Transcript of May 4 Webinar: Understanding the Energy Policy and Regulatory Environment

Office of Indian Energy Policy and Programs

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Good morning, or good afternoon, wherever you may be and welcome to the fifth webinar of the 2016 DOE's Tribal Renewable Energy Webinar Series, "Understanding the Energy Policy and Regulatory Environment." I'm Randy Manion, today's webinar chair and manager of Western Area Power Administration's Renewable Resource Program. Let's go over a few event details first. Today's webinar is being recorded and will be made available on DOE's Office of Indian Energy Policy and Programs website along with copies of today's Power Point slides in about one week. Everyone will receive a post-webinar email with the link to the page where the slides and recording are located.

Because we are recording the webinar, all phones have been muted for this purpose and we'll answer your questions at the end of all of the presentations. However, you can submit a question at any time by clicking on the question button located in the webinar control box on your screen and typing your question. If you've entered your audio PIN when you joined, at the end of the webinar you can also raise your hand by clicking on the "Raise Your Hand" icon and I will unmute you so you can ask the panel your question directly. We'll try to keep the webinar to no more than 90 minutes but depending on questions we could go out to a full two hours.

We have several speakers on the webinar today, so let's get started with opening remarks from Sarai Geary. Sarai is a member of the Muscogee Creek Nation and a program manager in the Office of Indian Energy Policy and Programs. As program manager, she designs and implements technical assistance and educational programs that positively impact Indian energy development and promotes energy education for Indian tribes. Sarai has a bachelor's of arts in organizational communication from the University of Portland and a law degree from the University of Missouri Kansas City. Sarai, it's a pleasure to have you back to give opening remarks. The virtual floor is now yours.

            Thank you, Randy, and greetings to all of the callers that have joined. Randy and I welcome you to the fifth webinar of the 2016 series. This webinar is sponsored by two U.S. Department of Energy organizations; the Office of Indian Energy Policy and Programs and the Western Area Power Administration. The series is designed to promote tribal energy sufficiency and to foster economic development and employment on tribal lands using renewable energy and energy efficiency technologies. The Office of Indian Energy Policy and Programs directs, fosters, coordinates and implements energy planning, education, management and programs that assist tribes with energy development, capacity building, energy infrastructure, energy costs and electrification of Indian lands and homes. To provide this assistance, we work within the Department of Energy, across government agencies and with tribes and organizations to promote Indian energy policies and initiatives that help tribes overcome the barriers to energy independence.

To help tribes overcome barriers, the Office of Indian Energy has developed several programmatic initiatives and partnerships. This tribal renewable energy webinar series is an example of the type of education and capacity building efforts we have developed with our other DOE partners. Today, the webinar attendees will learn about federal, regional and state policies and regulations as they pertain to energy development and how tribal and intertribal policies can be implemented to foster a sustainable energy future.

We have another seven webinars remaining in the series. Each new webinar builds upon the previous webinars. The foundation is strategic energy planning in the often undervalued or overlooked benefits of economic development in the strategic planning process. In each of the 2016 monthly webinars we will try to include tribal case studies and information and hands-on tools that we can use to progress toward self-determination and energy independence. So let us start with today's webinar. I will now turn the virtual floor back over to you, Randy, and thank you.

            Thanks Sarai. Following Sarai today, we have Doug MacCourt, Theresa Cole and Jana Ganion. I'll introduce them all now. Doug MacCourt is the policy advisor to the director and staff of the Office of Indian Energy Policy and Programs and works throughout DOE and with other federal and state agencies on policy, legislative and funding issues that are critical to office's mission of developing and deploying clean energy and related economic development projects on Indian Country. He has more than 25 years' experience working with tribes, Alaskan Native corporations, and tribal business enterprises on all aspects of energy development and natural resource matters.

Doug published the Renewable Energy Development in Indian Country; A Handbook for Tribes and is listed in the Chambers USA: America's Leading Lawyers for Business and Best Lawyers in America for Native American and natural resource law. Prior to joining DOE, he was a partner in the Portland office of Ater Wynne for 15 years where he chaired the Union Law Group and led the Land Use Redevelopment Practice. Prior to that, Doug created and managed the City of Portland Brownfield Redevelopment Program where he successfully negotiated and implemented redevelopment of residential, commercial, mixed use, industrial and transportation projects throughout the metro area.

Following Doug is Theresa Cole, Special Projects Coordinator for the Akwesasne Housing Authority. Theresa is enrolled member of the Saint Regis Mohawk Tribe in Upstate New York. She has worked in Indian Housing with the Akwesasne Housing Authority for the past seven years. Prior to that, she worked in the field of education as a teacher, coordinator and administrator for 20 years. It was in [audio skips out] _____ where she gained valuable experience in grant proposal writing. As the special projects coordinator, she researches and developed grants and report writing. Theresa holds an MS degree in education from SUNY Potsdam and McGill University. She also holds a professional services coordinator certificate to better serve their aging population in successful aging in place programs.

Then closing it out will be Jana Ganion, Energy Director with Blue Lake Rancheria California, a federally recognized tribal government. As the energy director for the Blue Lake Rancheria, Jana has worked to establish and refine the tribe's government energy strategy and has implemented a wide array of clean energy initiatives to reduce greenhouse gas emissions, reduce and levelize retail costs of energy, to increase energy security and climate resilience and fight the causes of climate change throughout outreach and education programs. Jana has worked to develop successful partnerships resulting in completed projects and energy efficiency, renewable energy, green fuels and community resilience including biomass power, biodiesel manufacturing, electric vehicle infrastructure and fleet migration. Her current clean energy project is a low-carbon community scale micro grid which includes a half a megawatt solar array with a one megawatt hour of battery storage and a micro grid management control system to provide power for the tribe's critical facilities. The micro grid will reduce the use of fossil energy in business' usual mode and provide emergency power in islanded mode for as long as needed.

Jana currently serves on the U.S. Department of Energy Office of Indian Energy, Indian Country Energy and Infrastructure Working Group where she works with other tribal governments on energy policy. In 2014, the Blue Lake Rancheria received the Pacific Gas and Electric Company Integration award in recognition of active participation in PG&E's programs, bundling energy efficiency, demand response and distributed generation into energy management solutions that serve tribal operations in the larger community. Due to the tribe's successful implementation of greenhouse gas reduction and community resilience projects. Blue Lake Rancheria was selected by the White House as the 2015-2016 Climate Action Champion, one of 16 communities in the United States to receive this honor. So with that, Doug we're going to start with you. I have your slide deck up and the virtual floor is all yours.

            Well thank you Randy and thank you Sarai. It's really a privilege to be here with this panel with Theresa and Jana. I think we're going to have an excellent presentation. So thanks to everyone across the country and especially in Indian Country who are attending the webinar. We can go to the next slide.

So this is a particular treat for me to present in this with our tribal representatives and Randy and Sarai today because I came back from 25 years in the private sector to the Department of Energy to assist all of our staff and our new director, Chris Deschene, to develop this office and help develop out the policy program in the Office of Indian Energy. We're going to be talking about subjects a lot broader than just our Indian Energy office here but I'll try to weave in some of the new directions our office is going to try to implement policy on the various levels that we're going to discuss today. That really is what the purpose of this slide is, is of course we work very closely with our Congressional staff and with delegation from all over the U.S., in particular the Senate Energy Committee staff and Senator Murkowski and various others who have worked across the aisles.

We're seeing, as I point out later in this presentation, bipartisan support for advancing key pieces of policy at the legislative level to advance tribal energy development. That's across the board or all of the above, as President Obama likes to say in terms of all our energy resources and all of the Indian Country's energy resources. We follow really the same pattern even though this webinar series is dedicated to clean and renewable energy, development. Our office operates on what we describe as a fuel neutral basis. So whatever resources try to bring to the table we assist them and try to direct them not just with policy but with innovation and of course our core deployment grants and technical assistance programs. So I think we can go to the next slide.

We're going to first – the first part of the presentation we're going to focus on policy considerations then I'm going to update the group and the attendees on some late breaking developments, in particular at the legislative level both in the appropriation side as well as the current leading energy bill at least on the Senate side. Next slide, please.

So before we dive into the details of where Congress is, we just – taking a couple steps back and considering what the legal issues are and exploring the market, the point of tribes participating at least on certainly at the utility scale and to some degree the community scale when we talk about things like net metering and certain with respect to funding projects. There are some core considerations that really need to be considered at the tribal level. Will the project operate as a profit making enterprise? Is this part of the government function? Is the tribal entity operating as a political subdivision or is it an entirely separate business?

That is of course another big component of the services we provide and it's gone into detail in the handbook that is still used across the country to really describe, "What does that mean and what are the available entities for setting up different types of tribal energy businesses?" At the state level, certainly to the extent that state incentives can apply and those can apply in a variety of ways. How do those incentives and policies impact energy development on tribal lands, notwithstanding the fact that in general, certainly with respect to trust lands, the general rule still stands that state laws generally don't apply? But those incentives for energy, in particular renewable energy, typically still do including the fact that most states that have adopted or certainly all states that have adopted renewable portfolio standards are still on target to meet them whether those projects come from Indian land or off Indian land. Then of course at the federal level, legal issues concerning a whole host of laws that some of which affect the permitting, the leasing, the development process, rights of way, transmission, those types of things. Of course, once that power is sold into the market how it's taxed and how will tax implications both at the federal level and to some extent at the state level impact the overall profitability and viability of the project. Next slide.

So I always like to start with just making sure that people have a solid grounding in a couple of bedrock legal principles here. These two I think are some of the most important as tribes look at the business of tribal energy development. First, tribes are free to choose the form of governmental or non-governmental entity and organization through which they do business and that is whether they're on tribal land or off tribal land. As a general rule, as I mentioned before, state civil laws do not apply inside of Indian Country because those laws are either preempted by federal law or those state laws infringe on Indian self-ruled self-determination. Those are older Supreme Court opinions. They are still valid precedent today and continue to be cited in opinions in 2016. Next slide.

So we're going to dive into a couple of recent developments here. What you see on the slide is an image of Senate 2132 from back in 2014, the 113th Congress, 2nd Session, introduced by Senator Barrasso. Now the reason I have this here is this is where – it's just to kind of remind folks of the process and sometimes the long process of getting legislative policy that impacts Indian Country and Indian Energy Development in particular.

Then Indian Tribal Energy Development and Self-Determination Act amendments of 2015 that were then wrapped into Senate 209 and now are a part of Senate 2012 which is Senator Murkowski's bipartisan energy bill along with Senator Maria Cantwell from the great state of Washington. I'm going to dive into some of the details here. Essentially what Senate 209 is doing is trying to fix the problem of tariffs or tribal engine resource agreements. But it also authorizes a number of pilot projects in Indian Country and provides some other interesting benefits as well. Next slide.

So I want to dive into the current bipartisan energy bill because there are some late breaking policy developments there that could be very, very important to Indian Country energy development. As I mentioned, Senate 2012 incorporates Barrasso's provision by a voice vote into the Senate version of the energy bill. What that energy bill also does is it has a provision that – under section 4002 – that modifies the existing loan guarantee program that the Department of Energy runs. We refer to that because it's the section of the law that authorizes 1703. So we call it the 1703 Loan Guarantee Program.

What section 4002 of Senate 2012 does is it allows green banks, essentially investment vehicles that states set up as well as tribal entities to access loan guarantees for non-innovative projects. I know that may sound funny. What it really means is when Congress established a $170 million program that just goes to the clean energy projects, not the fossil projects and not the nuclear projects in the $40 billion Loan Guarantee Program that our loan program office runs here in the department, they put several critical conditions on that money. One of those conditions was that it had to go solely for innovative projects and that's defined as a technology that has no more than three commercial applications across the U.S. and those commercial applications cannot be – are in a five-year time period.

So what that effectively did is it cut out a lot of the base plain vanilla solar, wind, geothermal, all the various types of clean energy projects that tribes really wanted to pursue if they weren't going to try to do something that was driving innovation which is also important. But the bedrock of where we get most of our megawatts are from fairly plain vanilla renewable energy projects. Unfortunately, they weren't eligible for this particular loan guarantee. I have a site to the particular provision there in Senate 2012 for your reference. Next slide.

So what this does in addition to eliminating the technology requirement and opening this up to all federally Indian tribes including Alaskan Native Village and Region Corporations is it maintains the requirements that the projects have to reduce, sequester or avoid greenhouse gases, it authorizes DOE to make the loan guarantees to state energy financing institutions, creating loans to lenders where the lenders are also state energy finance institutions such as GreenMax but it allows also tribes to directly access those loan guarantees as well. Now the one issue with this is it does not make them eligible for the credit subsidy that's offered through the loan program. So what happens is there is a charge for accessing this money that is basically – it's somewhat like an insurance policy that the borrower has to pay up front in order to get the loan essentially to guarantee the loan from default.

Some projects are eligible for – some borrowers are eligible under the basic program for having that credit requirement subsidized by the department. Under this program they would not, but overall it's a positive change. It would make it easier for state energy financing institutions and tribes including Alaskan Natives to access these funds. That is a big part of what the policy that we're trying to promote here in the Office of Indian Energy to increase access to private capital, to debt capital and any other form of investment to help drive these projects. Next slide.

On the appropriations side, a very interesting development occurred under Senator Franken's leadership from Minnesota and that is that he inserted a report to the energy and water appropriations bill essentially carving out or re-designating $9 million of existing loan program authority – and again, that's the $170 million that I mentioned earlier – to go specifically for a tribal loan guarantee program. The details are currently being worked out. It's only a one-liner in the report to that appropriations bill but what we hope we see coming out when the sausage making is done is something that looks somewhat similar to the section 4002 amendments in the bipartisan energy bill that also are a very flexible program that doesn't have the innovation requirement.

It is possible – we're seeing that another movement from Senator Franken is that we may actually see this authority or this appropriation moved into a currently unfunded program that was established in the Energy Policy Act of 1992 – that's the section 26O2C Loan Guarantee Program for Tribal Energy. If that occurs, then the Office of Indian Energy will actually be having its own tribal energy loan guarantee authority separate from the Loan Program Office. Now unfortunately, this current energy water appropriations bill was pulled from the floor due to partisan disagreement over the Iran settlement. It had nothing to do with this or any other issue in trying to promote clean energy in Indian Country. As of yet, it has not been passed by the Senate but we're hopeful it will. We'll keep you updated on what developments there are on our website. Next slide.

So let's go back to the component of the current energy bill that is what got blended in from Senate 209. Remember, that got woven into Senate 2012, the current bill that's moving forward on the Senate side, the Energy and Policy Modernization Act of 2016. So what Senator Barrasso explained when he introduced his bill several years ago that in 2005 everyone thought the tariffs were an answer to tribes taking control of developing their energy resources without the burdens that lengthy BIA leasing approval and oversight. Well as folks know from the history of those programs, no one took advantage of it in part because it does require a fair amount of capacity and program operation that it would then be shifted to the tribal side, funded and maintained at the tribal side.

The fact is that a lot of tribes simply don't have the capacity or the funding to set up the kind of environmental – the NEPA-like environmental process that the 2005 energy bill required in order to get a tribal energy resource agreement. So they really weren't used. Next slide.

So what Barrasso's bill would do is several things. One, have an automatic approval is the Secretary of Interior doesn't disapprove the proposed Tribal Energy Resource Agreement in 270 days, it would allow for a certain type of eligibility determination and for tribes to demonstrate they have sufficient capacity to regulate energy resources pursuant to a TARA if they have three consecutive years of a self-determination contract or a self-governing impact that includes programs for management of tribal land and that during those years and under those programs it hasn't had material audit exceptions. Next slide.

So other changes wrapped in the energy bill include limiting challenges on environmental reviewed basis from outside parties to interested parties. There's a definition of that in the bill. Directing the secretary to make TARA tribes essentially eligible for shares of federal funding and explicitly preserving tribal sovereign immunity. It also clarifies the limitation of liability released to the United States which had been a sticking point for some tribes. Next slide.

Lastly, other features that of what was Senate 209, again now part of Senate 2012 is the technical assistance to tribes from the U.S. Department of Energy is wrapped in including a biomass energy demonstration program and – this very important – clarifies that tribes are included in the municipal preference under the Federal Power Act when applying for hydro licensing projects. I'll take 30 seconds to just stay on this subject for a minute. Hydro licensing applies not just to small or large hydro projects but it applies to a variety of wave technology projects, other types of in-stream hydro. It applies to off-river pump storage projects. Essentially it could create massive baseload power that is carbon-free and it's off the river if you have enough grade in order to develop a project like that.

Historically, in the legal community for those of us who have represented tribes for many years, we always argued that tribes were included under the municipal preference. Fir took a different view of that who issues the Federal Power Act hydro licenses. This would settle that issue. The municipal preference is really important because that that allows is anybody who can exercise the municipal preference can take over the license application of a non-municipal party. It gives a lot of power to tribes to acquire projects and project licenses from third parties. We can – probably enough said on that because we've got a lot of other detail. Let's go to the next slide. But we can certainly take questions if there are any on that.

Lastly, the – what was wrapped into the current energy bill includes a new option for eliminating the requirement for secretarial approval of leases, rights to land business agreements on trust and restricted land. It codifies tribal energy development organization transactions that would not require secretarial approval. Next slide.

So this is something I alluded to at the beginning but we really do think it is good news. In addition to continuing to see bipartisan support for policy development in tribal energy at the legislative level, we've seen some good results from Interior's wind and solar lease amendments that occurred several years ago that didn't require Congress to take any actions to create those. We're seeing certainly modest support for federal AC program budgets. They're not at the level we all had hoped but we're hopeful we can get where we need to go. We have a very interesting and shifting political landscape, but so far we see two things that have remained constant. One, everybody keeps talking about producing results instead of gridlock and, two, energy independence, self-determination in supporting tribal economic development has never been out of favor regardless of what side of the aisle politically you're on. Next slide.

So we're going to shift now to some of the issues in permitting and regulatory considerations for projects and we're going to pick up the pace a little bit here, again, so we make sure we save enough time though for Q&A and our next presenters' presentations. Next slide.

So this slide basically gives you some key requirements for projects that are going to have to be at least considered if not met during the project depending upon what the facts are and the setting for each particular project is. Those include interconnection regardless of whether it's on an existing gridlock like a WOPA grid or with the utility, net metering particularly in the area of community scaled projects, of course the local legal requirements and the tribal permitting in addition to the environmental and particularly the federal environmental requirements that we talked about earlier. So this just kind of gives you an idea of how those interact with whether they're applicable, kind of what the timeline is.

The key takeaway here is transmission is often one of the Achilles' heels of any clean energy project. Our experience is this is where tribes and their representatives, their team needs to start the communication with the utility early. That goes also for power purchase agreements. But it really should be one of the first topics discussed and understood before it much development activity and certainly before construction takes place. Next slide.

So again, we have to remember the legal issues that apply both tribal, state, federal and those apply different when you're inside tribal boundaries or outside tribal boundaries. Remember, tribes are perfectly free to pursue whatever course and structure of business they want whether it's on trust land or outside on other types of land or completely outside the jurisdiction of the tribe. But again, in general, if located on private, non-tribal or state properties, the state policies including land use policies do apply and if located on tribally owned fee land then at least in certain circumstances the project is subject to state and local land use permitting jurisdiction. Although I have had experience working on energy projects on fee land and there actually can be some significant benefits for tribes seriously considering developing fee land for energy because it may avoid other and in particular other federal requirements that come to play. So it's worth analyzing both. Next slide.

So this is really just to give you a snapshot and it's – this may vary depending upon the project again. But it's just a quick view of in general what type of permitting is necessary for grid connected system. Of course an interconnection agreement is always required whether again you're working with a large transmission organization like Western or you're working with the utility. Whether you need permitting for environmental transmission net metering and certain federal issues it really depends on the facts and usually off-take agreements and local and state permitting, again, on tribal lands is rarely a requirement. Next slide.

So understanding the basics of interconnection are really key and there are some shifting sands with respect to policy issues and the whole transmission/interconnection area. But we operate in an open access tariff as far as connecting to the grid. Usually some type of agreement is required to connect your energy system to the grid. There can be advantages for systems under 20 megawatts, certainly in Western's territory for fast-tracking the interconnection project. Again, the main takeaway is involve whether it's the tribal utility or just a merchant project early and consistently through the development process. Next slide.

Again, interconnections required for any power project to become grid tied, the process varies state by state but most utilities have tiered applications based on the size of their system, have their applications online and follow times and strengths on the application process flow very rigidly. Next slide.

A lot of us have in developing tribal energy projects have dealt in depth with the National Environmental Policy Act or NEPA and the whole environmental assessment or the Environmental Impact Statement process. A couple of key things to know. Say you are taking out a DOE loan or a loan guarantee or you're going through RUS, the United States Department of Agriculture RUS funding. Those are two examples of where those fundings with very few exceptions trigger NEPA.

Each agency usually not only has its own NEPA procedure but some agencies as people know have their own NEPA regulations that vary agency to agency. So again, it's key to understand what those requirements are and work closely with the agency and the experts and the staff in those agencies to determine and then prepare the required analysis. Next slide.

There are certain categorical exclusions for certain types of activities that have been pre-determined not to have a significant effect on the quality in the environment that require neither _____ or an EIS. If we're seeing more and more projects being approved under environmental assessments – I worked on project before coming back to the Department here that went from start to finish through an EA and a, "Finding of No Significant Impact," or a FONSI, in eight months. We have a note here. It can take a lot longer than that even for an EA but what we're seeing is a greater understanding and motivation on the part of the federal agencies that are processing that on the behalf of the applicant to understand one critical part in the tribal energy development and that time is always the enemy of any developer whether it's tribal or non-tribal. Next slide.

So of course, there are other ways that a NEPA could get triggered. It could be under the Clean Air Act, although there are some key exemptions for things like PSD review under the Clean Air Act. So if a tribe is considering a facility that might require a PSD permit, that's an important exception. Clean Water Act and of course Endangered Species Act and there are others. Next slide.

So one of the things that tribes have – and Jana here is one of our leading national experts along with a few other tribes across the country in taking a look at the Clean Power Plan which of course now is currently stayed or on hold by the Supreme Court, but the Clean Power Plan's goal is to reduce carbon pollution from its largest single source, that being power plants, and is kind of a two-part program. One as emission reduction targets depending upon how they're measured and the second part has a whole program for essentially creating credits for clean energy projects that can apply against those emission reduction targets. Next slide.

By the way, that map just showed those states that are actively pursuing plans under the Clean Power Plan. Those states in red that have suspended planning due to the Supreme Court's stay, state is a wider assessing planning. Of course the dark shade, the grey shade is for Alaska and Hawaii which are both exempt from the Clean Power Plan. Now being exempt from the Clean Power Plan doesn't mean that you – if a tribe from Alaska or Hawaii wanted to invest in a clean power project, in a state that – in any other state where the Clean Power Plan does apply assuming we see something similar come out after the stay, those tribal entities can still develop and take advantage of the carbon market that is proposed to be set up under the Clean Power Plan regardless of the fact they are from exempt states.

So that's an important consideration if you're from Hawaii or Alaska and may be interested as several of the Alaska Village and Native Corporations are mainly on the regional corporations are impossibly participating in some clean energy investment in the Lower 48. So I think we basically covered this slide. So let's go to the next one.

I would highly recommend you to get ahold of Jana. Sara Drescher with Forest County Potawatomi in Milwaukee has also been spending a lot of time looking at this subject. We've been actively communicating with tribes that have expressed interest in this with the EPA's folks working on the Clean Power Plan. Again, we can maybe cover some questions if people have any there. So let's go forward to the next slide. Next slide, please. There we go.

So state incentives and programs. These are some things that cannot be overlooked because they can provide – they can lower the cost of programs whether they're credit subsidy types of incentives or whether they're actual cash. Tribes may be eligible for some of these including rebates, tax incentives, community solar programs. State regulated utilities are often mandated by renewable energy or renewable energy credits through the RPS or Renewable Portfolio Standards and what – so for example, we know in the State of New Mexico the regulatory commission's view is that if a tribe wants to take advantage of the 50 percent renewable energy credit booster that's in the 2005 energy bill for energy developed on tribal lands or Indian lands and then sold to a federal purchaser they can still do that by running those projects through the regulatory commission as long as the commission sees on the other end a federal purchaser and essentially the power from that project is a pass-through.

There are many other regulatory commissions that see that fairly similarly. So that's just one example of the fact that there can be a lot of benefit in extracting real value from these incentives by working with the state where tribes traditionally don't have as great or as good of a working relationship. Next slide.

Just a little note on what RPSs are. I think we can move on from this slide. This just shows you as of last year kind of where RPS policies were in the country. You see that some states in the Midwest are still – they haven't adopted them or maybe have voluntary [background noise on audio] _____ _____ _____. The point here being, that it's not consistent but it is a large portion of the demand center states and a large portion of where a lot of our electric distribution and transmission lines are are where a lot of demand centers are. Next slide.

Now net metering is worth spending – because this is a policy that is – it took some regulatory commissions in states a little time to warm up to but pretty much is now standard across the U.S. It's not consistent across the U.S. but it's a fairly standard approach. It's way for utilities to encourage customers to deploy reconnected generation whether it's owned by the customer or third party. It's simply, as the name implies, allows generation or electricity that's not used to flow onto the grid and be credited back to the customer.

Often credit for the net excess is all that occurs. You don't – it's very rare, it may be non-existent where somebody's actually cut a check but that credit is valuable and it not only cuts utility bills down but can be carried forward in many systems. Overall, having that metering can improve the economics of the smaller scale, especially the residential applications that I know are becoming more of an interest and more popular on the tribal level because of the large financing hurdles and other regulatory issues related to utility scale projects. Next slide.

Again, just a map showing those states. A little bit better performance here than states that have adopted RPSs, those states that have adopted net metering rules. Next slide.

So again, just a note here that we do now have an extension for the production of the investment tax credits which has been the backbone of producing renewable energy in the U.S. at least for those entities that don't have such large balance sheets. They can ignore the 30, 40, 50 percent price of the project that can be monetized through these credits. Next slide.

By the way, the reference to MACRS is simply that it's the way depreciation is calculated. So when you add depreciation, again, it has to be to somebody that has a tax appetite and to the federal either production or investment tax credit, the amount of cash to the project can exceed 50 percent. This just shows you kind of the roll out for certain types of technologies under the investment tax credit proposal and how that is going to play out over the years. Next slide.

So we're going to end up here on tools and technical assistance. Next slide, please. Basically, what I would refer everyone to, I found this to be extremely useful in private practice and it's still very useful on the government side is the Database of State Incentives for Renewables and Efficiency or DSIRE. I know that sounds like something you don't want to punch into your Google on your computer but it is D-S-I-R-E. That database is updated constantly. It's one of the best out there. Next slide.

This is just a listing of links for regulatory and policy resources including the DSIRE resources database. Also a grid website for best practices on net metering, American Planning Association for Zoning and Planning Considerations, DOE state and local energy data for basically energy market information by zip code or community name and then the rapid tool kit about the federal, state and local permitting and regulations for utility scale energy and transmission projects. The links are all there in the slide. Next slide.

Lastly, this is our online request for technical assistance snapshot of our webpage. It's very simple to fill out. If tribes – especially tribes are kind of figuring well they have a project concept or they know they may have a good resource but they're either at the very beginning stages or they have very specific questions about those projects or they may want to do strategic planning, any step along the line of where they tribe is in the process, the technical assistance can really help our contractors for technical assistance, largely the National Renewable Energy Labs but we contract out transmission capacity studies to WOPA for example. We also work with Sandia National Labs and a host of other contractors in Alaska. They're the best in the country. It's a simple, easy process and it's available to every federally recognized tribe in the country. Next slide.

That is all for my presentation. So I will hand it back over to you guys. I think we've got Theresa up next. But again, happy to answer any questions either about our programs here at the Office of Indian Energy or any of the material we covered on the slide presentation.

            Thank you Doug. Theresa, just give me a moment to get your slide deck pulled up. The virtual floor is now yours Theresa.

            Okay, thank you. Thank you Randy for your insightful presentation. I'm sure we will be contacting you because – we're just at the beginning stages of our solar project and we would like to get whatever information we can for it. Good afternoon, and thank you for inviting me to present today. My name is Theresa Cole. I am the special projects coordinator for the Akwesasne Housing Authority. We're from the Saint Regis Mohawk Tribe in Upstate New York. Today I will talk mainly about our Go Solar Initiative. Slide two.

Some topics to be discussed; the intro to Akwesasne Housing Authority, our energy vision, Sunrise Acres Complex, technical assistance and strategic plan, project goals and outcomes, community awareness campaign, solar initiative goals, AHA and energy conservation and education programming, funding sources, New York State and utility rules, net metering location and progress and next steps. Next slide.

Just an introduction. Akwesasne is the Mohawk name for the Saint Regis Mohawk Tribe comprising of more than 10,000 community members who live and work on both sides of the U.S. and Canada border as you can see on the map.  Akwesasne has two government systems. In the U.S. it's the Saint Regis Mohawk Tribe and in Canada it's the Mohawk Council of Akwesasne. As you can see, our community is unique in that it straddles the American and Canadian borders but also in Canada in the provinces of Ontario and Quebec. This can be challenging at times.

The Akwesasne Authority is the tribally designated housing entity for the Saint Regis Mohawk Tribe. It was created on July 19, 1984. Since that time they have built over 400 low-income homes, 41 low-income elderly units and have participated in numerous ventures in the community such as the Akwesasne Boys and Girls Club, the Akwesasne Diabetes Center and Office of the Aging to name a few. With the support of the tribal council, AHA is paving the way for the tribe to go green. Next slide.

Our combined energy vision is to minimize our environmental footprint, employ diverse energy systems, to become energy efficient and reduce energy costs and produce alternative energy resources. Our dilemma was that the average electrical rates in the United States is around $12.22 per kilowatt hour while our facilities in New York State were paying an average of $0.18. to $0.19 per kilowatt hour. We were not sure how long we would be able to continue to absorb the rising electrical costs and still remain affordable for our elderly residents who are on a fixed income and our units include electric. Next slide.

We've had previous experience with solar when we expanded our elderly complex with 20 units in 2011. Each quad was equipped with a solar PV system and other energy-saving techniques. During that time, we tracked the savings for the five years in operation and we saw the benefits. That initiated our next step in developing more units and we decided that from this point on any development we do would include energy-saving, solar and whatever we could do. Next slide.

So we were fortunate to receive funding through the DOE Indian Energy Technical Assistance to develop our strategic plan. So on January 2015 we hosted a strategic planning session which was attended by members AHA, our tribal department, the tribal council and board members. In conclusion, after we developed our plan we felt we needed to further develop it and to include more participation within our community. So in June 2015 we received technical assistance again from DOE and we hosted a community wide session to continue our strategic plan. What we got out of it was an overall plan and a commitment from the tribal council to prioritize energy in all our future ventures. We decided that we would employ certain degrees to engage all our tribal departments in the development of our renewable energy strategy. Next slide.

This slide is what we received from NERO and it gives an overview of the resource availability on the Saint Regis Mohawk Reservation, mapping out our community. We also received a market assessment of the Saint Regis Mohawk Tribe from the DOE Indian Energy. Our land base was not suitable for wind power. Solar power was our best option. The Saint Regis Mohawk Tribal Land has also the technical potential for a rural utility scale PV, geothermal and hydropower. Next slide.

Our goal is to build 614.74 kilowatts of solar facilities, providing energy to 145 tribal members, residents and 14 AHA and Saint Regis Mohawk Tribe buildings. This would also produce over 20 million kilowatts with a cost-saving of over $4 million and reduce the greenhouse gas emission by 351,000 pounds per month. This project would also create 11 training and job opportunities in solar installation and maintenance for tribal members. Next slide.

What we did was we had a community awareness campaign. We put information out in our local papers. We did radio announcements. We had put information on our website and we also have our Facebook page which we put information on all the time. It seems like that's the way we kind of reach more people.

We presented at tribal council meetings and community meetings and we also developed promotional items that were given and distributed to the community which was Solarize Akwesasne. Announcement in the paper and on the radio was for community members who were interested in solar installation. They had to bring in a year's worth of electrical and heating bills. This was all gathered and sent into our funding agency. A priority list was made with low-income being the priority along with seniors and disabled residents. Next slide.

With our PV, my solar PV goal would allow us to expand and continue to provide our affordable housing. This would also benefit our community members by reducing their consumption. They'll be involved in their own cost-savings and conservation plan. This would reduce the cost of utilities for all our low-income residents. Next slide.

With the participation of our entire council would have to commit to conserving energy and participate in an education programming. This would include continuing to make their regular payments to the utility company, agree to have their utility bills monitored, families would be complete and educational program and agree to reduce their energy consumption by 15 percent. Next slide.

Some of the funding which we went after were $600,000.00 through the ICDBG grant, NYSERDA and the DOE Indian Energy. It was up to $1 million. Next slide.

The State and Utility Rule. In June of 2011, New York State enacted legislation allowing for net metering. In July of 2015, the New York Public Service Commission issued an order establishing community net metering. National Grid, which is our service provider, allows up to 2,000 kilowatt net metering. National Grid and the Saint Regis Mohawk Tribe are working together by employing a community liaison to work out a payment plan with community members who are delinquent in their payments. Next slide.

The next map is the land parcels owned by the tribe. These were the areas that were looked at to put the net metering location. Next slide.

What was decided was the land chosen was next to a vacant building and across from the Akwesasne Mohawk Casino. As you can see, so more development will be happening. Right now, like I said, we're just in the beginning stages. Next slide.

This diagram, it shows our next development. We will be building two supportive housing buildings which will feature solar. One building is a 12-unit expansion of our supportive housing for our elderly. The next one will be a supportive housing for Native American homeless veterans will be our six-unit expansion within our Sunrise Acres complex which houses 41 senior tenants. Next slide.

We were fortunate to receive our Indian Community Development Block Grant in February of this year and our DOE in March of this year. What – we sent out an intent to apply to our local Indian home company for solar installation. We are now just beginning to develop our energy conservation and education programming plan and we're expecting that this all will be completed by 2017. Next slide.

That completes my presentation. If you have any other questions, Retha Herne is our executive director of the Akwesasne Housing Authority and I included her contact information if you need to discuss it further. But one of the things that I found, too, is that we'd be more than happy to take on any – if we are able to present again and to let you know some of the hurdles that we encountered along the way, but right now we're just like at the beginning stages.

            Thank you Theresa. You've been very busy, haven't you?

            Yes.

            Jana, give me a moment to get your slide deck pulled up.

            No problem at all. I just – in the meantime, I just want to thank the Office of Indian Energy, Sarai and Randy for pulling these presentations together, to Doug for your expert remarks. There's so many useful pieces of information in there and to Theresa for just this stellar example of how one tribe has worked with their state and has worked at the nexus of many of these policies and regulations and incentives to get projects implemented. I'm going to go pretty quickly through my presentation so that we have time for Q&A. I'm specifically going to focus on our experience in implementing projects on tribal lands but have been at least in part state partnerships. Next slide, please.

Again, I'm Jana Ganion, the energy director for the Blue Lake Rancheria. Next slide, please.

We are located in far northwestern California in a geographically pretty isolated, rural location. This is important for all kinds of reasons but one of them is that in our area we are concerned about energy assurance and energy security among other issues. We are actively working with the State of California on many of these which I'll get into detail here in just a little bit. Next slide, please.

Here are some details. The Blue Lake Rancheria is a relatively small tribal community. We have about 100 acres of tribal trust land. So we have to be very sort of compact and efficient with our onsite energy development. The tribe has some experience in utility scale energy projects but most of our experience is in community scale and facility scale projects in the renewable space. Next slide, please.

For a small tribe, we have an outsized energy vision. We are focused on climate action and greenhouse gas reductions and community resilience is kind of the three legs of our energy stool. We have aggressive greenhouse gas reduction goals. We have 40 percent less GHGs by 2018 measured from a 2014 baseline. That measurement is being conducted by the National Renewable Energy Lab through the generous technical assistance provided by the Office of Indian Energy. Ultimately, we want to achieve 100 percent renewable energy onsite and 0 net greenhouse gas emissions. Next slide, please.

Why do we have these goals? Because here on the North Coast and I'm sure everyone on this call is already experiencing impacts from climate change. These are just some of ours. We are in many ways very fortunate to be located within the State of California because California has aggressive climate goals and targets as well. I think that one of the things that we specifically deal with are, as you can see at the top right-hand picture, we have specific infrastructure threats that literally every year cut off access to our region by road. We are experiencing water quality issues as everyone else is as well, huge wildfires and we're starting to pay very close attention to the more recent science on short-lived climate pollutants such as black carbon and particulate matter 10 and 2.5. Next slide, please.

We are working closely with the State of California and tribes do work with their respective states obviously as everyone on this call is aware on many things. Gaming is a common one, but energy development touches on many points of partner. There are over 100 tribes in California. So if we can get a state tribal partnership facilitated here, that is really something that benefits a lot of stakeholders. Just as a few examples of this, we are working with the state.

We serve on their technical advisory team for Governor Brown's executive order B3015 which implements California's amazing greenhouse gas reduction targets, 40 percent below 1990 levels by 2030 and 80 percent 1990 levels by 2050. These are aggressive goals. California is on track to meet those goals and we are thrilled to be helping with that effort. Some of the specific projects that we have received state funding for for energy projects on tribal land include our repowering Humboldt with community scale renewable energy which had electric vehicle charging stations and a biomass gasification and fuel cell distributed generation energy system as a part of that project.

Then our current project is a low-carbon community scale micro grid for critical infrastructure. That is being funded with a $5 million grant from the California Energy Commission which I'll get into a little bit of detail here in just a minute. We are also working closely with our regional utility and our PG&E, Pacific Gas and Electric Company. They have been absolutely incredible to work with.

I'll echo Doug's statement that when, especially in a community scale or facility scale project, when tribes are implementing those if they're going to be grid connected really reach out to the utility and start that relationship as one of the first things that you do. They're very knowledgeable about the energy infrastructure, the electric infrastructure. They have certain regulations and requirements that they need to meet mainly around safety. Those requirements will be a part of the tribe's project. So developing that relationship is absolutely critical. Next slide, please.

As I mentioned, some of our other partnerships include California Energy Commission as funder and project manager and just all-around incredible support. We are partnering with Humboldt State University which is part of the California State University system. This partnership really leverages the CSU and Humboldt State University STEM expertise, Science, Technology, Engineering and Math. There's a built-in knowledge transfer to the tribe and it helps build capacity in all of our energy projects through this University tribal partnership. As I mentioned, we have an amazing working relationship with Pacific Gas and Electric Company. Then we have in all of our projects utilized and worked with a number of California based technology partners. Next slide, please.

Some of the lessons learned. When we started our micro grid project, because we were using state funds for a project on tribal lands we triggered this – it triggered state environmental review under CEQA, the California Environmental Quality Act, but it was a new context for that team to develop to do CEQA for our project on tribal lands. So just to really summarize and effort that took a lot of goodwill and a lot of coordination, we worked through a compliant process that respected tribal and state legislation and sovereignty and notably the State utilized the tribe's environmental assessment and our Finding of No Significant Impact or FONSI within their negative declaration and CEQA process. At the end of the day, it worked out beautifully. Next slide, please.

This is where I want to spend just a few minutes because there's a lot to say here. Unfortunately, we could spend probably the rest of the day talking about it but we don't have that much time. We see the need for developing tribal/state project guidelines, guideline documentation around energy projects as a proactive measure. In the State of California, the California Department of Transportation or CALTRANS as it's called has developed this kind of a guideline. It is an extraordinary example of a document that state staff and tribal staff can use to start any project, get the lay of the land and not have everything be sort of new and perhaps intimidating.

So it removes a lot of the discomfort between tribal and state staff that are tasked with implementing a project. If we could do that for energy projects, I think it would be incredibly effective. Within a project guideline we would want to talk about obviously streamlining tax exemptions for energy projects, the process for that. We would want to also talk about obviously environment review, general introduction of and references for tribal legal and regulatory frameworks and other starting points.

The other things that Theresa was talking about, tribal access to state incentives, utility incentives, RPS based incentives and as Doug mentioned, some of these are readily available for tribes. In some cases, the regulatory language is silent on tribes. So we have to work through those issues on a case by case basis. We've got a couple of those in California, the Community Choice Aggregation program is an example of that where it is specific entities that are eligible for it are cities and counties. Tribes are – it's silent with respect to tribes.

Again, if we had more time we would delve into more detail. But we see the need for more work around joint powers authorities, joint powers agencies which are typically formed under state laws for kind of sub-state entities, for counties to work together or cities to work together. But we'd like to see tribes folded into those processes. We'd like to see tribe to tribe JPAs underpinned by a federal regulatory framework of some kind.

Now there is a case study. The Tahoe Regional Planning Agency was formed to regulate land use in Lake Tahoe Basin in a JPA which includes territory in both California and Nevada. So that's sort of an example of a state to state JPA that could provide some sort of a starting point for a tribe to tribe JPA structure. But that was formed with a bi-state compact that was ratified by Congress. We know from comments earlier today how difficult it is to get things passed through Congress these days.

But looking at those things in terms of how they can be used to develop tribal energy projects we think are really important from our experience. There's a couple of other things like developing a national tribal utility commission that could benefit tribal utilities wherever they occur and discussing frameworks for that I think warrants some specific attention. Next slide, please.

So there are many things that I've cut short today. I would like to wrap it up by saying that there are some upcoming tribal regulations and policies and programs that are pertinent. A couple of them, as Doug mentioned. One of them is the Clean Power Plan. If anyone would like details on that, we are pushing – the Blue Lake Rancheria is pushing for a federal implementation plan for tribes underneath the Clean Power Plan.

There's a lot of details to that that we won't have time to cover today. But I'm happy to answer questions on a one on one basis. Then the quadrennial energy review, comments are – the comment period is open for any policy recommendations, regulation recommendations that tribes see as needed. That is a place to lodge those recommendations and those solutions. With that I will turn it back over to Randy for Q&A with the final comment that I will be available and responsive if anyone wants to email me questions after the presentation. Thank you.

            Thanks Jana. Let's go to our panel for Q&A. We have Sarai Geary, Doug MacCourt, Theresa Cole and Jana Ganion. Just give me a moment to see what questions are coming in and get our Q&A slide pulled up here. So let's see what we have coming in. I don't see any written questions yet. I know Shawn's working on those.

So let's see if anyone has a raised hand and remind the audience you can click the "Raise Your Hand" icon and ask the panel a question directly or you can type a question by clicking the question box and we'll get to all your questions. I don't see any raised hands yet. Let's go back and – just bear with me. All right, here's a long question. "Offtake agreements or PPAs are likely to become one of the most common ways to finance PV systems between 1 megawatt and 20 megawatts. With community solar systems of this size proliferating across the country, what steps has the DOE taken to assist in these types of agreements?"

            Well so this is Doug MacCourt at the Office of Indian Energy and I'll take a stab at this but anybody's open to chime in. I'll answer it in a couple of different ways. First, we spend a fair amount of time both in our technical assistance program as well as in the materials and the research that we put out both through the National Labs as well as through other partners digging into just what are PPAs, how are they negotiated, what are the critical terms, what do the tribal business entities and their representatives need to think about in terms of things like reserves or provisions for curtailment. Those are technical terms in every PPA but they're in every PPA.

Let's take curtailment, for example. In a transmission constrained environment, Power Purchase Agreements have provisions for the utility to just turn off your project if they have to in order to serve demand through other means. This is very common in the Bonneville territory where we have so much wind on a hydro based transmission system that it – when we need to make changes seasonally to the output of the dams and things like that, we simply have to curtail the output of wind farms. What that does is you have to factor that into your profit profile and the liability of taking on a project like that.

So that's an example of the kind of detail that we help tribes through our education and training processes. But we also – if a tribe wants to bring a PPA to us through the technical assistance program, that's a pretty common thing whether it's a PPA or any other agreement that they're asked to enter into. We can't provide legal advice but what we can do is work with your team to understand maybe some options, some alternatives both in terms of the entire agreement as well as various provisions within the agreement. So that's one thing we do.

Then another way we share information about PPAs is through the Tribal Energy Program's annual review. We get the leaders in Indian Country – I mean this is totally separate from the leaders like Jana we have in our Indian Country Energy and Infrastructure Working Group but in our annual review we bring all the projects together and that's an open meeting for anybody in Indian Country, frankly, the businesses that support energy development in Indian Country to attend and learn from the other tribes what their experiences are and _____ _____ PPAs and what worked and what didn't. So there's a whole lot of information we can provide out there.

I guess the last comment I'll make is there are some models other than PPAs for smaller projects, specifically some kind of construction agreement type of documents that can serve – if the primary purpose of the smaller project is to serve the local demand and the local load and then through a net metering agreement work out the excess energy – I mean once you're over a megawatt that's – it may not be the case but it depends on what the local load is. Right? You may have a pulp mill or a lumber mill or some other type of industrial or commercial enterprise that just takes a lot of load for which a different type of arrangement might be possible and it actually might work better. So PPAs are essential to financing. Whoever asked the question got that right. It's not the only game in town.

            Thanks Doug. Another question related to PPAs. "Following up on that comment, I'd like to know if there are clear provisions in PPAs about who owns the RECs associated with the energy. I know it's a detail but this makes a difference to how greenhouse gas reduction are attributed." I can address that, Doug, as well if you want to –

            Well yeah. I think, Randy, you and I are probably going to say the same thing but I'd be curious if we do. What I can – from my experience, it is very unusual if the RECs are not bundled with the power. That is usually at the insistence of the utility if you're negotiating a PPA whether it's an investor-owned utility, a public utility, or what have you.

Now you may have a little more flexibility on the power marketing side. Randy, I'd be curious to know that. But the reason that the utilities require that the RECs be bundled with the power is that they want the flexibility ultimately to determine how to use that RECs and what value they can make out of them. They always start from that position. There may be a different outcome depending upon what you can negotiate but that's the typical rule.

            That's exactly, Doug. It's important that the RECs, the ownership of the RECs are spelled out in the PPA. That's a must. So if you're signing a PPA and the REC ownership provision is not in there then that's not a good thing for the seller or the buyer because that'll just lead to litigation.

The other issue here is that the Federal Trade Commission has very specific language on what you can claim if you own the RECs and if you do not own the RECs. Every tribe should look at the FTC language on that, because if you do sell the RECs to your project you no longer have green power. So look at the Federal Trade Commission guidelines to make sure you're not making any false claims if you are selling the RECs.

            Yeah. Randy, I'll add one more – just I'll build on a point you made that's so important is the contract, whatever kind of contract it is. If RECs are generated which they will be no matter what amount of power you develop in a clean energy project, you'll develop some level of Renewable Energy Credit. The real question is, "Can you monetize those and what value do they have?" But leaving that question aside, the contract needs to be clear.

Now it's very unusual that you're not going to get – if you're working with a utility on a utility scale project you're going to be handed the utility's form of Power Purchase Agreement in most cases and it's going to be very clear that the utility is going to own those. But at the end of the day – at least that's where they start from. Again, I always take the position, it's always negotiable and you reach the best decision for the tribe and the tribe's interest but it's got to work for everybody. I also want to point out that I hve seen deals on the community scale where the parties didn't think they needed to clarify that because they were community scale projects.

But then when the utility started buying power through a net metering agreement it insisted that it got the RECs then they worked their way back through the contracts that weren't clear. Guess what? It created litigation between two parties who were working very well together and were – they were both non-profits. They both had great goals and greenhouse gas reduction objectives in mind. Here they end up in court because essentially their profit profile and the whole value proposition for the project changed once the utility insisted that it owned the RECs. So just a longwinded way of saying it's got to be clear in the contract.

            Thank you Doug. It doesn't look like there are any other questions. Let me just scroll through the screen. In closing, Doug, Jana, Theresa, any last comments?

            This is Doug. Real briefly. I just want to thank Theresa and Jana because they're leaders in their tribal communities for doing the kind of projects they're doing and taking the kind of steps. I think they also show – I mean even though Akwesasne is larger than Blue Lake, there are tribes up there that cover a lot bigger footprint. But here are examples of tribes doing very impressive work in the clean energy space.

Blue Lake's a pretty small tribe and that doesn't limit how far you can go in this and how much a difference you can make. I will also note – and thanks Jana for reminding me – the quadrennial energy review is really important to Indian Country. Specifically, what it is, it's an attempt to do two things; describe the state of the electricity system from generation to end use and it's a White House directive placed upon the Department of Energy several years ago.

Then it's also – the second key feature is, "What recommendations should parties make about how to improve that electric _____ system?" We have – for the first time the Department of Energy has – and largely because we've been ringing this bell, we've been taking the QER out to Indian Country and letting people know what the schedule is that the Department of Energy is going to create its own Indian Country section inside the QER which they've never done before. What that tells me is they're starting to get the picture that electricity in Indian Country is different than it is or may be in a lot of the rest of the world. But at the end of the day, the way that this works is you need to go to energy.gov/QER.

In all of the comments that are received come in in two forms, either through one of several listening sessions that are – there's the next one is schedule Monday in Austin, Tuesday in L.A. then there's one on the 24th in Atlanta I think which concludes it. But the primary way tribes provide input into the QER is online. So I urge everybody with an interest in trying to describe whether it's the good, the bad or the ugly about the state of electricity in Indian Country get on the Web and do that on behalf of your tribe. Also, as Jana pointed out, make some recommendations for how we can improve this and improve the economies and the lives of people in Indian Country. Thank you very much for letting me go on.

            Thanks Doug. Jana, Theresa, any other last comments?

            This is Theresa. I just wanted to say that this was very interesting and I will probably reach out in the future to Doug and Jana on some of their information they presented today.

            Thank you. Jana, anything else?

            Yeah, this is Jana. I just want to thank everyone for attending and I think that one area of focus that we talk about kind of in general but we don't really get down into the details of is where tribes are building, owning and operating their own energy infrastructure especially clean energy infrastructure. There are significant ways in which we can both improve regulation and policy and utilize regulation and policy that is already on the books. We just want to put the message out there that where tribes are interested in working on these things, our door is always open and we are so proud to be part of this community and especially having such great team members too on the federal level to work with. Thank you all.

            Great. Thanks again to our speakers. Up on the screen, one last plug, our remaining webinars for the year. The next one, "Tribal Business Structures for Financing Projects," May 25th. We hope to see you all there. With that, have a great rest of your day. Bye-bye.

            Thank you.

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