily properties And and and so you know my question is and again to toss it back to you all because I don't want to Come away with the assumption that enough is being done And so and so my question again is how do we ensure that you know a greater proportion of investment? From you know that that is that is generated that isn't incentivized from it from the clean power plant actually reach These sectors so that you know a state doesn't and it's in its in its plan for compliance doesn't say well We can reach our energy efficiency target through putting everything in Industrial or commercial and we don't need to address this sector So we want to make sure how can we make sure that these communities are actually at the table that they're actually included in the In the in the compliance plan to a rate that's actually you know fair Why that's a slightly different question and I would and I think that you're correct We have to make sure that they're at the table I would say just back to your point about there simply replacement programs in the single-family residential area that's certainly not correct In multifamily utility-oriented programs that may be very true So I think that that certainly needs to be addressed within weatherization as we think of it for typically either very small Multifamily or single-family residential. It is much more comprehensive up to the point that the law allows So there are very strict cost effectiveness guidelines around it But I do think Certainly looking again not only to environmental justice issues, but also least cost the opportunities in multifamily are enormous And I think just from a low-hanging fruit of you well perspective even that's an important important one that we've been working I know your organization has as well. We have a group at Nazio that's been focused on this for the last year and a half And I think it's a I think it's one we need to to tune up and elevate Just a quick point affected affected constituencies whether they are regulated or low-income or others are Invited to the table and we have at the state and local level Public hearing well, they're invited to the table because if you want to weigh in with a state or local official you know knock on the door or call ahead or send an email and set up a meeting and They take meetings and secondly These processes when they get more formal and they get to the proposal stage at the state level As you know, there are public hearings and there are opportunities to share this information but your point is well taken and You know, we will continuously try to do better and I must say I think based upon everything that we heard here to that An important thing to remember is that there's all there that most states also have state consumer utility advocates It is very very important I think to make sure that all of these people are truly engaged and and Understand these really important issues that are being raised because that is a terribly important issue And I would just also quickly mention that another Approach that is being used by a number of different kinds of utilities including rural co-ops and Municipal utilities as well as some investor-owned utilities is a whole approach called on bail financing for energy efficiency Retrofits, which is a way to provide a much greater expansion potentially than what we are able to achieve through the low-income weatherization program and that can really bring real savings and multiple benefits to to homes to residential Dwellings across the country. Any last questions or comments? Oh, okay Two more Sure. Hi Matt Connolly with the Center for Climate and Security. I know you all focus on state level issues Maybe more than what's happening on the hill here, but I just want to get your perspective on If there are any Proposals in the House or the Senate that you're looking at that could be complementary to the Clean Power Plan Obviously, there's an effort to allow states to opt out of it But both the House Energy and Commerce Committee and the Senate Energy and Natural Resources Committee are trying to put together comprehensive energy bills To try to enact something this Congress Are there anything any specific proposals that you're all looking at whether it's on the energy efficiency side or? natural gas permitting or perpa or any potentially complementary policies that would Help the Clean Power Plan be successful Thanks for your question. Go ahead David. Sure. There are excuse me. We are very engaged on the process going on in Congress in that area from the energy perspective among the efficiency bills in particular But all the energy bills. I think there are some 70 now Underway at least on the Senate side a number of those I think would complement the Clean Power Plan in the sense that they promote efficiency Most of those are bipartisan in nature There's the SAVE Act and a number of other bills that I think produce efficiency benefits They're not intended for the for for compliance with the Clean Power Plan, but they certainly produce some benefits the one thing I would point to though that We've been very interested in it's actually one of the few energy bills that have passed have been signed into law This year and that's Tenet Star Something that Nazio and the energy office supported It's a voluntary recognition program for leasehold energy efficiency improvements So for example, if you're leasing office space recognition program put forward in part by the commercial real estate industry, which I think has great promise again Promoting private sector investments. So those are the kinds of things that we see among those bills that I think would be helpful There are also some financing measures that I think are important that Contribute to that which is Carol just suggested. I agree with what David said and I'll repeat what I said earlier that One of the most important legislative actions that could be taken over the next couple of months is to Provide funding under the in the appropriations bill under EPA's budget to help states fund the Clean Power Plan and the administration has recommended 25 million dollars for Assistants for the Clean Power Plan and a 15 million dollar increase for other air pollution programs and what we have said to make it easier to support is You don't need to earmark 25 million dollars for the Clean Power Plan, but lump the money together the 40 million dollar increase Provide to the states Make them accountable for how they spend it and for those that can spend it on climate Let them do so and for others that don't want to they have a great use for it for other clean air programs That would be very important Just very quickly we've been looking at some of the the PERPA amendment legislation that's been offered by and I think in both both houses and Some of that is consistent with what state commissions are already doing. I'm talking about this is a different 111d It's 111d in the in PERPA and talks about different policies that the states are Asked to develop or consider and some of those would be beneficial. I think to the Clean Power Plan Great next question. Thank you. Hi Stacy we spoke with renew and sustain consulting Our question is going back to reliability affordability sustainability is the CPP going to support Ecodistrics micro grids net zero projects and all associated innovative renewables energy strategies This is where I need my chauffeur I have no idea That's so I help you understand your question a little better Could you go to the microphone again? So that that's actually a good question to make a broader point if any of you and your your colleagues constituents the public Has any viable You know compliance option that they think could help a state or local agency Everything is on the table and that was a point. I was making earlier that we are not constrained by how EPA set the targets for each state the states press a reset button and They're on their own and coming up with the array of measures that could be included And if you think yours is a viable one then the responsibility is to talk to the states as best you can share that information and maybe we can follow up afterwards and Let them decide on their own with your input as to whether or not it makes sense Anything I think that it's really important that Not to assume that everybody knows about every possible compliance strategy or technology or particular approach that may work and It strikes me that that we are looking at a challenge that is very different with regard to the proposed regulation That all of our speakers have have talked about in that it really does provide for much more in the way of options great flexibility in terms of how the Plans are put together in terms of the array of options that can be Assembled across sectors et cetera and put together But it really is incumbent upon I guess everybody to make sure that as many options as possible Are really brought forward to those who are going to be held responsible for making those final decisions And we should not assume that everybody is going to know what all of those possible ideas might be and how they could work and So on that note, I want to thank all of our speakers. I hope that this was helpful to you and please make sure to Look at that menu of options and at least at the summary that was outside The whole report and and please at the whole report because it'll make bill feel so much better If you really go through that for over 400 pages so that they can feel really good that they're That their work is being taken seriously And I hope that you leave this forum with a better understanding of why I actually think this is a very Exciting time in that we are really seeing kind of the coming together of of Officials at the state and local level who are really working together to understand each other's perspectives responsibilities and how best to solve problems that are really going to make sense for their states So join me in thanking our wonderful panel