 And my name is Carol Werner. I am the Executive Director of the Environmental and Energy Study Institute. We're very, very glad to see you all here this afternoon on this cold and blustery spring afternoon, because today we're going to have a good session with regard to sort of a grad level seminar on transmission. And really looking at a lot of the very basic issues around how important our transmission grid is, what are some of the things that need to be addressed with regard to thinking about economics, about citing, about the updating of the grid, which we've all been hearing a lot about. And it's obviously a hugely important issue, because it is complicated, but it is so fundamental to how we are able to run our country, our economy. And so at this point, I would like to turn the introduction of our seminar this afternoon and our speakers over to Jim Hecker. And of course, we have worked with Wires. Jim is the general counsel, the chairman of Wires, and is a counsel at Bush Blackwell, and is, of course, former chairman of the Federal Energy Regulatory Commission. So he brings years of very important, valuable experience to our forums. And we've been very, very pleased to work closely with Jim and Wires in looking at transmission issues over the last couple of years. Jim? Thank you, Carol. True, there are years and years of experience between these years. Pleasure to be here. Let me tell you a little bit about Wires before we start. I am counsel to this as a national trade group, a non-profit association that spends its time thinking about how to promote investment in the high-voltage grid. Our presentation today is basically educational in nature. We're trying to give you sort of the basic facts you need to understand how the grid works, how it's regulated, what benefits it produces. We think a well-planned, well-managed, environmentally responsible electric transmission system is really going to be critical to the nation's electricity or energy economy going forward for the next several generations. And in order for us to make intelligent choices about those kinds of investments, we need to know what we're talking about. And that's particularly true of national policymakers here in Washington in the not too distant future because the grid is aging. A lot of it was built a half century ago. It's congested in spots. It doesn't reach a lot of new fuel resources, energy resources like wind and even natural gas that it's going to need to in the future. But for all those reasons, we need to invest more heavily over the next 20 or 25 years. This is a long-term bet on the nation's economic future, really. I think that electric transmission is probably the most important thing that you never think about. And today, we're happy you're here because we want you to think about it at least for an hour or two. And our panel is going to tell you an awful lot, hopefully, that you don't already know about the grid and its benefits, how it's cited, and so forth. We're going to lead off with Laura Mantz, who's executive consultant for a group called Smartwire Grid. It's a manufacturer of smart transmission distributed series reactors for improved grid utilization. It's a lot of highfalutin words there, but basically, we're talking smart grid. And the transmission system has been smart for a long time and it's getting smarter. People like Laura have been working hard to improve the grid. She's worked on microgrid issues as well, the University of California at San Diego. She's worked on the Trace Amiga Super Station in New Mexico. And it's quite a career. And she's going to give us the basic facts as to how the grid works and do it in relatively short order. I'm going to follow quickly with Judy Chang. Judy is a principal of the Brattle Group, which is my estimation one of the top economic consulting firms in the country, particularly when it comes to anything having to do with energy on the electric system. Judy, I think, resides in the Boston office. She has got a master's degree in public policy from the Kennedy School. She's on the board of the Massachusetts Clean Energy Center, founding executive director of the New England Women in Energy and Environment. And she's done reports for us before they've been really high quality. And we're glad that Judy is going to talk a little bit about the benefits of transmission. A lot of benefits that frankly aren't recognized by even a lot of people in the business. Jeff Dennis, this is the second or third time Jeff has been with us. He is director of the Division of Policy Development in the Office of Energy Policy and Innovation at FERC, the Federal Energy Regulatory Commission, a great agency with a lot of folks who are thinking about the future of the electric system. And Jeff is sort of at the top of that ladder trying to map the energy future for the nation. Now, Jeff is going to talk about economic regulation, kind of the FERC 201, everything you needed to know, at least from the basic stuff. And I'm delighted he's here. He's a lawyer from the University of New Mexico Law School. And has a Certificate of Natural Resources and Environmental Law and a BA from Merriman University. I didn't know that well. Kevin Reeves, Kevin you can tell is from his bearing as a West Pointer. He now works at the American Electric Power. He's managing director of energy marketing at AEP, Energy Supply. And AEP is one of our proud members. He has a Bachelor of Science from West Point, a master's degree from Penn from the Wharton School. And Kevin's going to be dealing with some very complicated issues, and he can explain it in very simple terms. Regional transmission organizations and energy markets, that is, other than the retail energy, the stuff that comes through the walls here to light the room. We're talking about transfers of bulk power across high-voltage lines and the markets that depend on that infrastructure. And Kevin's going to talk about that. Lastly, we're going to focus on siting and permitting. We have two really excellent speakers from two different firms that deal with these issues. Dan Bielin is with Ecology and Environment. He's the director of electric transmission there. He's going to talk a lot about permitting, all the various hoops that you have to jump through in order to get a project approved at state and even local levels. A very complicated process. He's outside right now watching our luggage, but I think he'll be here in time. And Jack Halpern is with Stantec. He's been a senior consultant in the energy industry for several decades and has seen an awful lot of change in that time. He's going to talk about siting. His specialty is looking at land management and resource issues that are affected by the construction of electric transmission lines. And it's one of the most sensitive issues that transmission faces, because let's face it. I mean, this is really great stuff if you look at it from the standpoint of the operation of the system we all depend on. But it's not something everybody wants in their backyard. So Jack will deal with that. Let me turn it over to Laura and away we go. Hi, I'm Laura Mans. Happy to be here. I'm here with a company called Smart Wire Grid. We do advanced transmission technology deployment. And my background is the grid operator and grid planner. So I'm going to try to get you through the basics in a fairly short order, so the rest of the panel and the deep dive they'll take on their topics sort of makes sense. So if I do my job right, everything else will be crystal clear. I'd like to just go over the basic elements of the bulk power system. And when we talk about the bulk power system, we're really going to talk about the high wires in the regular vernacular. And I'll talk about how we control the system, what are some of the limits of the system, and some of what we're looking at in the future down the road. So the basic terminology we use in the industry is we talk about voltage. Voltage is like pressure in your garden hose. We talk about current. And so it'll take you back to your high school physics or maybe even before then to know that the current and the voltage working together give you power, or if you're doing something with it, will actually give you useful work. And I'm not going to go into the engineer's version of reactive power and all of this. There are more complicated features on the electric grid. We'll save that for the more advanced piece of this. I'm going to just talk about what we would call real power today and just know that there's more to it. And so when we talk about our house, we talk about either kilowatts or watts. When we're talking about the bulk power grid, we talk about megawatts. That's all how many decimal points and how many zeros you put on the end. We tend to talk about millions of watts or megawatts. And so that will be the term we use today. If you're working with your home, you would tend to be talking in smaller units. The other thing you need to know, and I've taken all the slides on Westinghouse and Tesla versus Edison, but the basic function of the grid right now, it operates on 60 Hertz power in the US. There are parts of the world that operate on 50 Hertz power. That's just as you're looking at generating stations, they have magnets cutting through a field, just like you did in high school physics. It's how many times those magnets cut through a field. The important takeaway here is that the backbone or our backbone grid is based on a 60 Hertz alternating current technology. As we move forward with some of the advanced technologies, we talk about DC current, which is a battery current. It's a steady current. And so as you look at renewable energy coming from solar panels and different things, what we're doing is starting to integrate these two kinds of power. I won't go into the art of how you engineer those two things coming together, but just know that there are two different kinds of power that we're trying to integrate into the grid. But as you're working at home 99% of the time, stuff coming in your wall is going to be 60 Hertz power. That's the goal. Lights on 60 Hertz. That's all a grid operator really is trying to accomplish at the end of the day. Omega Y is about powering 800 average homes, 250 homes on a peak day in Phoenix. And this is kind of the more important slide so you can talk about. I'd like to talk about what we're going to talk about and what we aren't going to talk about just to give you an orientation into the grid. So over on my side, you'll see the generating station. The power comes from somewhere. That's a piece of it, and it steps up through a transformer. So the transformers are essentially how we give a boost up to the power and get it onto the high voltage lines. Once it's on the high voltage lines, we consider it transmission. And so it moves to either a customer connected to the transmission system, which would tend to be an industrial facility, or it goes down into the distribution system. And on another side, I'll talk a little bit about how it's regulated a little bit differently. The important thing is everything's connected. And so there isn't a way to kind of peel off or segregate. So everything's working together all at the same time. As you folks know, we're shifting our supply mix. That's kind of true all the time in the industry as technology's developed. We look at different ways to produce power, either more efficient ways, more effective ways, cleaner ways. And so I've just put a smattering of different options up here, coal, nuclear, wind, gas, biomass, solar, and hydro. We could start talking about storage and how that fits in here. And so every day there's something new on the grid and how we actually create the electrons that go into the customers that are going to be using this. And so we start thinking about little things, like our cell phone, where we think about microgrids, which are, in fact, grids behind the bulk grid. And if you think about a community like the University of California at San Diego, they're a pretty hefty load. They're almost 50 megawatts for a college campus. And so we start looking at a lot of power. My voice just got better. I must have had a power boost. The distribution grid, it's usually the smaller wires on the poles that are running down your street. We're not going to talk a lot about the distribution grid today, but know that distributed energy, energy that's being controlled and managed sort of behind the meter all the way down to your electric vehicle charging in your home, is all part of the challenge that everyone's trying to figure out how do you make sure that you can safely, reliably, economically hook this all together. And it goes back to that first slide. I was showing you everything has to work in concert with everything else. And so when we talk about why is FERC here, the Federal Energy Regulatory Commission, they are the regulator over the bulk power system or essentially sale for resale. And if you were in a quiz class, we would say, what is the seven factor test? There are seven things that determine whether you're transmission or whether you're distribution when we talk about wires. But it tends to be that FERC is looking at the transmission wires and how we're getting things either between states or across the high voltage system. And then they hand their regulatory jurisdiction ends as you start dealing on the lower voltage systems and as you deal with unused customers. And so those tend to be regulated by your state or in this instance, the DC Public Service Commission. So there are two sets of regulators working on your electric bill at any point in time. And the other thing we're looking at is how do you, as I said, tying everything together all the way from your big power plant to your electric vehicle and your garage to the solar panel and your neighbor's roof, how do we make this all work together? That's one of the problems we talk about. But then as we look more and more, the grid is being tied together on a large, large footprint. And so some of the people that are talking later, Kevin will talk to you about interconnected systems and power markets that go over a large geographic region. As we talk about how you keep the grid reliable, these regions are in the vernacular called balancing authorities and I'll talk about balancing in a minute. But when you're reading the press, you're reading the trade press, you'll probably see them referred to as either system operators or grid operators or independent system operators. In some cases for DC that would be true or regional transmission operators. And so those are all just fancy terms or terms of art to say we have people that are like air traffic controllers over their own section of the power grid. And as power moves, they will move it just like an airplane over into the next section of the power grid where somebody else has a jurisdictional view of the whole thing. And so that's a little bit of what it looks like. It's a little bit of a mess, but it's also a wonderful thing because it is the world's biggest machine. And so what we look at is there are many different voltage levels where power is moving down and up across the grid. And then on my next slide, oops, it's not my next slide, I'll talk about it in a little while. So we're looking at the alternating current system. That system is all tied together, but then you have in certain places high voltage DC systems and high voltage DC systems tend to act like an extension cord. So if I wanted to plug in all the way down to Chairman Hecker at the end of the table, I could run a DC current down to him and nobody else would be impacted. If I was running AC current, I'd have to hand it off to Judy who would hand it to each person at the table. And so that's the difference as to how we use the AC system versus the DC ties in between the systems. There's not a lot of DC in the US. So let me just say that for the first piece of it. The stuff we have is really important. As we mentioned earlier, I'm working on the Trace Omega Super Station, which is a high voltage DC system to tie the three power grids together. So that's some of the advanced technologies that's coming into the grid to try to make sure that we can in fact, create a national and seamless grid. But the state of play right now, Kevin will talk more about this, is that we're interconnected into three regions. So the Eastern interconnection, which is where we are, goes from the Atlantic Seaboard to the Rocky Mountains. There's another Western interconnection, very cleverly named from the Rocky Mountains to the West Coast to the Pacific Ocean. And there's ERCOT, which used to be the Electric Reliability Council of Texas. And that covers about 80% of the state of Texas and they are their own grid. And so you'll see that there are three, the Western interconnection, the Texas interconnection, which is ERCOT, and then the Eastern interconnection, which is on your right if you're looking at this. And so each of these operates as its own machine. It operates at 60 Hertz and everything within it is tied together. But we haven't really tightly tied the Western to the Eastern or Texas into anything, but we're working on it. The goal of the grid operator is really simple. Everything that's coming on the grid has to match everything that's going off the grid. And that's it. It sounds really simple, but if you try to do it, I was once at a, I can't even remember, some display at TVA and you had 60 seconds that you had to keep your mock grid in balance and nobody could keep the grid in balance for 60 seconds. It's pretty scary. But there are computers and engineers and operators that know how to do it as their job instead of as their hobby. And so essentially the way it used to be was that you would match generators, you could ramp them up and ramp them down and they could follow the patterns of usage from the customers in aggregate. So you're doing this across the Eastern interconnection, for example. As we put renewable power onto the grid, what's happening to the supply is not as predictable. And so that's why we're starting to see further discussion about distributed energy, about microgrids, about how you would use customer resources to act as virtual power plants. So you have essentially more resources at your disposal to make sure that everything's in balance. But that's the name of the game is to keep everything in balance. And there are rules that are set by the North American Electric Reliability Corporation. That would be NERC. If you're reading the trade press, NERC. NERC tells you how many times you are allowed to have a mismatch, how far that mismatch can be. And it's all within very, very tight tolerances. And the other thing they make sure is that you always have a solution for what we call a contingency. Your worst thing that can happen, the grid operators are prepared ahead of time to recover from bad things happening. And so it's a very proactive mindset that they go in with to say, not only do I need to be able to deal with the grid in front of me, I need to deal with the grid in front of me should something bad happen. And so just know that there's an awful lot of forward thinking and planning that goes into this. The other thing that's really a unique feature of the electric grid is that it is not a network with switches. So it's not the phone company. It's not the gas company. There are no valves. There are no little pieces of electricity that are going, go here, go there. It's just free flowing. It's like a water network. And so when we say, oh, we have a contract to move power between two parties, well, the paper knows the electrons are gonna go between those two points, but the electrons themselves still travel across the path of least resistance. If you're an electrical engineer, it's the path of least impedance, but it is just gonna go by the laws of physics and not by the laws of contracts. And that's why sometimes we get into these robust conversations about why we need markets and how does that underpin private contracts between parties, then I know other people are gonna talk about that later. So as we're preparing the grid, we look at thermal limitations. And thermal limitations are really saying I wanna make sure no lines sag into the trees or into the ground. And so it's a really, really simple thing with an elegant term on top of it that says I'm gonna respect my grid and operate to its thermal limits, meaning if I run too much power along a wire, it will heat up and it will sag. And it's really quite simple, but we make it sound really complicated. And then there's this thing called stability. The thing that you need to know is that it's really hard. It's almost like if you could use the grid as a valve, imagine if you tried to close a huge valve that was wide open or just a little bit open. When you go to synchronize or put these power grids together, like I was talking about the interconnected operations among these large regions, you need to make sure that they're kind of close together. It's really hard to move the power grid because there's so much inertia in the grid. It's the whole country or two thirds of the country is the inertia in your grid. And then as I said, we make allowances to handle failures. And depending on how close you are to either a critical city or a critical resource, you may have more than the basic requirements. I want to recover from one thing or two things or five things or these things. And so there's a lot of planning that goes into managing the grid. We use this term of art called congestion. And congestion is just like you would think it is on the highway. I want to get over there really fast. I'm an electron, I travel at the speed of light, guess what, there's no room for me. And so one of two things happens. I still try to move power through the line. It sags, it falls into the trees, the grid trips off. We don't do that, but that is what could happen. The other piece of it is, I'm gonna have to find a different way. I'm gonna have to find ways to move that power along the grid. And so I move generators up and down. When I have no congestion and my grid's fully utilized and fine, I just operate at what we call economic or lease cost. And that's how I arrange what's gonna happen next. If I can't get everything in where I need to, I'm gonna do what's called a security constrained dispatch or I'm gonna do congestion management, which means I might have to run a more expensive source of power, but the physics will help me get it to where it needs to be. And so I'm gonna give you the very basic physics lesson quickly. So if I had a grid like this and I could get power wherever it was, I would always try to use the cheapest generator. In this case, I would try to use the $15 generator. And if I had too much load coming out at sea, I would turn on the $30 generator and then I would turn on the $60 generator. And so the way I would charge the load generally is to say, well, whatever the most expensive thing is on, that's what your bill is gonna be for this hour. And this, again, is on the transmission system. How you get your retail bill is a little different. I'm gonna just flip really fast. But sometimes I can't get all the power through. This is an example of congestion. So I couldn't run 600 megawatts or 1000 megawatts if my limit is 600. And that's what the computer systems look at. That's what the grid operators look at. And so all they're gonna do in this case is say, well, I can't get it all out of the $15 unit because I have to keep that line loaded at 600 megawatts or it's gonna sag. So I'm gonna turn on another more expensive generator and it in fact, it's gonna push power back because it's gonna come down that A to C leg, move back up the C to B leg and it's gonna give me some more pushback on that. So that's essentially everything you need to know to run a reliable power grid, go out and do it. Now, and then what happens when we're on the bulk system? And again, Kevin and Dennis, Jeff will talk more about this, is that we price this where we have open electricity market so that you know what the value of power is at every locational spot. It's called a bus or a node or a location. And so you'll see the power prices on the grid break into many, many prices. When we go to expand the transmission system, those prices inform very quickly and fairly precisely where the grid needs help because what you're looking at is where do I have chronic high prices and where do I have splits in my prices? And that's where I know I'm gonna need to look at the transmission grid and see if it's a long-term problem or a short-term problem. And if it's a long-term problem, then I have many more things to do to expand the transmission grid so I can keep it robust, I can keep it working to do all the great things that it does. And Judy is next, thank you. Wow, that is the best presentation on electric system I've ever heard. And very quickly, that's really amazing. Thank you for having me here. I will talk a little bit about the investment trend in the transmission network as well as the benefits associated with transmission. Here's the content of my presentation. I will primarily focus on the drivers of the investments and the benefits of the investments. Here's a graph that starts in 1960. If you can't see the small print, it's on the left-hand side, starts in 1960 all the way to the projection in the next few years, I think it ends about 2017. And you can see the largest investments were actually occurred in the 60s and 70s. That's when we were actually growing our currently existing transmission network. So a large amount, this is measured in circuit miles. It's one of the units used in transmission investments. And this is not even all of the entire nation, but it's approximately, you can see in the last few years, it's about 3,000 to 7,000 circuit miles per year. And it's equivalent to about $7 to $16 billion per year. But you can see from the graph that really the recent years are quite low relative to back in the 60s and 70s. And what's also really important from this graph is that guess what, those investments made in the 60s and 70s, they are quite old. So we are now at the wave, at the beginning of the wave, to actually replace them or upgrade those investments made in those years. This is another view, doesn't capture the entire country, but it's another estimate. You can see by region the United States is broken up by the map, and by region the investments in the last 20 years or so. And you can see that there is a trend to grow due to need, and I'll talk next about what are the drivers for that need. So what is driving the need for new transmission or investments? First of all, the country is going through a renewable penetration increase in various different states, have a renewable portfolio standard that increases the desirability as well as the building out of renewable resources. Comes with that, and a lot of those resources are located in remote areas, and we need transmission to bring them and integrate them into the current grid. Load serving and reliability meets. These are just generally, we're actually consuming more and more electricity. Certainly, since the economic crisis, the country has slowed down in general in our energy consumption and electricity consumption, but still we're gradually growing. Also the economic crisis provided more incentives for consumers to be more conservative about their consumption, so there's more energy efficiency and conservation, and it's a good thing, which means that the growth of the need has gradually decreased, the growth rate has increased, however we are still growing in our electricity power consumption. So that's what we call load serving. We call the consumer serving the consumer load and reliability. That means as that demand grows, the grid has to continue to stay very reliable, just as Laura explained and described. To stay reliable, it doesn't mean for every megawatt hour you consume, we build an extra megawatt of transmission. It means that we have to look at the entire network over and over again and looking forward to ensure that system stays reliable. So the investment's very much forward looking with anticipation of that growth and keeping the system reliable. Third driver is replacing and upgrading just as I showed you in the graph, because we have that wave in the 60s and 70s of the large bulk system investment, now we're at the cost of the upgrading and replacing a lot of that infrastructure and that's also true in our local distribution systems. And of course regulatory drivers, we are now, and we'll talk more about the power markets later with the other speakers, but now we have a competitive wholesale power market. It has additional drivers for using transmission to open up that market so that we can benefit from the competition that's involved in generation selling into the market. And transmission is basically your road, your highway, to invite those generation resources to provide electricity to the consumers. And so you can imagine if you are limited in how much highway you use, there's only so much resources can get on the highway and so if they're expensive, then you don't get the benefits of competition. But if you broaden the highway, you allow more resources to get on the highway and therefore it encourages lower cost resources to reach consumers. And of course that's also complicated by our environmental regulations and policies going forward. So not only do we need to consider the cost of the generation, but we now have to also consider various environmental impact that they use up in our economy. Okay, and then inter-regional build out, as you saw that our countries divided into regions, but across the regions there are essentially gaps around the regions where we still need to interconnect between the regions. So I think those are also opportunities and drivers for additional investments. And then the entire, the, here's the first acronym, a region transmission organization. They essentially represent the regions that we will talk more and more about it by the other speakers. There are waves of planning. So we, again, we look forward as planners, we look forward and we anticipate how much consumption there will be needed, as well as use of the system from generators. So if we anticipate that say, 5,000 megawatt of remote wind or remote solar to be added to the system, we have to anticipate them being added into the system and build a transmission to where it's needed. Importance of considering all benefits. So now I'm deep diving into some of the policy questions about transmission. One of the challenges of investing in transmission in a competitive environment is somebody has to pay for that transmission. Somebody is always gonna ask, what am I paying for? And the answer to those questions are, here are the benefits of making this investment versus another investment. So the rest, the next few slides are talking about the benefits of transmission. And one of the policy objectives of certainly of WIRE's group as well as all of us working in industries to help policymakers and planners understand those benefits associated with transmission because transmission is not just bringing power from A to B but it's supporting the entire grid and it provides expansion opportunities. It allows integration of renewable energy, et cetera. So what we have done for the WIRE's group that Jim had talked about is create a checklist for policymakers and planners. And this checklist basically says, every time you think about the next wave of investments in transmission, what do you consider are the potential benefits of that investment? Just like you invest in a highway or a bridge or any infrastructure, you want to ask yourself, what are the benefits? Why are we making this large investment and certainly transmission is a capital intensive investment and it's a long-term investment. Once you saw that slide, once you place this in the ground, they're gonna last 30, 40, 50, 60 years. They're gonna be there for a long time. So the question about what are the economic benefits associated with these investments are extremely important. So every region and all the planners and their policymakers are asking this question because if the costs exceed the benefits, then it's not worth your while to make the investment. If it costs too much and I'm not benefiting from it, I shouldn't make the investment. But the question becomes, well, what are these investments? And we have made a checklist of those investments. First, these are some terms of art what we call production cost savings. Production cost savings basically is what I tried to explain before. If you have a larger highway, you allow more resources to compete to serve your customers. So you should get a lower cost of production. So allowing a wider transmission network or a broader and open access transmission network, you allow more resources to compete to serve that customer. And that savings associated with making the transmission investments, what we call production cost savings. Next is reliability. You already heard about how important and absolutely central to grid planning is reliability. Reliability is basically nobody notices when the lights are on, but everybody notices when the light is off. And so reliability is saying we are, as an industry, do not tolerate the lights going down. And resource adequacy is just another word to say, well, how many resources do I need to make sure the lights don't go out? So you have heard probably through regular press about, well, you know, there's a hot summer day and there was all these disruptions. Thank goodness we did not turn, we didn't have rolling blackouts. Thank goodness there were some controlled, management of the grid. But in the end, we have to have enough electrons simultaneously on that grid to serve everybody's needs. So if you want your pool pump running and your TV running and your air condition running simultaneously, we have together as a grid, we have to have enough resource to serve that need, otherwise it's not just your lights go out but everybody's lights in that region goes out. Generation capacity, cost savings, this is a set of savings that says, if I can build those highways, I could then locate generation in perhaps lower cost regions. So as a society, we all benefit. Additional market benefits, this is another essentially competition, benefits associated competition. Environmental and public policy benefits. We will then, following me, there will be lots of talk about Federal Energy Regulatory Commission and how the policies are set so that transmission build out can consider state and federal policy objectives because these policy objectives essentially set the next wave of direction of our electricity grid. For example, regional renewable requirements, certainly environmental needs to retire some of the higher emitting resources and allowing lower emitting resources to be added to the grid. Employment, economic stimulus, any time that you have large capital investments, you are creating jobs for that locality and those are also benefits associated with certain build outs and operations. And then there are other very specific to a project. So a project could be creating more robustness in an area that's storm-ridden so that the local network is more reliable than the traditional planning. So this is our checklist and we have been going around and hoping that all planners and policy makers will consider all of these benefits in evaluating projects. Let's see. I wanna just very quickly talk about we have proposed through wires a planning framework that essentially goes through a very sophisticated planning process, helping planners to think about what are the potential benefits and what are the process to think about? Again, we're facing a lot of uncertainty in an industry which means when you're making large capital investments you have to think about the future but the future is uncertain so how do we make large investments given those uncertainties? So there's a lot of work from a lot of talented people in that area. Okay, I think I will pass the baton to Jeff. I apologize ahead of time but I do need to leave but I know all of these people can answer the questions that you might pose to me but if you have a quick one or two I could take one or two questions right now. If not, I will pass my baton to Jeff. Great, thank you very much. Thanks very much. Good afternoon, it's great to see so many people here. I'm gonna talk for a few minutes about the role of regulation in all of this and particularly the role of federal regulation and of course the Federal Energy Regulatory Commission but I'll also touch a little bit on state regulation as well. I always have to start with this obligatory disclaimer. In fact, I probably shouldn't have even introduced myself before but any views I express in this presentation are just my own. They don't represent the Federal Energy Regulatory Commission, any of the commissioners or the government. They're just mine. So this is kind of just an overview. I often try to provide a little bit of an overview of what I'm gonna talk about but just an idea of who's responsible for what. So you look down that left side, that's everything that is under federal regulation and almost always FERC. So wholesale sales of electricity for resale and interstate commerce, wholesale sales subject to FERC jurisdiction. Transmission of electricity and interstate commerce as we're gonna talk about today. Generally at those higher voltages like Laura talked about subject to federal jurisdiction under the Federal Power Act. Very, very, very, very, very limited transmission siting authority which we'll talk about a little bit later, extremely limited. FERC also does a few other things under the Federal Power Act, permitting of hydroelectric plants for example but outside of those hydro facilities that is the only generation planning or facilities siting authority that the commission has. The rest of that resource planning and siting authority as you'll see on the right side belongs to the states. And of course we talked a little bit about reliability of the transmission grid as well that's under federal jurisdiction. So moving over to the right, states really have control over that retail sale to end users. What you pay, PEPCO, Dominion, whomever for your power. And then again that low voltage distribution system. That is under state regulation as well. And then I talked earlier, siting of power plants, siting of transmission line, we're gonna talk about that a little later but that's under state jurisdiction almost exclusively. And then of course resource planning is very important to remember is under state jurisdiction. What types of generation utilities are gonna use to serve customers? That is all decided by state commissions. If you were to take Laura's earlier slide, I think it was slide seven, you could in theory draw a nice line in that system that diagram she had there between federal and state jurisdiction. In this theoretical environment you could do that. In the real world particularly as the grid has expanded and gotten much smarter, that line is much more difficult to draw. So when we talk about regulation of transmission, it's a pretty complex hodge podge of a number of different federal, state and local entities. And there's a number of broad sets of issues and sort of categories of issues that are regulated. Rate making, operations, so think of allocating that capacity on the transmission line out to different users, how service is scheduled, that's kind of all in the operations. Planning of expansion and upgrades which we've talked about already and I'll talk about a little bit more, siting and reliability of course. But what this is all focused on at the end of the day is ensuring a safe, reliable and economically efficient transmission grid. And that transmission grid as we've talked about a little bit already as well is really, it does a number of things obviously in addition to just getting power to you and me. And really it's become the platform for wholesale competition. Congress has had a consistent policy of supporting wholesale competition and electricity. FERC has as well and that transmission grid is really the platform for that. As Judy talked about it's the highway by which that competition happens. When you're thinking about who regulates the transmission grid, you've got one of the things you've got to take into account is who owns that particular piece of transmission equipment. And the ownership of the transmission grid is fragmented among thousands of entities. About two thirds of those entities are public utilities as defined by the Federal Power Act. Essentially investor owned companies that own and potentially operate transmission as well. Those folks are regulated by the Federal Energy Regulatory Commission. But about a third of that transmission grid is owned by publicly owned entities. Think municipal utilities owned by a city, a cooperative owned by its members. Those folks are generally not regulated by the Federal Energy Regulatory Commission subject to some exceptions about how they get their financing and other things, but generally not regulated. It's also important to remember, and we'll talk about this again a little bit later, independent regional system operators, as we've talked about earlier, operate about two thirds of the country's grid. Those independent operators are also subject to FERC jurisdiction. And if you are otherwise not subject to FERC jurisdiction but you turn your facilities over to one of these independent operators, they become subject to Federal regulation on that basis. So there's a number, it's not just FERC regulating the transmission grid, there's a number of entities. I'm gonna talk a lot about what FERC does in a minute. The Department of Energy has a role here as well, less regulatory and more policy, data collection, setting broader policy and supporting research and development. The Department of Agriculture and the Forest Service, Department of Interior, they will have some responsibility for siting on federal lands and I think some later speakers will talk about that. But so federal agencies are involved in that way too and that's very important in the West, in particular where there's a lot of federal lands. And finally, there are federally owned utilities. The Bonneville Power Administration and the Tennessee Valley Authority are two of the best examples, most known examples. They are not subject to regulation directly by FERC and they are generally subject to specific statutory schemes by which they were created. So the Northwest Power Act or the Tennessee Valley Act, I can't remember the exact name of it, govern their operations. And so certainly there's a lot of interaction between FERC regulation and what they do, but they are not regulated directly by FERC. So let's get into a little more of the specifics of what FERC does. Under the Federal Power Act, section 205 of the Federal Power Act, FERC regulates the rates, terms, and conditions of transmission service. So what does that mean? That's everything from obviously what folks are paying to use the grid, what owners of the grid are charging for that use. Down to some other things we'll talk about in a minute, but terms and conditions of service, how they provide service to others, under what terms, et cetera, et cetera. Raymaking is obviously sort of the bread and butter of what a regulatory agency does in the energy, in the electricity arena. And the basic statutory standard by which FERC judges rates is whether they are just and reasonable. What does that mean, right? Well, it's a pretty malleable standard that's subject to a lot of interpretation over time, but it's generally been driven by the embedded cost. What did it cost to develop that system? We call it cost-based rate making. And generally what happens is a utility establishes a revenue requirement. What money does it need to earn to both earn back its investment and earn a rate of return? And so if you try to break that down real simply, it turns into those four boxes on the bottom. The expenses to continue to operate and maintain that particular asset, the return on the investment, which I'll talk about in a minute, and of course the return of the investment. What did it cost you to build that facility? You're allowed to cover a certain amount of that cost every year in rates over some useful life of the facility, 20, 30, maybe 40 years. That return on piece is particularly important and is becoming more important recently. That's the return on equity. It's essentially, you could think about it as the profit that the utility is allowed to earn in return for building this facility and making it available for public use. Essentially it's based on what do you need to attract capital from investors and to cover service on debt or money that you borrowed in order to build that facility. And there's no right answer. That just and reasonable standard is pretty broad and there's a number of rates that can be just and reasonable. There's no single right answer and it's really a range. It's determined by complex financial analysis. It looks at things like bond yields, treasury yields, stock prices generally in the industry, comparison of one utility to another, comparison of utilities to other similar industries, and it's become increasingly important as financial conditions have changed so dramatically in the country over the last seven or eight years. This has become a lot harder to do and so there's a number of pending cases before FERC addressing that issue right now. Moving sort of to that terms and conditions of service piece and away from ray making, FERC authority over this is really based around a principle of open access. And it's a key part, this open access principle I'm gonna talk about is a key part of the overall effort by Congress as well as the commission to promote wholesale competition in electricity. And essentially what the commission decided in a landmark order called order number 888 in 1996 is that it needed to open up this grid to competition under fair and reasonable terms. And the basic principle of that is that you've gotta treat others as you treat yourself. In 1996 when that was passed, pretty much the entire transmission grid was owned and operated by vertically integrated investor owned utilities. And so they could control the access to those grids, controlled access to that platform to competition, they could favor their own generation. And so the commission adopted rules to ensure non-discriminatory access by generators that were seeking to access the market. It created open access rules and principles that every jurisdictional entity has to follow. And in fact, they were required to file a generic tariff that governed their operations and that dictates how they were going to provide open access to anyone who wants access to their lines. But again, just think about it as you have to treat others as you treat yourself. And in fact, utilities that own transmission have to take service under that tariff just like every other customer. Open access has evolved over the years and what we think of as key to open access. Originally it was terms and conditions of buying service on that transmission grid. Eventually it came to include interconnection rules. What rules and charges can a utility place on a generator for the privilege of interconnecting to the grid. And more recently as we'll talk about as Judy talked about earlier and I'll talk about it in a minute, it's come to incorporate transmission planning. What are the terms by which utilities go and plan their transmission grids? That's really kind of just another principle of open access as well. FERC also adopts and enforces reliability standards that NERC as Laura talked about earlier creates. That's a unique and special provision of the Federal Power Act. It's section 215 of the Federal Power Act. There's an industry stakeholder process that's conducted by NERC. NERC is considered the Electric Reliability Organization under that law. FERC approves or disapproves those standards but does not write them. NERC writes those standards through an industry stakeholder process. And I believe that'll be the subject of a future briefing that Jim's working on. We talked a little about regional operators. RTOs and ISOs, you'll hear a lot about them. They cover two-thirds of the country, PJMs, the RTO that covers this region. And they were created, they're voluntary. FERC does not require them but has strongly encouraged them since order 888, particularly since order number 2000. And really what they do is ensure independent operation of the grid. So I talked earlier about the grid used to be largely operated by vertically integrated investor-owned utilities who also held the generation and control access. Well, one way that you can kind of break down that wall is to have the grid operated by an independent third party that's not affiliated or associated in any way with any participant in the market. And so FERC encouraged those over the years to facilitate more competition. And as I said, they've been created in about two-thirds of the country, East, Northeast, Midwest, and California principally. If you were to look at a map and I keep forgetting to put the map in my slides. But they do a number of things as this slide talks about. They do all the planning and operation of the grid. Those utilities still own the grid assets but they turn the entirety of the operational control over to that RTO or ISO. And after order 2000, those entities not only operated the grid, they began to operate wholesale markets for electricity as well and conducted that security constrained economic dispatch that Laura talked about on a regional level based on bids by generators to ensure that the most economic resources were being used to satisfy demand. And one of the things that we talked about earlier is that those markets are very, very transparent so they've provided a great deal of transparency into what generators are being used to satisfy demand and what their costs are over time. And that's provided a lot of transparency to know where congestion is on the grid and other things. And we could talk about those details as we move on. So I'm gonna talk a little bit about Order 1000 to close out, which a lot of you've probably heard about. It's FERC's recent landmark rulemaking, transmission planning and cost allocation. Order 888, as I mentioned, was kind of that first foray into open access. Required that, as I mentioned before, that the grid be open to access by third party generators and others. Required utilities to unbundle their service. Previously, there was a strictly a bundled rate. You saw one rate, it included transmission, distribution and the wholesale energy component. That was unbundled after Order 88 and all stated separately. Order 890 was an update to Order 888 that was issued in 2007. And that was when FERC first decided that the open access requirements in the course of updating those required that there be more transparency into how the grid was planned so that customers, wholesale customers could have some input and insight into how the grid is planned and how future expansions would be decided, where they would go, where they're needed. And so in Order 890, FERC adopted local and regional planning requirements. Order 1000 in large measure updated those based on a few years of experience under Order 890 and just the continued changing nature of the grid in the last 10 years. The first set of requirements under Order 1000 is that jurisdictional, FERC jurisdictional utilities plan on a regional basis with their neighbors. So if you think historically about the grid, it was originally planned at a very local level. Individual, vertically integrated investor owned utilities planning to meet their own needs, get their own generation to their own loads. Over time, that has expanded and so they're relying on third party generators, independent generators, they're relying on resources that are further and further away from their own loads. And that's required a broader look at transmission planning. The commissions Order 890 required that utilities have an in depth local planning process, have how that process is conducted, where there are opportunities for stakeholders, customers to participate in that process laid out in their tariffs that are on file with the commission and also that they publish a local transmission plan. 890 also required some kind of softer regional planning requirements and what Order 1000 did was make those planning requirements more explicit. So regional transmission planning, the terms by which that is done, all have to be on a file tariff with FERC and they have to result in a plan, in a published regional transmission plan that identifies projects that can meet regional needs on a more cost, I just have to get these words right, on a more efficient or cost effective basis than those locally planned alternatives. So it's a requirement that you get with your neighbors and figure out what the most economic solution is to your regional transmission needs. We talked a little bit about this already, but another key area that FERC addressed in Order 1000 was planning for public policy requirements. Those RPS standards that Judy talked about driving the need for new transmission is the best example of a public policy requirement that FERC required that utilities plan for. What the commission had heard over time was that there really wasn't a home in the planning processes that are conducted for those kinds of transmission needs. There's obviously a home for reliability-based transmission planning that's been done since the dawn of time. There's a home for economic transmission planning, which is to try to resolve constraints, remove more economic power to loads. Those all had a home, but planning for accessing resources to satisfy a renewable portfolio standard, for example, or to address environmental regulations was not something that had a neat fit into the transition planning process. And so FERC required that there be rules in place and in tariffs that would establish processes to plan for those kind of transmission needs. There were also a set of inter-regional planning requirements, and that's really getting beyond your region. So the example of a region, let's call New England a region, six states, there are a region for planning purposes under Order 1000. There are also inter-regional requirements in that rule that also require them to get with their neighboring regions, so New York, PJM, anyone they're interconnected to on an inter-regional basis to take a look at those regional plans and figure out if there are more cost effective or efficient solutions at the inter-regional level that could be built to replace those. One of the drivers of that is really one of the places where there's still a lot of economic efficiency in the grid is those what we call seams between regions. So we've had, RTOs have been built, they've been expanded, they've captured a great deal of efficiency in the system, but those seams between the two markets are where we lose some of those efficiencies, and so inter-regional planning can really help with that, and so the commission adopted some requirements in that regard as well. In terms of cost allocation, obviously this is where the rubber meets the road, right? Who pays for that transmission once you build it? This is the hardest part, in my opinion, of transmission is deciding who pays, how much they pay, and when they pay. And Order 1000 tried to address this problem by adopting regional cost allocation requirements for those regional planning processes. And essentially what it requires is that each region have on file a method for allocating the costs of new regional transmission projects. One of the problems that FERC saw was that there was no upfront certainty about how costs would be shared for transmission facilities once they were built, and so the idea here is to get that upfront certainty, to provide some measure of certainty to investors and developers of transmission. As with much of Order 1000, FERC did not dictate any one size fits all approach to cost allocation. Instead it laid out six relatively broad principles that any regional cost allocation method had to satisfy, and then regions came in on compliance with a method that they believed would satisfy those. And the principles, we could go into them in detail, but sort of the basic requirement of those principles is that those who benefit from a transmission facility must share in their costs, and those who do not benefit may not be assigned any costs. This is what the Seventh Circuit Court of Appeals is called the Roughly Commencer at Standard. Costs have to be allocated roughly commensurate with benefits. It doesn't have to be dollar for dollar. You don't have to pay one dollar for every dollar of benefit you get, but cost allocation methods have to roughly approximate the benefits that individual pieces of the system, classes of customers, et cetera, received from that transmission line. As Judy talked about, there's a lot of benefits to transmission. Some are easier to quantify than others, and that's one of the developing areas that the commission's still looking at, that the industry's still looking at, is how do you quantify those benefits? Because the better you can quantify those benefits, the better you can get agreement on them, the easier cost allocation becomes. There were also a set of non-income and transmission developer reforms. Essentially what these were tried to do is break down barriers to competition from non-traditional entities who wanna come in and build transmission. Transmission's historically been built by the traditional utilities that have served load for decades. They've traditionally developed footprints by which they developed transmission, largely growing out of their service territories, their retail service territories. And many tariffs around the country had in place barriers to allow non-traditional new transmission developers, we call them non-incumbents, from participating in that process. So the commission required that certain of these barriers be broken down, particularly a set of tariff requirements called rights of first refusal, which essentially gave existing transmission owners the absolute right to build facilities in their region. The commission required many reforms to get at this area and again to promote competition and transmission development with the idea that more transmission, more competition in bringing solutions to the regional planning process will result in more cost efficient and effective alternatives. So FERC is right now in the middle of a pretty deep compliance process on order 1,000. All compliance filings have been made, they were made over the course of about 12 to 18 months since the rule was issued in 2011. The commission has issued initial rulings, they were filed in two batches, regional, complying with the regional requirements of the rule, the regional planning requirements was one set and the interregional requirements was a second set. So the commission has issued orders on all of the regional filings that have been made, initial orders, those orders all required the regions in some measure to do some more work and so regions have filed a second round of compliance filings, those are pending before the commission now and interregional compliance filings have been made as well, the commission has yet to act on initial orders there and so that'll be one of the next things the commission does as well is begin to rule on those interregional compliance filings. One last thing I'll note on order 1,000 last Thursday, the DC Circuit Court of Appeals heard oral argument on challenges to order 1,000 from a number of entities. There were kind of four broad sets of challenges that the court is looking at. The commission's authority under the Federal Power Act to establish rules or requirements for transmission planning is at issue. Obviously the cost allocation determinations were controversial and so that's at issue in the appeal as well. The role of states in these processes and the jurisdictional lines between the federal and state government in these planning processes is at issue and finally those non-incumbent developer reforms that I talked about are at issue as well. And likely the court will rule this, I believe this fall. Just real quick, FERC has a lot of other authorities that touch indirectly on the transmission grid. Obviously FERC monitors energy markets and pursues market manipulation where it finds it. We also have authority to approve mergers and acquisitions made by public utilities, overseas issuances of securities by public utilities. We resolved disputes among market participants. Entities can file complaints with us if they believe something is not just and reasonable. And then again, we have that very limited backstop siting authority that I talked about earlier. And I think that'll be discussed a little bit later but it's essentially a role behind the states who have primary role and there's a number of hurdles to FERC actually exercising that and those hurdles have gotten much higher over the years. Lastly, I'll let you read this on your own because I think I'm running out of time but this is just a little more information on some of the things that state commissions do as well. As I mentioned, as the grid has become more interconnected and become much bigger, that line between federal and state jurisdiction has gotten a little bit more difficult to determine. And so at FERC we constantly work with state regulators and vice versa to try to keep lines of communication open and avoid jurisdictional disputes where we can but sometimes they still happen. So that's a quick rundown and I'll be happy to answer questions, thanks. So we've been going at it for a little bit more than an hour now and I'm certainly see some heavy eyelids out there. So if you all want to stand up and stretch for a quick minute, that's perfectly fine. No takers? Anybody? So my name is Kevin Reeves. I'm a managing director with AEP and AEP is a large investor owned company. We're based in Columbus, Ohio. We serve approximately five million customers in 11 states and so that's the commercial for AEP. So we will move on. So regional transmission organizations and independent system operators manage organized markets throughout the country. The RTOs and ISOs were created by regional stakeholders in response to FERC Order 888 which was issued in 1996 and FERC Order 2000 which was issued in 2000. So never let it be said that FERC doesn't have a sense of humor. Among the many functions of the RTOs they exist to do the following functions that are outlined on the slide and I won't insult your intelligence by reading the slide to you but I will give you a couple minutes to read it. All right, so the grid in North America consists of three interconnections and they operate largely independent of one another. So that means that the ability to move large scale amounts of power between each interconnection is largely limited. So as an earlier speaker said there's a west interconnection which is essentially the area west of the Rocky Mountains. There's an east interconnection which is essentially the area east of the Rocky Mountains and then Texas or at least 80% of Texas is an entity unto itself. In addition to the eight NERC regions that are shown in the slide, I'm sorry, in addition to the three interconnections there are eight NERC regions and the NERC regions are charged with maintaining reliability in the region and they don't operate markets. It's important to distinguish between NERC regions and RTOs. So RTOs are voluntary. NERC regions are mandatory and NERC regions predate the formation of RTOs. So because RTOs are voluntary, memberships can shift over time. So for example, there's a utility not far from where we are called First Energy. First Energy used to be part of MISO and they decided they didn't like MISO so then they moved to PJM and that's perfectly fine because membership in RTOs is voluntary. Excuse me, the NERC regions though are standard or static and so you take the state of Michigan for example. Most of Michigan's geography is actually located within MISO but the NERC region that Michigan is assigned to is actually covers most of the geography of PJM. So there can be a little bit of overlap just due to some of the idiosyncrasies of kind of how those regions were set up. So as you can see from this map, there are significant parts of North America that are not part of an RTO and this speaks to the voluntary nature of RTOs where it's clear that in many parts of the country and I will leave it up to you to draw your conclusions as to why but in many parts of the country, it's clear that the benefits of joining an RTO are not perceived to be worth the costs, whatever those costs may be. So whatever your goal is from a policy standpoint, whether you want to increase the market share of renewable energy resources such as wind and solar, if you want to increase our country's energy security by developing shale plays in the continental United States or if you want to ensure grid stability in the wake of an estimated 30 to 40,000 megawatts of coal retirements, a robust transmission system and significant transmission investment is required to achieve any and all of these objectives. So if you look across the different RTOs within the country, you'll find that while they all perform similar functions, they each go about their business in very different ways. For example, to take two very different RTOs, ERCOT and PJM, power plants and ERCOT only get paid when they generate electricity. You know, no generation of electricity, no revenue. In PJM, power plants receive what's called a capacity payment from the RTO for their ability to generate electricity when needed in addition to the revenue that they receive when they generate electricity. RTOs allow for more effective grid management by providing a central clearing house for transmission and generation transactions. And they also allocate transmission rights in managed day ahead and real time markets. However, market participants are still free to negotiate bilateral contracts. That's just an arms link contract from party A to party B with one another as their business needs dictate. And as I've mentioned before, participation in RTOs is voluntary. However, FERC provides incentives to encourage membership in RTOs. So the jurisdiction of FERC is limited only to public utilities or investor-owned utilities like the one I work for, American Electric Power. Fully one-third of transmission within the United States is not subject to FERC jurisdiction. Transmission facilities that are owned by public power entities such as Bonneville Power Administration, Tennessee Valley Authority, most major cooperatives in most of the utilities within Texas are not regulated by FERC. Once you get outside of the realm of RTOs and ISOs, FERC's ability to promote the coordinated enlargement of the interconnected grid is significantly weaker than it is within the RTOs and ISOs because FERC policies do not apply to all the owners of that interconnected system. So with the Energy Policy Act of 2005, FERC was tasked with overseeing the reliability of the nation's electric transmission grid as if they didn't already have enough to do. One of the ways that FERC has gone about trying to ensure a more robust transmission system is through its insistence on a regional approach to transmission planning. Regional transmission planning is one of the mechanisms through which relatively remote resources such as a wind generation facility in Iowa gets to serve distant load in Minneapolis, St. Paul, or Chicago, for example. So understanding the regional transmission processes integral to understanding how transmission projects are analyzed, selected, and paid for. So a potential project is submitted to the RTO for modeling to evaluate the impact on the regional transmission system to include the project's cost and benefits. So if the data shows that the project has been official based on the RTO's established cost-benefit criteria, it's accepted or it's approved. Projects that are approved by the RTO are eligible for cost recovery according to each RTO's established methodology. So each RTO is free to establish its own methodology for cost recovery. Projects may proceed outside of the RTO planning process, but cost recovery through the RTO would in that case not be available. I wanna be clear and draw a distinction between cost allocation and cost recovery. Cost recovery for regional transmission projects is determined by FERC in accordance with its transmission formula rates. Cost allocation is the methodology to assign cost to rate payers. For example, in SPP, for transmission projects that are less than 100 kV, and forgive me for using the jar, kV is just a kilovolt, the costs are allocated entirely to load to the load in the zone where the transmission is built. For projects between 100 and 300 kV, costs are allocated one third to the load in the zone and two thirds of that cost is socialized across all SPP rate payers. And then for projects above 300 kV, 100% of the costs are socialized to SPP rate payers. Each RTO approaches cost allocation in a slightly different manner, each in its own way trying to strike a proper balance of cost allocation. So if you looked at a transmission map from the not too distant past, most of the extra high voltage lines, say 345 kV and above, would be clustered along the lines of where population is centered, along the coasts, pockets of the Midwest and Texas. And that's because historically individual utilities built transmission to meet their individual needs only without really taking into consideration any regional requirements. The transmission map of the not too distant future will have extra high voltage transmission lines in places they never would have been otherwise. West Texas, SPP, the upper grade planes portion of MISO. And this is due in large part to the regional transmission planning process. This regional planning process allows for the large scale integration of renewable energy into our generation resource portfolio. It will also allow for continued grid reliability as natural gas fired generation ultimately displaces a significant portion of our coal fired generation. Regional planning and related cost allocations is expanding beyond RTOs and ISOs as a result of FERC order 1000. Entities that are not in RTOs will have to join a transmission planning region. So kind of an RTO light. And each planning region has to include more than one utility. Certainty regarding cost allocation and cost recovery of transmission investments are critical for grid expansion. Not surprisingly, cost allocation is extremely challenging given the complex and highly interconnected nature of the bulk power system and the existing regulatory framework. Not to mention that merchant transmission development and other opportunities which can transcend regions. So over the course of this presentation, I've mentioned both bilateral and organized markets and I would be remiss if I didn't spend a minute to at least give you a better sense of each. A bilateral contract is simply, as I mentioned earlier, a contract where a buyer and seller negotiate directly and sign a two-party agreement to trade electric power. Outside of the RTOs, and that's mainly the Southeast, the Upper Great Plains and the West, that's not including California, wholesale power trades only occur through bilateral contracts because those are the areas that don't have RTOs. Now, within RTOs and ISOs, there are both bilateral markets and organized markets that pool all sellers and buyers. In most RTOs, this organized market entails a market clearing price for energy that changes every 15 minutes based on the supply and demand balance at that time. In the RTOs, first oversight of transmission is stronger because all transmission owners follow the RTO's transmission policies which have been approved by the commission. Regional transmission planning is without a doubt challenging but compared to implementing a regional transmission plan, the planning may be the easy part. Siting of transmission lines is a long arduous process that is likely to have very strong localized opposition. And while the Energy Policy Act of 2005 gave FERC limited, limited siting authority in DOE designated areas, the fact of the matter is that the siting of transmission lines is still very much a local issue that comes with a myriad of potential obstacles which have to be successfully navigated. The other major obstacle to carrying out a regional transmission plan is determining who's gonna pay for it. FERC Order 1000 established six key principles of regional and interregional cost allocation. And these principles are the cost allocation must be roughly commensurate with estimated benefits. No costs should be allocated to those who receive no benefit. Costs can only be assigned to regions where the facility is located. There has to be a transparent and documented process for cost allocation. Different cost allocation methodologies are perfectly fine for different types of facilities. And if a cost benefit ratio is used, that cost benefit ratio should not exceed 1.25 to one. Interregional transmission planning between RTOs is the next frontier and it's probably a subject for another day. So I think with that, I will just say thank you very much. AP looks forward to the process continuing to work with stakeholders and for going forward. Thank you very much. Not to take anything away from our fellow speakers. If we don't cite the transmission line, whatever they have to say is meaningless because if you don't have a line to cite, we don't have to worry about the power going through the line. Site selection is, I'd like to say it's a science but it's really not, it's an odd. And it's putting together a bunch of different factors involving the human and the built environment and the human environment and the ecological environment. And these things need to be blended along with the engineering factors and the costs. And there is no such thing as a one size shoe fits all. Each siting study, each particular area will have its own significance in terms of the local physiography, the local environment and the population. And this is becoming more and more important in terms of siting. We've talked about the reasons in terms of trying to connect renewables, new renewables. These are generally involving longer lines, lines that are as much as six, 700 miles long from major wind centers or solar centers. Also reliability in terms of trying to solve reliability problems by additional transmission reinforcement of the grid involves also siting. So what are we doing in site selection? We're looking at trying to connect a series of points, usually point A to point B. And what we're doing is we want to understand what's happening in that area. We want to identify, are there any opportunities that would simplify the siting? Could we parallel existing facilities such as existing transmission lines or roadways or gas pipelines or highways or whatever from that point of view? What kind of alternatives do exist out there in that area to get from point A to point B? What are the impacts of each of those alternatives? And from that, we would go to identify a proposed route. Now, I put this up there and on the Y axis going up and down is the amount of relative effort and on the X axis across the bottom is time. And you can see all these different areas that are involved in the whole transmission project. Route selection, you see the term NEPA up there, National Environmental Policy Act, that would be involved if we're crossing or affecting federal lands or federal permitting, NEPA could be involved, National Environmental Policy Act, right away actually acquiring the land. NEPA in terms of the actual permitting and we look at NEPA and part of the siting because what we try to do is we try to simplify our siting approach. We try to avoid federal lands. So that is part of the actual site selection process. But when we get into the permitting, if we're involved in that, we have to deal with NEPA if we're on federal lands or again if we're involved in a federal permitting action and Dan will talk more about that. Then we have the engineering aspects, the construction management aspects. Can we get into the transmission to build it? One of the keys is access roads. That turns out to be a real major consideration when you're building new transmission in what I would call green areas where you have no prior access or no prior right of ways existing. Can you build the access roads? Can you get around that bend? Can you move the equipment in? Public involvement. You notice how high that goes at the beginning and that really varies from project to project in terms of how people consider and how they work in terms of public involvement. Are we out in the rural areas? Are we more towards an urban area? One of the things to think about is this whole closing of coal plants. Coal plants that were built tens of years ago were built in urban environments. With the closing of these coal plants, we now have to redo the transmission system to bring in power to those areas. So now we're talking about transmission going into urbanized areas, which involves a lot in terms of human impact and public involvement is a key, I think in terms of that particular process. The yellow line stands for the completion of a siting study and I'll just give you some ranges. I've seen siting studies six months to two and three years. The green line is actual submission to a State Public Utility Commission and generally the period between the yellow and the green takes about a year, six months to a year to prepare those documents to a year and a half. Depending if you're talking about possibly multiple states. And then the blue line represents authorization by a State Public Utility Commission to go forward with construction. And that's probably a year to two years as well. But that doesn't mean you have your permits. You first still also have to get your permits through this process and Dan, as I said, we'll talk about that. The red line on the right is the energizing the line. So if you add this all up, probably one of the fastest projects I ever worked on was a project here that went from Southwest Pennsylvania through West Virginia into Virginia called the Trail Project that was completed several years ago. And we completed that project in three months on to five, four months, four years, nine months. But at the same time there've been other projects one down in Virginia, West Virginia to Virginia that AEP worked on that I think was about 14 years. So there's quite a variation in terms of the timeframe. So the routing process. Initially we developed very broad level routing guidelines. We want to avoid national parks. We want to avoid urbanized areas. And as we go through the process we're gonna develop more detailed guidelines as we go through. And by the way, I would mention I normally give a two day course on sighting which we're converting to 10 minutes. So just understand that part. But we're developing specific alignments and you can see the spaghetti, kind of the spaghetti lines through there. And we're actually developing potential routes and from these potential routes we'll actually develop what we call alternative routes which any one of which could solve the problem. But then we look in terms of which would be the best that would meet all the different criteria involved. This is one of the issues particularly for Backeastern I threw this up. This is a partial map of the Appalachian Trail that runs from Maine to Georgia. 1400 miles along controlled by the national park system. If you have a viewer utility or you want to build a transmission line in Eastern United States and you want to get over to the Eastern part of your state you will cross the Appalachian Trail which triggers a National Environmental Policy Act. Now on a sighting point of view so it's really difficult to avoid it for utilities such as Dominion or New Jersey Public Service Electric and Gas or Pennsylvania Power and Light or other utilities to avoid it. But what we try to do when we're sighting we try to take a look at existing crossings. What existing crossings are the Appalachian Trail there? Are there older crossings that such like for example there's a project up in New Jersey that was in the news quite a bit and actually is in construction now called Susquehanna Roslin, about 150 mile project. And that's actually crossing the Delaware Water Gap National Recreation Area. There we identified a crossing that was 92 years old an existing transmission line, 92 years old that needs to be rebuilt no matter what for reliability as a crossing point. However, there's a case in point that where that project because of we needed an existing right away existed but for nine tenths of a mile we needed another 50 foot of right away. We got pushed into the National Environmental Policy Act and had an EIS had an environmental impact statement had to be created to make a long story short that project's running about eight years and it should be completed this next year. In reality, if we didn't get pushed into an into NEPA or into an EIS we would have been completed within five years. We already had state approvals and permits and everything else would have been completed. And I'm raising this to give you an idea of the timing and how we approach siting for things like this where you can avoid it. And what we try to do is to avoid these kinds of things that would lead to NEPA actions that would lead to increased environmental impact, et cetera. So these are just a list of guidelines and it's in the handout that you have so I'm not gonna bore you with it but generally we look at large constraints at a regional level and then we start honing in with smaller constraints. So when we actually get on the ground and we actually look for houses we wanna stay away from houses we wanna stay away from schools and that's our intention to try and do those things. So actually this is a preference for siting and how we look in terms of how we want to site our lines. Our first preference is to upgrade or double-circuit an existing line transmission line. Secondly, we would try to parallel an existing line. Thirdly, we try to look at paralleling roads, railroads, and pipelines. And our last alternative is trying to develop what we call Greenfield solutions where there are no other linear features that we can work with and to ameliorate the impact. Now here's an example out in West Virginia this is actually the trail project and you can see the existing line in this area we paralleled and the reason I put this up is I mean there's not much out here but imagine if you were in more of an area that had much more people and they were living next to this existing transmission line and then all of a sudden you go to build it and they've lost the part of their backyard because most people consider these things part of their backyard. So paralleling an existing transmission line is not necessarily a panacea. I think it really depends in terms of what else is there and the possible human impact. The other key part of this is eminent domain. If you can acquire the property, everything else is meaningless and that kind of varies from state to state. You need to get the public utility commission approval before you can go forward with an eminent domain. There are some states such as Delaware that do not have eminent domain. So you have to buy the property and if you can't buy the property you can't build a project. And at that point I think it's time to turn it over to Permanent. Great, thanks a lot everybody for sticking with us and in the interest of trying to maintain some time for questions I'll try and be as brief as I can. My name is Dan Bielin. I'm the director of electric transmission at E&E and like Jack do a lot of siting and permitting work and so I appreciate the opportunity to share our experience with you today. So what I plan to talk through today a lot of it's already been said so I'll be able to move through a lot of what I was gonna talk about but really what I'll focus on is regulatory authority surrounding permitting and then what that translates into in terms of challenges and opportunities with a particular focus on recent trends and developments. So background a lot of this has already been talked about. There are a lot of key drivers to building new transmission and one of the evolving challenges for permitting that infrastructure is the lack of a continuous federal authority. This could be contrasted with the natural gas pipeline infrastructure network that has the natural gas act to use as a permitting framework and that's a very consistent known entity. It's a known regulatory environment that pipelines can move through. There's no equivalent of that in electric transmission. So what that translates into at the end of the day is that as time has gone on, as we've come into the present, it's taken more and more time to permit transmission lines, particularly the large interstate projects that Jack was referring to. So in getting to authority, a lot of this has been talked about but really at the federal level, the authority is really piecemeal. It's based on what's called a federal nexus so that and that's determined on a project by project basis. So if your project proposes across federal lands, then that would involve resource management agencies and I have a list of some of the federal nexus up there along with relevant agencies. But one of the key things to also note is that federal authority in terms of permitting does not translate necessarily into citing authority. So for example, if there were an international border crossing, the Department of Energy has federal authority to issue a presidential permit, but they have no authority to cite a transmission line. And like Jeff talked about, a lot of that citing authority occurs at the state. But even at the state level, that's a challenge because as you can see with this map here, the areas in blue are states with varying levels of citing authority. So there are roughly 75 states with some type of citing authority or process but they're all different and the states in white are areas with no citing process. So if you're proposing a line in Colorado, you're gonna be doing your permitting at a county by county level. And so what that results in is basically a very fragmented, disjointed regulatory environment that is just different on every project. And so that disjointed process really is the result of having to deal with permitting at a local state and federal level. And so even though it is complex in that environment, the actual permitting itself is a very simple process. Whether you're permitting at the local level, state or federal level, the permitting process is very straightforward. It's essentially just a few steps. Pre-application process, and a lot of that is what Jack talked about with citing public involvement, those types of activities. And then developer or utility will file an application and agency will review it and make a decision. What's the problem? Easy. Well, it's an easy process but it takes an extraordinary amount of time and has a large degree of complexity to it. And that complexity really is one of the key challenges that there is a lack of standardization and essentially regulatory certainty. Some of the other challenges to permitting I've listed up there, but a big one is agency resources and staffing. And the agencies need to review these applications and with budget cuts and staffing levels that can be quite a challenge. The technical complexity of the subject matter is also a key component of that. But at the end of the day, what these challenges and complexities translate into is impact on schedule. And so the more challenges you come up against and the more difficulties you have, the longer it's going to take to permit your line. So Jack had referred to Susquehanna Roseland. I have a sample project schedule up here for the Gateway West project. And it's fairly similar. And I'll just use it as a case study here. The Gateway West project is one of the large high-voltage Western transmission projects that runs roughly 1,000 miles across three Western states. And it has been formally fast-tracked through the Department of Energy's Rapid Response Transmission Team, as Jack's project was too. That, and I will give credit that that fast-tracking procedure has helped. But even with that, it still took over six years through the National Environmental Policy Act, which is not a permitting process. It's a prelude to the permitting process. So getting through NEPA is the precursor to going through all of your federal permits. And then it's also, they have another five years for state and local permitting. So really what you're talking about for these large multi-state projects is a five to 10-year timeframe, which is significant. But it's not all doom and gloom. There are certainly opportunities that have been evolving as of late. And most of those opportunities sent around the early stages of that permitting process in the pre-filing approach. And really the focus of efforts has been in public involvement, stakeholder outreach, agency consultation, basically getting out to the public earlier in the process. And that has been facilitated also by social media and internet. But really I think the federal agencies have caught on to this and have instituted several examples of streamlining initiatives, which I'd like to just talk about quickly here. So the recent, sort of in the recent past, the fast-tracked or streamlining initiatives began in 2009 with the Department of Interior under Secretary Salazar. They fast-tracked several projects, both generation and transmission, across federal lands. And during that time, there was a nine-agency memorandum of understanding signed among the various federal agencies. And that MOU gave rise to the rapid response transmission team. And the Department of Energy should be given a lot of credit in this realm for stepping up to the plate and providing a lot of leadership through the rapid response transmission team and other federal processes. Through DOE's guidance, they have also floated the IIP process, what's called the Integrated Interagency Pre-Application Process. And essentially what the Department of Energy through these frameworks is trying to do is stitch together this disjointed framework. And it's certainly a challenge, but those are the recent developments and those have been bolstered by in a presidential executive order along with the memorandum. And it should also be noted that these fast-tracking initiatives are not just at the federal level, they're also occurring in California and New York to the places that need fast-tracking. But the governor's office in New York established an energy highway initiative, and last year as part of that initiative formally announced a expedited permitting process. So all of these initiatives are looking to try, recognize the challenges with the current state of affairs in permitting and are doing what they can. But really at the end of the day, they're limited by federal authority. And that's, so they're doing the best they can with what authority they do have, but that's the limiting factor. And so that's really gonna be my conclusion here is that it is the lack of authority, that's the primary bottleneck. And what that translates into is just a longer time to get projects permitted. And so absent of that authority, there are opportunities in this prefiling process, but there's certainly a lot of work to do. So thanks a lot for Baron with us today. You have been a fabulous audience. I'm pleased that most of you are still here, and we will be happy to take your questions. I think you get the message here that there are some overall themes about how the grid works on a regional basis. The fact is that it is largely in interstate commerce and subject to federal regulation, except for some certain major things, including citing, as citing is very complicated. It doesn't just translate into time, it translates into cost, and that translates into rates. And one of the resistance that we, areas of resistance we get to transmission development is who's going to pay? And what's the impact going to be on rates? The only thing I would suggest is that we try to put this all in a longer term perspective as the economy changes, as the electric industry changes. We're talking about putting facilities in the ground that are going to serve the public for the next to maybe three generations of people. That means benefits to the economy for a long period of time, benefits to the environment in terms of access to new sources of energy. But it is going to be price sensitive. I mean, there's no getting around it, but the benefits are long-term, and we look at this long-term transmission is really a great bargain. Questions for this Auguste panel? Yes, sir. Terry Hill with a passing pass. This is mind-boggling to me, but you don't need to sleep. But, and it's basically, I think you're talking about what he is. But if you look at it from the customer point of view, who's looking at it from a net zero energy house perspective? And a micro DC micro grid in a city block. What impact does that thinking have on this whole magical system? So I can talk to the efforts, and it's coming from a lot of different places. I'm based in California, so a lot of this is coming through the California Energy Commission rates and incentives through various public utilities commission, and it's not just California. There's New England, all kinds of states, or first of all, promoting energy efficiency. So that's the first piece of it, is how tight can you make your energy usage? And if you look at some statistics, let me pick on the gas industry as well. Southern California gas, they have no load growth. They are that efficient, and then you look at the developments in LED technology. I mean, imagine all those light bulbs that cannot be replaced, right? So there's all of this efficiency coming from changes in technology, from promoting state by state, how much more efficient can you be? The next thing we're seeing is, how do we leverage things like the customer micro grids, like customer assets? And so if you look at specifically the state of California, they have a loading order, and they say, okay, energy efficiency is number one. How do we help customers deploy their resources effectively number two? Renewables number three, and then the more traditional fossil fuels would be sort of number four. And so that's done as a planning region, it's done as a state, but it's not just California that has these kinds of initiatives. Then I'm gonna talk about the micro grids, because that's coming from two places. Micro grid development is coming, first of all, from the economies of being able to have behind the meter generation. So if you look at UC San Diego, they're like a laboratory, a living laboratory of cool things that you can do on a campus. They have fuel cells, they have solar panels, they have chiller tanks, they have all kinds of stuff that they're using more effectively, more efficiently, and it's become a living laboratory. The other piece that's happening is that it's coming from the need for resiliency. And so that's the next driver, is to say, I can't guarantee that nothing will ever happen to my grid. I can't afford to plan for 12, 10, so the worst thing that could happen. How do I make sure that locally, I'm in really good shape? And so you see a lot of these initiatives coming through the Department of Defense, for example. The Navy in San Diego is looking at some of these things. And then also where you have the storm disasters, people aren't looking to say, how can I do business the way I used to? They're saying, how can I do business much more rigorously? So I'm using not only the ability to stand alone when I need to, but I'm using a lot more smart technology. And so it's not only the smart technology in the microgrid, but for example, smart wire grid, their devices go right up on the transmission line to help you manage the system in real time, more smart in a way that's more smart. So it's coming from the local initiatives, the ability to have technology. And then the other piece I would say are the computer algorithms to handle it. We're becoming more and more comfortable with the fact that we are moving to an internet of things. We are gonna be big data. And so we don't have the command and control the way we used to. And it's the ability to leverage that and have the computer algorithms that can handle it. It's all coming together slowly, but very definitely. Wow, I didn't answer. That's great. I appreciate it. Can I add one thing, Jim? Sure. I think the point to think about is they all still have to be connected to the grid as backup. And I'll just point that out. Yeah. We think, I think, wires is looking at this very issue. And we think that there's a lot about the high-voltage system and the bulk power system that's very compatible with the development of these local resources that you're talking about. This question may overlap a great deal, but distributed generation, I guess. And I was struck by the highway analogy that people were using so that you get too much traffic and so you have to build a bigger highway. And then that gets filled up and you have to build a bigger highway as opposed to kind of a smart growth. Can't we work and live close together, et cetera? So if you move generation and load close together, can you avoid some of the expensive infrastructure? And in thinking about the investment imperatives that you discuss, is there a broader framework to way, do we invest in batteries versus do we invest in transmission? Do we invest in distributed generation versus transmission? And so the question is, how is distributed generation considered? I think, Laura, you discussed that to some extent. But again, I think there is a broader framework. So we need all of it. That's the first piece. Distributed generation, I think, has really come into the discussion as an alternative because we have so much renewable energy coming into the supply mix. And so there's an interesting engagement. I do some work with water and wastewater utilities. How do you use their processes as a form of virtual storage? And so I'll look at just San Diego. There's over 500 megawatts of customer water, not in front of the meter, like big pumps to pump like the California Aqueduct, but behind the meter. And so they're now in a dialogue with the electric utilities to find the common language, to find a way to use their processes. And so I believe it's mostly that renewable energy changes the nature of supply. We used to, as grid operators, say, well, I can just put more generation on the system, but if the sun's not out, or if the wind's not blowing, I don't have that solution of old. And so I think that's where we're starting to look at the flexibility in customer resources and the willingness of customers to be smarter energy users, again, through technology and education, and the need for firming renewable energy and the, because it all has to balance. And so they are another resource. And so storage and the virtual storage are becoming very important. I just wanted to add one thing. I think that, you know, battery technology is a potential game changer. I think the limiting factor for large-scale adaptation of renewable energy has always been, as was mentioned, you know, what do you do when the sun doesn't shine? What do you do when the wind doesn't blow? If you have the ability to store energy when the sun shines and the wind blows and then release it during times when it doesn't, that, to me, is a, it's a paradigm shift for our industry. And, you know, I know, you know, Tesla, for example, you know, a Tesla battery, you know, stores enough energy to power a normal-sized home for about two and a half days. So, you know, that technology is probably not as far away as we might think it is. And so I think it's incumbent upon those of us who are in the industry, you know, to be prepared for that type of eventuality and be ready for, you know, the ground to shift underneath us. One last question. Anybody? Yes, sir? I was just wondering if we could have a show of hands from the speakers who are familiar with a new NOAA study that on solar and wind energy, and it's a potential now to reduce carbon emissions by 90%, but it will require, apparently, major transmission investments on a more than regional basis. And we were, well, one of our board members is wondering if you are aware of this study. Who's, who's study is it? Yeah. A NOAA study. I'm not specifically aware of the details, but I think, you know, we've seen studies like that before. And if you, this whole thing's been an exercise in regret because there's a couple of slides I wish I had. And one of them is the slide from NREL that shows you where the best renewable resources are in the country. If you overlay that transmission grid that Laura put up, they're not in the same place. So depending on what level of renewable integration you think you're going to have is going to directly drive a significant transmission build out. So I, yeah, I think that's beyond, beyond debate, at least in my mind. And I think there are about eight or nine trans, long line transmission projects. And I'm talking from 300 miles to 800 miles right now that are in play or in process, so to speak, for a moving that wind energy west and east. Yeah, that Gateway West project is one of those that 1,000 miles to bring the wind from Wyoming into the load centers in the Northwest. And likewise, there are 1,000 mile plus lines from a lot of it is in those areas is wind in Wyoming going to Las Vegas in California. I mean, that's encouraging, daunting. I think it also brings distributed generation back into play. Are we really considering a 1,000 mile transmission line to bring in wind? So it just, I think raises a lot of issues. Laura? We're only limited by our imagination. There's a really fun study out of MIT on how you move computer computations across the country to follow your solar panels, for example. And so if you think about all the things you can tie together, yes, you need the wires to bring a lot of it. But if you can use smarts and move, you know, I'm gonna compute on the east coast because the sun is up, my solar panels are working, moving it to the west coast. And there's been some studies done in California to actually move computations between supercomputers so I can take advantages of prices. I can take advantages of local resources. And so I think we're just at the beginning of a brand new conversation around all of this. And thank you for bringing that up. Just think of one point on these large transmission lines that are hundreds of miles to 1,000 mile long. At one point, you have the people who are producing the power with the windmills who are making money from the sale of that power. At the other end, you have the consumers of that power and that 500 to 1,000 miles in between, you have all the people who are gonna look at that transmission line and say, why is it going to be there? It's not going to help me. So that turns out to be a major problem. Sorry, sorry, Jeff. One thing I wanted to mention was just to bring this back to the policy, it really ties back to one of the policy justifications in order 1,000 about having these regional planning processes whereby stakeholders can participate in that development. And it's one of the things we talked about. States and other and utilities and other entities and end users are all involved in that process to really choose that future. How are they gonna balance that investment in 1,000 megawatt or 1,000 mile transmission line versus encouraging distributed generation on the state level? It's really an attempt to bring all those things together into a planning process so that we build the right transmission for customers. Because that's, in first view, what makes for just and reasonable rates is that we're building the best and most needed transmission. Well, we're gonna wrap it up except I see that Bill White is standing there with a microphone. Yeah, I'm sorry, Jim. I'm Bill White with Americans for Clean Energy Grid. And I just wanted to first agree with what Laura said about we're gonna need it all. Absolutely, we're gonna need it all. We're gonna need the grid and we're gonna need all those local solutions, efficiency, so forth, all the technology, all the smart technology, all that stuff, all at the same time to get where we need to go, which I think is very high renewable, low carbon energy on the grid. But I also wanna, I think a point that may get lost to your transmission projects individually are quite expensive. In aggregate, they're a very small part of your bill. They're 10 to 12% depending on who you talk to. Generation is over 60% of your bill. And the rest is the distribution. So using transmission to lower the cost of generation is generally a good deal. And it's why the benefit cost ratio is primarily of many big transmission projects are so favorable and many recent ones in particular. So I think that's just an important to keep in mind. The second point I'd make is no resources benefit more from transmission, especially high voltage transmission than renewables do. They're widely distributed. They can be balanced. Their variability, diverse renewables can be balanced over large regions with high voltage transmission. So transmission helps renewables more than it helps anything else. And those low cost resources which were mentioned, I think Jeff mentioned the NREL map that we've all seen a hundred times are places where we don't have transmission right now. And if you cite things there, the generation there, those resources are really cheap and they're really abundant. So I would just throw those out. I know these projects are really expensive. They're as Jack pointed out, they're really hard to build. They're tough, but they also deliver a lot of value in many cases if we do it right. And actually, I would also just add on top of that that one of the things to consider is that with a lot of these long haul, long distance, high voltage lines, a key thing that people may not realize is that there are stakeholders and non-governmental organizations that are advocating for these, including the wilderness society and other entities that you would not really associate with large scale infrastructure development, but it's because of the ability to tap into the renewable generation. You have to remember that Greenpeace is advocating a super grid for Europe. So it's a new world. Build transmission, save the whales. Those are my final words. We're gonna wrap this up. We're gonna be back in about six weeks with another transmission thing. It's gonna be a little higher level. We're gonna be talking about grid resilience, physical and cybersecurity. We'll be talking a little bit about maybe some cost allocation issues. We urge you all to come back. It'll be another good panel too. Thank you. A dynamite panel. And as he said, we hope to bring you this other briefing. And thank you all very, very much for being here. And thank you all very much. Thank you. Great job.