Operator: Today's Wednesday, July 1 2020.
I'll turn the call over
to your host President Marybel Batjer.
-: Thank you, operator and good morning everyone
and thank you for joining us today.
I am calling the CPUC Commissioners' Committee,
meeting of July 1 2020 to order.
There are three committees,
the Finance and Administration Committee,
the Policy and Governance Committee
and the Emerging Trends committee.
Today the Policy and Governance Committee will meet
to discuss the draft enforcement policy.
If you wish to make a public comment, or ask a question,
please dial 800-857-1917
and enter code and press star one.
You will be placed into a queue
and will be called upon to speak.
When get to the public comment period
Which will be after the presentation.
We will also, excuse me, read questions sent via the email
to the policy and government Governance Committee.
Additionally, there will also be an opportunity for public
to provide general comments at the end of the meeting.
Okay, I will now turn to Commissioner Rechtschaffen
so he can begin the committee meeting.
-: Thank you very much, President Batjer.
Can everyone hear me, okay?
-: Little loud please.
-: Okay, I will try to talk forcefully.
Good morning, today we're going to be discussing
our draft enforcement policy.
Can you turn to the next slide, please?
You can see here where the outline of our agenda for today.
We're going to talk about the policy,
how to participate, the key elements
and the next steps going forward
in terms of getting public comment
and proceeding to adopt the policy.
Next slide please.
Oh, can you go back one slide.
This is the information about how to participate.
Like the operator may have told folks
already about doing this
but there's two options for participating.
Dialing 1-800-857-1917 entering code 7218384
and pressing star one.
Or you can participate via email
as one word policyandgovernance@cpuc.ca.gov.
Next slide please.
The policy we're discussing today is an outgrowth
of a compliance and enforcement initiative
that we launched at the PUC in 2018.
We've had a few public meetings
and some discussion over the course of the past two years.
We've done a lot of work internally.
I just want to set the stage
by re-recapping this very, very briefly.
The PUC has many existing enforcement efforts,
many programs and policies across industries.
It was great diversity among
the industries that we regulate.
And we regulate a range of industries
from gas, electric, railroad, rail safety,
transportation, passenger companies.
The initiative started out of concerns that were expressed
by some Commissioners, some of our stakeholders,
some outside observers, about the pace of our enforcement.
Sometimes enforcement took too long, it wasn't timely,
it wasn't always uniform,
and we also do not have the kinds of formal policies
that many other regulatory agencies have.
We also got criticism by the,
Federal Pipeline Hazardous Safety Materials Administration
after the San Bruno accident
about the lack of certain flexible tools
that other agencies have.
Some Commissioners raised concerns
that as markets evolve and new business models emerged,
we weren't equipped to keep up with enforcement
and compliance issues that those raised,
and we also had an overriding concern
that what we were doing was not especially visible
or transparent to the public.
We started the initiative with an internal review
and survey of all the divisions
that are comprised of the PUC,
the ones that do enforcement only
and the ones that also do other regulatory activity,
but refer enforcement actions to our enforcement units.
We interviewed staff about how effective
the tools that we have are,
ideas for improvement,
what gaps there might be in authorities
and what gaps there might be in resources.
We also consulted with other,
regulatory agencies as part of this process.
And the goal was to establish and then come up with a plan
for implementing a policy.
First, a set of principles and a formal policy
that strengthened our enforcement practices,
provided for greater uniformity,
addressed whatever gaps we found
in administrative tools and resources.
So, that's what we're coming forward with today.
I wanna thank the excellent staff engagement
and support we've had over the past couple of years.
Executive Director Stevens has been very supportive.
April McQueen, Deidre Cyprian in Executive Division
have been very, very helpful.
We've benefited greatly by having a retired annuitant
with decades of enforcement experience,
working for the California Attorney General's office
and other state agencies,
Denise Hoffman, who you'll hear a little bit later.
There were enforcement leads from each of
the different divisions who helped us.
Mira Metakey also played a key role.
And I wanna thank my Commissioner partners in this effort
and the steering committee, in particular,
former president Picker and president Badger,
who were very instrumental in working on this policy.
Next slide, please.
Our enforcement staff is very very busy,
and this Snapchat just gives you some small sense
of a number of investigations,
other activities that our staff is involved in,
across the industry division.
Electricity, gas, railroad and rail safety,
other transportation related incidents.
This does not cover the entire universe.
It's just indicative of some of the activities,
some of the diversity
and the importance of having enforcement and policies
Next slide, please.
One of the goals of the initiative was to
create more public insight into what we're doing.
Many, if not most, of the regulatory agencies
routinely publicize their enforcement activities,
their enforcement accomplishments,
they provide access to what's pending, what's been resolved
and so forth and we wanted to move in that direction.
Because part of the effort to increase transparency,
we launched an enforcement webpage last year
which you can see a screenshot of the current webpage.
And this includes a list of
all our citation programs in one place,
which we had never done before.
And Jason Reeger and others were fantastic in helping
to compile that.
It also lists all citations in fines issued each year,
major opened and closed investigations.
This continues to be very much a work in progress,
we have great ambitions for this to become
a one stop shop for public information
on enforcement matters,
many other agencies have something like this.
The webpage right now is current as of last fall,
we're updating it and as I said,
it's very much a work in progress but it shows
the kind of transparency that we're aspiring to.
Next slide, please.
What is the enforcement policy?
It is a vehicle for articulating the broad principles
that guide our enforcement activity.
It applies to all CPUC enforcement activities,
all industry divisions, all types of actions whether
very informal, just a phone call, to more formal
in order to instituting investigations,
referrals for criminal actions, everything in between.
Very importantly, it builds greatly on existing practices.
As I said, we do a lot of enforcement here,
we've done it for a long time,
there's many things that are done well,
and this policy builds on those types of improvement
to prove them identify and revenue gap
but very much built on existing practices and programs.
The overriding goal is not enforcement for enforcement sake,
but to promote maximum compliance
with our rules and regulations.
That's the keystone.
How do we make sure that the
entities we regulate comply to the greatest extent possible
with our rules and regulations that are designed to
protect the public, ensure our liability, safety, and
consumer protection.
So compliance is the ultimate touchstone.
Next slide, please.
Last year, we discussed publicly and adopted at a
July 2019 policy and governance committee meeting
a set of principles that we developed internally
working with staff and the other Commissioners.
And these principles are at the face of our
enforcement policies.
I'm not gonna go through all of them,
but I want to highlight a few.
I just mentioned maximum compliance is the ultimate goal.
And then we have a series of other principles
that follows very much the court teachings of what
good enforcement should consist of.
One, enforcement should be consistent.
We have different statutory authorities and
directives that provide different rules for
different types of industries.
Industries and regulative entities,
of course we must follow
but consistent with what those allow,
we wanna have tools, approaches, policies, practices,
that provide for consistent enforcement.
Like industries, like entities, are treated similarly.
We follow predictable practices.
Second, we wanna have firm enforcement
that provides for meaningful deterrence.
A key part of meaningful deterrence
is to have an appropriate set of penalties,
which we have, and which we've implemented
for two decades or more,
penalties that recoup economic benefits
that a regulated entity is not better off
from violating the law than complying with the law,
and that are calculated based on the harm they cause,
the conduct of the regulated entity,
and the financial resources of the regulated entity,
and their ability to pay a penalty.
So these principles which are reflected in this document,
and in an appendix to the document,
are very similar to current practice.
We want enforcement that's timely.
Decades of research shows,
timely enforcement is much more effective.
And progressive enforcement.
That means, you start at an appropriate level
given the nature of the violation,
and you escalate it in severity
based on how serious the violation is.
We wanna have transparency.
I mentioned that already.
We have a principle that we wanna make sure
we are promoting fair treatment of all communities,
consistent with our environmental justice
and social justice action plan, and state law.
And this means,
this includes tailoring enforcement responses
to address the needs
of vulnerable and disadvantaged communities,
which may be differently situated
than other communities, in terms of their needs,
and enforcement requirements.
And finally, we wanna be adaptive.
We wanna be able to respond to new business models,
new markets, emerging consumer issues and abuses,
which we've seen over the years.
For example, consumer protection,
or net energy metering of customers,
which has been a subject of an ongoing proceeding.
Next slide please.
So what's in the policy?
We create Division and Commission enforcement teams.
We describe the range of tools
that are available for all industry divisions.
These are uniform tools.
There's a menu that is available,
but these apply across the board.
As I mentioned, we have a penalty assessment methodology
that's in the appendix to the document,
and it's very much, it's built on existing practice
and existing statutory guidance.
We also outline a settlement process.
I won't talk very much about that today.
So now I'll go into a little more detail
about som of the elements.
Next slide please.
One of the key ways that we seek to promote consistency
is the creation enforcement teams,
again, a best practice for many other regulatory agencies.
And we do it in two ways:
one, within a division,
there will be enforcement teams.
These will meet to make recommendations
about how to proceed with cases within the division,
prioritize what cases are more important.
We can't do enforcement everywhere.
We can't go after every
potential violation with the same level
of resources across the board,
we have to decide what's most important.
That's part of the task of this team.
And these enforcement teams within the division
also will be the ones to track enforcement activity
and publicize them, so that's within each division.
And then Commission-wide, a liaison from each division
will be appointed and a Commission-wide enforcement team
will meet and discuss enforcement matters
of statewide concern with the goal of promoting consistency
and efficiency throughout the Commission.
Not entirely possible to have
100% uniformity, consistency,
different statutory directive.
But we wanna make sure that
each division knows what the other's doing,
they're sharing best practices
and we're working from the same script.
I know this was a concern of one of the comments
we got in advance of this meeting CCPA ask how
will our policy promote consistent enforcement?
And this very much speaks to that.
Next slide, please.
This is a very busy slide,
and the point here is,
these are described in the enforcement policy.
The great majority of what's mentioned here
are existing tools.
Measures that our staff right now relies on
or can rely on to respond, to violation,
to do investigation, issue appropriate remedial orders,
or to escalate violations, to more formal actions.
And many aren't formal.
What I mean by formal is there's no hearing,
there's no administrative order
or notice of violation issue.
And that could be simply picking up the phone
and talking to a company
or sending an email or a warning letter,
or asking for information
on an audit or inspection thing you need to correct this.
But the policy does say, you need to document that,
put it in the file so we can keep track of it,
systematize it and ask some uniformity.
There are more significant actions that can be taken,
including decent assist orders and stop work orders.
The policy are explained that those can be done as provided
by existing law without none of this extends on the exists
any authority that the Commission staff doesn't,
or does not have already.
Notices of violation to be issued and so forth.
If you go down toward the bottom,
you can see that in more serious cases,
we can take more formal or serious actions.
We can issue an order instituting investigation,
which is a formal condition proceeding.
We can issue an order to show cause
or the most serious cases,
we can refer a matter for civil or criminal action.
Again, these actions,
these range of tools that are available
uniformly throughout industry divisions
and the policy explains how they can be used.
I wanna now ask to turn Denise Hoffman,
because one of the goals of the policy based on input,
we received a query from staff
was to provide them with some additional flexibility
to respond to violations by either settling cases
or issuing administrative orders.
And this is another,
an additional tool that we think will help streamline
and make our processes more efficient.
So, Denise I'm gonna turn this over to you
to go through the slide and explain.
Denise: Great.
Can you go to the next slide, please?
Thank you, thank you Commissioner.
Good morning, everyone.
So after a violation is identified,
the policy establishes a process for staff
and a regulated entity
to negotiate a proposed settlement of that violation.
The settlement process was included in the policy
in response to discussions with staff
who said it would be helpful.
This settlement would be in the form,
as you can see on the slide
of an Administrative Consent Order.
And it's a proposed Administrative Consent Order
that becomes final only after Commission approval.
In situations where settlement is not pursued,
the policy gives staff another new tool
for responding to a violation.
At present, Commission enforcement
includes a multitude of citation and compliance programs.
Staff is authorized to issue citations
when certain violations
specified in a citation program are identified.
The citations include the assessment
of a preset penalty amount for the specified violations.
Staff cannot issue a citation for violations
that are not listed in a citation program.
And staff cannot deviate
from the penalty amount prescribed by a program.
The policy would not change the citation programs
nor would it create a disincentive to issuing citations
or adding new citation programs.
Staff could continue to issue citations
if appropriate for a case.
What the policy would do is give staff the option
of issuing a proposed Administrative Enforcement Order,
instead of issuing a citation.
The order is an alternative to a citation
and could be issued if a case does not necessitate
an OII, an Order Instituting Investigation.
A proposed order would be subject to appeal
by the regulated entity
in accordance with the hearing provisions that already exist
in the citation appellate rules.
If no timely appeal is filed,
the proposed order would then have to be approved
by the Commission before it became final.
The ability to issue a proposed order
or negotiate a proposed consent order
would fill a gap in the existing toolbox
because the orders could be issued
or negotiated when a violation is identified,
that is not included in a citation program
or where staff determine
that the violations warrant a penalty amount
that is different than what is set out
in a citation program.
That concludes my comments.
Go ahead, Commissioner.
-: Thank you very much Denise.
And of course, Denise will be available for questions.
Could you go to the next slide please?
Those are the main things
we wanted to highlight about the policy.
Of course, there's more details that we can discuss,
but those are the highlights.
The policy will be adopted
by a resolution of the Commission,
and that of course, will include our customary opportunity
for public review and comment.
But in addition to that,
we wanna get...
We wanna provide an additional process
through this committee process.
So we welcome comments to this,
the Policy and Governance Committee
and this slide says the comments are due by July 15th,
but actually, in response to some suggestions from staff,
we're going to extend that for another week
so that there'll be a three-week opportunity
to provide comments.
So people can submit comments to us
at the policy and governance email,
that's policyandgovernance@cpuc.ca.gov,
by July 22nd.
We look forward to any comments through that process
and as I said,
we will propose a resolution for Commission adoption,
which will provide another opportunity
for formal public comment and review.
Any comments that are sent
to our policy and governance email will be posted
to our website,
I think we've already done that
with the comments we've received so far.
We may have another policy and governance meeting
to discuss comments before issuing the draft resolution.
I don't know if we're going to do that or not,
we'll see the nature of the discussion
and what the feedback
and desire of the other Commissioners are.
But at the very least, we have this opportunity
for public comments now,
and then we will have a draft resolution for CPUC approval,
which will provide additional opportunities
for public comment.
There are lots of other implementation details
once the policy is adopted.
We will do training, develop templates,
constitute the enforcement teams
within divisions and Commission wide,
and those will be left to staff
who are designated to form these teams
and others to implement.
I don't think we need to get into that right now,
we understand there's a lot of implementation details
to work out.
So with that,
I will stop and invite questions and comments
from my fellow Commissioners.
Randolph: Commissioner Rechtschaffen,
this is Commissioner Randolph.
I just wanted to let you know that I just logged in
and I'm trying to hop on to the WebEx event, so thank you.
-: Welcome, Commissioner Randolph.
So as you can see,
we just went through the PowerPoint presentation
and we're now having Commissioner discussion.
Randolph: Okay, great, thank you.
-: So thank you very much
for not only the very hard work
in the last two years, you and the staff,
Commissioner Randolph and Commissioner Picker,
President Picker, for doing this extremely important work
of trying to bring consistency to our enforcement activities
and indeed to the policy.
Appreciate that very much.
It seems like there's some concern
about parties being able to comment properly on the policy.
I'm not quite understanding that,
'cause we were open for public comment
and we just extended it, correct?
So I don't understand the concern
about some of the parties have written in concerned
about not being able to comment on the policy
in an appropriate way.
-: Well, we did extend the comment period.
I think there may have been some uncertainty
about the process
by which we were going to adopt the policy,
and explaining that we're going to have a draft resolution
that's subject to our normal public comment and review
hopefully allay some of those concerns.
-: Okay, thank you,
just wanted to have that explained
so anyone listening in would understand
that has concerns about public comment, thank you.
Commissioner Shiroma.
-: Yes, thank you, President Batjer.
And thank you, Commissioner Rechtschaffen,
and Commissioner Randolph, who will be joining us soon.
This is a tremendous and Herculean effort
that the policy committee undertook.
You know the Commission has
developed and adopted other policies,
the environmental and social justice plan,
the tribal plan.
We also have policies surrounding
disadvantaged communities and so forth.
So I view this proposal within that rubric,
and certainly there'll be opportunities for
parties and our regulated utilities
to weigh in on this.
I do want to thank you,
Commissioner Rechtschaffen, for bringing it forward.
I do remember when I first came on board last year,
one of the first things that,
I forget if it was you or if it was
Michael Picker at the time giving me
some materials that had been developed at that point.
And now here we have a comprehensive product.
I think through this enforcement policy,
we have an opportunity to formalize our approach
and consistently apply
the Commission's enforcement mechanisms.
As I reviewed it,
I looked back at the Commission's Strategic Directive Five
on compliance and enforcement,
which outlines the Commission's core values
on compliance and enforcement,
and specifically on parts one and two
of the strategic directive.
One, promote compliance and deter violations
with laws, standards, and regulations,
and to enforce applicable law, rules, and regulations
in a fair and consistent manner.
So I do thank you and Commissioner Randall
for teeing this up for our committee meeting today.
It looks like it's goal is
to provide the staff with additional tools,
to provide for being more nimble and effective timely,
and really, my question at this point is,
the draft policy discusses both
enforcement teams within each division,
and then of course, across the CPUC.
We are governed by all kinds of rules.
Badly key, next party, and so forth and so on.
And so in terms of formalizing this cross division approach,
I imagine it's going to involve a lot of training,
and where the firewalls are or are not.
And then, how do we work within
those sorts of requirements while allowing
the industry divisions, the enforcement divisions,
being able to work together.
-: Thank you, Commissioner Shiroma.
That's a very important point, and one we're cognizant of.
We've been consulting closely with the legal division
about that implementation issue.
And as folks know,
we are bound by, by state Supreme court law,
to make sure that we have a separation
between our advisory staff and our advocacy staff,
and staff who work on active enforcement cases
and active matters need to be separated
from staff, we're providing advice
to decision makers, this will pose some challenges,
but they are certainly, they can certainly
be overcome, we have to be careful
and thoughtful, we do this already,
to some degree in cases, once we convert
from an investigation to an enforcement action,
but it's a very real and important legal constraint,
and we're working with legal to figure out
the best way to effectuate that.
-: And my only other thing is to suggest that
because SD-5 is the strategic directive,
that it's really the umbrella,
a directive that there'd be a reference in
the policy added to, to our SD-5
and otherwise indeed your team with Jason, Roger,
and Madosky Denise Hoffman.
It's a really solid team that puts this together,
and I can see that all four corners of
the CQC were, reviewed past practices,
past decisions, past compliance
and enforcement, I mean, it it's,
got everything and the kitchen sink,
I'm not sure where that term came from (laughs)
I use it all the time, it's got everything
in the kitchen sink, so thanks for
the very thorough job, I'll look forward
to hearing, hearing the comments, thank you.
-: Thank you, and I think that makes a lot
of sense to incorporate a directive,
a reference the strategic directive five,
and we'll do that, Liane Randolph,
you just joined us, do you have
any comments or questions?
-: No, thank you,
I did read through the power point
and obviously the, the proposal itself
and I'm I, and I also found the comments
that we've gotten so far interesting
and I'm, I'm hoping folks will
be commenting today, I do think that
this presents a huge opportunity
for consistency, you know,
for a sort of careful thoughtful approach
where regulated entities understand
that, you know, there are going
to be basically, you know, escalating
and enforcement opportunities where
the regulated entities can be informed,
they can understand when there is
a potential violation when there's
an actual violation
and what the steps that staff is
gonna take to respond to that violation
and ensure that it is corrected
or penalized as appropriate,
and the policy, I think,
you know, appropriately recognizes
the due process, rights of the parties
and the opportunities for appeal,
and so I think it's a good framework
for how to proceed with consistency
and cross agency collaboration,
so looking forward to hearing additional comments
from the parties.
-: Thank you, Commissioner Randolph.
Before I open it up
to people on the line,
we did get several advanced written comments,
and I want to address at least a few of the major points
that have been raised,
not all of them,
because parties obviously can present
more specific concerns here or
in follow up comments.
But as President Batcher mentioned,
and as I mentioned,
there were several questions
about the process,
we will use to fully consider and adopt the policy
and I think we covered that.
How we'll provide the parties with an opportunity
to review and comment.
There was one particular question from CCTA and asked
if this is chained to our rules and policies
of policy and practice.
And the answer to that is no.
This is just internal guidance.
It's not an amendment to those rules.
Mr. Sherman, sent an email
asking if the policy relate to a 2018 state auditor report,
finding that PUC was out of compliance
with the auditing requirements for water utilities
and whether the policy would apply retroactively.
And I just want to answer the question
about the retroactive application.
The policy stayed at page one,
and quoting 'this policy does not apply to any violation
that as of the effective date of the policy
is the subject of a citation in order
to show cause,
in order instituting investigation or a referral
to the legal division for the filing
of a civil or criminal action'.
So that's the answer to the question about retroactivity.
TCTA, CTIA, and Com McBride of Goodman McBride,
raised a concern
that the policy represents
an illegal delegation, of authority
to staff.
In short,
we've had the legal division look very carefully about this,
and they are comfortable
with what we've done here.
They don't agree with this interpretation,
and we've,
we've explained that
in other recent decisions,
including the adoption of the citation appeal rules.
Course we'll look closely at any specifically returns that
are presented in the formal comments we get.
And then finally,
CCTA raise this specific question,
while a matter is being appealed
to the full Commission,
what measures can be put in place
to prevent accruing penalties during the appeal?
The question raises a couple of issues
that I want to break out as precisely
as I can.
Again, the question is what measures can be put in place
to prevent accruing penalties
during an appeal if a matter is appealed?
Just as under current practice,
and no matter which enforcement tool
is used,
until a violation is remedied,
liability and potential penalties continue to accrue.
Nothing in the policy changes that.
If the entities
in violation, until and unless they correct the violation,
they're subject to continued penalties.
if an enforcement order is issued,
and the entity contested and
asks for a hearing,
the policy provides that the penalty doesn't have
to be paid, until the appeal is resolved.
So in other words,
payment of the penalties is stayed once the appeal is filed,
but penalties
potential penalties,
accrues so long as there's an ongoing violation
that's not corrected.
So those aren't all of the comments we got,
but those are some I wanted to answer directly.
And now we're open to any public questions
and I'll ask the operator
to call in any public comment
that would want to ask questions.
Operator: At this time, we have no public comment.
As a reminder, you may press star one
only record your first and last name
to be placed into the queue.
Once again, please,
please press star one on your touch tone phone.
Still no parties in queue.
-: Let me ask Deidre Cyprian
who's monitoring our policy and governance website.
Are there any comments submitted
through the policy and governance email address?
Deidre: Pleased to, Commissioner.
There are no emails that have come through
to that email address.
-: Okay.
Well, we can give, we can give parties another minute or so
in case they wanna call in and just wait.
Operator, maybe checking another 30 seconds.
And then if not I will turn it back
over to President Batjer.
Operator?
Operator: We still have no public queue at this time.
-: Okay.
Well, are there any additional comments or questions
from the Commissioners?
Okay, I will--
-: Commissioner Rechtschaffen,
maybe if you would repeat
what the comment deadlines are
for the public and the parties.
You said it's gonna be extended from July 15th.
-: Thank you, Commissioner Shiroma
and Robert, if you could go back to the
and show, share the screen with the second to last slide,
Robert: Yes, Commissioner
-: We've extended the public comment period till July 22nd.
So there's now three weeks available from today's date
in order to, to provide comments.
And it is the, the email is policyandgovernance@cpuc.ca.gov
You can also see on, on the slide
that Deidre's email is listed here.
If folks have specific questions about the policy
or what we're doing, or the website or anything else,
you're welcome to email Deidre directly.
-: There will also, em, the comments obviously will be
that we received that we referred to
Commissioner Rechtschaffen and I referred
to earlier as well.
They'll be looked at by staff
and answered as we're drafting the draft resolution.
Is that correct?
Just as part of process when we're developing a policy,
maybe we could explain that a bit.
-: Well, we will.
Yes, we will.
Staff will review all the comments we received,
as well as any comments we receive on the draft resolution
and in the resolution as proposed for Commission approval,
we will explain our answers to the comments that we receive.
-: OK, great.
Just wanted to let the public know
how the questions that have been sent in today
will be responded to.
-: 'Kay, any other questions?
-: Once again, I wanna thank Commissioner Rechtschaffen
and all the people, the staff, and Commissioner Randolph.
Commissioner Shiroma, thank you for your participation.
It's notable to note again
how hard they obviously have worked to put
this enforcement policy draft together.
I thank them enormously for all that hard work
'cause everybody also has day jobs,
so this is only one of their many assignments.
So, again, thank you so much for the presentation.
Definitely it's so important that we have
the right tools in place, and as I said earlier,
that we need to be consistent and transparent,
as well, as you mentioned, Commissioner Rechtschaffen,
flexible to be a very effective regulator.
I look forward to the stakeholder's input
as we've talked, I hope people take a close look
at the draft and provide their comments,
especially now that the comment period has been extended.
Before we end this meeting, I'm gonna ask the operator
one final time if there's anyone on the telephone.
Operator: At this time we have no questions
or comments.
-: Okay, well, thank you operator,
and thank you again for joining us today.
This meeting is now adjourned.
Please,
one was already opened up for the public comment line,
have we not?