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From YouTube: Business Meeting for Tuesday, June 14, 2022
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B
Good
morning,
all
right,
I'm
dwight
king,
I'm,
chair
of
the
kansas
corporation
commission,
I'm
joined
this
morning
by
fellow
commissioner,
susan
duffy
and
andrew
french.
At
this
time.
I
will
call
to
order
this
meeting
in
the
kansas
corporation
commission
on
this
tuesday
june
14
2022.
commissioners.
The
first
manners
up
for
our
consideration
this
morning
are
17
items
on
the
consent
agenda.
B
I
would
denote
this
at
the
outset.
That
is
my
intent
to
recuse
on
item
number
five,
which
is
docket
number
22
day
seal
in
s-3458.
B
A
A
B
Very
well
that
we
approve
the
order,
as
as
as
moved
by,
commissioner
francis
ended
by
commissioner
duffy.
B
B
We
have
one
noticed
item
this
morning
at
the
request
of
the
sierra
club.
This
morning
we
have
a
presentation
to
the
commission
regarding
svp
ordering
elcc
and
reverse
adequacy
in
kansas.
Our
presenter
this
morning
is
ty
gorman,
who
is
the
kansas
campaign
representative
for
the
sierra
club
good
morning
time.
B
D
B
Very
well,
if
you
would,
we
have
been
provided
with
a
copy
of
your
power
points
so
with
no
further
ado
I'll
turn
it
over
to
you.
D
All
right,
thank
you
very
much.
Is
the
powerpoint
going
to
be
run
from
from
you
all
up
there,
or
should
I
share
my
screen.
D
A
Michelle
do
you
have
those
slides
or
do
we
need
to
get
those
to
you
fairly
sustainable
chimney?
I
believe
okay.
D
Well,
first
just
want
to
take
this
time
since
I'm
we're
waiting
here.
I
want
to
thank
you
very
much
for
having
me
here
today,
as
chair
keen
said,
I'm
tight,
gorman,
the
kansas
representative
for
the
sierra
club
and
then
beyond
coal
campaign,
especially
and
I
we
represent
tens
of
thousands
of
kansans
who
support
an
equitable
transition
from
coal
to
clean
energy
by
2030
in
order
to
meet
affordability,
reliability,
health
and
climate
goals.
D
So
we
are
really
glad
to
follow
up
on
that
comprehensive
report
on
june,
2nd
from
sherry,
feist
dalbrecht,
where
I
think
at
the
end
of
that
meeting
about
all
the
spp
related
topics,
the
call
call
was
made
for
more
communications
on
issues
in
the
southwest
power
poles,
some
that
kind
of
could
fit
into
that,
and
thanks
for
inviting
me
to
add
to
the
conversation
around
the
the
about
all
the
changes
that
are
going
on
in
the
spp
and
the
electric
industry
as
a
whole.
D
As
we
move
toward
all
the
energy
sources,
we
need
to
avoid.
D
Over
the
next
few
years
so
appreciate
it,
and
thanks
for
putting
the
slides
up
there,
the
two
policies
I'd
like
to
present
on
today
are
elcc
and
order
2222,
and
we
can
go
to
the
next
slide
and
I'll
define
those
real,
quick.
D
Okay,
thank
you
so
elccc
on
the
top,
there
is
effective
load
carrying
capability
and
that's
the
first
of
two
rules
that
ferc
has
required
that
the
spp
implement
and
the
spp
is
in
the
midst
of
figuring
out
how
to
implement
that
rule.
D
It
uses
probabilistic
grid
modeling,
so
base
the
bases,
those
the
resource
and
how
it
can
prevent
a
shortage
by
looking
at
when
a
resource
is
likely
to
generate
electricity
and
when
electricity
shortages
are
most
likely
to
occur.
D
The
elcc
calculations
depend
on
the
type
of
renewable
technology
being
studied
patterns
in
electric
usage
and
the
type
and
quantity
of
other
resources
already
on
the
grid,
but
ultimately
it
just
measures
whether
it
can
prevent
electricity
shortages
in
any
given
time.
So
implementing
the
eocc
properly
would
allow
kansas
to
include
generations
of
resources
from
many
different
owners
in
our
capacity
modeling
and
and
give
value
for
that
capacity
to
those
owners.
D
It
would
allow
us
to
ramp
up
solar
storage
and
other
grid.
Reliability
needs
faster
and
cheaper
than
the
utility
could
do
it
on
its
own.
So
that's
a
quick
overview
of
elcc.
The
other
one
I
want
to
discuss
is
for
order
2222.,
that
one
removes
barriers
from
customer
side,
energy
resources
and
it
creates
opportunities
for
increased
grid,
reliability
and
economic
value
for
customers
through
clean
energy
like
demand,
response,
storage
and
renewables,
and
a
variety
of
other
customer
side
of
the
meter
applications,
especially
those
that
can
be
aggregated.
D
So,
if
you
put
together
a
bunch
of
distributed
energy
resources,
it
looks
like
a
virtual
power
plant
and
in
kansas.
These
are.
These
can
be
very
clean
and
affordable
generation
sources.
Order
2222
has
is
a
huge
opportunity
to
just
expand.
D
The
are
all
the
rtos
around
the
country
have
been
asked
by
have
been
told
by
ferc
to
implement
these
rules,
and
the
order
22
to
22
makes
clear
that
there
have
been
barriers,
a
lot
of
barriers
to
the
participation
of
other
energy
sources
in
the
markets
up
until
now,
which
no
these
barriers
reduce
competition
and
they
fail
to
ensure
just
and
reasonable
rates
for
customers.
D
Pretty
good
overview,
I'm
not
sure.
Maybe
I
should
stop
every
now
and
then
for
questions.
But
unless
I,
unless
anyone
wants
to
come
off,
mute
I'll,
just
keep
rolling
on.
A
Hi,
I
don't
have
any
questions,
but
I
did
notice
jeff
and
jeff.
Mcclanahan
and
sherry
albrecht
are
on
here
as
well
and
and
jeff
and
sherry.
I
think
you
you
all
should
feel
free
to
jump
in
whenever
you
want
as
well.
D
So,
just
a
quick
look
at
the
status
of
where
these
rules
are
right.
Now
in
spp
for
the
elcc
spp
provided
a
some
some
details
of
our
filing
a
few
months
ago,
and
that
filing
was
rejected.
They
asked
questions
from
ferc
and
they'll
be
providing
a
new
filing
in
the
future.
The
2222s
just
received
comments
on
june,
9th
and
and
protests
on
their
filing
of
how
they're
attempting
to
comply
with
order
2222..
D
So
we'll
go
over
here.
You
know
what
those
two
are
missing
in
the
next
few
slides,
we'll
look
at
how
that
affects,
or
what
kind
of
reliability,
affordability
and
energy
burden
issues
these
bills
affect,
and
look
at
how
the
kcc
can
incorporate
and
distribute
energy
resources
and
the
lcc
accreditation
kansas
markets.
D
So
you
know
basically
we
want
to
get
our
communities
the
benefits
of
customer
side
generation
and
distributed
energy
resources
and
wholesale
markets.
That's
the
purpose
of
these
rules
and
the
spp
is
slow
to
move
towards
successful
implementation
of
the
rules.
Utilities
are
still
struggling
to
see
how
they
can
best
meet
profit
targets
under
these
new
technologies
and
they're
in
this
new
paradigm
and
of
distributed
energy.
D
D
What
was
contained
they
didn't
and
which
is
part
of
what
was
required
if
the
rule
and
what
they
put
in
their
business
manual
was
was
flawed
because
it
applied
inconsistent
capacity,
measures
to
and
value
to,
different
technologies
arbitrarily,
including
different
capacity
values
to
otherwise
identical
wind
or
solar
resources.
D
B
D
No
sbp
has
met
the
deadlines
and
then
so
then
there
was
a
a
comment
reply
period
and
then
ferc
replied
to
the
elcc
deadline.
Spp
met
the
2222
deadline
and
then
that
will
be
consideration
of
the
protests
and
comments
that
were
just
received
and
then
a
reply
from
ferc
on
that.
So
just
moving
through
the
process,
but
no
so
so
far
haven't
met.
The
the
spp
hasn't
met.
What
the
orders
require,
but
they're
moving
through
that
process.
E
D
Yes,
there's
action
required
by
ferc
to
respond
to
the
spp's
filing
on
22
22
and
the
refiling
on
elcc.
Exactly.
E
As
with
regard
to
elcc,
what
is
the
path
for
time
frame
for
implementation
at
spp
once
ferc
would
approve
that.
D
I
know
they
put
a
year
a
20
25
2025
year
on
on
one
document,
but
I
believe
that's
part
of
what
has
yet
to
be
determined.
C
All
right
thanks
and
I
will
pile
on
too
tai.
Are
you
aware
of
any
rto
that
you
believe
they're
filing
has
met
the
spirit
of
the
order.
D
To
my
understanding,
all
the
rtos
in
the
country,
other
than
mizo
and
spp
so
far
have
have
met
that
met
the
order.
I
haven't
myself
gone
through
each
of
their
filings
to
see
which
is
best
from
our
point
of
view,
but
I
think
that
I
would
look
to
if
I
were
trying
to
figure
out
how
this
would
play
out
here.
D
I
would
feel
comfortable
looking
at
all
the
other
rtos
other
than
mizo,
which
is
moving
a
little
slower
and
put
a
farther
put
a
deadline
farther
out
for
their
implementation.
D
All
right
thanks!
Everybody,
let's
see
so
this
next
slide
here
I'll
just
go
through
a
couple
of
the
deficiencies
that
we
see
from
our
clean
energy
advocates
point
of
view
in
these
filings
and
I'll
start
with
22-22.
D
Thanks
the
some
of
the
things
that
are
missing
from
order
2222
is,
they
have
very
restricted
geographic
areas
from
which
they
can
draw
distributed.
Energy
resource
aggregations,
there's
really
kind
of
some
barriers
being
put
up
within
the
spp
filing
that
we
don't
think,
have
any
need
to
be
there
and
will
make
the
cost
and
efficacy
of
these
resources
go
down.
So
they
need
to
expand
their
geographic
reach
for
aggregations
that
they
allow
in
spp.
They
should
remove
also
that
this
very
burdensome
metering
and
telemetry
requirements.
D
So
these
are,
you
know,
basically
having
to
know
in
a
big
old
group
of
aggregated
resources,
exactly
what's
happening
from
each
one,
all
the
time
like
at
the
spp
level,
instead
of
at
the
aggregator
level
and
that's
not
required
in
most
places
and
not
necessary
and
adds
a
ton
of
cost
and
barriers
and
finally,
there's
the
process
to
approve
distributed
energy
resources
on
the
grid.
D
So
far,
there's
this
kind
of
byzantine
process.
Where
there's
I
mean,
there's
a
68
timeline
required
in
the
rule,
but
it's
a
something
that
can
expire
and
if
the
utility
doesn't
have
time
to
or
incentive
to
to
put
the
distributed
resource
on
the
grid.
It
can
just
reply
that
it
doesn't
see
that
that
resource
is
safe
or
doesn't
isn't
able
to
complete
that
kind
of
assessment
and
the
resource
isn't
on
the
grid,
and
so
there's
really
just
not
a
great
process.
D
D
It
you
know
it
might
take
that
long
for
this
process
to
be
completely
up
and
running,
but
it's
not
necessary
to
have
a
start
date
that
far
out
to
begin
the
process
of
integrating
these
resources.
D
So
that's
most
of
what
are
some
some
of
our
major
issues
with
that
filing
the
participants
in
the
regional
market
are
are
already,
I
think,
speaking
with
utilities
and
with
the
kcc.
Possibly
some
of
these
aggregators
so
encourage
more
communication
like
that
and
and
spps
filing
gives
leeway
to
kcc
and
evergy
to
work
on
these
barriers,
develop
reliable,
low
cost,
flexible
load
from
behind
the
meter
resources
ahead
of
the
to
begin
working
through
these
issues
ahead
of
the
2025
deadline.
D
Thank
you,
so
the
rule
of
reason
is
one
of
the
main
reasons
why
we
ask
for
a
deficiency
from
ferc
on
spp's
filing,
which
is
they
just
haven't,
included
anything
in
the
tariff,
and
that
was
one
of
the
requirements
there.
D
D
They
have
a
four
hour
continuous
runtime
requirement
that
ignores
some
realities
of
how
storage
can
cycle
and
continue
to
provide
effective
generation
over
you
know
much
longer
than
that
period
and
or
within
shorter
increments
than
that
period
and
finding
finally,
the
value
to
their
the
elcc's
value
to
resources
based
on
the
is
based
on
the
utility
relationship
with
that
resource
owner,
and
that
is
discriminatory
as
well.
The
utility
controlling
that
relationship
to
the
extent
that
it
doesn't
that.
D
Finally,
so
the
next
steps
there
just
try
again,
if
I.
B
Could
briefly
dwight
kane
again,
let's
go
back
to
the
real
reason.
Just
very
briefly
am
I
to
draw
from
what
you
said
there
that
the
sierra
club
has
requested
a
deficiency
from
ferc.
Has
that
been
initiated.
D
Yes,
they
ferc
replied.
I
I
don't
believe
the
reply
was
that
rule
of
reason
was
violated,
but
they
required
more
information
to
to
try
to
fulfill
the
rule
of
reason.
After
our
filing.
D
Yes,
that's
correct,
yes,
and,
and-
and
we
work
also
with
a
coalition
of
of
other
organizations
that
are
involved
here
with
some
clean
energy
advocates
in
the
spp
process,
including
nrdc
and
others.
So.
E
Since
the
spp
made
the
the
elcc
filing
at
ferc,
ferc
has
issued
two
deficiency
letters
and
that
hasn't
invited
a
response
from
spp.
Regarding
those
deficiency
letters,
the
most
recent
submission
spp
made
in
response
was
on
june,
the
8th
to
the
second
deficiency
letter.
B
Sure
that's
very
helpful.
I
I
think
what
you're
what
I'm
hearing
you
say
is
the
process
is
quite
deliberative
and
I
take
it
that
that
that
plays
into
an
attempt
to
really
engage
in
a
genuine
back
and
forth
to
try
to
determine
the
extent
of
deficiencies
and
whether
they're
present
is
that
fair
conclusion.
E
Yes-
and
I
would
say
that
in
the
midst
of
those
deficiency
letters
the
coalition
to
with
of
which
to
which
tai
referred,
has
filed
two
protests,
one
after
the
first
efficiency
letter
and
one
after
the
second
raising
some
of
these
issues
that
are,
on
the
left
hand
of
this
screen.
D
Yes,
thank
you.
Thank
you
both
very
much
and
so
we'll
exactly
in
what
terry
just
said,
we'll
continue
to
work
on
these
issues,
they're
on
the
right
here
on
the
discriminoid,
discriminatory
treatment
of
clean
technologies
and
to
get
their
full
capacity
value,
and
we
can
look
a
little
bit
at
in
the
next
slide
at
why
that
is
important
for
affordability
and
then
reliability
after
that
within
the
kansas
context.
D
So,
as
we
look
for
resource
adequacy
and
requirements
and
winter
season
obligations,
we
can
reduce
the
costs
through
these
technologies.
If
we
can
go
to
the
next
slide,.
A
This
is
jeff
mclennan.
Sorry.
Could
you
sort
of
reconcile
for
me?
You
know,
I
think
you.
You
said
that
that,
like
some
of
the
issues
that
svp
is
or
I'm
sorry
perk
is
addressing
it's
discriminatory
in
nature.
But
how
do
you
reconcile
the
perceived
discriminatory
nature
of
some
of
those
issues
versus
reliability
in
the
sense
that
you
know,
storage
still
has
some
issues
right,
there's
still
fires
associated
with
battery
storage.
A
You
know
the
transition
is
extremely
complex
from
a
dispatch
perspective
in
the
sense
of
an
rto
being
blind
to
what's
happening
behind
the
meter.
What
sort
of
maintenance
is
happening
for
behind
the
meter
generation?
D
I
think
I
can
address
that.
I
guess
I'll
start
by
saying
that
from
a
reliability
standpoint,
these
clean
technologies,
some
of
which
you
mentioned
there-
have
come
a
long
long
way
and
the
the
barriers
aren't
necessarily
technical
anymore
to
there's
been
multiple
studies
that
I
reference.
D
D
So
the
ways
that
that
happens,
the
ways
that
the
demand
side
and
the
generations
and
the
storage
all
work
together
to
create
a
clean
energy
portfolio
to
to
to
replicate
what
the
capacity
of
a
coal
plant
or
a
gas
plant
can
do.
D
That
is,
that
is
very
complicated
and
a
process
that
requires
investment
and
software
and
a
lot
of
different
types
of
technologies,
and
especially,
you
know,
robust
demand,
side,
knowledge,
predictability
and,
and
a
lot
of
factors
there
that
that
we
are
hopefully
going
to
invest
heavily
in
across
this
country
over
the
next
few
years.
D
But
I
guess
you
know
I
I
will
say
that
was
part
of
the
way
the
question
seemed
to
be
getting
out.
D
Was
that
the
it's
not
discriminatory
in
the
sense
that
it
gives
renewable
energy
less
capacity,
because
that's
appropriate
as
you're
mentioning
here,
the
it's,
the
discriminatory
nature
is
keeping
the
resource
off
the
grid
through
barriers
that
go
beyond
the
the
appropriate
amount
of
capacity
that
can
bring,
and,
as
I
mentioned
earlier,
the
capacity
would
be
defined
as
being
able
to
stop
a
shot
down
from
lack
of
power
and
modeling
the
reliability
of
these
resources,
out
with
very
sophisticated
models
in
historical
data
and
and
projected
data
as
the
weather
and
and
the
climate
gets
more
chaotic.
D
C
So
ty
as
we
talk
about
reliability
and
and
the
discriminatory
your
concern
about
the
discriminatory
nature,
are
you
all
also
looking
at
the
security
aspect,
the
cyber
security
aspect?
I
mean
this.
This
is
my.
C
My
concern
is
that
we
have
multiple
ders,
you
know
and
and
various
places,
just
the
and
we
become
reliant
on
them,
that
the
the
cyber
security
aspect
of
of
of
trying
to
protect
those
and
and
ensuring
their
reliability
are.
Are
we
at
that
point
where
I
to
me,
that's
why
I
think
some
of
this
information
perhaps
is
important
so
that
the
utility
can
really
weigh
the
security
of
that
resource
out
there.
D
Yeah
thanks
for
the
question
commissioner
duffy
not
not
not
being
a
security
expert,
myself
or
knowing
too
much
about
the
cyber
security
aspects
that
utilities
have
to
invest
in
at
that
level.
I
can
just
tell
you
that
three
experts
that
I've
read
on
this
have
been
pretty
clear:
that
the
single
point
of
failure
versus
the
distributed
energy
resources
in
that
dynamic
distributed
energy
resources
are
much
more
reliable
from
that
perspective,
because
you
know
if
the
cyber
security
is
compromised
on
a
very
necessary
fossil
plant,
then
that
is
or
cuts
off
some.
D
You
know
part
of
the
grid
that
can
have
access
to
that
energy.
That's
catastrophic,
whereas
distributed
energy
resources,
there's
so
many
nodes
and
controls
and.
C
D
That
exactly
and
I'd
be
happy
to
essence,
I'm
not
an
expert
on
that
work.
Work
with
you
afterwards
to
get
some
sources
and
do
some
research
on
that.
C
I
would
appreciate
that
because
I
I
do
think
that's
part
of
of
the
discussion
as
well.
A
D
Well,
thanks
very
much
I'll
just
quickly
run
through.
D
Absolutely
I
apologize
for
that
this
internet's
supposed
to
be
impeccable
here
all
right.
So
thank
thanks
for
the
you're,
bearing
with
me
here
so
yeah
just
quickly.
D
We've
put
reports
about
this
out
in
the
past:
jeffrey
energy
center
from
affordability,
standpoint,
a
stranded
asset
in
the
next
year
or
two,
which
means
it's
it'll,
be
cheaper
to
replace
it
with
new
clean
resources
than
to
keep
it
running,
and
we
have
with
securitization,
especially
to
save
hundreds
of
millions
of
dollars
by
retiring
plants
and
replacing
them
with
clean
energy
once
the
capacity
is
and
the
reliability
is
is
there.
D
The
scene
will
follow
suit
shortly
after
that,
as
far
as
the
affordability
and
both
are
stranded
assets
and
should
be
retired
before
2030
and
the
occ
and
2222
can
bring
about
those
affordability
benefits,
and
I
can
jump
to
the
next
slide.
B
Before
before
we
move
to
the
slide,
you
need
not
bring
the
one
previously
back
necessarily,
but
my
question
had
to
do
with
the
narrative
that
you
have
in
the
lower
right
hand,
part
of
that
previous
slide,
indicating
that,
in
your
opinion,
90
of
clean
energy
portfolios
that
are
replacing
coal
plants
are
cheaper
than
plant
gas
gas
plants.
D
So
we
have
a
nationally
a
modeling
tool
that
allows
us
to
look
at
what
the
what
plan,
the
gas
plants
cost
versus
what
a
clean
port
energy
portfolio
costs,
which,
if
you
that
next
slide
that
she
showed
for
a
second
there
that
was
the
the
chart,
is
what
we
think
of
as
a
clean
energy
portfolio,
a
combination
of
solar
wind
storage
and
then
in
some
models,
efficiency
and
demand
response
as
well,
that
replicate
what
a
planned
gas
plant
can
do
as
far
as
ramping
and
and
capacity.
D
So
that's
where
we're
coming
from
there.
We
look
at
the
cost
of
the
of
building
that
plant
and
versus
the
cost
of
building
these
clean
energy
resources
and
that's
and
then
added
to
that.
We
have
the
you
know
the
climate
and
health
impacts
of
the
gas
plant,
but
also
the
price
spikes
that
aren't
included
in
our
analysis
from
fuel.
D
B
D
D
So
the
data
that
led
to
that
90
figure
excuse
me-
is
probably
a
year
old
and
the
we
I'd
say:
prices
of
everything
have
gone
up
since
then.
D
Well,
that's
a
that's
a
big
question.
I
mean
I
can't
say
that
I'm
an
expert
on
that
I'd
be
happy
to
get
a
full,
we'll
run
down
a
meeting
on
that
in
the
future
with
you.
But
you
know.
I
know
that
during
the
winter
storm,
for
example,
as
far
as
the
price
spikes
go,
the
the
producers
and
the
pipelines
had
conflicts
and
and
production
issues
that
would
cause
such
extreme
price
spikes
and
those
haven't.
As
far
as
all
the
analysis,
I've
seen
been
solved
across
those
two
sectors.
D
So
I
know
so
that's
one
piece
of
the
answer
to
your
question.
As
far
as
why
gas
prices
are
going
up
across
the
board,
I'm
sure
there's
infrastructure
investments
that
they're
that
they've
been
made
and
then
just
they
can
raise
the
price
because
of
demand
and
supply.
B
That's,
I
think,
that's
a
very
fair
answer.
It
wasn't
I'm
not
trying
to
mousetrap
you
here,
but
I
guess
I
guess
I
I
would
rhetorically
wonder
if
a
major
underlying
reason
isn't
the
under
investment
in
expiration
and
production,
for
whatever
reasons,
whether
it's
historically
low
gas
prices
that
have
discouraged
exploration
so
that
it
can
meet
higher
demand
in
a
post-covet
environment
or
whatever
I'm
saying
that.
B
D
All
right,
thank
you,
chuck
keane
yeah.
This
slide
here
gets
at
that
a
little
bit
a
quick
look
at
the
quantities
of
clean
energy.
We
need
to
replace
kansas
coal
plants,
and
these
clean
energy
portfolios
are
meant
to
exactly
replicate
the
rampability,
the
capacity
in
extreme
weather
over
you
know
over
the
whole
year
of
extreme
weather
that
we've
modeled
out.
D
D
That's
a
great
question:
it
does
not
include
the
securitization
and
or
the
funds
that
we
would
bring
back
from
securitization
after
retirement,
so
those
hundreds
of
millions
of
dollars
of
customer
benefit
would
be.
In
addition,
thank
you.
D
Thank
you
great.
So
we
we
can
look
just
at
these
replacing
these
over
the
next
few
years.
With
all
of
this
clean
energy
and
see
the
quantities
we're
talking
about
are
pretty
pretty
high.
That's
one
of
the
main
points
of
this
slide
and
even
though
it's
cheaper
to
build
all
this
solar.
D
As
far
as
you
know,
what
the
price
is
the
commodities
versus
the
maintenance
price
of
coal
is.
It
is
difficult
for
the
utility
well,
the
utilities.
Recent
plan,
for
example,
shows
a
much
much
reduced
and
slow
ramp
up
of
clean
energy
resources.
D
D
I
also
mentioned
that
winter
storm
yuri
in
those
spp
reports
showed
that
even
in
that
extreme
weather
as
well,
renewables
were
meeting
their
expected
capacity,
which
is
what
this
particular
chart
will
be
measuring
with
all
this
solar
during
that
crisis.
Well,
of
course,
gas
catastrophically
failed
and
coal
performed
below
20
of
its
expected
capacity
during
that
extreme
weather
event.
So,
just
from
a
liability
standpoint
to
plug
the
clean
energy
that
we
can
ramp
up
faster
with
the
lcc
and
order
2222.
B
Ty
another
overview
question
if
I
might,
because
I'm
trying
to
I'm
trying
to
grasp
the
significance
of
the
two
charts
here
on
on
this
slide
in
terms
of
reliability
so
and
in
my
understanding
to
say
that,
in
terms
of
reliability,
these
these
renewable
replacements
to
to
the
coal
plants
will
overcome
even
the
intermittency
of
renewables.
D
Yes,
yes,
the
quantity
of
these
resources
and
the
kind
of
the
elcc
type
modeling
that
that
that
I
described
earlier
about
when
they
produce
and
when
there
are
peak
events.
That's
that's
how
we
figured
out
how
much
renewables
would
be
able
to
replace
a
coal
plant
exactly.
B
So
let
me
rephrase
that
to
make
sure
I
understand
that
important
point
what
you
said
wasn't
incredibly
articulate,
but
just
let
me
kind
of
rephrase
it
if
I
could
very
succinctly.
B
So
what
you're
suggesting
is
that
over
the
because
of
the
increased
investment
in
the
various
types
of
renewables
that
will
compensate
in
effect
or,
let's
assume,
a
worst-case
basis
where
battery
storage
technology
remains
flat
throughout
the
entire
period
going
into
2030.
Notwithstanding
that,
the
the
the
increased
investment
in
these
in
in
these
kinds
of
resources
would
compensate
for
that,
because
if
I
rephrase
that
correctly.
D
I
think
so
I
mean
I
would
say
that
it's
not
increased
investment,
since
all
these
resources
are
cheaper,
but
it's
increased
name
plate
capacity,
so
you'd
have
a
big
increase
in
the
amount
of
nameplate
energy
that
we're
installing
versus
the
coal
plant,
and
the
capacity
value
of
each
of
the
intermediate
or
intermittent
technologies
are,
of
course,
rated
lower
than
that
goal
so
yeah.
All
these
together
can
meet
those
demands,
even
if
one
of
them
goes
flat
or
if
you
know
extreme
weather
comes.
B
Okay
and
that's
based
upon
basically
an
increasing
level
of
generating
capacity.
That's
a
major
contributor!
Is
it
not.
D
D
But
if,
when
everything's
kind
of
going
wrong
as
far
as
extreme
weather
and
all
those
things,
then
all
of
these
resources
meet
exactly
what
the
coal
plant
would
put
out.
B
B
D
Yeah,
I
don't
have
a
number
for
you
right
now.
It
totally
depends,
of
course,
on
location,
and
you
know
how
it's
implemented
and
if
it's
implemented,
for
example,
in
through
inverter
resources,
that
impact
would
be
negligible
if
it's
put
way
out
in
the
in
the
drier
part
of
kansas
and
has
to
have
new
lines
well.
That
would
be
that
they'd
only
do
that,
because
it
would
be
the
cheaper
version
of
the
the
resource
sighting.
I
would
assume
so
yeah.
D
I
don't
have
a
clean
answer
for
you
on
that
one,
but
I'd
be
happy
to
follow
up
and
and
look
into
that
further.
B
I
appreciate
the
the
one
of
the
major
impetuses
for
the
question
is
not
only
the
the
the
rate
impact
to
to
kansas
rate
payers,
potentially
from
the
capital
expenditure
build-outs
that
might
be
required,
but
also
the
the
the
pace
at
which
that
might
be
required
to
to
to
to
occur
in
accommodating
such
a
a
reduced
as
going
out
to
2030,
rather
than
40
and
beyond.
It's
a
reduced
time
frame
within
which
to
accomplish
the
goals.
D
I
would
say
that
you
know
solar
can
be
built
much
much
closer
to
load
than
than
the
wind
has
been
in
the
past.
The
transmission
costs
don't
need
to
be
as
high
for
the
solar
technology
and
they
can
be
built
all
over
where
the
jeffrey
energy
center
stands
right
now
and
produce
a
big
chunk
of
that
that
energy,
that's
that
we
list
out
there
and
but
yeah,
but
that
kind
of
analysis
is
really
helping.
D
That's
part
of
what
we
hope
you
know:
stronger,
modeling
and
utility
planning,
irp
and
capacity
analysis
can
suss
out
as
like
as
the
cheapest
possible,
reliable
location
and
framework
for
all
these
renewable
resources.
You
for
your
response.
D
D
It
I
think,
we're
ready
to
jump
to
the
next
slide
and
I'll
try
to
rush.
E
Through
these,
if
I
may
ty,
this
is
sherry
albrecht.
I
noticed
that
this
slide
relies
pretty
heavily
on
solar
resources,
and
you
make
reference
in
the
title
of
this
slide
that
you're
that
shortens
the
timeline
there
is
there.
It
is
an
issue
with
spp's
generation
interconnection
queue,
and
so
I'm
just
curious
to
what
timeline
for
solar.
You
anticipate
with
this
slide.
D
Yeah,
that's
kind
of
what
I
was
one
of
the
things
I
was
referencing,
in
apologies
for
the
typo
up
there
and
then,
but
that's
one
of
the
things
I
was
referencing
there
is
that
elc
in
2222
brings
on
these
distributors,
energy
resources
and
customer
side
resources
that
can
that
can
benefit
the
timeline
that
the
interconnection
queue
and
some
of
the
barriers
to
utility
side
sighting
of
renewable
energy
provide.
D
So
that's
all
I
meant
by
that
particular
line
and
and
then
there's
a
bunch
more
solar
resources
in
there,
mainly
because
kansas
hasn't
built
those
yet
and
and
they
provide
a
lot
of
great
peak
power
benefits,
so
we
gotta
catch
up
on
the
solar
side.
E
I'm
not
sure
that
it
does
entirely.
Are
you
suggesting
that
kansas
separate,
and
apart
from
it
from
the
utility
participation
at
spp,
could
be
implementing
its
own
elc
accreditation
processes
in
its
own
order?
2222
processes,
ahead
of
ahead
of
what
ferc
is,
would
authorize
with
regard
to
each
of
those.
D
No,
no,
I
was
referring
I'll
address
this
also
in
the
in
the
recommendations
at
the
end,
to
basically
calls
from
svp
during
their
working
group
meetings
for
regulators
and
utilities
to
to
get
involved
and
begin
working
through
all
of
the
authority,
issues
that
need
to
be
around
incentive
structures
and
and
the
best
way
to
move
forward.
With
a
transition
like
this
and
and
then,
of
course,
the
ferc
implementation
of
the
of
the
ruling
would
be
would
have
to
come
before.
D
Kansas
official
implementation,
but
but
they,
you
know
starting
to
work
through
those
issues,
is
what
we're
getting.
That
here
will
take
some
time.
C
Okay,
I
I'm
not
trying
to
belabor
this
slide,
but
you
have
a
you:
have
a
pretty
quantifiable
amount
under
energy
efficiency.
C
I
mean
whoa
okay.
So
what
what
do
you
exactly
base
that
on.
D
Well,
the
energy
efficiency
number
there
is
based
on
the
least
cost
most
reliable,
optimization
within
the
within
the
modeling
software.
So
in
this,
in
this
particular
framework
it
doesn't
match
like
how
quickly
can
we
ramp
up
energy
efficiency
in
kansas?
D
I
would
say
that
to
get
to
894
megawatts
over
the
next
few
years,
we'd
have
to
increase
the
energy
efficiency
proposals
that
have
been
made
by
energy
so
far,
quite
a
bit
and
we're
hoping
that
does
happen
over
the
next
few
years
to
to
triple
the
type
of
self-investment
that
they're
looking
at
now
in
energy
efficiency
and
demand
side
resources,
but
that
that
isn't
that
particular
like
roll
out
ramp
up
or
not.
But
you
know,
the
roll
out
of
the
programs
are
not
quantified
within
this
slide.
D
Thank
you
all
right.
Well,
we
can
jump
through
these
other
slides.
I
just
wanted
to
mention
also
in
the
context
of
the
lcc
in
2222,
that
the
both
those
rules
can
have
an
effect
on
and
be
beneficial
for
the
energy
burden
issue.
That's
so
near
and
dear
to
sierra
club's
heart
that
we
have
brought
to
you
many
times,
just
a
quick
refresher
here.
D
You
know
in
past
public
meetings,
y'all
have
expressed
concern
about
energy
burden
and
the
unfair
proportion
of
electricity
costs
born
by
especially
black
communities
and
latino
communities,
who
can
at
least
afford
them,
providing
appropriate
incentives
to
unlock
the
aggregation
of
distributed
energy
resources
behind
the
meter
in
in
these
energy
burden
communities
and
have
and
access
to
renewable
energy
through
so
the
lcc
and
2222
in
the
in
energy
burden.
C
So
I,
if
I
could
hear
to
me,
looking
at
this
problem,
I
agree
there
is
a
an
energy
burden
that
is
higher
on
on
certain
communities
and
when
we
talk
about
the
housing
stock
that
is
in
this
state.
C
C
What
are
we
requiring
in
terms
of
a
standard
that
is
not
a
substandard
for
folks
to
live
in,
and
I
think
there
is
a
real
difficulty
with
certain
landlords
who
feel
no
obligation
to
improve
the
outer
shell
of
the
house
or
apartment
that
they're
renting
and
the
the
renter
is
stuck
with
whatever
electricity
bill,
no
matter
how
hard
they
try
and
whatever
they
stuff
in
the
windows
or
whatever
they,
they
still,
they
they're
still
cold
or
they're,
still
hot
and
yet
they're
paying
a
very
high
amount
for
that
utility.
C
And
so
let
me
ask
you:
what
is
sierra
club
doing
on
that
end
to
effect
change
in
communities
with
landlords.
D
D
I'd
say
all
of
our
advocacy
work
is,
is
focused
on
there's
just
those
issues,
and
I
couldn't
agree
more
with
you
on
on
that
with
landlords.
Specifically,
you
know
we're
working
in
the
in
the
efficiency
docket,
so
I
won't
bring
that
stuff
up
necessarily
here,
but
but
a
lot
of
our
focus
is
certainly
on
low
income
and
renter
communities
within
the
energy
efficiency
context,
at
all
times,
and
and
also
working
with
our
partners
in
the
in
the
docket
and
outside
of
it
to
to
advocate
for.
D
So
it's
there's
a
whole
suite
of
innovative
programs
that
are
around
the
country
and
would
love
to
continue
to
work
on
that
and
part
of
the
way
to
work
on
that
is
within
the
energy
efficiency,
docket
and
the
utility
programs.
That's
a
good
good
part
of
the
energy
efficiency
needs
that
we
have
and
we
should
push
and
increase
that
as
much
as
we
can
as
far
as
the
investment,
but
and
on
the
other
side.
D
There's
also,
these
opportunities
opened
up
by
board
of
2222
and
elcc
methodology
for
those
for
those
landlords
to
be
aggregated,
to
be
put
into
programs
where
they
can
get
value
from
increasing
their
buildings
within
the
market.
D
Increasing
the
efficiency
of
the
buildings,
increasing
demand,
response
capabilities
and
programs
and
getting
paid
for
it
by
creating
that
market
service
when
there's
a
when
there's
an
event,
extreme
weather
or
other
reason
to
call
for
it
or
to
have
renewable
energy
associated
with,
for
example,
generation
or
storage
within
multi-family
residences
is
very
important
because
they
are
often
you
know
medically
have
them
have
medical
devices
and
are
at
risk
for,
if
they're,
at
risk
for
shutoff.
D
It's
a
very
dangerous
situation
for
a
lot
of
folks
so
having
the
ability
to
get
a
battery
into
a
low-income
home
that
can
be
drawn
on
for
the
grid
or
there
for
emergency
needs
is
another
thing
that
the
private
open,
opening
up
this
market
to
aggregators,
distributed
energy
and
and
through
the
elc
evaluation
capacity
methodology
that
all
brings
value
to
these
to
kansas
and
investment
into
this.
D
A
D
Excited
and
talking
too
fast
there
at
the
end,
but
did
that
answer
your
question
to
some
extent.
D
All
right,
I
think
you
nodded.
Okay,
let's
see
the
energy
burden
here,
you
can
see
the
chart
just
lays
out
in
in
one
format
how
much
more
communities
of
color
pay
than
their
white
neighbors.
We
can
go
to
the
next
slide
and
just
see
that
the
same
data
in
a
different
format.
D
Great
thanks
so
much-
and
this
just
shows
you
know
by
census-
tract
these-
are
majority
black
census,
tracts
that
have
energy
expenditure
four
to
five
times
higher
than
they
should
be
and
and
and
then
their
white
colleagues
are
paying.
For
you
know
for
much
lower
income
groups,
elc
and
2022
implementation
can
lower
prices
and
work
well.
With
other
demand
side
programs
to
reduce
energy
burden,
raise
household
income
in
in
black
and
latino
census
tracts
all
right.
D
I
think
we
can
go
to
the
next
one
there
just
won't.
I
won't
go
over
all
this
text,
but
I
know
last
when
we've
spoken
in
the
past,
it's
been
good
to
to
pull
some
utility
programs
or
to
some
other
states
as
examples
of
the
kind
of
implementation
that
I'm
talking
about-
and
I
know
you
know
kansas
can
look
to
other
experiences
around
the
country.
D
I
split
these
into
kind
of
the
best
practice
states
over
there,
hawaii
and
new
york,
and
some
california
and
oregon
utilities
are
doing
comprehensive
programs,
but
then
I
also
wanted
to
put
some
some
more
some
more
conservative
states
that
have
programs
that
are
implementing
these
types
of
distributed.
Energy
resources-
I
won't
go
into
it
anymore
than
that
unless
there
are
questions-
and
I
can
do
more
research
and
work
with
folks
to
to
dig
into
the
details
of
these
at
your
request,
you
can
go
to
the
next
slide
if
you're
able
thank
you.
D
D
So
the
some
of
the
thorny
issues
I
mentioned
earlier
that
we
can
start
working
on
now
are
listed
out
here
on
the
blue
side
and
then
on
the
white
side.
There
getting
this
getting
the
rules
as
stated,
and
the
implications
of
them
sort
of
put
into
the
planning
work
that
we
do
in
the
state
is
a
very
important
step
here.
D
If
we're
not
going
to
look
at
what
the
future
is
definitely
going
to
hold
for
us,
the
energy
future
and
then-
and
we
don't
plan
for
that
until
the
rules
are-
you
know,
kind
of
forced
in
on
us-
then
that'll
give
us
a
disadvantage
and
hurt
what
we
heard
her
customers,
affordability
and
reliability
needs
that
we
could
have
been
building
towards.
In
the
meantime,.
D
A
D
I'm
running
out
of
time
I
was
looking
doing
a
time
check
here
so
yeah
these
recommendations,
I
mean
one
thing:
that's
clear
from
the
spp
process
so
far
is
that
I
think
they
would
prefer
to
comply
with
ferc
in
a
way
that
relies
heavily
on
regulators
and
utilities
to
lead
the
implementation
of
of
order
2222
and
the
occ
methodology.
D
Kansas
can
get
a
head
start
on
the
customer
benefits
from
those
ferc
rules
by
working
with
the
utility
now
and
spp
to
find
the
right
incentive
structures
and
incorporate
these
customer
side.
Resources
into
evergy's
planning
and
modeling
processes
now
develop
the
relationships
that
are
needed
to
implement
through
these
distributed
energy
resources
and
equitable
transition
away
from
coal
and
towards
new,
clean,
affordable,
reliable
resources
where
we
can
can
work
with
each
other
and
reduce
the
burden
on
our
communities
and
I'll
leave
it
there
and
answer
any
questions
again.
A
B
That,
plus
all
the
back
and
forth
we've
had
this
morning,
has
been
very
instructive.
Before
we
close
out,
I
would
give
anyone
who's
on
board
here
the
opportunity
to
ask
any
further
questions
of
tai.
If
you
wish
to
do
so,.
A
Times,
commissioner,
french-
I
I
don't
necessarily
have
a
question,
but
I
I
just
wanted
to
thank
you
for
all
the
information.
I
know
I
didn't
ask
a
lot
of
questions
this
morning
and-
and
please
don't
take
that
as
a
lack
of
interest
in
the
concepts
I
I
am
definitely
in
learn
mode
on
all
of
this
right
now,
and
these
are
this.
Transition
is
happening
and
we're
all
trying
to
figure
out
what
the
most
reliable
and
affordable
way
to
make
it
happen
is.
A
I
agree
with
a
lot
of
what
you're
saying
that
we've
got
to
reduce
the
energy
burden,
especially
on
disadvantaged
and
low-income
communities,
and
so
that
is
part
of
the
package
as
well
as
far
as
accreditation
goes.
You
know
I
do.
I
agree
that
we
need
to
appropriately
accredit
our
clean
energy
resources,
because
those
are
kansas,
energy
resources
and
we
want
to
get
full
credit
for
that.
A
At
the
same
time
to
me,
I
don't
know
if
it's
the
bigger
bigger
concern,
but
maybe
the
more
pressing
concern
is
making
sure
we
appropriately
accredit
our
traditional
resources.
I
think
that's
maybe
where
we
saw
our
shortfall
during
winter
storm,
jury
and
so
starting
to
apply
some
more
performance,
accreditation
metrics
to
traditional
resources,
I
think,
will
be
helpful
and
and
potentially
also
valuing
the
availability
of
those
resources
we're
starting
to
find
out
which
ones
were
and
were
not
available,
and
if
we
can
compensate
resources
for
being
available.
A
C
And
if
I
could
add
my
two
cents
worth,
I
think
it's
valuable
that
we
hear
from
the
sierra
club
and
on
not
just
this
issue
but
other
issues.
I
think
it's
important
for
me
as
an
individual
commissioner,
but
also
as
the
commission
as
a
whole
and
staff,
to
hear
your
your
thoughts,
your
modeling,
what
you
you
guys
have
done
as
it
relates
to
kansas
and
getting
that
other
perspective.
C
I
do
I
I
would
agree
with
what
commissioner
french
said.
These
changes
are
coming
and
how
well
we
implement
them
is
extremely
important.
I
believe
that
storm
yuri
will
continue
to
be
a
petri
dish
that
we
can
use
to
model
the
worst
what-if
situation
and
the
fact
that
it
really
did
happen.
I
think
again
a
learning
experience
for
all
of
us
on
all
our
types
of
generation
and
how
well
they
performed
as
we
head
into
the
summer
months
of
a
summer.
That's
already
good
grief,
it's
just
sweating
hot
out
there.
C
I
I
think
again,
we
will
be
tasked
with
looking
at
how
best
can
we,
we
weather
this?
This
type
of
of
ongoing,
ongoing
weather
that
is,
is
changing
in
our
climate.
B
No,
you
didn't
I
I
talked
over.
You
know
I
didn't
mean
to
I
apologize.
Thank
you
very
much
ty
for
being
here.
I
want
to
thank
as
well.
I
appreciate
jeff
and
commissioner
albrecht
for
their
contributions
to
this
it
it's
always
instructed,
even
when
we
have
more
thoughts
that
are
being
advanced
in
the
public
arena
here
that
especially
informed
ones
and
that's
certainly
true
of
both
jeff
and
sherry.
I
think
with
that
tai
will
thank
you
once
again
and
please
don't
be
a
stranger
all.
B
Absolutely
by
my
reckoning,
we
have
come
to
the
end
of
this
meeting
unless
there's
anything
further
that
you
would
like
to
consider
at
this
time.
I
would
entertain
a
motion
that
we
adjourn.