If you’re the type of person who finds these things entertaining, here’s my 2017 application to the City of Boulder’s Planning Board…
What technical/professional qualifications, skill sets and relevant experiences do you have for this position (such as educational degrees, specialized training, service on governing or decision-making boards, etc.)?
For the past five years I have served on Boulder’s Transportation Advisory Board (TAB). As a member of TAB, I have participated as a member of the city’s Form Based Code working group, the Greenways Advisory Commission, and the Transportation Maintenance Fee task force. As a private individual I also served on the Decision Analysis Working Group in support of the City of Boulder’s bid to create a municipal electric utility. Since 2012 I have been a member of the board of the Boulder Housing Coalition, a small local non-profit affordable housing provider. For the last 3 years I have served on the Executive Committee of Better Boulder, a local sustainable transportation and land-use policy advocacy organization. I’ve also served on several successful local ballot campaign committees, helping to secure funding for Open Space and transportation maintenance in the fall of 2013 with the passage of measures 2B, 2C, & 2D, and helping to defeat measures 300 & 301 in the fall of 2015. I have also spent many years living in housing cooperatives, participating in and facilitating consensus based governance at weekly meetings.
In the above roles I have performed staff oversight, organizational budgeting and strategic planning, public engagement and outreach, and facilitated countless meetings. My professional background is in the geosciences and energy policy. When appropriate I have used my data analysis skills to help inform the decisions made by the organizations I’ve been part of (e.g. this analysis of Boulder County property records in association with the cooperative housing ordinance). My policy analysis work has often involved communicating the implications of complex regulations to a broader public audience.
In my last post, I suggested that while we like to think of housing as an investment, it’s really more like a crappy savings plan, potentially redeemed by the fact that you can live inside the piggy bank. Land can be a profitable speculative investment, but allowing land to appreciate and drag the cost of housing upward in real terms is fundamentally incompatible with housing being affordable.
Economists (including Adam Smith, David Ricardo, Thomas Paine, Henry George, Thomas Friedman, Joseph Stiglitz, and Matt Yglesias) have highlighted the negative impacts of allowing land owners to collect monopolistic “ground rents” but nobody seems to care. So now tens of trillions of dollars worth of real estate in the US is predicated on the idea that landowners get to retain these speculative gains. Barring a glorious Georgist Revolution, this is probably the arrangement we have to work within.
Build, Baby Build!
Luckily, in a city with increasing land values, where property owners get to keep all of those unearned financial gains, there’s an All American Capitalist Solution™ of sorts, which can potentially keep housing affordable, even when land is expensive: build more housing on less land. By building densely, high land costs can be shared across more households, reducing the overall impacts of expensive land, and allowing home buyers & renters to pay primarily for housing instead of land.
There’s a powerful cultural narrative in the US that says when you buy a home, you’re not only securing a place to live, you’re making an investment.
When I say “investment” I mean a thing that you can put some money into, and get more money out of later, in real inflation adjusted terms, net of the expenses associated with having the thing in the first place. Houses — as in, physical structures that shelter human beings — are clearly not this kind of thing. Anyone who has had to maintain an older home knows this. Roofs collapse. Pipes corrode. Walls need to be painted. Like bicycles, laptops, and virtually all other durable goods, left to their own devices, houses are depreciating assets: they lose utilitarian value over time. However, we’ve done an incredibly good job of ignoring this as a society. How do we fool ourselves?
We tend to ignore inflation. If you bought a house for $100,000 in the year 2000, and sold it in 2016 for $140,000, even if you didn’t put a single penny into maintenance, taxes, or insurance, you just barely broke even in terms of real purchasing power, if we’re talking about the house purely as an investment.
We tend to ignore the ongoing expenses of homeownership. In practice, you can’t avoid spending money on maintenance, taxes and insurance, but few homeowners record every property expense, and calculate whether they’ve come out ahead upon selling a home. Especially if the building is older “naturally occurring affordable housing”, maintenance costs can easily end up being a few percent of the building’s value each year. Property taxes and home insurance are also substantial expenses, typically less salient to homeowners than the purchase and sale prices of the home.
We can think of inflation and property expenses as cancelling out a fair chunk of any increase in the nominal value of a home. With 2% inflation, and spending 3% of the home’s value every year on maintenance, property taxes, and insurance, a home’s value needs to increase about 5% every year in nominal terms just to cover its own costs. In other words, if you bought a house for $100,000 in the year 2000, and sold it for $200,000 in 2016, you didn’t quite break even — again, if we’re looking at the house purely as an investment.
We tend to notice the accrual of home equity. Ideally, as you pay off a mortgage, the fraction of its value that is covered by your equity rather than the bank’s debt increases! Even if you just break even after accounting for inflation and ongoing expenses, you’ll hopefully have a larger chunk of change on hand to put into buying your next home. Continuing with the example purchase above (grabbing a mortgage calculator off the internet) if we assume a 20% ($20,000) down payment and an $80,000, 4%, 30 year fixed rate loan, after 16 years of payments, the remaining loan amount is about $49,000. So assuming you sell the home at the “break even” price, including expenses, of $200,000, you end up with $151,000 after paying off the loan. This is $131,000 more than you started with, which feels totally awesome! You “invested” $20,000 and “earned” $131,000, more than a 650% increase!
First, steep declines in fertility worldwide have largely defused the population bomb. Second, even if the bomb were still ticking, the population changes we see in Boulder, and more generally the Front Range of Colorado, the US and the booming megacities of Asia aren’t about population growth per se, they’re about migration. In the developing world, it’s migration from rural areas to cities. In the already rich countries, it’s mostly migration between cities, often from low-wage regions to areas with better jobs and higher quality of life. Or it would be anyway, if we actually let people build housing in those places.
How we choose to build and rebuild cities to accommodate these migrations and humanity’s peak population later this century will largely determine our ultimate impact on the Earth’s climate and biosphere, and the quality of life that humanity has access to. Contrary to many “population bomb” narratives, the main problem here as it relates to climate isn’t the impact of large numbers of poor people, because small numbers of rich people are responsible for the overwhelming majority of current greenhouse gas emissions. How we accommodate those wealthy, high emissions populations makes a big difference, both directly, and through the example it sets for the rapidly expanding global middle class.
The Self Sufficiency 2016 campaign hosted by the League of Women Voters of Boulder County has been pushing for a living wage in Boulder, and City Council talked about it last week. Employees of the University of Colorado have also been pushing for a $15 minimum wage. Unfortunately CRS 8-6-101 prohibits a city or county from setting a minimum wage, so we can’t simply pass a local minimum wage like Seattle, WA and Los Angeles, CA. Our state statue includes some kind of Orwellian justification for the prohibition. It says that the welfare of Colorado depends on workers having adequate wages, and therefore cities and counties shall not be allowed to regulate wages. Uh, what? Here’s the code:
After more than two decades of growth and success, Fort Collins based New Belgium Brewing became 100% employee owned three years ago, with the employee stock ownership plan buying out the 59% of the company previously held by its founders. Today it sounds like they might be putting themselves on the auction block. With around 500 employees, and a potential valuation of a billion dollars, it’s not too hard to understand the temptation. That’s $2 million worth of company value per employee.
Boulder faces an interesting decision in the wake of an Ignite Boulder talk by Code for America’s Becky Boone, exhorting a relatively young, tech-savvy audience to engage in the city’s civic sphere. Some have objected to her use of profanity, but given the positive response of the 21 and over crowd and the content of past Ignite talks, these concerns are overblown. Daily Camera columnist Steve Pomerance and neighborhood blogger Kay MacDonald have tried to level a more substantive criticism: they feel that Boone’s presentation was pro-growth, and that such advocacy would be inappropriate for even an off-duty city consultant.
I’ve watched the talk repeatedly, and transcribed it word-for-word. Boone clearly takes no such stance.
She highlights the accessibility and value of participating in our local democracy, and gives a couple of positive examples: the Fairview High Net Zero Club’s campaign to implement a grocery bag fee, and an unidentified citizen group gathering signatures for a fall ballot measure whose content is unmentioned. She also asks her audience their thoughts on whether Boulder’s housing issues result from too many jobs, or insufficient housing — a question that’s been raised by Boulder Housing Partners commissioner Dick Harris, among others.
None of these statements is political advocacy.
Rather, the political content of Ms. Boone’s presentation resides with her choice of audience. The Ignite crowd and Boulder’s startup community are younger and newer to Boulder than those traditionally engaged in city governance. They’re also probably more likely to be renters. Despite the city’s laudable efforts to recruit representative citizen working groups, these demographics have been woefully underrepresented in our housing policy process. We know this because we’ve collected demographic data at the city’s housing events. Engaging the Ignite Boulder audience makes our discussion more representative of our citizenry. This is good for our democracy. It also has political implications.
By definition, rallying a disinterested population to participate dilutes the power of those who are already engaged. To their credit, and despite this difficult set of political incentives, the city has prioritized “developing new approaches and tools that support more inclusive, transparent, collaborative, and interactive community engagement” in the development of our Comprehensive Housing Strategy. This is exactly the job that Becky Boone was hired to do, and which she has apparently done a bit too well for the comfort of some incumbent interests.
We now have a choice, and it’s an unavoidably political choice. Do we want to cultivate a representative democracy in Boulder that proactively seeks input from as broad a population as possible, or would we prefer a narrowly targeted discourse that is intended, through its choice of media and venues, to preserve the status quo?
Boulder should be better than that, and so I favor proactive engagement, as I believe much of City Council does. They need our support to make the right choice: to stand behind Ms. Boone and build upon her valuable work in Boulder going forward. We should live stream and archive any city meeting taking place in Council chambers on a well used platform like YouTube. We should subtitle the archived versions in Spanish. We should expect our elected and appointed policymakers and city staff to participate competently in social media, and use it as the incredibly cost-effective and democratically empowering platform that it has become worldwide. It’s been a long time since the Internet was the exclusive domain of a technological elite — today it is the people’s platform, much more so than Wayne’s World style public access cable TV, or even our beloved Daily Camera. Newer digital platforms that are accessible to parents with young children and full time jobs need to be weighed heavily in our policy discussions, right alongside inconvenient, time-consuming public meetings.
Given last week’s firestorm of activity in support of Boone on Twitter I suspect that going forward, Boulder politicians and policymakers will ignore the digital realm at their peril. Just because you do not take an interest in social media, does not mean that social media will not take an interest in you.
Predictably, such a blunt and impassioned call to action, presented to a currently mostly unengaged Boulder constituency (about 850 of them…) has pissed some people off, and some of them want Becky’s head to roll, because she had the gall to try and get some folks to give a fuck about local governance.
That, quite frankly, is bullshit.
The whole point of getting someone from Code for America involved in outreach related to the city’s housing strategy was to engage currently underrepresented constituencies in the city (as reported in the Daily Camera), yes, with a focus on using technology, but talking to our local technologists and getting them engaged seems like a good way to make sure this important work continues after the 6 month fellowship ends this summer. We’ve got the demographics on who participates today, and the crowd at the Boulder Theater that night isn’t showing up to tell the city what they think. Given that, this talk might even have made sense as part of Becky’s work for the city — but she didn’t do it as someone working with the city, a fact she points out right at the start of the talk. She did this on her own time, to try and get a community she’s part of to participate in the governance of their own city.
Some members of City Council and the Old Guard politicos might not find the tone of the talk “appropriate,” but she wasn’t speaking to them. The tone was calibrated to the audience, which by all (Twitter) accounts received it quite well. The talk, like all Ignite talks, was extensively vetted by the event organizers, who have little interest in offending their attendees.
So far as I can tell, the only overtly partisan statement in the talk was when she noted that no particular expertise is actually required to participate in local governance… while a photo of Sarah Palin was displayed. The talk was almost entirely factual in nature, with a few jokes (mostly poking fun at the audience itself) and a few questions. It included:
Demographic information about who currently participates in city meetings and processes. She noted that renters are woefully underrepresented, being about a quarter of all housing meeting attendees but making up about half of the city population. She also pointed out that while 65% of Boulder’s population is under the age of 40… only 17% of housing meeting attendees are in that age range.
A brief explanation of the structure of Boulder’s city government — that we have a City Council who appoints a City Manager, rather than a directly elected “strong mayor” acting as the city’s executive authority.
The fact that only about 1/3 of registered voters participated in the last odd year election (which she shamed the audience over).
Information about how much City Council gets paid for what is essentially a full time job… a whopping $11,000 a year. Good luck living on that in Boulder! (at least… without illegally sharing housing and eating dumpstered food… now if only we had someone on Council who did that!)
The factual statement that 5 of the 9 City Council members are up for re-election this fall.
A call to the audience to get involved and get their friends involved, to tell Council and the rest of city government what they think about that position, and generically, other governance issues.
Statements highlighting the relative ease and high value of engaging in local governance, compared to larger jurisdictions.
A call to the audience to bring their skills and ideas to the table in support of local governance.
Stripped of the F-bombs, this is some pretty reasonable, wholesome stuff. The audience didn’t seem bothered by the language, and truthfully, it was meant to rile them up. This wasn’t an official (or even an unofficial!) city communication. The calls Council are receiving calling for Becky to be fired are couched in terms of “appropriate” language and professionalism, but those norms vary widely between different populations in the city. It’s also worth noting that New Era Colorado has in the past made extensive use of the slogan “Vote F*ucker” in their attempts to get young voters to turn out… e.g. in support of Boulder’s bid to create a municipal electric utility.
Response to the Ignite talk online, amongst the constituency it was designed to reach, has so far as I can tell, been overwhelmingly positive, if you go look through the mentions of @igniteboulder and #igniteboulder @boonrs on Twitter. In fact, it might just end up getting some more young folks engaged in city governance. That’s the real reason people are calling for Becky’s head. They know that broader engagement by young people, renters, and the tech community will result in the erosion of their political power.
Becky Boone is doing a way the fuck better than average job of getting young people engaged with the city. Certainly a better job than a communications department that won’t let staff use social media as the spontaneous, interactive tool it’s got to be if you want it to be effective (all while forcing employees to wear ties. In Boulder. As if that adds credibility. Personally I get suspicious whenever I see a tie…).
If City Council and the City Manager’s office give in to the totally inappropriate, unreasonable demand to fire someone who is actually doing a good job of getting unengaged people to participate, it would be a brazenly partisan act, an act in favor of Boulder’s incredibly conservative status quo, and in direct opposition to the goal of creating a more broadly representative civic sphere in the city. It would also be in direct conflict with the stated goals of getting a Code for America fellow involved in the first place.
Additionally, this type of speech — by a citizen, on their own time, related to a matter of obvious public concern — is the most strongly protected speech in the US. Any disciplinary action related to this talk would raise grave issues related to freedom of speech, and might warrant involvement by the ACLU or other organizations interested in protecting the rights of citizens to freely express views related to issues of governance.
I trust that City Council and the City Manager will stand by this citizen, who has been working hard to make Boulder’s democracy less worthy of the curses I’m sure I and many others will end up hurling at it between now and November.
Okay, actually just kidding. I don’t trust them. Which is why you need to support this kind of outreach, and call bullshit on the people who want to shut it down:
If you’ve been paying much attention to the climate policy discussion over the last few years, you’ve probably heard mention of carbon budgets, or greenhouse gas (GHG) emissions budgets more generally. Put simply, for any given temperature target there’s a corresponding total cumulative amount of greenhouse gasses that can be released, while still having a decent chance of meeting the target. For example, the IPCC estimates that if we want a 2/3 chance of keeping warming to less than 2°C, then we can release no more than 1000Gt of CO2 between 2011 and the end of the 21st century.
The IPCC estimates that if we want a 2/3 chance of limiting warming to less than 2°C, then we can release no more than 1000Gt of CO2 equivalent between 2011 and the end of the 21st century.
The reason the IPCC and many other scientist types use carbon budgets instead of emissions rates to describe our situation is that the atmosphere’s long-term response to GHGs is almost entirely determined by our total cumulative emissions. In fact, as the figure below from the IPCC AR5 Summary for Policymakers shows, our current understanding suggests a close to linear relationship between CO2 released, and ultimate warming… barring any wild feedbacks (which become more likely and frightening at high levels of atmospheric CO2) like climate change induced fires vaporizing our boreal and tropical forests.
What matters from the climate’s point of view isn’t when we release the GHGs or how quickly we release them, it’s the total amount we release — at least if we’re talking about normal human planning timescales of less than a couple of centuries. This is because the rate at which we’re putting these gasses into the atmosphere is much, much faster than they can be removed by natural processes — CO2 stays in the atmosphere for a long time, more than a century on average. We’re throwing it up much faster than nature can draw it down. This is why the concentration of atmospheric CO2 has been marching ever upward for the last couple of hundred years, finally surpassing 400ppm this year.
So regardless of whether we use the entire 1000Gt budget in 20 years or 200, the ultimate results in terms of warming will be similar — they’ll just take less or more time to manifest themselves.
Unfortunately, most actual climate policy doesn’t reflect this reality. Instead, we tend to make long term aspirational commitments to large emissions reductions, with much less specificity about what happens in the short to medium term. (E.g. Boulder, CO: 80% by 2030, Fort Collins, CO: 80% by 2030, the European Union: 40% by 2030). When we acknowledge that it’s the total cumulative emissions over the next couple of centuries that determines our ultimate climate outcome, what we do in the short to medium term — a period of very, very high emissions — becomes critical. These are big years, and they’re racing by.
Is 1000Gt a Lot, or a Little?
Few normal people have a good sense of the scale of our energy systems. One thousand gigatons. A thousand billion tons. A trillion tons. Those are all the same amount. They all sound big. But our civilization is also big, and comparing one gigantic number to another doesn’t give many people who aren’t scientists a good feel for what the heck is going on.
Many people were first introduced to the idea of carbon budgets through Bill McKibben’s popular article in Rolling Stone: Global Warming’s Terrifying New Math. McKibben looked at carbon budgets in the context of the fossil fuel producers. He pointed out that the world’s fossil fuel companies currently own and control several times more carbon than is required to destabilize the climate. This means that success on climate necessarily also means financial failure for much of the fossil fuel industry, as the value of their businesses is largely vested in the control of carbon intensive resources.
If you’re familiar with McKibben’s Rolling Stone piece, you may have noticed that the current IPCC budget of 1000Gt is substantially larger than the 565Gt one McKibben cites. In part, that’s because these two budgets have different probabilities of success. 565Gt in 2012 gave an 80% chance of keeping warming to less than 2°C, while the 2014 IPCC budget of 1000Gt would be expected to yield less than 2°C warming only 66% of the time. The IPCC doesn’t even report a budget for an 80% chance. The longer we have delayed action on climate, the more flexible we have become with our notion of success.
Unfortunately this particular brand of flexibility, in addition to being a bit dark, doesn’t even buy us very much time. If we continue the 2% annual rate of emissions growth the world has seen over the last couple of decades, the difference between a budget with a 66% chance of success and a 50% chance of success is only ~3 years worth of emissions. Between 50% and 33% it’s only about another 2 years. This is well-illustrated by some graphics from Shrink That Footprint (though they use gigatons of carbon or GtC, instead of CO2 as their unit of choice, so the budget numbers are different, but the time frames and probabilities are the same):
Like McKibben’s article, this projection is from about 3 years ago. In those 3 years, humanity released about 100Gt of CO2. So, using the same assumptions that went into the 565Gt budget, we would now have only about 465Gt left — enough to take us out to roughly 2030 at the current burn rate.
There are various other tweaks that can be made with the budgets in addition to the desired probability of success, outlined here by the Carbon Tracker Initiative. These details are important, but they don’t change the big picture: continuing the last few decades trend in emissions growth will fully commit us to more than 2°C of warming by the 2030s. 2030 might sound like The Future, but it’s not so far away. It’s about as far in the future as 9/11 is in the past.
It’s encouraging to hear that global CO2 emissions remained the same in 2014 as they were in 2013, despite the fact that the global economy kept growing, but even if that does end up being due to some kind of structural decoupling between emissions, energy, and our economy (rather than, say, China having a bad economic year), keeping emissions constant as we go forward is still far from a path to success. Holding emissions constant only stretches our fixed 1000Gt budget into the 2040s, rather than the 2030s.
If we’d started reducing global emissions at 3.5% per year in 2011… we would have had a 50/50 chance of staying below 2°C by the end of the 21st century. If we wait until 2020 to peak global emissions, then the same 50/50 chance of success requires a 6% annual rate of decline. That’s something we’ve not yet seen in any developed economy, short of a major economic dislocation, like the collapse of the Soviet Union. And unlike that collapse, which was a fairly transient event, we will need these reductions to continue year after year for decades.
The Years of Living Dangerously
We live in a special time for the 2°C target. We are in a transition period, that started in about 2010 and barring drastic change, will end around 2030. In 2010, the 2°C target was clearly physically possible, but the continuation of our current behavior and recent trends will render it physically unattainable within 15 years. Barring drastic change, over the course of these 20 or so years, our probability of success will steadily decline, and the speed of change required to succeed will steadily increase.
I’m not saying “We have until 2030 to fix the problem.” What I’m saying is closer to “We need to be done fixing the problem by 2030.” The choice of the 2°C goal is political, but the physics of attaining it is not.
My next post looks at carbon budgets at a much smaller scale — the city or the individual — since global numbers are too big and overwhelming for most of us to grasp in a personal, visceral way. How much carbon do you get to release over your lifetime if we’re to stay with in the 1000Gt budget? How much do you release today? What does it go toward? Flying? Driving? Electricity? Food? How much do these things vary across different cities?
Featured image courtesy of user quakquak via Flickr, used under a Creative Commons Attribution License.
Utility revenue decoupling is often seen as an enabling policy supporting “demand side management” (DSM) programs. DSM is a catch-all term for the things you can do behind the meter that reduce the amount of energy (kWh) a utility needs to produce or the amount of capacity (kW) it needs to have available. DSM includes investments improving the energy efficiency of buildings and their heating and cooling systems, lighting, and appliances. It can also include “demand response” (DR) which is a dispatchable decline in energy consumption — like the ability of a utility to ask every Walmart in New England to turn down their lights or air conditioning at the same time on a moment’s notice — in order to avoid needing to build seldom used peaking power plants.
For reasons that will be obvious if you’ve read our previous posts on revenue decoupling, getting utilities to invest in these kinds of measures can be challenging, so long as their revenues are directly tied to the amount of electricity they sell. Revenue decoupling can fix that problem. However, reducing customer demand for energy on a larger scale, especially during times of peak demand, can seriously detract from the utility’s ability to deploy capital (on which they earn a return) for the construction of additional generating capacity. That conflict of interests is harder to address.
But it’s worth working on, because as we’ll see below, DSM is cheap and very low risk — it’s great for rate payers, and it’s great for the economy as a whole. It can reduce our economic sensitivity to volatile fuel prices, and often shifts investment away from low-value environmentally damaging commodities like natural gas and coal, toward skilled labor and high performance building systems and industrial components.
The rest of this post is based on the testimony that Clean Energy Action prepared for Xcel Energy’s 14AL-0660E rate case proceeding, before revenue decoupling was split off. Much of it applies specifically to Xcel in Colorado. However, the overall issues addressed are applicable in many traditional regulated, vertically integrated monopoly utility settings.
Why can’t we scale up DSM?
There are several barriers to Xcel profitably and cost-effectively scaling up their current DSM programs. Removing these impediments is necessary if DSM is to realize its full potential for reducing GHG emissions from Colorado’s electricity sector. Revenue decoupling can address some, but not all of them.
There are the lost revenues from energy saved, which impacts the utility’s fixed cost recovery. If the incentive payment that they earn by meeting DSM targets is too small to compensate for those lost revenues, then the net financial impact of investing in DSM is still negative — i.e. the utility will see investing in DSM as a losing proposition. Xcel currently gets a “disincentive offset” to make up for lost revenues, but they say that this doesn’t entirely offset their lost revenues.
Even if the performance incentive is big enough to make DSM an attractive investment, the PUC currently caps the incentive at $30M per year (including the $5M “disincentive offset”), meaning that even if there’s a larger pool of cost-effective energy efficiency measures to invest in, the utility has no reason to go above and beyond and save more energy once they’ve maxed out the incentive.
If this cap were removed, the utility would still have a finite approved DSM budget. With an unlimited performance incentive and a finite DSM budget, the utility would have an incentive to buy as much efficiency as possible, within their approved budget, which would encourage cost-effectiveness, but wouldn’t necessarily mean all the available cost-effective DSM was being acquired.
Given that the utility has an annual obligation under the current DSM legislation to save a particular amount of energy (400 GWh), they have an incentive to “bank” some opportunities, and save them for later, lest they make it more difficult for themselves to satisfy their regulatory mandate in later years by buying all the easy stuff up front.
It is of course the possible that beyond a certain point there simply aren’t any more scalable, cost-effective efficiency investments to be made.
Finally and most seriously, declining electricity demand would pose a threat to the “used and useful” status of existing generation assets and to the utility’s future capital investment program, which is how they make basically all of their money right now.
Revenue decoupling can play an important role in overcoming some, but not all, of these limitations. With decoupling in place, we’d expect that the utility would be willing and able to earn the entire $30M performance incentive (which they have yet to do in any year) so long as it didn’t make regulatory compliance in future years more challenging by prematurely exhausting some of the easy DSM opportunities.