 Okay, so we are recording. This is the Friday, September 22, 2023 meeting of the Valley Green Energy Working Group. We're happy to have Paul Gromer and Marlena Patton with us today from Miss Power Choice to get an update on our CCA application and then also to talk about the new DPU legislation. Darcy, will you be kind enough to take minutes or notes for today's meeting? Thank you. I do not have minutes from the August 11th meeting at this time, but that just gives us more time to sort of move on and capitalize on our time with Paul. So with that said, I'm going to just move along on the agenda to our update on the CCA application. So, I guess maybe Marlena, do you want to give us an update on where we are or Paul or both? Paul, did you want to start with that? Well, I was going to, I was handing it to you. Well, we have these new guidelines from the DPU and so we have been working to understand them. And what we're going to do is submit according to those guidelines, which means reorganizing things kind of behind the scenes a little differently than I had originally organized them. So I'm in the process of adapting the organization to the new guidelines behind the scenes. I think we're just missing one piece, which Stephanie, I think you know, which is the sort of like copy of the vote for Pelham is the one piece. I think that I know that we're missing. Yes. And I think Tom did get to us and said he's working on that. So, I mean, we've given him several, we've reached to him several times. I know that they were in the process. So I, you know, I'll just, it's just a matter of getting it at this point. They know they're working on it. I don't know how to make that move any faster. So under the proposed guidelines, would we be asking for an expedited review or a regular review? So under the guidelines, I think your plan would would be in the regular review bucket. And also just to amplify a bit what on what Marlena had said, the guidelines both sort of reorganize what the main documents would look like, and then also reorganize and streamline quite a bit. The supporting documentation that's required. What we've decided to take is to take advantage of the streamlined supporting documentation requirements. And so we're slimming down a good bit, the supporting documentations will fall will file so that's, that's better it's less stuff. It makes it the filing shorter hopefully makes it easier to go through so we're doing that. And we aren't though taking the step of reorganizing the plan itself to fit the guideline requirements, and that's because and I guess this is an issue for the group but our recommendation is not to do that. And the reason is, you're so far along now, you've already gone out for public comment with the plan organized the way that he used to tell us to do it. And for you and for one other community that we're working with that's in the same place framing him we've said, you're so far down the road you've had a public review, let's file it. The plan documents the way they are, but just take advantage of these streamlined supporting documentation requirements, both because it's too late to change. So, these guidelines are still just draft guidelines, maybe they'll change a little bit before their final. So, it didn't seem prudent to reorganize everything to fit the draft guidelines, when the final guidelines may be different. So, head, you know a few months from now when the guidelines are final, maybe we'll talk about whether it makes sense to revise the plan to meet the final ones but for now, it seemed best to charge ahead with what you have the plan as drafted since over time we've made changes to address new requirements the DPU was issuing, not in these guidelines but in orders and other things which are all headed in the same direction. So, pretty much in line with what the substance of what the guidelines require. The differences now are more a little bit organizational and then some very new things that only came out in the guidelines but just to recap we think you should charge ahead with your documents as they are. We'll take advantage of the streamline supporting requirements but just get your plan into the DPU and get it get the review underway. So, question. Can we, if we can we go ahead and submit everything that we have it looks like we're just waiting on the one verification vote from Pellum. Can we just submit it so there's no question that whether which guidelines we fall under and then attach the Pellum vote afterwards as an addendum I mean there they have so much to review to begin with are they are they a not going to start reviewing till they see a complete package, or would they even notice that we don't have that vote in there. You know, two weeks later two weeks later just sort of flip it in. That's an interesting question which I is not something at least I had thought about Marlene if you thought about this. Yes. We had assumed that getting the vote was an easy thing and so it would happen quickly and then so it's better to have it in from the beginning but I guess, if we can get everything else organized and ready to go which we're working on. I guess we could, we could certainly file it and then treat that as kind of an oversight and send it in send it in later I don't think that I don't think that would be the end of the world if we did it that way. I guess, yeah, I mean if it looks like we're not going to get the Pellum document. Like in the near future. I guess we could consider it. I think my hesitation as though is that the DPU likes to come up with reasons why communities have created their own obstacles to getting approved. And they'll say things like well you submitted this but then you wanted this but then you asked this question. And I would like for Valley Green Energy not to be in a position where you know the DPU could use this as an excuse for their own slow action, because that's what they've done with other communities they've said oh well but then you asked this question and that's why we haven't been able to respond for a long time because we were thinking. We would think it wouldn't be a big deal I guess I don't know I if we if we have to I suppose you're right Paul we could, I would say it wouldn't be the best thing though the best thing would be just give them what they want. My gut feeling. So I attended a meeting that was for it was through the MMA. And it was with community executives but some staff were invited and Paul had invited me to attend as well. So it was with a legal a legal team from DPU about these changes. And I my gut feeling I sort of lean more towards Marlena's response that I don't think we should do that I think we should just have it all together. Because I think in the end it might hinder us more than help us, like getting it in without that isn't going to necessarily move it forward faster, because I think the vote is such a key piece. So I think that's kind of an important thing to have in place but I will say that when Tom made the original request he made it to the town's administrator. And actually the town clerk who responded and asked that all requests go. I think it was to her directly. So, Marlena maybe after this call or offline. You and I could just sort of touch base and follow up and try to reach out to that town clerk directly and see if there's a way we can sort of expedite that by going through that person. I think we can maybe clarify if there are any questions and clarify what's needed, because they may be trying to find any reference to CCA in any conversation. And as you clarified with Northampton and Amherst. It only needs to be around, you know, during the vote, the process during the vote, not like every time it came up. I think they did. We do have the minutes. Hold on. I'm just checking for that now. I don't think the minutes are in question anymore. But let me just just look and see. I think it's literally the certified copy of the vote that we're looking for, which is just one single document usually with a signature on it. That says notification. I'd have to, I would need probably it's best if I don't review this while I'm on the call with you guys, but I believe, I believe he did get some minutes from Pelham. And it's just the vote just needs to print it out or like print it out, sign it, PDF it, email it. Yeah, so that does not seem like that should be that our do is a task so maybe though we could follow up directly I can maybe I can call at the beginning of next week and I'll just call I'll start with the administrator and then call the town clerk to see if we can move that along. I feel like Tom is really bogged down and some family stuff right now it's kind of an emergency situation so I really don't want to burden him, or make him feel stressed out with this piece so I'm happy to follow up. Next week. Sounds great. Okay. Did someone I thought I saw someone raise their hand or have a question. Okay, no. Welcome Catherine. Okay, with that then let's move on to our next agenda item and I guess Paul will let you just sort of take it from here to talk about the new guidelines and your draft template, the draft template plan and then also the other information I think you were. I, oh, I meant to get it on the, I did revise the agenda but I think I put the wrong one in the packet so you would mentioned another another bill. So absolutely so I'll kind of jump ahead and then, and then answer questions as we go so just to frame the discussions there are confused. Well not confusing. There are two initiatives underway regarding the DPS review of aggregation plans. On the one hand there's a bill in the legislature that would greatly streamline the DPU review require, you know, no more than 90 days for review and importantly, build in a lot of additional flexibility for cities and towns beyond what the DPU has been allowing. The legislation has been filed that's supported by a wide number of municipalities and so one of the things I've offered to you is there's a sign on, you know, some letter of support going around that will be signed by many cities and towns. If your cities and towns would like to sign that letter. You're, you're welcome to, you know, would be your encouraged or I would encourage you to do so. It's not the end of the world if you can't because there will be scores of, you know, signatories to the letter so it's not critical but be wonderful to have your support. So that's one thing that's legislation in parallel a little bit as we've discussed the DPU has issued draft guidelines for the review of aggregation plans which would in a bit the process for review, speed it up. So saying that it would either be four months or six months, as opposed to the current three year plus that we've been dealing with, and it articulates a lot of the DPU's requirements for aggregation plans. So the reception to these guidelines has been, I would say, mixed because it's maybe mixed at best, because while the faster process would be good and putting all the rules in one place would be good. The guidelines do also continue or even extend the DPU's trend of micromanagement of aggregation plans so lots of little details, you know, silly things like, well, you can't call your product green you have to call it renewable they're just like hundreds of little things that you know the state is telling the cities and towns that they can do. And one of the big issues in the guidelines which some, some folks in the aggregation world have resisted is, there's a lot more requirement for notification of customers, in particular at the time of of a price change or the way aggregation works is when the program launches everybody gets a letter about it in the mail and they can either opt out or continue. The aggregation continues but after two years or so you'll come to the end of your supply contract you'll enter a new supply contract the price will change. Historically aggregations would make an announcement of this but they wouldn't send everybody a letter. The DPU now wants the cities and towns to send everyone a letter and there's some unhappiness about that that some of the DPU's been building towards for a long time and and it's in these guidelines now and there are new forms that have to be sent all sorts of other stuff. And so, just like there's a letter of support for the legislation, there have been efforts to develop what would be joint comments regarding the guidelines and I've been working with the other aggregation consultants and the Cape Light Compact which is the biggest aggregation to try to get a common set of comments that we could all file. And I think we've, we've had some luck and are shortly able to send a draft of that. It's sadly complicated by two things. One is that what we've been able to agree on is that a high level of principles, not so much at very specific detailed recommendations. So I think what's going to happen is, we'll have a very large number of communities sign on to a general set of comments at the principal level. Maybe there will be a few others, you know, one from the towns we work with one from the towns that the other each of the other consultants works with on more matters of detail. And then the second complication. Sorry, this is complicated is that one of the consulting firms colonial power has taken kind of a different approach to responding to the guidelines and we all agree. on the substance but colonialist approach has been more to encourage the DPU or to say to the DPU. These are terrible. Throw them out, start over with something new. And while others agree with that sentiment, I'd say most of us feel that's not as a matter of tactics. That's not the best way to persuade the DPU. They're very invested in these guidelines, they've been working on them for a year. They've been going they made a presentation as about them as Stephanie said at the MMA, they issued a big press release. You know, they're going ahead with these guidelines and my fear is you tell them your point number one throw these away and start over, they're just going to stop listening at that point so we're more in line with 100% in line with acknowledging which good about them and then making some recommendations for change. On one specific point so that's big picture of difference. And then on a level of detail. There's another difference among the different consultants on the particular issue of all these additional notices that I mentioned a minute ago, a new requirement that the towns have to inform send a letter whenever there's a price change, for example, some folks want to push back against that requirement and say the town shouldn't have to do that. My own view is that the towns really should embrace it that you lose the moral high ground if you say we're against notifying customers. Instead, the towns are you should and are in favor of notifying customers so I'm thinking it's not good to fight about that. That's a good thing to do. Let's fight about the other stuff like, you know, little details about what you can call your products or, most importantly, how much flexibility you have to change the plan to deal with market circumstances or new opportunities. My view is it's best to push for that give the town's flexibility, but not say not fight about notifying customers that notifying customers is a good thing let's just agree with that but let's, let's have flexibility in how we run the programs. Yes, perfect time for a question or for a break so please. You muted Darcy. You can put it in the chat maybe. Maybe the host. Sometimes you can click on their box and ask to unmute which will bring up a box where they can just click a button. Meanwhile, I would like to ask who from the various municipalities would be asked to sign these two letters, if we decide that we want to move in that direction. Mayor, would it be this the Valley Green Energy Working Group, etc. Yes. So as far as the letter to the legislature goes. It's really whomever the towns would like to have signed the letter so, and it's really it should be someone representing the city or town but it could be anyone in different communities. Some have the mayor sign, some have the town manager sign, some have a sustainability, you know, staff person sign, it could be whatever you're comfortable with and that's the way the letter would go because that is from the towns to the legislature. In terms of the DPU comments. It's a little bit different because there it's a regulatory proceeding. Typically filings and regulatory proceedings are filed by the lawyer for the entity who's representing them and these are kind of proceedings in general. So for the DPU comments what I'd ask would just be for your approval. For me to sign as the legal representative for the communities before the DPU and that's the way I'd be handling it with the other cities and towns that we work with as well. Darcy has successfully unmuted herself so grad Darcy. I just was going to ask about the, because I'm not that familiar with the new draft rules, whether the provision to notify the customers requires that they opt in or whether it's still assumed that they're in the program and they, and that they're not. They don't have to do anything to stay in. So that that's a really good question and that's a place where the, there's a little subtlety in the rules so what the DPU rules said is that for anybody who's in the standard opt out product. You get this letter and unless you opt out, you see unless you take action and opt out you stay in the program at that product. It's a voluntary product that they chose either, you know, one optional 100% green product or a basic product. The rules are the little different. There the DPU has said the product doesn't change at all. Still the same amount of Rex for example, and the customer stays in unless they say they want to leave. But if the city or town changes the percentage of Rex, then the customer has to affirmatively opt into it again. And if they don't, it would go back to basic service. At last part doesn't make so much sense to me I think they should go to the program standard product and we'd suggest that in the comments but I don't, I don't have much hope the DPU would agree. But I, as there is a way and I think of managing this and I think Joshua actually mentioned it on one of our earlier calls is just don't change the Rex in the optional product so you have 100% product and you keep it 100% product. And if you decide you want a 50% product, don't change the 100 to 50 just have a new product that's 50 and then you don't have to deal with this problem of people bouncing back to basic service unless they take an affirmative action. Catherine, you had your hand up. Yeah, I had the same question as Darcy. Thanks. But isn't the default of the basic service at also at issue. I mean, to me, that's egregious. Oh, so that's a point where the guidelines were a little confusing, but the actual rule isn't, if I'm understanding where you're headed is not as bad as what people thought so some people reading the guidelines and this was not an unreasonable reading I thought that what the guidelines were saying was the aggregations basic standard product default product has to be the same as basic service no extra Rex. That isn't what it said, what they're saying is something a little different which is just that new customers when you sign up for a new account, you start out on basic service, and that's been the rule for several years now. You get the opt out letter and you become part of the aggregation unless you opt out, but the DPU wasn't saying that the aggregations standard product had to be equal to default service. Even, even for a expedited review. I don't think so but the expedited review rules are a little murky and in my view nonsensical so I think there might be some way to get some improvement there. But I think what they said for expedited review was. You can only have two products, and one of them has to be the same as basic service, but I don't think they said this default product has to be the same as basic service to see had to offer that. But I think one thing we would say in comments is why in the world should you know someone with three products not qualify for expedited review what is it about having a third option that makes the review process so much harder. You know, they're 75 aggregation plans with three products why you know what why is that a barrier to expedited review it doesn't. It doesn't really make any sense and I don't think it advances the DPUs objectives, you know, even if you embrace all those objectives I don't think that's helpful. Yeah, that was what my one of one of my takeaways from that session was was that we wouldn't be eligible for expedited review with our application. For that reason, I, I do have the slides from that meeting that I'm happy to share, you know and forward. So I'll just forward them to the group so people can see them. Oh, if I may as a tangent I someone else also sent me those slides. I did want to make two comments about them. Before you read them so one is that DPU staff listed a whole bunch of things that make aggregation problem, you know, review cumbersome things like towns not actually answering information requests, you know, making a bunch of errors in their things. I'm pleased to say those are not problems that we've encountered so that is true some of the other consultants run into this all the time but I don't think you'll you'll have that with us. And then the other thing in there and I apologize for burdening you with this but the DPU is on this. It's continuing to mention that consultants have something of a conflict because we get paid through the volume of sales through the program. And so they're suggesting that that would give us an interest to try to do things that would increase the volume in the program but that's actually not true I mean, both, you know we've never suggested something to increase the sales to benefit us. And it's in part because that wouldn't be an honorable thing to do but even more that's not really in our financial interest our financial interest is to have a successful program and for us to continue to you to think we're doing a good job and we continue to work with us with you. That's the, that's our motivation as to that's our financial motivation as to make the program successful not to make it a little bigger at the expense of making it less successful. So the financial we're actually quite aligned I think with the goals of the program and the municipalities. I have another question that's related to timeframes. Is it, is it okay to ask it now. Okay, well, not hearing no, I guess I'll proceed. But there's no timeframe for if the DPU disapproves of a plan. There's no timeframe for re review. And, and yet that is in the legislation that's been proposed. And also, there's no timeframe. If a plan is amended and submits amendments for approval. There's no timeframe given. So it could they could still take three years to to to evaluate a reapplication after a denial or an amendment. And so to me, that's a real weakness of the so called streamlining effort. Yes, fair enough. And I think a good, a good thing to comment on. I hadn't flagged on that disapprove. I hadn't noticed that disapproval point, but I think you're right about that. So that would be a good thing to say. Tom welcome, glad you could join us. Thank you very much. Sorry for the delay. No worries, not at all. I just want to check in real quick with you. We sort of covered this at the beginning, but I just want to circle back now that you're here. Is there, I guess at this point, the only thing we're waiting for is the certified copy of the vote. I need to triple down on that, I guess. I don't have them yet, but I was afraid that they still hadn't come through. So, the process had been initiated, but I guess we have to spend a send a specific email to that one individual. So I will get that taken care of that holding up the whole shooting match right now. It sounds well, it kind of is a big piece, but it sounds like it has to go to the town clerk because I think when you had sent it originally, all of this went to the town administrator. I think that is the one who actually actually has to print it and certify it. So, I think the request needs to be in writing to her. I think it's a her. So, and if you need any assistance at all just let me know I'm happy to help follow up. Thank you. I might just listen in and multitask and get it done right now. How's that. Sounds good. Marlena, were you about to say something? I was just going to say that the thing that you're looking for is a document that says this vote occurred on this date with a certification from the town clerk. So it's not typically a multi page thing. It's typically one page although some communities that will be a couple pages, but hopefully it's going to be a pretty straightforward thing that they know what a certified copy is and they can just kind of produce it for you. Do you need and you don't need the originals. Do you Marlena? No, electronic is fine. Okay. Yeah, I think ours was just literally a half page and it's actually sitting on my desk right now, but it was only like a half page with an official seal. Okay, so circling back to, to this I just want to understand Paul you've said a few things so one is that it would be great if the municipalities could send a letter. I'm imagining that I would want to get this to our town manager to sign. Supporting the legislation. And then the other thing it sounded like you were saying is that for comment on the proposed legislation that you would essentially be submitting that on our behalf with a group of other consultants. Is that what you were asking for? Yes, or just to frame a bit on the letter so on the letter to the legislature, the specific request is, I guess it's for the town to sign but the, all I would need back as your statement to me that yes, the town would sign it and this is the person, this would personally be the signatory. And then the ideas that would be submitted to the let the legislature is that same letter, but then a long list of towns attached to it so everybody on the same letter. So it seems like a big group rather than rather than individual one so it says maybe a slightly easier task all I would need if you wanted to sign is just let me know that and who. And there'll be a process to get that in on the guidelines. Similarly, those would be would be from a group. And there though, yes, I would be the literal signatory but it would be on your behalf and so what I will be sending you haven't don't have them to send yet would be those draft comments for you to take a look at and then to decide whether. Let me know whether it's okay with you if I include you on the list of towns that are, you know, so together submitting these submitting these comments. So would it be valley green energy, or would it be each individual municipality. I'd say it should be valley green energy. So you'll get those comments to us for review sounds like what we should do is once we get them will schedule a follow up meeting to discuss our feedback. And then get them back to you, whether we're on board or we have additional comments we'd like you would include. Yes. Yes. What about other municipal entities, writing their own letter, is that not advised or is it, does it make the case stronger. This would be to the, I think, I think the answer is the more the better so if other that that you know if if other entities want to send something, you know, either to the legislature the deep view or both. Yeah, that's always good. Thank you. In my mind. Yeah, in my mind Adele I sort of see the advocacy groups, you know, kind of doing their version of a letter but I do personally would like to see us as an entity. As Paul suggested that we send our comments that way. But that doesn't preclude like, you know, your group doing a separate set of comments. Yeah, the advocacy groups would be a very separate thing, but I was thinking of Caroline of the energy and sustainability commission, for example. And whether it's helpful for that group to send a letter or not. And do you what was the, how long is the public comment period open. Until October 13 or something like that. I think for the, for the DPU comments. It's the deadline is October 6 for the initial ones and then November 6 for the final for the legislation, we are targeting the hearing before the house which I think is October 12 and so looking to just to give a day or two to get the letter together to know from people whether they want to sign on by October 10. Do you say October 10. Okay. Yeah, so the, our next meeting is the 10th of October for energy and sustainability Adele. So we could potentially vote on that day. It's late in the afternoon so it wouldn't be till first thing in the morning on the 11th, Paul that you would get that. I don't know if that makes a difference. I don't think it does but for the for the sudden, for the letter to the legislature sorry it's hard to follow the to be so clear about this. There I think you really only want one signatory on behalf of the community so and it's going to be like some a municipal official whether mayor town manager sustainability director something like that but one one per town. So if the sense sustainability commission wanted to send a letter to either to the legislature for the DPU, I think you'd want to send your own letter. And you could send, you know, essentially the same letter, but the idea of that main group one is it's, it's, you know, one one entity per town and it's some, you know, sorry just one entity per town. So we probably have to get the second one. I mean, because certainly from our committee perspective in North Hampton and we wouldn't be able to get it, except for that. November, sort of second final base piece. And then otherwise I guess it would be either the mayor for your piece on the 10th, or from one of our departments. Yeah, that's a good question to me. We have an ECAC meeting next week that I could actually put this on the agenda and see if they'll, if they'll do their own letter which I think they probably would Darcy. Just wondering, are there, are there two comment letters, one the high level principal letter and one the detail letter or how does that work. So, there are two big buckets one bucket has to test to sub buckets within it so for the legislature, there's just one letter, and that's the one we would hope the mayor or a municipal staff person would sign so that's to the legislature just one thing. The DPU comments, which is a separate path different audience, there will be two, one is very high level, and there'll be a lot of communities signed on to that, you know on the order of, you know, 50 75 something like that, the high level principal comments and then separately there will be some much more detailed recommendations that will be a smaller group, not still not a insignificant but that would be more on the order of 20 towns that we work with, rather than the bigger broader set and they, the real difference between those. So unfortunately, there are two things there, the, and the reason for that difference again is that some of the groups want to push for changes that I don't think are realistic, and I actually think it's harmful to ask for like, don't make us send customers that doesn't seem to be a helpful position to take to me so we would be arts are our specific recommendations would be limited to things where I think there's some realistic opportunity that the DPU could be persuaded, and making the request we wouldn't, wouldn't weaken the town's position by, you know, seeming like we didn't share the values of keeping customers fully informed about the programs. So, do you think that, is there wiggle room as far as like if, if we're, if we sign on to the detailed letter that says that we're okay with con, you know the letters going to customers. Is there a way to couch it in a condition that, that, you know, something to do with not requiring that the customers have to opt in again or something like that, because, you know, somehow changing it over to a opt in instead of being without is really could be devastating. Yes, absolutely. It would and I think we're on the. I think we're on the same path here which is, I'm thinking that the detail of recommendation should be on the important things that go to the structure and success of the programs. I think the structure of letters to customers doesn't interfere with the success of the program it's actually probably a good thing because customers learn more about the program and they can make informed decisions more informed decisions so I think that's, I think it's good to separate those things, and we wouldn't even have to say in the comments, you know, we support sending all these letters, we just wouldn't say, don't tell us we have to send these letters we just wouldn't say anything about it. So if Paul's going to send us those comments then we can schedule a meeting and review it and if we have any suggestions or questions. We get them right back to Paul. Sounds good. I would just like to clarify. The letter to the legislature might be from the Northampton perspective might be in the mayor. But in addition, other units of Northampton could write a letter to the legislature is that did I understand that correctly. For example, the Energy and Sustainability Commission is. I think that's where Paul was saying that it would be better to have one. Okay, individual. That's where I'm trying to clarify. Yeah, that's the one the letter to the legislature should just be probably the mayor. In our case, I would ask our time manager. You know, in Tom's case, it might be the chair of the select board. Correct. So that would be the person to sign that letter to the legislature. It's the other comment letter. So and Paul, correct me. I'm trying to follow here. So correct me if I'm wrong though. So the comments. Paul is putting together with some other groups comments that would be sent on our behalf and all of his other clients. And we would be reviewing those comments to see if we're okay with him representing us. But we could separately have other committees also send comment letters and they could use that. You know, that comment letter is kind of a, you know, a launching point, maybe, but sort of create their own language, maybe with a lot of the same content. Or points at least, but in their own language to also send as separately. Am I on track here? You are absolutely. And then this probably assumed and certainly outside groups so outside advocacy groups. It's wonderful to have those groups and send letters, your comments and, you know, saying whatever you want and then we're all pushing in the same general direction here and I think the more the better. And I'm sorry. So I want to be clear the letter to the legislature that we would get our executives ostensibly to sign is the one that would be included with the long list of other municipalities. Yes, in fact, there'll be three lists. The letter to the legislature will have the longest list so that just depending on how many, you know, towns, decide they want to engage that'll be let's say, I don't know what 75 towns will sign that one. So that'll be the longest list. Then there'll be the DPU comments that are at a high level, and that will also be a big long list, probably not quite as long but maybe, I don't know, 50. And then there'll be the detailed comments, and that will be the shortest of lists, but it'll still be 10 to 20, maybe even slightly more so we'll have like 75 to 150 and 25 will be the three, the three list is my expectation and just reflects how much alignment there is among the different towns and the different people who work with the towns. I'm sort of following. I think I'm lost at that last point but that's okay. We'll just go with getting your draft and then we'll go from there. But it sounds like I think the, what some of the questions regarding comment is that people just want to ensure that even if an individual wanted to send comments they certainly can. So even if you're a member of this group if you wanted to send your own separate comment even outside of your own advocacy group, you are certainly free to do that. Okay. Are there any other questions while we have Paul here. When do you think we would be ready, assuming that Pellum produces the document, when would we be ready to submit our application. Do you have a sense Marlena. I'm just looking at the calendar right now. 20 seconds. I mean I think sometime in October, hopefully the first half of October would be my hope. So we still need to get the, we still have to set a filing date and get a docket number from the DPU on that right Paul. Correct. We haven't done that till we had all the documents ready. So we need all the documents that we're going to submit before we can get a docket number instead of filing date. It sounds like we're close to that. So then what we have to do is I have to finish reorganizing everything, which is its own little project. And then they have to be sent over for approval. Paul, how many affidavits have to be signed for this? I'd say one. One. Okay, so we'll have to pull all the files together, put all the DPU like organize them the way the DPU ones with the DPU header on them then package them up and send them over to you guys. And then somebody has to sign an affidavit saying that these have been prepared under their supervision and their accurate as far as I know, send them back to us and then we file them. So we have to make it a little bit of time for their review as well. If it's only one, then because we have three communities. So wouldn't we have our three? Wouldn't we have our basically our clerks who would be reviewing them. Oh, just have David. Yeah, so typically it'd be either either someone like you Stephanie on behalf of the, the, the valley green energy working group or conceivably, someone else in the municipality. So this is just the name affid, the term affidavit makes it sound like a bigger thing than it is. This is just a DPU administrative requirement that okay documents come to them in order for them to consider it in a decision that document has to be attached to a person. There has to be a document that came in there has to be somebody who stands behind it, but all that stands behind it. That means as the affidavit says, these, this filing was prepared under my direction so not by you but you know by the way, it's a document that you're working on your behalf, and it's accurate to the best of your knowledge. That's all you're about, you know, not asserting to anything beyond that. It's just, it's an important requirement is just administrative and it will never be mentioned again, but it's just a filing. Okay. Yeah, that's fine if you signed it Stephanie. Okay, yeah, that's fine I'd be more than happy to get that going. Yeah, so then I would send the, I would send the whole shebang, which is really, as I think we've talked before just pulling together a lot of pieces that you guys have already seen we're just putting them in one place like minutes and letters and things like that. So I'd send it all to you so that you could reveal it so I guess I'm hoping, I'm hoping, you know, first half of October, I don't, that seems reasonable to me. Okay. Thank you. All right. So if you need any assistance to I'm happy we can follow up offline after this meeting, and I can, if there's any way I can help, because I'm not sure which coast you're on right now. I don't know what gave you that impression but I will accept any offers Stephanie thank you very much. Okay, yeah we can, we'll touch base after, after the meeting I'll just give you a call. That's okay. We have a moment after this meeting to talk. I will. I'm three to four and four to five I might be done before I might. Are you still in before four, if I call you to like quarter of four. Yes. I'll be here. I should be free then. Okay, sure. Sounds good. Yeah, because if I have to physically go to Pelham and pick it up I can do that. Well, so. Okay, thank you. You know, just, you know, I just that way we can at least have it so. So you don't have to, you can get it off your plate. Thank you. Okay, sure. So with that, are there any other questions or comments for kind of running out of time here and I don't, we actually don't have any public so we don't have to worry about public comment, but. Everybody's good. All right. Sounds like we're so close. Go ahead Darcy. I just have a question about the deadlines for the comments are they. Are we also going to be commenting on the final draft. Or just doing one round of commenting. Oh, so. I think we'll need to see. So there's right there, two rounds of comments. There's initial comments and then a month later, what are called reply comments where people can respond to what other people say. I have to see what other people say. I don't know if it will be necessary to file reply comments or whether the initial ones would be sufficient. And that November 6 is when the final comments is are going to come out, or. Yes, the initial comments filed on October 6 reply comments filed on November 6. What happens after that is unknown at some point the DPU will issue the final version of the guidelines themselves. That will be sometime after November 6. They haven't set a schedule for that and they haven't said whether anything's going to happen in between November 6 and the final version of the guidelines will have to see what they. Unfortunately, we just have to wait to see what they say. So I have a question, Paul, if we're submitting in October. And it's still under in their draft guidelines, we should not be. Shouldn't we be adhering to the existing guidelines and not the revised because they haven't been finalized. Oh, for your filing of your plan so I did speak to DPU staff to ask just this exact question. And when over with them the approach we had discussed which he was he was comfortable with where we file your, your plan, the plan itself, as we've written it, which is largely in line with these guidelines but not exactly in line with these guidelines but I don't want to put that in. But he said, with regard to the supporting documentation, we'd encourage you just to give us the stuff that's in the guide that guidelines asked for, not that much longer list of things that we used to ask for, because we actually don't want that much use of lists list of things so DPU staff is what was comfortable with the approach we suggested. Okay, great. Thank you for that clarification. Okay. Anyone else. Okay, great. Thank you so much Marlena and Paul so greatly appreciate all you are doing on our behalf and for all the information you helped clarify for all of us. Really great. So, I guess I'll just wait to get those comments from you. And I think I'll wait till I get them before we schedule the next meeting if that's okay with everyone so. So that way we can factor in some time for people to review as well. Prior to the next meeting. So, I will let everybody know when that is so as soon as you can get them to me Paul that would be great. Really appreciate your time and I think we're so close. I feel pretty confident we can get that document from Pelham sooner than later so I think we should be good to be moving ahead in October. So, thank you so much. I don't think there's any public comment so our next meeting agenda will basically just be reviewing the comments. And maybe just an update on where we are with our application and I think that should be sufficient and I will let you know I'll follow up with everybody. All right. Thank you all so much. Thanks Stephanie. All right, thanks. Take care. Bye.