Legislature(2023 - 2024)BUTROVICH 205
03/13/2024 03:30 PM Senate RESOURCES
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| Audio | Topic |
|---|---|
| Start | |
| SB217 | |
| Presentation: Alaska Energy Authority (aea) | |
| Adjourn |
* first hearing in first committee of referral
+ teleconferenced
= bill was previously heard/scheduled
+ teleconferenced
= bill was previously heard/scheduled
| += | SB 217 | TELECONFERENCED | |
| + | TELECONFERENCED | ||
| + | TELECONFERENCED | ||
SB 217-INTEGRATED TRANSMISSION SYSTEMS
3:31:51 PM
CO-CHAIR GIESSEL announced the consideration of SENATE BILL NO.
217 "An Act relating to the taxation of independent power
producers; and increasing the efficiency of integrated
transmission system charges and use for the benefit of
ratepayers."
3:32:20 PM
CO-CHAIR GIESSEL announced invited testimony on SB 217.
3:32:11 PM
SENATOR DUNBAR joined the meeting.
3:32:39 PM
ANTONY SCOTT, Director, Economic and Regulatory Analysis,
Renewable Energy Alaska Project (REAP), Anchorage, Alaska,
presented SB 217 on behalf of the administration. He stated that
he is an economist and former commissioner at the Regulatory
Commission of Alaska (RCA), with decades of experience in
economics and policy analysis in the state. REAP is a member-
based organization. Its membership includes public utilities,
independent power producers, labor groups, Native associations,
consumer groups, and others. He moved to slide 2 and detailed
REAP support for SB 217.
[Original punctuation provided.]
REAP supports SB 217
• Creates favorable economic conditions for new
investment that will create ratepayer value by
solving two significant existing problems:
1. Inefficient cost recovery mechanism for
transmission system infrastructure costs impede
economic development and raise rates paid by
consumers
2. Inefficient and inequitable local tax burdens
for Independent Power Producers (IPP) increase
their investment costs and raise rates to
utility customers
• It offers a simple and understandable approach
• It does so with a minimum of overhead costs and
institutional disruption
• It refrains from using overly prescriptive
mechanisms
3:34:42 PM
MR. SCOTT moved to slide 3 and explained wheeling charges:
[Original punctuation provided.]
Inefficient Transmission System Cost Recovery
(current "toll-road" system)
• Significant portion of transmission system costs
are currently recovered through "wheeling rates"
Example: for Homer Electric Assoc to buy power
from a wind producer in Fairbanks, HEA pays for
both cost of generating the power plus the
combined costs to "wheel" the power across the
various components of the Railbelt transmission
system:
o $0.00531/kWh to Golden Valley Electric Assoc
(GVEA) to use its transmission system
o $0.00512/kWh to Alaska Energy Authority (AEA)
to use the Intertie,
o $0.00415/kWh to Matanuska Electric Assoc (MEA)
to use its transmission system
o $0.01412/kWh to Chugach Electric Assoc (CEA) to
use its transmission system
Total transmission wheeling charges = $0.0287/kWh
• The actual costs of transmission are not
increasing with this use, but
• These additional "toll" charges can prevent an
otherwise economic generation project from being
built
MR. SCOTT stated that the inefficiencies in transmission system
cost recovery are a significant issue. A portion of transmission
system costs are recovered not from a utility's own ratepayers
but through wheeling charges. When one utility uses another
utility's transmission system, they pay a $1 per kilowatt-hour
charge for moving electricity over that transmission system.
These charges essentially function as a tax on the transaction
of power generated in one area and consumed in another, and this
tax is quite inefficient. It can be likened to a toll paid on a
road because the costs of the transmission system do not change
even when it is being used. The result is that these individual
wheeling charges can render an otherwise economically beneficial
project uneconomic, preventing the project from proceeding. The
example on the slide illustrates that if Homer wished to
purchase wind power from a development north of the range in
Fairbanks, it would have to pay for the cost of generating that
power to the Independent Power Producer (IPP). Even if Golden
Valley built the wind power themselves, they would still have to
pay for the power's generation cost and the combined cost of
wheeling that power across various components of the rail belt
transmission system. These combined charges amount to almost
three cents per kilowatt-hour, which is enough to prevent the
transaction from happening. This would be unfortunate for
economic development in the Fairbanks region and a loss of value
for Homer ratepayers. It also increases Homer's difficulty in
incorporating more wind power into the system, as having a
geographically diverse source of renewables is beneficial for
overall system reliability. The cost reallocation in this
example, specifically the nearly three cents per kilowatt-hour,
raises concerns.
3:38:11 PM
SENATOR WIELECHOWSKI asked how the wheeling charges are set and
what exactly differentiates these rates. He expressed
appreciation for slide 3, noting that it was the first time he
had seen the information broken down in this way.
3:38:29 PM
MR. SCOTT replied that wheeling charges are set through general
rate cases. Each utility, excluding AEA, determines their rates
through a rate proceeding at the Regulatory Commission of Alaska
(RCA). Utilities calculate their total system costs, which
include their transmission, generation, and distribution
infrastructure. For example, Chugach Electric's transmission
system is used by other parties. In its rate case proceedings,
Chugach allocates a portion of their transmission costs to be
recovered from these other parties. This allocation is often
contentious, but once determined, it is converted into a dollar
per kilowatt-hour or cents per kilowatt-hour rate. Chugach's
total transmission costs are divided based on the agreed-upon
allocation percentage, and this amount is then applied to the
projected power transmitted over their lines by third parties.
3:40:46 PM
SENATOR WIELECHOWSKI noted that Chugach might argue that their
ratepayers have paid higher bills to cover the cost of building
their transmission systems, and that the wheeling charges are
their way of recovering those costs. He questioned how one would
respond to Chugach's position if the company says they are
losing revenue for each kilowatt-hour transmitted through their
system, which their ratepayers have already funded.
3:41:30 PM
MR. SCOTT replied that it is entirely reasonable for Chugach to
argue for cost recovery. However, the allocation of costs and
benefits of transmission infrastructure is inherently arbitrary.
As a former regulator, he explained that while there are various
mechanisms for determining the appropriate split, the process
often involves considerable debate and negotiation, similar to
choosing between different types of cuisine. If a utility can
build transmission infrastructure for the benefit of its own
customers and have others partially cover the costs, it might
not incentivize the construction of the most efficient
transmission systems. All users benefit significantly from being
part of an interconnected grid. This interconnection improves
reliability and increases opportunities for power transactions.
The current system of wheeling charges, which turns a fixed cost
into a variable cost, acts as a tax and reduces these overall
benefits. Moving to a lump sum collection system would allow for
a fairer allocation of system costs without treating them as a
tax on the movement of electricity. This approach would still
involve debate over the best allocation method, but it would
recover costs based on fair system usage rather than per-
kilowatt-hour charges.
3:44:24 PM
SENATOR WIELECHOWSKI asked if a levelized rate, such as seven or
eight cents per kilowatt-hour, would result in other utilities
receiving a bit more for their transmission while Chugach might
receive a bit less. He inquired about how much this might cost
Chugach's customers.
3:44:53 PM
MR. SCOTT replied that SB 217 wouldn't replace multiple wheeling
rates with a single wheeling rate; instead, it would eliminate
wheeling rates altogether. However, he acknowledged that the
question of cost responsibility and the best way to address it
remains. The bill recognizes the need for a gradual transition
to this new cost recovery mechanism, though it does not specify
the pace of this transition. This will be determined by the
interested parties before the RCA. SB 217 acknowledges the
current historical arrangements that produce specific cost
responsibilities and revenue streams. A gradual transition over
a period, such as one to three years or five, might be sensible.
In the interim, the hope is to build new transmission assets,
partly with federal support. REAP supports this and aims to
ensure that new transmission is used efficiently for economic
development and ratepayer benefits. Over time, the lump sum
approach to allocating costs is expected to benefit the greatest
number of people through the integrated planning process managed
by the RRC. This process will involve broad stakeholder input to
determine which transmission projects are needed, the cost
responsibilities, and the methods for cost recovery, ultimately
leading to a more efficient and fair system.
3:47:48 PM
CO-CHAIR BISHOP asked if debt is included in the cost recovery
equation.
3:48:05 PM
MR. SCOTT replied that debt is absolutely part of the cost
recovery equation. He explained that cost recovery encompasses
the entire cost of service, including debt payments,
depreciation, and operation and maintenance (O&M) expenses.
Therefore, the full cost of service associated with transmission
will be recovered.
3:48:32 PM
SENATOR CLAMAN asked if the importance of Grid Resilience and
Innovation Partnerships (GRIP) funding, which provides federal
support for building additional transmission infrastructure
without requiring utilities to finance it themselves and pass
those costs to their ratepayers, is a significant reason why
this approach makes sense today.
3:49:07 PM
MR. SCOTT replied that transitioning from the current system
makes sense regardless of the situation, but it is especially
important given the need to enhance the robustness of the
transmission system, which will involve significant expenditures
from ratepayers, the state, and the federal government. He
emphasized the importance of ensuring that these large
investments provide the greatest value for Alaska consumers.
While there is a strong reason to focus on this now, due to the
new transmission projects, he suggested that the current system
of wheeling charges should be fixed and eliminated even if no
new transmission were ever built.
3:50:21 PM
SENATOR CLAMAN asked if SB 217 would create a structure where
wheeling rates are eliminated for transmission. He inquired if
the bill mandates that, in the absence of federal funds, any new
transmission built will have its rates evaluated at a system-
wide level, ensuring that the transmission cost is uniform
regardless of where electricity enters the grid. He wondered
whether this approach is necessary even without federal funding,
to ensure an equal transmission rate across the system.
3:51:08 PM
MR. SCOTT replied that the legislation would eliminate wheeling
rates entirely. Instead of a unified transmission charge, the
bill proposes that transmission costs be allocated directly on
an annual basis to each load-serving entity. At the beginning of
each year, each utility would receive a bill from the
association detailing their transmission cost responsibility,
such as $25 million for one utility and $35 million for another.
These costs would then be recovered from the load customers. For
example, Chugach would receive a bill for its total transmission
cost responsibility and would recover these costs from its load
customers. This would replace the current system where
transmission costs are embedded in energy and demand charges on
customer bills, even though no separate transmission charges are
itemized. The issue with the current system is not that third
parties contribute, but how they contribute. The $1 per
kilowatt-hour or cents per kilowatt-hour wheeling charges act as
a tax on the movement of electricity.
3:53:36 PM
MR. SCOTT moved to slide 4 and spoke to the new freeway system:
[Original punctuation provided.]
SB 217 Eliminates wheeling rates
(Creates a new "freeway" system)
Steps
1. Adds up all transmission system costs
("ownership")
2. Allocates those costs on an annual lump-sum
basis to each loadserving entity (i.e.
utilities) based on their proportionate load
("cost responsibility")
3. Utilities then recover those costs from
their rate-payers
MR. SCOTT noted that all transmission system costs would first
be pooled into a single bucket. The total costs in this bucket
would then be apportioned to each load-serving utility, though
the exact method for proportionality is not fully detailed in
the legislation. SB 217 would direct the commission to allocate
costs based on each utility's proportionate electricity
consumption relative to the total system consumption. Every end
user benefits from being part of an integrated grid, which
enhances reliability and provides opportunities for transactions
that improve ratepayer value. In the final step, each utility
would recover its allocated transmission costs from its own
customers. Essentially, this replaces the per-kilowatt-hour
wheeling charge for electricity movement with a per-kilowatt-
hour charge included in the utility's overall billing to its
ratepayers. The rate may vary depending on how the cost
responsibility is ultimately apportioned.
3:56:10 PM
CO-CHAIR BISHOP asked for an explanation of the difference
between ownership and cost responsibility.
3:56:34 PM
MR. SCOTT replied that the percentages shown for ownership and
cost responsibility are hypothetical, as he did not have time to
review filings for the current actual numbers. He explained that
entities like AEA, Chugach, MEA, Golden Valley, and Homer own
various transmission assets, such as the Alaska Intertie. The
costs associated with owning these assets include interest
payments, depreciation, and operation and maintenance (O&M)
expenses. These ownership costs make up the annual cost of
maintaining the assets. If SB 217 becomes law, the cost
responsibility for the entire system would be allocated based on
percentages determined through a regulatory proceeding. These
percentages would be based on load ratio shares and other
factors reviewed during the regulatory process.
3:58:47 PM
MR. SCOTT moved to slide 5 and spoke to the transmission cost
allocation approach:
[Original punctuation provided.]
SB 217 Transmission Cost Allocation Approach
• An "Association" made up of all transmission-
owning entities calculates total system ownership
costs and files a tariff to be regulated by the
RCA
• The "Association" is essentially an accounting
construct established to manage the cost
allocation process
• Alaska's telecom industry employs a similar kind
of association currently the Alaska Exchange
Carriers Association (AECA) created via AS
42.05.850
• AECA has just one paid employee
MR. SCOTT addressed the cost allocation process and ownership of
the transmission tariff under SB 217. He clarified that the
tariff would not be levied on a cents per kilowatt-hour basis
but as a lump sum to each utility, which would then recover
these costs from their customers. The proposed association would
comprise all transmission-owning entities. Although it might
initially seem intimidating, he likened it to the Alaska
Exchange Carriers Association (AECA), established under AS
42.05.850. AECA, an industry association of intra-state and
interstate inter-exchange carriers, performs a similar cost and
revenue allocation exercise. He noted that AECA's role is
essentially an accounting exercise managed with minimal
overhead, as it operates with just one employee and files annual
tariffs with the Commission. The members, who are the affected
inter-exchange carriers, handle the necessary accounting tasks.
He emphasized that the intent behind SB 217 is to create a
straightforward, low-overhead organization focused on
bookkeeping, similar to AECA.
4:01:17 PM
MR. SCOTT moved to slide 6 and spoke to the taxation process:
[Original punctuation provided.]
SB 217 Addresses Inequitable Tax Burden For
Independent Power Producers (IPP)
• Municipal and Cooperative Electric utilities are
exempt from state income and local property taxes
• This helps ensure lowest cost of energy, as
property taxes are passed along to consumers in
their utility rates
• IPPs must recover all costs in the rates they
negotiate with purchasing cooperatives or
municipal utilities
• Property taxes can be a very substantial portion
of those rates
• Existing property tax rates can and do prevent
IPP projects from progressing, which ultimately
impact ratepayer costs
• No property taxes can be collected from unbuilt
or failed power projects
MR. SCOTT said that municipally or cooperatively owned electric
utilities are exempt from state income tax and local property
taxes. The policy rationale is that without these exemptions,
such taxes would be passed on to consumers through higher
utility rates. Independent power producers (IPPs), however, must
recover all their costs through the rates they negotiate with
purchasing cooperatives and municipalities. This means that any
taxes imposed on IPPs can significantly increase the rates
charged to consumers, potentially making some projects
economically unfeasible. This creates an uneven playing field
that can hinder project development and negatively impact
ratepayers in two ways: by increasing costs for projects that do
proceed and by preventing many projects from moving forward at
all. MR. SCOTT suggested that if it is reasonable to exempt
cooperatives from property taxes on their own generation and
transmission assets, it would also make sense to extend this
exemption to IPPs selling power to cooperatively owned
utilities. Addressing both issues would alleviate a significant
burden on project development in the state, delivering greater
value to consumers, creating jobs, and fostering a more robust
state economy.
4:04:01 PM
CO-CHAIR GIESSEL concluded invited testimony and opened public
testimony on SB 217.
4:04:39 PM
MATTHEW PERKINS, representing self, Anchorage, Alaska, testified
in support of SB 217. He introduced himself as the CEO of Alaska
Renewables and said the company is working on several large
power plants aimed at providing low-cost, reliable energy to the
Railbelt. He sought support for two critical policies: property
tax exemptions for independent power producers (IPPs) and the
elimination of tariffs between electric cooperatives and IPPs.
These changes would help reduce rates, remove barriers to
collaboration, and increase competition. The difference between
export resource financing and domestic renewable energy market
financing. IPP contracts are structured as long-term fixed-price
agreements with financial inputs contracted upfront, making any
taxes a pass-through cost to consumers. He also noted the
importance of removing barriers to collaboration among
utilities, citing the pooling of projects like Shovel Creek and
Little Mount Susitna as an example that could significantly
reduce no-wind periods. He raised concerns about specific issues
in the bill's wording: a redundant tax on kilowatt-hours
generated by IPPs and ambiguity regarding the removal of
wheeling rates. He requested support for these free-market
principles and limited government intervention, and asked for
amendments to the bill to eliminate the double tax and ensure
the full removal of wheeling tariffs.
SENATOR CLAMAN asked that Mr. Perkins be allowed to briefly
address Senator Wielechowski's question.
4:07:32 PM
MR. PERKINS said that in response to Senator Wielechowski's
question about the benefits to Chugach's members or any electric
cooperative members, the numbers are indeed calculable. He
mentioned that he is working with the dispatch and engineering
teams to determine specifics. He emphasized that the broader
economic benefit comes from allowing more arbitrage among
markets, aligning with fundamental free market principles. The
benefit, as shown by their modeling and other reviewed models
related to energy on the Railbelt, is significantly greater than
minor differences in individual gains, such as one group making
10 cents versus another making 11 cents. In response to Senator
Claman's question about transmission costs, he explained that it
is most likely that for each project, transmission lines will
need to be built, increasing the associated costs. These costs
would be included in the total Power Purchase Agreement (PPA)
for the project and recovered through the sale of electricity to
participating utilities.
4:09:02 PM
CO-CHAIR BISHOP asked if he is referring to building
transmission lines, meaning constructing a line from the project
to the substation.
MR. PERKINS replied yes.
4:09:37 PM
PENNY GAGE, representing self, Anchorage, Alaska, testified in
support of SB 217. She introduced herself as the Managing
Director for Launch Alaska, a nonprofit focused on accelerating
the energy transition by integrating the latest technologies
into Alaska's energy, transportation, and industrial sectors.
Launch Alaska works with a portfolio of 32 for-profit startup
companies from around the world, addressing climate challenges
and creating economic opportunities in Alaska. She expressed
support for SB 217, particularly the provision that would grant
independent power producers (IPPs) the same local tax exemption
received by non-profit electric cooperatives. Gage noted that
Launch Alaska's CEO, Isaac Vanderburgh, who was appointed by
Governor Dunleavy to the Alaska Energy Security Task Force, co-
chaired the incentives and subsidies subcommittee. This tax
provision change was a key recommendation in the final report of
that task force, which Mr. Vanderburgh championed. The provision
would attract private investment, support energy development,
and lower energy costs for Alaskans. However, according to a
Department of Energy (DOE) report, less than five percent of
Alaska's electricity is generated by IPPs, compared to over 40
percent in lower 48 states. SB 217 would send a positive market
signal to investors and developers, accelerate the deployment of
low-cost renewable energy, level the playing field, diversify
the electricity mix, and support job creation.
4:12:06 PM
DOUG JOHNSON, representing self, Anchorage, Alaska, testified in
support of SB 217. He introduced himself as the Director of
Development for Ocean Renewable Power Company and said the
company has been actively developing hydrokinetic power in
Alaska since 2006. SB 217 would provide a thoughtful, elegant,
and workable solution to two key problems facing the energy
industry. The first problem as the inequity in taxation of
independent power producers (IPPs), requiring the need for a
level playing field for all power producers. The second issue is
the application of wheeling charges across the Railbelt. He
highlighted the need for a standardized and proportionate cost
recovery mechanism as envisioned in SB 217. The bill offers a
straightforward approach to addressing these industry challenges
in Alaska. He expressed a desire for the swift resolution of
these issues through the passage of SB 217, emphasizing its
critical importance to the future of the emerging industry.
4:13:46 PM
KEN HUCKEBA, representing self, Wasilla, Alaska, testified in
opposition to SB 217. He stated that much of the support for SB
217 is based on fictitious claims. He characterized the bill as
a 'gold rush grab' for Inflation Reduction Act (IRA) funds by
opportunists seeking to advance the transition to green New Deal
policies. SB 217 focuses solely on eliminating transmission
charges, particularly benefiting independent power producers
(IPPs) of solar and wind energy. However, he argued that these
energy sources are unreliable, with wind farms producing only
around 30 percent of their capacity even on good days. On
windless, snow-covered days, they contribute nothing,
exacerbating costs for utilities and ratepayers who must back
them up with reliable power sources. Existing utilities, owned
by ratepayers and cooperatives, are forced to cover the costs
associated with the poor performance of these renewable energy
sources. He criticized the bill for allowing IPPs to operate
without contributing to the costs of maintaining and upgrading
the legacy energy system. The tax savings touted by the bill
come from taxpayers and existing infrastructure owners, rather
than some external source. He rejected the idea that renewable
energy sources are truly lower in cost. Their affordability is a
result of subsidies and the absence of charges for the
additional impacts they cause. He described SB 217 as a takeover
of infrastructure by special interests. He also criticized the
use of the term 'stakeholders,' asserting that these entities do
not represent ratepayers or taxpayers. The United States is a
representative republic that should prioritize the interests of
its citizens, not special interest groups or nonprofit NGOs.
4:16:27 PM
DAVID BRAILEY, representing self, Eagle River, Alaska, testified
in support of SB 217. He noted that he is one of the owners of
the Juniper Creek hydroelectric system in Eagle River, a 300-
kilowatt facility with a 60 percent capacity factor, meaning it
operates at full capacity 60 percent of the year. He
acknowledged that he could not improve on former Commissioner
Scott's explanation of why the bill is beneficial for the grid,
independent power producers, and ratepayers. He emphasized that
because the bill is good for ratepayers, it is also beneficial
for cooperative utilities. He shared his experience, noting that
he has been working on his project for about 13 years, though it
has not produced electricity for the past three years. He
expressed that the Alaska rail belt market is one of the most
disadvantageous for independent power producers in the United
States. He believes that SB 217 would help level the playing
field between independent power producers and utilities, turning
things around in favor of a more balanced energy market.
4:18:11 PM
SENATOR WIELECHOWSKI asked what recommendations could be made to
improve the situation so that the state is more open to
independent power producers (IPPs) and other potential utility
generation options.
4:18:28 PM
MR. BRAILEY replied that Alaska's Railbelt is one of the few
places in the United States where capacity has zero value,
despite being allowed by regulation. He noted that no renewable
energy producer or independent power producer (IPP) has ever
been paid for capacity in the Alaska Railbelt. Zero emissions
have no value in Alaska, as there is no market for renewable
energy credits. He explained that all power purchase agreements
between IPPs and utilities in the state require the IPPs to give
away at least 50 percent to 100 percent of their renewable
energy credits. He questioned why a private business would give
away something of value and explained that the condition of
interconnection, particularly with his utility, Matanuska
Electric, forces the IPP to cover all interconnection and
integration costs, including building the interconnecting power
line. Despite these costs, the utility still takes the renewable
energy credit. He described the situation as a monopsony system,
where utilities hold all the cards. If an IPP disagrees with the
terms of the agreement, they are told to find another buyer, but
that option is blocked by pancaking charges that prevent selling
to another utility. The system is rigged in favor of the
utilities.
4:20:41 PM
JENN MILLER, representing self, Houston, Alaska, testified in
support of SB 217. She stated that she is the CEO of Renewable
IPP, an Alaska-grown small business focused on developing,
constructing, and operating renewable energy projects in Alaska.
She mentioned their Willow and Houston projects and spoke to the
company's dual commitment to advancing renewable energy and
suppressing energy prices for Alaskans. She said she recently
served on the governing Energy Security Task Force, which
aligned with their mission to diversify energy generation,
improve affordability, and maintain reliability. Independent
power producers (IPPs) play a crucial role in this
diversification and affordability, while also meeting
reliability standards. For their projects to advance, they must
agree on power purchase agreements with utilities and remain
competitive with current generation costs. The Houston project
is currently 10 to 20 percent below the existing cost of
generation, making it essential to have a level playing field.
SB 217 would equalize their cost base by addressing property
taxes and eliminating pancaking charges. This would help reduce
their power purchase prices and, in turn, lower costs for
utility members. Additionally, having an established tax policy
for IPPs would reduce uncertainty for investors and incentivize
private investment in new generation projects. This would aid in
deploying various energy sources, including wind, solar, and
hydro, contributing to a more stable energy supply. She
emphasized the urgency of passing this bill to incorporate
reduced cost bases into power purchase agreements and pass those
savings onto members.
4:24:24 PM
CO-CHAIR GIESSEL closed public testimony on SB 217.
4:24:41 PM
CO-CHAIR GIESSEL held SB 217 in committee.
| Document Name | Date/Time | Subjects |
|---|---|---|
| SB 217 Letter of Support 3.12.24.pdf |
SRES 3/13/2024 3:30:00 PM |
SB 217 |
| AEA Update SRES Presentation 3.13.24.pdf |
SRES 3/13/2024 3:30:00 PM |
|
| SB 217 REAP SRES Presentation 3.13.24.pdf |
SRES 3/13/2024 3:30:00 PM |
SB 217 |
| AEA Responses to Senate Resources-Wheeling Charges.pdf |
SRES 3/13/2024 3:30:00 PM |