 So he's been 15 minutes starting with Riley, right? No, Peter. No, Peter. Okay. Let's go with Deputy Secretary. When I walked in the door, at least. Welcome. I haven't checked Facebook. Governor doesn't generally fire people via Twitter, so I think we'll be okay. For the record, I'm Peter Wach. I'm the Deputy Secretary of the Agency of Natural Resources. I wear lots of hats within the administration relative to climate change and transportation activities, and happy to talk with you about a range of pieces. I understand from talking to Michelle Boohmauer that there's interest in the BWSOMA monies in the bus pilot project that is moving forward, and I understand that Matt has already reached out to some of our folks, Paul, in kind of where that is, and have a discussion around that topic. So I think that would be a really good one to have. Certainly, we, as we've thought more about how we spend those resources in support of the overall objective, which is the reduction of NOx emissions from heavy duty transportation and transmission generally, we think there's value in doing as much as possible to transform different sectors of the heavy duty world into electrification as much as possible, and there are opportunities to do that via not simply providing incentives for people to switch, but also helping businesses and organizations think through what that looks like and how it fits into their business model. So in some ways, a pilot project is more effective than simply giving out, you know, 10 mumps of money to people to change over vehicles, to help them actually think through what does it mean for how they operate and what does it mean for what, where they're, you know, how their operations run in order to integrate them and is there a benefit to it? Is there, what are the unforeseen consequences? That's been the idea behind the bus pilot as well in building on the work that the DEIC did in Massachusetts to sort of understand what the challenges and what works well and, you know, all those things that, you know, it's not as simple as swapping one bus out for another. So I wanted to touch on those. That piece, I think primarily you're interested in the Transportation and Climate Initiative work that is going on. So I want to put that into context and talk about where we are and what my role in others is within the administration and working on this. So the Transportation and Climate Initiative is a broad group of state stakeholders, state and the District of Columbia, stakeholders that extends. The group extends from Maine down in the Eastern Seabourg to Virginia, including D.C. So the group has been formed since 2010. So this, this is just, it's been a body that have gotten together to think through how do we make progress on issues related to emissions from transportation. What has been, what was announced in December, which Vermont is a part of, is the, is the sort of, I call it the two-gate process. There's, we are, we, the group that signed on agreed to go walk through the first gate and say we're going to look at what a cap and trade program for transportation emissions could look like and what its potential benefits and potential costs would be. And then we would spend the next year working through those issues and try to develop a program. And then by the end of next year or an end of this year, excuse me, this, the individual states would decide whether or not they wanted to pursue that policy. It is somewhat aligned with the work that we've done on the Regional Greenhouse Gas Initiative, which is Reggie, if you may hear from our owners, the cap and trade for the power production sector. We, it is most of the same states, but not all of them. Some of them are new in TCI, some of them are different. It isn't just the energy and environmental folks as it is in Reggie. It includes the transportation folks, so that's been a great addition. Obviously we need, we need sort of the agencies of transportation at the table to have the discussion be effective, but it also means we have new people to sort of think through lots of new topics. So that is the general framework that we're operating under. What we are doing now as part of the administration is sort of, and in discussions with other states, it's sort of figuring out what the decision making process over the next year is going to look like. What are the pieces of data we need to know in order to make decisions on what the program looks like or would look like? So that we can then do some economic modeling to see what the impacts are going to be and then have an opportunity for stakeholder engagement through that process to sort of, to provide feedback and then sort of come back to the table with everyone together to say, okay, based on what we've heard, what is the general consensus on how we would move this forward. And then that, at that point, then the decision making might come. So it's, if that sounded convoluted and like a lot of things to do in a year, it is. It, you know, it sounded good in a press release. It scares the crap out of me. There's just a lot of work to do. There's a lot of pieces to a cap and trade program that are complicated. If we don't get them right, then we have to go back and fix them. And more importantly, it has impacts on real people. And as I like to say, generally speaking, when we try to get something right from policy realm, we usually get it wrong. It's a question of how wrong we are. And we need to be able to make changes and fix things as we go, but it's nice to get it relatively close the first time. And that is certainly a challenge with working with this many states to try to figure out where the sweet spot is for all of them. They all have different needs. You think about different states have different sort of traveling profiles. And we have, we and some of our other, you know, colleagues have more rural, long distance travel profiles that, you know, with fewer opportunities now for public transit and things like that that we are certainly factoring in. And so within that process, not only will what the sort of structure of the program looks like, and I'll talk a little bit about through cap and trade in concept in a second so that it doesn't just sound like jargon to you, but, and then also whether or not the group is going to have a shared position on how those, the investments from those proceeds occur. For example, Reggie, the agreement that established Reggie requires each state to invest at least 25% in sort of virtuous cycles, sort of investments in efficiency or other things. We have invested all of those proceeds into thermal efficiency work. 25%? At least 25% of the proceeds that come to the state from Reggie from all to all of the states have to be spent things. So whereas in New Hampshire much, many of the proceeds go back directly to ratepayers, there is a buyer proportion that some of that goes to efficiency work or to other things that drive down emissions. So the so-called auction, when utilities submit, I guess, a proposal of how to spend a million dollars in auction, right? So Reggie, that's something that has some sort of, so let me step back and talk about what a cap and trade is generally. So a cap and trade is a sort of hybrid model of regulation to get reductions in some pollutant that we're looking for. It was used to look at socks and knocks for large power plants when we were talking about acid rain. It has been used in Reggie. It's been used in other places for different pollutants. It's a way to basically say what our overall goal is, the reduction of this pollutant from the environment. We are somewhat agnostic about whether you do it or you do it or you do it as long as it gets done. And if you can sell, you can do it more cost-efficiently than you can, then you can buy those allowances from them in order to build a pollutant. So that's the sort of basic concept is to say, how can we harness market efficiencies to get the same result that we want without saying each one of you has to reduce your pollutant output overall by the same amount? Because we know not everybody can do it the same and so we want to make sure that we get the result while getting it done efficiently. The way it works in Reggie and Reggie is somewhat simpler and easier to understand is that if you are a generator of electricity, you are required to at the end of a three-year period hold enough what we call allowances. So one allowance equals one ton of carbon. So if you have to hold enough allowances and submit them to A&R to match what your emissions profile is, we have a whole quarterly auctions where people can wear emitters or anybody else for that matter can buy allowances in the auction. We auction a certain amount. And then there's what we call a secondary market where if you realize all of a sudden your emissions are way lower than you thought they were going to be, then you can sell those in the secondary market or if you realize that you need more, you can also buy those in the secondary market and that's where that sort of trading comes into play. We're doing that today with election utilities. We're doing that with election utilities. So you are too. Yes. And we did that with stocks and stocks criteria, means? Who about utilities? Well, I think it covered all. I would have to go back and look at the specifics but I think it covered all industrial sectors. We didn't do it through an auction process then. We did it simply through that. That's one of the other options is to simply allocate the allowances based on current emissions and if you can do it better than you can trade within your. So we think the auction model creates more financial incentive for people to work faster. So and that's the approach that's been taken with regent and has been effective at producing emissions and keeping the price impacts on consumers low. That's not how we got an action. Yep. I don't think that's how we got stocks reductions from Midwestern coal power plants, is it? That was cabin trade that was used to, yeah. So it's a tool that allows, you know, if you, you know, let's go back to the coal power coal power plants. If you are a brand new facility that, you know, can optimize quickly and reduce stocks quickly versus an older system that, you know, is going to take more time and more money. There's the economic efficiencies of one producing their emissions faster is more than the other and then they can work together to sort of balance that load. When we're talking, and when we're talking about pollutants where the specific geographic distribution of them isn't as critical, when we're talking about an overall problem that gets up in the atmosphere, then it becomes, it's a worthwhile solution to consider. Okay, I did not know that. I thought that under the RIEPA just finally told that question. I usually think I had to cut off emissions. So it's always good to have learning together. I learned new things about this all the time. Anyway, so this is, that's the process that we are undergoing right now is to figure out specifically what does the program look like and that means just, you know, from a basic level saying what is the initial cap going to be? And the cap sets the overall emissions that we think is acceptable for to happen and then it ratchets down over time. So we get that incremental emission decreases over time and setting that initial cap and how quickly it goes down is the sort of the key driver of what the policy will look like. But it also, there are also other pieces in there. We usually incorporate some sort of price ceiling so if the cost is getting too high, the more allowances can come into the market. Therefore, it's sort of stabilizing things so that we don't put too much of a burden on the overall system. There's also something we've installed and put into Reggie now. We call it an emissions containment reserve. If the price gets too low, then allowances are pulled out of the market in order for it to come back and aid the living. Because what we saw in what we've seen in Reggie in the last 10 years is that the cap was set too high and we lowered it once and then we've been ratcheting down again and yet there are still additional unspent allowances in the system. There is what we call it bank of allowances where people didn't need them. And that creates inefficiencies in the market because people can kind of come in and go as maybe it also means that potentially down the road those allowances could be used and we can end up with emissions higher than we'd like to see them sort of get a little like hockey stick effect termination. So it's how we deal with all of those factors when the marketplace really matters. And it's a and so those are the sorts of things that we need to work on. So you can go back and and say oops we would put the cap too high and then we do what if we follow the Reggie model we have what we call a program review where we all the states get together every few years and say all right what's working what's not what needs to be adjusted and we go through that's a stakeholder process where we go out with various iterations of proposals that the utilities that other interested parties that you know that folks who are looking after repair interest all those things can comment on to say what you know what they believe the impact should be and where we should focus our efforts. So we have just completed the most recent Reggie program review in our undergoing the regulatory process to adjust those now. The other thing to bear in mind about Reggie is that it's not a compact. It's not a group of states that are acting as one. It is a group of state programs that are linked and functioning cohesively. So we each have the same or very very similar set of either laws or regulations on the box and then we share the auctioning and overall management services. So we are not a compact. That would require congressional support and we don't believe that that likely to happen and it's worked out reasonably well. But it means we all have to come together and reach agreement on everything. So it is a complicated process but the benefit to Vermont is that we are one creating a competitive environment throughout the region and we are seeing greater reductions overall across the region than we could achieve through action in Vermont. And so while it is a somewhat deliberate and at times frustratingly slow process it is incredibly effective in delivering greater scale of reductions and missions than we would see from Vermont alone. Molly. So do you have, is there a board for Reggie? Who makes those decisions? So there's a board, there are two representatives from each state. So it is a member of the PUC or equivalent for each state and then somebody from the environmental agency from the state. So for Vermont it is Sarah Hoffman from the PUC and me. And does large space have no more representation? No, while New York kind of has this great situation where they have three but it doesn't really matter because they, we all have to come to agreement. They don't get to outvote us with their third member and so it doesn't really matter. It's just they, they have a larger organization. I'm just curious, you kind of opened with the talk about the Volkswagen settlement in the bus pilot program. I just wondered kind of, I think we were looking at where the monies had been in the different pots and I just wondered if that's something you were also going to speak to? I am happily speaking to what I know about that. I don't know all of it. So I can say what I'm trying to do now. We're trying to piece it together so you can find yourself. So I can, I can, I think I can probably clear up the things that you already know, unfortunately, but certainly there have been multiple settlements with the BW Corporation and its associated entities over the past few years. There have been two environmental settlements and one consumer protection settlement. The, there is a state environmental settlement that was the $4.2 million that the, you know, I think in April of 2017, the legislature appropriated that money to fill a pending gap in the environmental contingency fund, which is what the, what A&R uses to address emerging contamination issues like in Bennington. We, it's where we pay for state shares of super fund program, super fund cleanups. It's an incredibly important tool that enables us to respond quickly in the event of a contaminated appearing in a place where it should not be. That the second settlement was the federal environmental settlement, which is the $18.7 million that you often hear about. That is, has, it comes, it is, that one is a little bit more trickier because there is a trustee that hold that money. You as a legislature at our request appropriated 10%, we have 10 years to spend that money. So you appropriated 10% of those funds for us last year and we will ask you for another 10% this year to spend on, to essentially go forward and ask the, the trustee for to release those funds. The third, the, and then there was a consumer, a state consumer protection settlement that was just announced this past June that I, I can't remember the full amount because a portion of it went directly back to consumers but the state, the portion that went to the state was $3.6 million. You appropriated that in FY 19th to the general fund and I don't know where it precisely went from there. And so the, and then there is, there have recently been settlements with Bosch and with Fiat Chrysler around similar issues relative to essentially emissions cheating scandals. It's not, they haven't, they were not on the scale of a BW but certainly Bosch was providing some of the technology that enabled that cheating to occur and Fiat Chrysler was doing simpler things to what BW is doing. So it doesn't answer your question in full but I hope that helps a little bit. And the best pilot that you may just tell them to do is, do you know how to expand on that? So that, that is coming from the $18.7 million. As you'll recall, as we talked about, I think you heard from Megan O'Toole a lot last year about that, that money has specific confines associated with it. 15, up to 15% of it can go to like vehicle charging stations or charging infrastructure generally. Often called EVSE or Electric Vehicle Support Equipment in case you hear that acronym thrown around. That essentially means it's not just charging stations, it could be hydrogen fueling stations and other things that count as sort of in that, in that way. Those, that, that money we plan as we and you I think all agreed that that 15% appropriately should be spent. We have been out for one round of proposals already and I believe it's going to be announced soon the results of, of that and I can safely say that we've received much more interest than we had resources for in the first round which is encouraging that communities and businesses and organizations are really looking to put charging stations in place. But it's also important as we think through these issues to make sure that, that we as the state play the gap filling role. One of the major needs is, is in the fast charging network to help people really get around the state that is more of the sort of gas station equivalent model. And there are parts of the state where it's not going to be economic for somebody to install one anytime soon and that's where the state can play a role. And I think it's an important, so that's. Thank you. I'm trying to keep it on the forefront that it never gets overlooked that there is great concern that electric vehicles don't give those pennies to the infrastructure that task powered vehicles currently do. We have figured out how to, how to be an incremental tax that isn't annually, we say you drove this many miles and now you've got this huge bill but that as you're filling your car you give us a couple dollars towards the bridge in the road and I just hope that doesn't get lost as the transportation voice now joins what was just climate oriented voice. Absolutely and I think you will hear some from Riley about that next, actually hear a lot about it because that's part of what the PUC proceeding is looking at now, which is exactly, and it's not, you know, it's, it's, let's get past this sort of free rider discussion and get to, what does our transportation look like, system look like in the future and hasn't paid for it, right? If, if our equivalent of the gas tax is, you know, is how we pay for the network now, what does that look like when we're not selling gas in such great volume? So that's, I think that's a great discussion and Riley will go into more detail on it. Thank you. My, so my, my concerns are, my question is really the inverse because I think we, we heard from the colleagues in behind you the financial impact of the EVs that are on the road today is about $200,000 estimated in the impact of efficiency and as, you know, efficiency goes down far more than 10 times that. So what I'm really looking at though and my concern is that the policies that we have in place now aren't connected to the greenhouse gas reduction commissions that we have that are not connected. There's no clear path between the policies we have today and getting to the 2025 comprehensive energy plan or especially not getting further out. So I'm wondering if you think that TCI will allow us to get to a place where we can connect those policies and one of the biggest things that I'm, that I'm focused on this year and want to learn more about especially in light of what your Climate Action Commission recommendations were is that we're excited to have about the incentive proposal and concerned that it's only maybe going to be 200 or 300 grants that come out of that which is going from a couple thousand cars to 2,500 cars. When we've got goals that say we should be looking at something like 50,000 cars being in the fleet in five years and so I'm just wondering if you think TCI can help us drive that and if we're really going to read this in our goals and if it would be helpful for us as legislators to drive that connection between our greenhouse gas production policy and the policy that we have around TCI and our participation. So you pretty much went to the heart of the point of the discussion. I will answer it in a few ways. We don't necessarily know exactly what TCI is going to look like because we could create a program there that everybody could agree to that had a cap that was too high that didn't go down in any sort of meaningful trajectory and it wouldn't produce the results you want to see. We drove it down to the point where we could actually meet any of those things and it was a drag on the economy and on individual repairs that there's a sweet spot in the middle but we don't know what that's going to look like. So that is generally the idea is to align a cap trajectory that meets or matches our goals and is done in a way where we based on the economic model we can kind of see what the impact is going to be in theirs. A spot in there that makes sense so I'm not I don't have an answer for you because it's hard to know what this is but there's the potential for it to work and there's the potential for it not to work. It certainly is and then to your broader question about what can you do to sort of help to show your intent and push it along I think there's a couple of things that I would ask one and certainly the legislature has already provided the administration, past administrations I can't remember when the law was put on the books to advocate for regional compacts around emissions generally. We are operating sort of under that authority now there is also so that's there in terms of if we were to need anything to be able to negotiate there isn't anything that we need I think the thing that I worry about if you were to weigh in is there are lots of pieces to this that are going to be given takes with the various states. If we say in Vermont we need it to look like this and it I can come back with a solution that looks like this but gets us to the same general result what do I do there, right? Because if I can't deliver this one then I'm not going to comply with your directive but but if I so I can't come to agreement with the other states on this because you told me to do something else and so there are lots of different ways that we can set the various framework of the program reach roughly the same emissions reductions and do it in such a way that meets different constituencies needs and each of the states brings a slightly different perspective on this kind of what they can what's supported in their communities and what's supported but it's a I would just ask so that my ask is essentially if you're going to show your support do it in a way that doesn't ask for specific outcomes to more of have an evaluation process of the outcomes at the end to say whether they're acceptable to you I guess that would be more of the approach that I would recommend I was going to ask a similar question that I wasn't thinking of what might be a directive but rather authority that you feel you need any more authority or at some point you probably will so I I don't think we need any more authority now I would look to legislative counsel to see if they have any additional thoughts on that but we feel pretty confident that we have the ability to do what we're doing now the way it worked with Reggie was the sort of the initial year the legislature put some broad parameters on the program and then gave us will-making authority to do the rest I could see something similar to that happening again obviously there will need to be a discussion about the revenues that are generated and where to appropriate those so you know if that were if we were to move forward with the program then obviously that's a discussion that we'll need to have this building next year well if able to and willing to I'd like to hear a scenario of what we might be looking at and I know this is going to be another place where for example with the difficulty of transportation and CR2 emissions because Reggie was mainly dealing with enormous power plants and all of that public business we use them every day but we're pretty far from that the regulation of that and that's really the problem the difficulty of transportation versus the electric especially can you share with us possible scenarios what this might look like and tell us how it would be affected sure I can try so one of the questions is always sort of how how does a depending on where we put the point of regulation which is one of the questions right is it some sort of upstream wholesaler or distributor or a refinery level right where exactly does that fall which fuels are covered because their well Vermont doesn't have robust poor infrastructure other states in the region certainly do and are certainly interested in whether or not those are covered so it's where does that take out so those are some of those general pieces so depending on what sort of hit the nail on the head it's going to be upstream as it is with the utilities but the utilities are also the generators at that point as well we are all the generators of carbon emissions from transportation so in trying to figure out what it looks like for for whoever the regulated entity is to comply in a cost-effective manner might be to more carbon or less carbon intense fuels things like compressed natural gas or other things whether it's biodiesel and other things there are opportunities to comply that aren't simply selling less gasoline and diesel sort of fossil fuel based gasoline and diesel and so it's hard to know exactly what will happen because we weren't expecting some of the innovations that occurred in the power production sector and we got way more of that than we were expecting and so that may happen once the signal is in place that this is where we tend to go as a region then we'll see some of that sort of innovation take on yes I mean that's and for the TCI discussion certainly we wanted to make sure that we didn't miss the salient point of what you just said when we did cap and trade with Reggie it drove more innovation than we expected and drove down to the greenhouse gas emissions of our electricity so the combination of innovation and honestly cheap natural gas is a huge factor in that and the reinvestment of proceeds into efficiency work so that we were using less energy has led to Reggie being way more effective and way cheaper than we originally thought of so if you were in a group with the TCI could each state just determine where it wanted to invest the proceeds we could say well we want to invest in electric vehicles and somebody else wants to invest in modernization I think that we as the executive branches of all of these states recognize that we don't have the authority to say where we're going to invest in that's your job we can make recommendations I think there probably will be a statement of principles around where we think it should be invest and I think that will include everything from electrification to public transit to especially things that are focused on for how we make this an equitable transition I think it will also focus in on how we make our transportation infrastructure more resilient right we know that the transportation network that we have now is subject to the devastation of climate change related events how do we make investments that move those investments forward and reinvest in the system in a way that is survival of for climatic events and but I don't think it will be prescriptive to the point of saying you will spend 15% on the incentive we'll spend so there's some of the millions of dollars in allowances oh and the X number of dollars from the allowances and then that would be a legislative decision about where we allocate it just a little bit of an alarm bell went off and we spoke to the chief natural gas being a key component because I think there's some concerns that maybe the full cost of that has been paid for yet but there's some concern for the infrastructure so I just want us to be a little bit cautionary about what might be available as dollars when we're talking about it I don't disagree with you I'm just conveying what the facts on the ground no I appreciate that exactly it was easier technology was available but the achievements of natural gas and the availability of it was a huge part of the success of the program you were finished with what you wanted to tell us I am I know it's complicated I imagine more than one conversation about this but I just wanted to sort of bring up the basics of where we are and I'm happy to come back when I know more about what the process is going to be we're meeting at the end of this month down in DC all of the states together to sort of hash out the process about decision making in the life so Mike and then there and then David we're presiding Berks mentioning authorization and then we want to ask the boundaries of what's going to be discussed around poor MTCI are really going to be focused on the transportation in every sector and not that has been the nature of the discussion since 2010 right, not the other unregulated fuels that we have correct my mind transportation transportation and climate initiative to spell the acronym I can remember to Srej and this is the other time at TCI but thanks to the methane emissions at the source of natural gas I don't believe so I would have to go but I think it's simply the emissions from the burning of the so I but I would need to ask I could find that out and get back to you okay so kind of room to imagine what you said today so I'll ask kind of a global question does is Vermont a net gainer in these negotiation processes is Vermont a net gainer with regard to Reggie as it's been formulated and do we get we are in Reggie for sure we gain more than we put into the system that's without a doubt is a little more complicated because our miles driven per capita is higher than our use of electricity per capita in a general sense but so it all depends on how we negotiate what the sort of who gets what out of the system and that's why that's where the horse rating really comes in and that's where the flexibility of the negotiators come in to be able to say I can live with this piece or a share of the proceeds and there are states that are more student in the outcome than they are in the proceeds because they're getting so much of it that doesn't matter but for us we're a rounding error in Reggie and we'll be roughly rounding error here too and want to make sure that we are a proceeds a match that we can reinvest so we really don't know what's going to happen with these negotiations and transportation but let's just hypothesize that we aren't a net gainer in these negotiations and so how how is it anticipated that we would pay for that deficit the gist of it? I do get that question so it won't be a sort of there won't be a bill for the state that comes due at the end of it and the costs associated with will be sort of on an ongoing basis and it depends on how much revenue we bring back in and what we do with it to sort of figure out what the overall impact is and I think if we come back and we realize that it's really not a great investment for this date of the month and that's where the hard decision making comes in whether or not it's an appropriate mechanism if this is not a forgotten conclusion this is to say this might be a policy that could work but we need the details to be able to make that decision so you kind of stood in and answered the question you helped a little bit so how would we actually pay for it? so the policy the way it works we all pay for it with Reggie the costs that the allowances that the utilities have to buy they're going to defer that cost down to their rate pairs eventually the overall effect on bills across the region has been negative that we're all paying less for electricity because of Reggie because of the efficiency work that's happening so the actual impact on the bills across the region is a good one for positive economic peace it's taken care of way back at the wholesale yes so tell us how it would work that would be the same sort of thing that the wholesaler would pay the cost and pass that cost on to the consumer in terms of windcast yes in terms of the fuels that we're going to cover well not as considered now heating oil wouldn't be part of that it's only been about transportation so that was my question the challenge for transportation a few transportation so kind of like with Reggie we the average guy don't really understand or figure these sense these calculations with regard to our electricity we pay it and we don't think much about it absolutely so you're saying it's going to happen somewhat that way it would be you would simply see it in the cost of electricity we're not going to be keeping track of it on weekly basis we probably I don't think we would really ask a wholesaler to figure that out that's a calculation they need to do as a business to be competitive and to cover their costs but it's not something I think we would try and it would be something to consider I think the other sort of broader piece is that the difference between so there's a sort of the carbon pricing models that are typically out there and the tax where government sets the price and hopes for emissions reductions accordingly the cap sets the emissions reductions we want to see and lets the price respond to what the market can meet and that's the benefit of the cap and trade approach is that generally speaking the prices are lower and you also guarantee the emissions results for me as a regulator concerned about the pollutants going in the air I want to see us meet our goal and do it as efficiently as possible and if we can't do it in such a way we need to have a different discussion about how that should work how long have you been doing this let's see I have been working on Reggie issues since 2013 when I worked for the state of New York before coming home to work on it here so okay Mary so what what has happened since it's been nine years since you got together yep well I wasn't found for the first I wasn't involved much in TCI in New York so I don't know a lot of what happened in year between 2010 and 2017 but I think that the delay has been mostly a reflection of all of the issues that you've been raising about how exactly do we get those emissions reductions it's easier when it's large point sources one in one series of investments and get large reductions when it's an individual choice for all of us on how we drive what we drive if we drive that's a more complicated discussion I think that the conversation in 2010 wasn't advanced that far you really weren't on the market in a meaningful way at that point and so there wasn't a technological solution to for the vast majority of entrepreneurs or folks around the region that was cost effective and so we've come a lot the technologies come a long way there are options that are out there and I think that's helped make it get to the point where there is enough sort of broad based support for acting in this sector that that's why the progress is that made more of a difference are we going to need to just to question about the Western Climate Initiative that's already up and running that's consisting what would it be are you looking at what that would be a greater benefit already set up easier to penetrate to I don't really know what their success has been in terms of transportation but just what can you say about that? so it's a complicated system we have Reggie's been affected in different sectors of WCI you don't have to join the whole program WCI, the Western Climate Initiative covers all sectors of the economy so transportation, building, heating, industrial energy use and the electric sector among other things but so we probably wouldn't do Reggie so it would create a price distinction right now the price for Reggie is I can't remember where it is but it's basically a third of what the price in WCI is and WCI hasn't actually really addressed many emissions from the transportation sector because of the cap at this point because they're still getting all their efficient emission reductions from the power production because that's where it's easiest to get from as we've seen with Reggie so they're essentially on the same path we are the generally transportation fuel folk have been able to be net buyers of allowances and complied in that way so while they have used many of the proceeds associated with their capital trade to invest in programs that cover all fuel types the actual reductions as a result of the cap have primarily been from power production there has not been a discussion within TCI about the group as a whole about joining WCI primarily because I think most people think that prices is higher than their communities would be willing to accept and what's WCI? Western Climate Initiative it's the California thank you very good so now we have Riley and then much of our engineer is with you so so Molly Brian and Dave I hope you don't mind that sometimes I just need to introduce you to remind you to speak to the whole committee I used to sit right there Brian and I did it every time I had a question so I don't expect you to remember but don't mind because you tend to get into a conversation with the witness you get softer and softer as you're just chatting you used to sit at that end and I used to sit right there so I know I did it and I've never sat here you'll figure it out on the right Molly does it she does it I'm sorry I got all without you officially releasing the help that's on me I said thank you that's my submission so I'll just say for the record my name is Riley Allen I'm deputy commissioner of the department of public service with me is Bill Jordan he's our head of the engineering department at the department of public service and in the back of the room there's a daughter who's with her planning group and I think he gave this presentation last year so I've stole some slides from him so I've got to take care of that I do have paper copies I wasn't sure if there was electronic but you have paper copies for those of you that would like it so I'll just kind of pass this over thank you Swinney I'm going to say I'm not in line right now so I need work thank you okay okay very good so this is the first time I've testified this year before this committee I'll just say a few things about myself just to orient you a bit so I am a deputy commissioner I've been kind of on and off of the department for more than 30 years in different positions throughout so I'm fairly familiar with the regulatory scene and with the electricity regulation Bill Jordan has also been around a while and will help with some engineering questions also work for a number of organizations in Vermont and overseas working in Africa for regulatory issues so I'll walk through the slides I have control over this I just wanted to let you know what I plan to cover in the presentation I think I have around 40 minutes or about minutes feel free to ask questions as we go along I started with a discussion of the goals that we have that are relevant to transportation I wanted to talk a little bit about the status of electric vehicles in this state where we are and kind of making progress relative to our transportation initiatives and electric vehicles I want to touch on the public utility commission investigations investigation into electric vehicles the legislature last year asked for the public utility commission to help kind of advise on some policy issues and I'll just update you on that a bit transportation fund that came up in the prior question that's an issue that's before the public utility commission they're asking questions about that the department is working with our sister agencies we have a position that we think is relevant to and kind of speak to the options that the commission is considering for addressing the funding issues I'll talk about the load forecast part of the concern might be that these are potentially very significant new loads what are they going to do to our grid and what are the invitations Bill is going to back me up there if we get into some technical areas but I feel like I can cover that as well and then I have some extra slides that are also relevant to the issue of electric vehicles and grid integration what I'm going to try to communicate through that is with effective rate design we can actually take what are flexible loads electric vehicles are immensely flexible loads and we can kind of mold them to do good things and that's part of the message that I hope I leave you with so I remember that this transportation is really not energy technology so you just came out of that briefly explain some of these concepts I'll go into the level I mentioned we'll build that first I'll talk about that so the next slide which is slide three this is a list of the goals from our comprehensive energy plan you may hear mention of the comprehensive energy plan from time to time this is a plan that was adopted by the department and the then Schumann administration and it articulated a set of goals and objectives some of which are I think mirrored in statutes some of which extend beyond statutes 90% by 2050 you'll hear that mention a lot that's the renewable objective 90% of our total energy objectives will be met by renewables by 2050 there's also a kind of a carbon related overlay on that the greenhouse gas goal is 80 to 95% below 1990 levels by 2050 I think there's a role also in statutes 75% by 2050 relative to the 1990 levels here's a visual that came from the Vermont Climate Action Commission Peter's gone Peter led that initiative it shows you kind of where we are in terms of our greenhouse gas emissions and some of the relevant goals that we set and essentially what we need to do to accelerate the our improvement or our path in order to achieve some of these goals we've already missed one of those goals that was one that was in 2012 it was called for 95% below 1990 levels and I think it was in 2012 but we have other targets that are still in front of us that we're going to try to meet so this is this next slide on slide 5 is just to give you a sense of proportion where is transportation in our what is transportation relative to other energy in our overall portfolio in terms of the actual BTUs transportation at least according to the EIA data is about 38% of our energy demand in terms of energy expenditures it's also about 38% in terms of greenhouse gas emissions it's more like 43 or 44 I see different numbers 47% but it's a big it's where a lot of the opportunity is to make quick progress just to clarify a question on the prior paragraphs when you're looking at the dollars for energy are you excluding the taxes etcetera I'm just a little bit again going back to the infrastructure component of what we spent for our transportation dollars I'm not sure that I'm curious if the energy includes that well I pulled this from EIA I don't think they exclude the taxes I think they just kind of do the math off the top and say what are the energy expenditures so I think these embed with them in any of the taxes that are associated with them I just want to further emphasize that as we look forward when we're talking about the cost and there's been an example given to the table that there's this wonderful discount on what it costs you to fuel your vehicle when you use electricity I think that we we're removing also something that's being purchased it's not an apples to apples it really needs to stay out there I have a slide I think that speaks to that I think we're covered so the greenhouse gas major contributor major factor I just to kind of reinforce that point of that it's covered in the comprehensive energy plan the importance of kind of moving on transportation and progress toward our greenhouse gas objectives but this is a report from the energy action network they list a number of things that we need to do you see the first item is electric vehicles and making progress on transportation that's really where there's a lot of opportunity so now I'm going to get into the second topic which is current status where are we as I'll show in the following slides there are actually 614,000 registered vehicles in the state and we're at about 2,800 electric vehicles relative to that amount so we're still the very early stages of making progress in terms of moving our electric vehicle fleet towards significant concentration within that sector there's a slide to the right that is kind of helps one to sort of understand the evolution of new technologies and how they enter as an S-curve there that shows where you are at different stages we're still at the very early end if it's we're in the innovators stage we have the early adopters that are even preceding the early adopters of the road of entry there just a couple statistics vehicle registrations it says 777,000 registrations but this includes trailers and other things I think the relevant number is probably at 614,000 become road worthy vehicles that are out there that are registered we drive about 3,000,000 miles in Vermont on our roads and that's a number that's increased over time but it's been relatively steady for the last decade or two we have about 200 publicly available charging stations around the states I think 209 now but we need to make a lot of progress I include this slide on number 11 because I find this interesting it helps you to understand or helps one to understand why it's such a challenge to make quick progress with the change over in the fleet every year we'll have a significant new tranche of vehicles but vehicles last a very long time electric vehicles may be less than internal combustion engine vehicles but the way to average life I'm guessing is something in the neighborhood of 12 years and this is the curve that shows you how they age and what has to kind of be displaced over time there's still a significant number of vehicles that are still on the roads from 2000 or 2000 in the late 1990s the next slide gives you a sense of the types of vehicles that we drive we drive a lot of trucks we drive a lot of all-terrain we drive a lot of vehicles that can do well on our back roads and can carry cargo and do other things the top models include the Ford, Chevy Toyota Super Road not until you get down to Toyota Corolla that you get down to a kind of more standard passenger vehicle car but looking forward there's kind of good news which is there are new announcements of electric vehicle models that are being introduced all the time this happens to be a slide it's actually from 2017 so in the intervening period there have been major new announcements from General Motors I think for 20 new models that are coming out that are going to be electric you have Ford has announced some of its trucks are going to be for plug-in charging electric vehicle but what you see in this chart is the range of the vehicles and the models are coming on from a wide range of manufacturers touch on the PUC investigation as I mentioned earlier Act 158 from 2018 required the public utility commission to conduct an investigation with respect to electric vehicles they're making good progress they opened the investigation in July January 23 they issued a letter to the legislature with their recommendations relevant to some jurisdictional issues what should the jurisdiction of the commission and the public service department be relative to electric vehicles and their recommendation is largely to exclude charging stations anyways from the jurisdiction so we would obtain jurisdiction over the traditional utility apparatus and their involvement in electric vehicle charging certainly the charges that they charge on the public charging stations but not the charging stations themselves Mary just a quick question what if some were third phase 3 what if that added a peak to the utility have you thought about how so that's a topic that I'll be covering more extensively later in the conversation but some of the high points are one we actually have a lot of headroom in our system currently and I'll try to share that graphically it's important in my mind that we send appropriate price signals and that we price whatever system costs that fast charging stations or anyone else frankly imposes on the system and ensure that other non-participating rate payers are protected from that so that's a great design and that's part of the conversation we do have demand charges and we do have great structures that try to get at that the department just issued a report about a week ago that speaks directly to things that we can do with demand charges or to address those peak challenges and opportunities going forward even better than we have in the past so that's a fairly complex rate design but that report from Act 194 is available on our website if anyone's interested in the details there but that's the topic I'd love to talk about and I could kind of geek out on that but I'll let you go for that and a great design and EV charging and the transportation fund or topics that the commission is essentially help us with so the department is working with our sister agencies the agency of transportation and the agency of natural resources to essentially help facilitate a sensible solution around the transportation fund I think the monies that are affected through diesel gasoline sales I think they're in the neighborhood of $97 million something like that I'll defer to my colleagues from the agency of transportation on that particular issue but I see that as kind of the reference point as we move from electric vehicles to gasoline and diesel vehicles what happens to those ones and how do we kind of make those up we think that there's a sensible option leaving the interagency group and the department of public service in a voice before the public utility commission that we place a fee or tax on the kilowatt hour sales that is that there be essentially a component of the charge to retail customers that help to address the shortfall now you might say Jolly G isn't that problematic are we trying to encourage electricity sales why would we really want to kind of put that price there I'll get to the reasons but the good news is coming back to the issue of rate design is we think there's a lot of a lot of room that we're going to create to make that possible so would you see the graphic in front of you get started by just providing some reference points on the right hand bar you see essentially the cost per mile for gasoline that is associated with traditional internal combustion engines it's pretty high it's in the nature of 12 north of 12 cents per kilowatt hour that green area on there that is intended to reflect the transportation fund that's the tax that is essentially on the bill that's how much is essentially flowing from that price of gasoline to pay for our roads through the the fees of taxes that are gasoline and diesel middle bar the gray bar is simply the retail price of electricity so that's something in the neighborhood of 15 or 16 cents per kilowatt hour is what we pay for electricity currently so if we just flip from internal combustion engine vehicle to an electric vehicle there's a significant savings in terms of the energy cost per mile just moving from one to the other now it varies between the system so in the non-electric co-op territory that would be a much higher number and in the Burlington electric territory that would be a lower number but on every one average it's something in the neighborhood of 4 cents per kilowatt hour so it's 12 cents per kilowatt hour versus 4 cents per kilowatt hour now I'm here to tell you that we actually can improve that further what you have because electric vehicles represent a flexible load that is they have a huge battery system embedded within them charge those vehicles pretty much you have an awful lot of flexibility there's 12 hours a day where you have an awful lot of flexibility I think the average person drives maybe 30-35 miles a day to get to it from work maybe stop at a shop or two but there's not a lot of energy typically associated with that that would roughly equal maybe maybe 8 or 8 or 9 kilowatt hours with electricity to essentially move that this it might be a gallon of gasoline or it might be a gallon and a half of gasoline but that's the cost to recharge that you probably need in the neighborhood of an hour or an hour and a half of charging time typical vehicle on the roads is idle or is parked for 22 sometimes more than 22 hours of the day that's a lot of flexibility there to choose when it is that we charge the vehicles again maybe different than when they were actually charging and that's kind of an important point you may get home from work at the end of the day you may plug in your vehicle doesn't necessarily have to charge just at that time it can charge after 11 o'clock you can be on a time of use rate that can provide you an incentive to sort of charging at 11 o'clock at 12 o'clock but you don't want to set 11 or 12 o'clock either everyone starts doing that that can be a problem as well so you might want to implement some mechanisms that help you to kind of feather in that charging at 12 1 2 o'clock in the morning what you need to do is you need to cover that vehicle needs to be fully charged by 6 or 6 30 in the morning the next morning when you're ready to go that's kind of the thing to be aware of generally that what this left hand bar here is intended to show is that we have at least from a system perspective there's value that can essentially be captured by managing those loads to the the system so green mountain power can benefit burl until electric can benefit our other utilities can benefit because they can manage those loads around their monthly charges for the bulk transmission system so the R&S charges they can manage those loads around high energy price times they can manage those loads around the forward capacity market and that has real value to burl until electric green mountain power and our providers and that is value that can be used and passed on to the retail consumer without harm to the system much deeper than even that great bar there that 15 or 16 cents one of our utilities has already made some progress in this area they brought the rate down essentially down to 8 cents kilowatt hour there's still a margin there's still a contribution that is being made to the system through that rate but it creates room to essentially feather in or layer on that attacks if you will or fee to help cover that green bar which is the transportation part so if we can create a kind of mechanism that further further creates an economic advantage customer economic advantage to move toward electric vehicle we have room to essentially layer in a charge to cover the transportation fund and the revenues that would otherwise be lost from the movement from internal combustion engine vehicles to electric vehicles I'll pause there so I am so excited about this image of the future where we're using creative rate design in order to signal to people where the solar sun is shining I'm imagining getting a text online that I can charge my electric vehicle at the lower rate because there's power locally like those kinds of things are so incredible and I'm so excited about this conversation I'm wondering if you could tell us at what point in the adoption of electric vehicles like how many electric vehicles do we need to get on the road for this kind of pricing model starts to make sense and you may have heard my comments in Deputy Secretary Wolk's presentation that I I think other people on this committee are really concerned that like how do we get to the place where that makes sense from where we are right now given the limited resources we have to kind of get the market to move faster well and we can do it today there's no reason we can't in fact we have we have at least one utility the Burlington Electric that has essentially moved in this direction we have another utility, Green Mountain Power that is interested and is engaged around this topic I think they're looking hard at different ways to do it I just want to be clear that it doesn't necessarily require the end user to essentially do something different I don't need a text message from Tim or from Green Mountain Power to motivate me to say I've got to plug in the vehicle I can come home, I can plug in that vehicle I can already have my charging infrastructure at home set up to automatically flow the electrons at that time so there's a software set up potentially to respond to those price signals I can do it on the dashboard of my car it doesn't have to be through the charging equipment or I could allow Green Mountain Power or Burlington Electric they will offer me a discounted rate in exchange for their ability to manage the flow so they can feather in the loads at 2, 3, 4 o'clock in the morning so that everyone isn't suddenly charging their vehicles at 12 o'clock in my world you could have other third party entities actually playing a role in the user and the utility that is acting as an agent either for the utility, the customer or both that is essentially providing services that are essentially analogous to what either the customer doing it on their own or the company doing it on their part to further extend the reach of that flexibility of the goal being that you want most or almost all vehicles on some sort of a flexible charging plan ideally without any inconvenience to any of the users Let's try to have you get three years slide and we will try to hold more questions to you I apologize I get a little excited about that stuff so here is an example that happens to be analogous to what Burlington Electric is going to produce to charge from about 15 cents per kilowatt hour Why a per kilowatt hour charge we think it is there is a fairness issue we think it kind of reflects the impact the adverse impact of heavier vehicles on the roads heavier vehicles will consume more kilowatt hours and so there is a symmetry there a parity with the gasoline attacks is essentially what we are doing to electricity and by the way obviously travelers also are cost causes for our road system so if we can take it out of the registration system and oppose it on the volume of energy they are helping to contribute to the costs that they are causing how would it occur mention the sound rate design we think it can be sleeved into a good beneficial electric rate doesn't require some creativity from our utilities but they have already demonstrated that they are able to handle this and manage it Burlington is an example there are potential complications for some of our smaller systems that don't have some of the infrastructure that our longer systems have so there might have to be some accommodation there why now as we talked about earlier we are just getting started with electric vehicles it is much easier to get this neatly dealt with at the early stages than it is to wait another five or seven years when there actually are a significant volume of vehicles out there that are suddenly going to feel the impact of an extra charge better to sleeve it in as we are talking about rate design so we do it all in the adjustments all at one time so that customers see the benefits they don't necessarily see the downside effects of making that change demand charges I heard that you all were interested in the topic of demand charges just issued a report last week on demand charges we introduced the concept of at least a relative to to charging stations especially if they are high voltage DC charging stations can potentially have adversely impacted by high demand charges that creates a problem for all of us as we want to move this electric vehicles forward because high operating costs for them means that the economic case for creating new stations is going to be adversely impacted we think there is a sensible way that doesn't adversely impact other customers essentially making some reforms to demand charges so that we address both the needs of these stations and the system to not adversely impact the system and other rate payers design demand charges are designed to do just that so we have demand charges demand charges this is real so we wrote a 25 page report this is I could honestly spend an hour and then some talking about this but I'm not suggesting getting rid of them I'm suggesting reforming how we apply them so we have more surgically targeted the cost that they drive rather than really talking about more efficient pricing signal rather than the relatively broad brush approach to deal with the issue but these big past chargers doing peak hours they're in use there are options available they could install battery if you could surgically identify the hours what's that what you just said wouldn't necessarily change the rate it probably does what I'm suggesting is an example would be applying a demand charge maybe offering them a dynamic credit for interrupting their charging they use a local batteries system to essentially charge their station and their electric vehicles for an hour while the system is experiencing either a monthly peak or an annual peak so there are workarounds and broadly it's about creating potentially retail price riders or other dynamic mechanisms utilities, renowned powers already kind of thinking about and applying happy to talk about that and there is a report and this is I think my last slide before I get into questions but this just gives you a sense of the loads we built up our system historically loads were growing to 100% wasn't until about 2009 or 2010 that we started to realize oh geez loads are really materializing lots of reasons for that our forecast going forward seemed to suggest a significant growth in electric vehicles but in terms of the overall load growth the loads are actually this is actually over a 20 year horizon we're not yet achieving loads assuming the worst possible load shapes basically current load shapes are continued to apply we're still not even building to the peak that we hit historically in 2006 so there's a lot of headroom there on our system to allow electric engology if we can just manage those loads through efficient rate design we can accomplish much more for consumers integrate renewables to integrate electric vehicles and other loads a lot of good things this is kind of a visual of that relative to the region historic peaks what you see is loads just didn't materialize relative to what we were forecasting this is kind of where we are we're looking going forward with energy efficiency continued to contribute and these other slides just to show you just how flexible these loads are and how they can kind of be managed through effective rate design people are very responsive to the price signal they've said all stop there okay if you have asked your why now slide that has the current revenue adoption I just wanted to because we're concerned about the transportation fund that we have here first and foremost so if we got to 100,000 EVs so that's like a core of our light duty vehicle fleet in the state the net revenue impact if we did nothing if we charged them nothing is this really saying it would be between 1.5 and 1.8 million dollars a year am I reading that right? I might have to defer to Michelle on this one I think this is her slide I would study it I'd have to study it that would be great to really understand a lot of the reason we're here and we structured this this way was to because there's this anxiety about EVs and I think what I'm taking away from this is that the impact on the transportation fund is next well it's 2 million dollars if we hit 100,000 and do nothing so I think what it is right now is only 100,000 dollars a year and so I'm much more concerned with not having enough EV adoption than I am about its impact on the T fund in the short term and the long term absolutely we think transportation fund issue needs to be addressed and we want to address it at the front and we kind of have received that we received that message very clearly over the last couple of years and we think that's an important step in kind of making progress on the lack of vehicles I think you have to grow your charts but at the cost for a total of an hour do you have in there a charge that's the green area on that on that left hand bar but when you said that with the T fund that's what you meant okay so you went roughly with that same vehicle that size yes I'm sorry I didn't get the answer so two questions it came up before before you were here Dave and Connie were interested in what and build out what we're trying to do how is that going to look physically and my question was how does it work for meeting that boat our electrical system now in the state how do we meet that boat which is not there now so it's the kind of same similar question how does it look actually I mean I can I can only speak in terms of general 209 stations currently most of the charging that occurs at least currently 85% of the electric vehicle charging is at home I expect that in the future most of the charging is probably going to be at home or in the workplace as the future kind of unfolds I suspect that what we're going to see is we're going to gravitate probably to more fast charging stations relatively high volume DC fast charging level 3 stations and we're going to need a fair number of those in the right places and that's also kind of a great design issue and we're trying to kind of motivate that through our use of VFB funds and other things they're in my mind there are potential strains on our electric system it's going to be relatively location specific our system at the transmission level has in my mind is never really going to be adversely impacted by transportation we're going to manage those loads the only sensible way to do this is to manage those loads even if we didn't manage those loads within the next 20 years doesn't look like there's much risk that there's going to be mass adverse impact but if you put a high voltage DC charging station that is essentially pulling in electricity at 350 kW that's a lot of juice that could strain the system and that's where Bill Jordan might be able to help us further can you add anything to what I just said I can add a little bit I completely agree with your assessment of the bulk transmission system and where there may be issues if there are any would be down at the local system and the individual utilities on the distribution system would need to assess that if they know the charging stations are getting built they can plan for that they also even if they didn't and the load surprised them they would see it on their monitoring system that there's an increased load there and could plan for infrastructure upgrades on individual circuits it would be a local effect not a statewide effect I take it when we remember that we are electrifying station and we are adding tremendous amount of air conditioning that doesn't even exist before the heat pumps so now anybody has air conditioning because it's okay with the heat pump so remember that and then to have a high portion a large portion of our transportation and the electrified including with fast charging and I this is the first I've heard of the lot of that's 180 volts that's tremendous that's why I question how how I'm going to deal with that peak in the map we're not supplying electricity for such a load today where's the electricity going to come from well the source of electricity the additional electricity are you asking about the source of electricity the capacity to deliver it both the source of electricity would be purchased on the ISO New England market if the utilities didn't have their own contracts or their own generation and ISO New England has some headroom on its system in terms of generation in terms of the capacity to deliver it on the local distribution circuits they're all different some have a lot of capacity on them now and we're seeing this with solar projects which is the opposite problem of exporting electricity instead of importing electricity that some solar projects there are so many on the circuit that it's approaching the capacity of the substation and as that if that would happen with electric vehicles the utility would be aware of it and would need to integrate the transformer or other aspects of the substation or maybe even the wires on the system Mr. Chairman in my mind it's kind of exciting because I'm an economist and I think the elegant solution is actually pricing and I think there's a way if you imagine these are new loads but they don't necessarily require kind of all the electrons flow from upstream and central station generators increasingly the system is shifting to a world in which the generation is happening locally you can well imagine within the household the wire system may not even see the flow of electricity you may have a PV panel on your roof you have an electric vehicle in your house you may have a Tesla power wall on the house what the system is going to need to address is kind of the residual loads when all that isn't kind of being managed internally so it doesn't necessarily lead to and to the extent that you can get the distribution company to think in terms of locational incentives other rate design solutions you can kind of rationalize things without necessarily kind of building building up the overall building system I would say we have automatically coming in kind of 70% load factors that means 30% of our system is being underutilized at the regional level it's more like 46% of our system is kind of underutilized no I mean the difference between the capacity of our system is that is 100% load factor being all the energy all the loads are essentially matching the generation all the time and there isn't any difference between the bricks and mortar and the wire system and the loads we're just using the system at 100% efficiency where it is at full capacity essentially all the time right now we're using the system at the regional level something like 53-54% within Vermont we're much higher we have much better load factors it's in the neighborhood of 7% so we have some flexibility to move loads around to help smooth those loads and that creates potentially a lot of head load I do want to break the committee so I'm going to pursue this with mine I'm actually frankly not satisfied I'd like to talk to you offline I'd like to yeah, thanks Thank you Any other questions for Riley? He's coming back sometime I will have questions as we get more into this because if they're going to have to upgrade if you're a local distribution company it's going to have to upgrade they of course are obviously there but they still have to go through the C hearings and all of this and the question do the great payers of that upgrade does Brian Savage want to put in a huge charging station commercially? I'll ask them Yeah, they're good questions and they require good answers and I'll try to do a better job in the future I don't need to criticize your answers Okay, thank you