Duke Energy announced Thursday that it will take more time to review public comments and consider alternatives to its proposed Foothills Transmission Line.
Duke Energy announced it would not release its preferred route for planned transmission lines in early October as it had planned, saying it needs more time to consider input from the public as well as possible alternatives.
"More time is needed to continue to carefully consider more than 9,000 comments received on the proposed transmission line and create a solution to deliver cleaner, reliable power to Western Carolinas," Duke officials said in a news release. "The company is looking at all options that can meet the region's power demand over the next 10 to 15 years — including possible alternatives to the transmission line, Campobello substation and the configuration of the proposed Asheville natural gas power plant."
So, Duke recognized that continued pursuit of this project is an expensive, losing proposition. And that's because of the size and intensity of the opposition it's been receiving from the Carolina Land Coalition
and other opponents.
It's refreshing that Duke capitulated so early in the process, instead of pumping money and propaganda into a search for third-party advocates. In this instance, the company made the correct choice in seeking compromise. Maybe it could give lessons to some other wanna be transmission companies (psst... Clean Line...)?
So, what are the options now being considered?
Possible alternatives include the reconfiguration of the planned gas plant at the Asheville site.
Configuring the gas plant in different ways could change the related transmission needs, he said. Federal regulations require enough capacity in the system to compensate for the largest generation unit going offline, and if the plans for the gas plant call for a smaller unit, the transmission capacity needed could be lessened.
Duke is looking at different substation options as well, leveraging existing transmission infrastructure and other options, he said, but there is still a chance that the plan could stay the same. Other, smaller transmission upgrades that are already planned will continue, he added.
But here's what won't change:
The company still plans to replace the Asheville coal plant with a natural-gas-burning plant, Williams said. "We're not suggesting the need is not there; it very much is there."
Looks like Duke is betting that most of the opposition to its plan comes from the transmission line and substation, not the gas plant. And if Duke doesn't build a transmission line or substation, will those folks accept the compromise?
I guess we'll see...
Here ya go, DOE, you're going to need this:
The U.S. Department of Energy's Inspector General has completed his investigation of FERC's Office of Enforcement
. He found that FERC is following the rules it makes (but didn't stop to ponder whether those who make these rules, or the decisions that spring from them, are correct). The investigation completely glossed over any detail that would have actually looked at the issues. Sort of like that fictional guy from long, long ago who couldn't find his ass with both hands and a flashlight. This investigation was so bad, I think DOE must have been missing the flashlight. Or maybe a hand or two. Or maybe both.
As SNL puts it:
The U.S. Department of Energy's Office of Inspector General has given a big thumbs-up to the way FERC's Office of Enforcement is conducting its investigations.
"Based on our review, nothing came to our attention to indicate that [Office of Enforcement] had not performed enforcement activities in accordance with relevant policies and procedures," the inspector general said in a special report.
However, one of FERC's biggest critics in that regard assailed the inspector general for focusing on whether FERC complies with its own policies without discussing whether those policies are flawed or violate due process in the first place.
"That takes damning with faint praise to new heights," William Scherman, a former FERC general counsel and partner with the firm Gibson Dunn, said in an interview. The lawyer also said the inspector general appears to be inviting Congress to address the problem, "and hopefully they will" in the energy bills moving thru the Legislature.
The investigation reviewed:
7 closed investigations, 20 closed hotline cases, and 10 closed cases regarding potential violations, which had been self-reported by regulated entities.
Also, we specifically evaluated an allegation that the settlement of an enforcement action involving Constellation Energy Commodities Group, Inc., (Constellation) was inappropriately linked to a then-pending request for a merger between Constellation and the Exelon Corporation (Exelon). Specifically, the Senators expressed their concern that Constellation's agreement to settle the enforcement action was provided in exchange for FERC's approval of the merger (referred to as quid pro quo).
And if there's any question in your mind about whether the Inspector General actually looked closely at the closed investigations and hotline calls, take a look at their findings in the Constellation/Exelon debacle.
We found that that the Constellation-Exelon merger was specifically mentioned in the terms of the FERC/Constellation settlement agreement. Further, we determined that even before the merger was approved, Exelon executives were directly involved in the settlement negotiations. Finally, we note that the approval of the merger by FERC and the consummation of the enforcement settlement agreement took place on the same day. The lingering question was whether these actions represented an inappropriate quid pro quo. While these actions may have raised understandable concerns, the evidence did not support such a conclusion. In fact, we found that Exelon had specifically asked for language in the settlement agreement that linked the effective date of the settlement with the effective date of FERC's approval of its merger with Constellation.
Nothing to see here, move along. It's all just one big, funny coincidence! Maybe they should have used a flashlight on that one...
Here's another funny co-inky-dinky... Inspector General Gregory Friedman retired on the same day this report was released. Apparently DOE has a history of retiring employees who don't want to answer questions.
But(t), all is not lost... the Inspector General thinks the basic fairness of FERC's enforcement authority needs to be reviewed by Congress.
In addition to the issues we specifically evaluated, there were several that we were unable to review. Those concerns related to what was essentially the basic fairness of FERC's enforcement authority/processes. We concluded that these matters were public policy questions which, as important as they may be, are best addressed by policy makers and as such, were outside the purview of the OIG.
Our government is outta control and needs a Congressional flashlight in order to see...
Potomac Edison sends out confusing electric bills and rate information that nobody can understand. The West Virginia PSC allows it.
Did you get one of those hand-dandy Potomac Edison "Electric Rates for West Virginia Customers" pamphlets in your recent bill? Did you try to use the pamphlet to check Potomac Edison's math or to figure out what the different line items on your bill mean? Don't. Don't try to figure it out. You're going to drive yourself crazy!
If you're one of those folks who just go with the flow and pay whatever the company charges you without even looking at your bill, then don't read any further. However, if you're one of those folks who scrutinizes things and speaks up when they're not right, this is for you.
There are two, possibly three lines items on your bill. Your "base charge," your "environmental control charge," and if you live in a municipality that imposes taxes on your electric consumption, there will be a line item for "taxes."
What goes into your "base charge?" If you use your rate pamphlet that Potomac Edison just sent you, the W.Va. Rate Schedule R - Residential rate is detailed as a flat $5.00/month customer charge, plus an Energy Charge of $0.08747 per kWh used. So, if you multiply your kWh used by the Energy Charge rate and then add the $5 Customer Charge, it will add up to the base charge line item on your bill, right?
WRONG! It doesn't add up.
Try calling the company for an explanation. They give you some complicated explanation that there are additional charges for things you can't find on your rate pamphlet under the Schedule R section. If you push them to explain it to you so you actually understand, they get their panties in a bunch. Try calling the WV Public Service Commission to see if they can explain it to you. They'll send you a bunch of schedules and a list of charges that went into your bill, but again, you can't find these charges on your rate pamphlet.
Turn your rate pamphlet over to the back cover. Under the heading of "Lighting Fixture - Customer Owned Pole" you will find some additional charges entitled "Environmental Control Charge," "Environmental Control Charge Normalization," "EEC Program Cost Recovery Rate," and "Temporary Transaction Surcharge."
Hey, Environmental Control Charge -- that's a separate line item on your residential bill, isn't it! And if you multiply your kWh used by the Rate Schedule R rate, you will get the same number!
But what about those other three charges? They're not separate line items on your residential bill. But they're in there. They've been added to your "base charge," along with your Customer Charge and Energy Charge.
Go ahead, try it. Multiply your kWh by each of the three remaining charges (taking note that the Environmental Control Charge Normalization is a credit, or subtraction from your bill for residential customers). Then add that to your Energy Charge and Customer Charge and see if you don't get the same subtotal that Potomac Edison got on your bill. Add in your Environmental Control Charge and Tax line items and you get the amount of your current bill! Amazing! Doesn't that sound easy?
No? You're not alone. It shouldn't take an intelligent guy a week and countless phone calls and numerous emails to become utterly frustrated with this confusion. You know what the ratepayers think, Potomac Edison? They think you make your bills confusing on purpose so that you can find new and interesting ways to gouge them without them noticing. So, I explained the rate pamphlet, the actual rate, and the correspondence, tariff sheets and other "explanations" he was sent by the company and the PSC. Just one more service I provide. I won't say he's thrilled, but he understands now. Why did you waste his time (and yours) like this Potomac Edison and WV PSC?
Why can't you include the ENTIRE Residential rate scheme on the front of your rate pamphlet, Potomac Edison? Why did you put those mystery riders on the back page under the Lighting Fixture Schedule? You're a special kind of stupid, aren't you? There's no reason calculating and understanding your residential electric bill needs to be this hard. Maybe you should ask a customer now and again about how you can improve their understanding of their electric bill and the rates they pay. Because I'm not going to be here to clean up after you forever.
Remember when the U.S. DOE's triennial "congestion studies" under Sec. 1222 of the Energy Policy Act were a big deal? That was before the 4th Circuit told them that a state's denial of a project was not a "failure to act" that triggered federal intervention to usurp state authority to permit a transmission project. And that was before the 9th Circuit vacated the "corridors" the DOE designated in 2009 because of DOE's failure to consult with affected states. What's left behind is a useless section of statute that doesn't actually DO anything except waste taxpayer money on ridiculous "congestion studies" that do nothing but compile unverified data and opinion from the internet and the industry to inform the DOE's designation of future "congestion" corridors. Now when DOE issues one of its "reports" (three years past the deadline, or maybe it's on time and DOE just skipped the 2012 report) it's so anticlimactic that nobody knows about it.
And that's what happened with DOE's 2015 Report Concerning Designation of National Interest Electric Transmission Corridors. Big nothing. In fact, it was so uninteresting that DOE didn't even bother to send notice to all the folks who commented on its draft that it had completed its study. An astute commenter just happened across it.
Despite the industry's urging to continue attempting to use this tool to usurp state authority to site and permit transmission, or to simply delegate its authority to create corridors to transmission builders, the DOE decided not to designate any new corridors. Seems they have lost their taste for it after the beat down they suffered in federal court.
So, isn't it time to do away with this waste of taxpayer money? How much did this limp "report" cost to create? Congress needs to reconsider this mandate in any new energy legislation. It's a waste of time and money.
DOE's got issues. I note that this "report" appears to be the agency's recommendation to the Secretary on the designation of new corridors. I guess that would make it an "internal deliberation" that should be swept under the rug and hidden from the public? Maybe that's what the lack of notice was about? How come DOE is making this "internal deliberation" available to the public, but hiding its "internal deliberations" regarding Clean Line's application under Sec. 1222 of the Energy Policy Act? Something really stinks at DOE. They're operating like they are somehow above the public scrutiny and transparency that our federal agencies are bound to operate under. It's just one big taxpayer funded, opague industry party. And that spells trouble down the road the next time DOE finds itself in federal court over its industry-sympathisizing machinations of the Energy Policy Act.
So, let's toss Sec. 1221 on the failed legislation heap, but save room on the pile for Sec. 1222. It's coming.
When does cleaning up your dirty habits turn into an even bigger problem? When you're beleaguered dirty energy maven Duke Energy, and you try to profit from cleaning up your mistakes. And the folks in the western Carolinas are having none of it.
Duke's audacious plan is to shut down a 368MW coal-fired generator in North Carolina, replace it with a 650MW gas-fired generator, then build a new 230kV transmission line from the upgraded plant to a new super-sized substation in South Carolina so it can ship out all that excess generation for big profits.
Except the good people of North and South Carolina have come together to oppose the project. And they don't seem to be getting the least bit tired, or distracted by Duke's efforts to divide and conquer them by fomenting local routing battles between neighbors.
Word is that Duke had to fast-forward its initial routing comment period after it received more than 9,000 comments in just a few short months. What's going to happen when 9,000 people show up to oppose Duke's plan during regulatory commission hearings?
Get more information, and sign on as a supporter, at the website of the Carolina Land Coalition. Becoming a supporter is free, and you don't have to be from the local area. You just have to have a healthy skepticism for any utility's plan to overbuild generation and transmission to fatten its own balance sheet.
More fun to come...
What's been happening in transmission news this week? The Virginian Pilot
took a look at Dominion's Skiffes Creek 500kV transmission project... and it sort of looks like the project itself is up the creek. Dominion has lots of excuses for why it needs to build a ginormous transmission line across the James River, but none of them are exactly logical. Skiffes Creek is not really the only option to ensure reliability, it's just the one that regional grid planner PJM Interconnection approved a long time ago in an uncompetitive environment. If the transmission project is not approved by the U.S. Army Corps of Engineers, then PJM will have to go back to the drawing board and re-engineer another solution to what it views as a reliability problem.
Gotta wonder... if this problem was put out for bid in PJM's new competitive transmission process, would other companies have better solutions? Solutions that solve the problem without creating an eyesore and river hazard of an aerial crossing of the James River? Probably.
Dominion contends that the technology doesn't exist to run a reliable line of the caliber and kind needed under 4 miles of riverbed - at least not without a price tag in the billions.
Oh, baloney, Dominion! Take a look at the Artificial Island project
that is proposed to cross underneath the Delaware River just a couple states to the North. When transmission solutions are evaluated in a competitive environment, a submarine crossing suddenly becomes viable, not only from a cost standpoint, but also with an eye toward "constructability," a measure of the ease of getting a project approved and constructed with minimal opposition. In the case of the Artificial Island project, PJM ultimately selected a proposal by LS Power that uses a 3.5 mile submarine crossing of the river in which the company capped its construction costs
. Dominion needs to re-evaluate its submarine options.
The Skiffes Creek project is a cash cow for incumbent utility Dominion. Under PJM's old, pre FERC Order No. 1000 transmission project selection process, the incumbent was allowed to propose all solutions. The incumbent could propose only those solutions that would provide a healthy shot to its balance sheet. FERC recognized that this process didn't necessarily inspire the best and cheapest solutions and has revolutionized the way regional grid planners select new transmission projects.
Dominion tries to hide behind an aura of concern for ratepayer issues.
Curtis said the Skiffes over-the-river plan, at $60 million, is indeed on the lower cost end of the dozens of routes and options the company considered. Whatever the expense, though, customers will reimburse Dominion. Rate hikes are automatically allowed for utilities that build infrastructure to strengthen the grid.
"So these are rate-payer dollars, not Dominion dollars," Curtis said. "But the opposition is still committed to the conspiracy theory."
Curtis tells only part of the truth here. The part he leaves out is that Dominion will be earning a double-digit return on its $60M investment in the project over its useful life of approximately 40 years. The more the project costs, the more Dominion makes in pure profit. Dominion is hardly agnostic about ratepayer costs. Also, if Dominion had to compete to build this reliability solution, it would face giving up this potential profit entirely to another company with a cheaper, less intrusive proposal. There IS a conspiracy... because the investment is Dominion's dollars, not ratepayer dollars. And Dominion earns a healthy return on every dollar it invests in this project.
So, are there other solutions? Opponents accuse Dominion of not examining and considering all options.
"What's frustrating is that people think we're being disingenuous," Curtis said. "They don't believe we've looked at all the alternatives, or they think we're only concerned about making the most money for our shareholders."
The article reveals
Several lines already feed outside power to the Peninsula, but it won't be enough without the Yorktown plant, which Dominion says is too costly to upgrade in the face of new federal clean-air standards.
Did Dominion consider upgrading and rebuilding the existing lines to increase capacity before settling on an entirely new transmission line? C'mon, Dominion, you're no stranger to this plan... after all, your plan to rebuild the 500kV Mt. Storm-Doubs transmission line to increase its capacity is what killed the entirely new 300-mile PATH transmission line. Or are much cheaper rebuilds only considered when Dominion finds itself in a competitive environment?
How much time and money will Dominion's effort to keep itself from being propelled "up the creek" with Skiffes Creek cost ratepayers? Dominion's blind pursuit of this project in the face of better alternatives is what may cause "rolling blackouts" on the peninsula. The longer Dominion delays by backing a lame horse, the closer the peninsula gets to a genuine reliability issue. Get with it, Dominion, and switch to a solution that everyone can agree upon. Don't you have a legal obligation to keep the lights on? Or only one to increase shareholder dividends every quarter?
...or maybe we should call it a lesson in identifying good guys vs. bad guys?
Hey, Feds, your right hand should introduce itself to your left hand.
This article in Vista Today
informs that FERC bad boy Rich Gates will apply for a "Whistleblower" reward from the U.S. Securities and Exchange Commission for his work in exposing Credit Suisse's "dark pool" after the penalty is announced. Gates estimates he could be in line for a reward in the neighborhood of $5 - $15 Million.
Meanwhile, the Federal Energy Regulatory Commission has fined the other Gates twin $30M for alleged "market manipulation" for exposing a loophole in PJM's poorly designed energy markets.
So, if Rich Gates takes in $15M from the SEC, could he use that money to pay off part of the FERC's $30M fine (assuming FERC can make it stick in court)? I'd say that's some pretty smart money management!
Next up... will Disney be making a good twin vs. bad twin flick starring Rich and Kevin Gates? This story has been done many times over, but I think some government employees might relish the chance to prance across the big screen as cartoon characters set to an inspiring theme song and cymbal-crashing, energizing score.
Rich can play the "good" twin, who developed tests of buying and selling the same security in numerous dark pools or exchanges to see if anyone was getting in front of client’s trades, as chronicled in Michael Lewis's book, Flash Boys.
Kevin can play the "bad" twin, who performed a similar test of PJM's MLSA payment market and ended up making money that would have gone to certain gigantic utility holding companies if not for his participation in the market and exposure of PJM's poor market design.
But, wait, which twin is good, and which twin is bad? They sort of look the same to me. Like maybe identical? Both twins demonstrated that they were much smarter than the regulators who are supposed to be monitoring both markets. Maybe it depends on where in the federal government you're standing when you blow your whistle. By offering a reward for whistleblowing, the SEC demonstrates that it could actually be helped by those who expose things the agency wasn't smart enough to catch. On the other hand, FERC punishes those who expose things they weren't smart enough to catch. I don't think FERC offers any rewards for exposing utility scams. In fact, it punishes those who expose incumbent utilities, dumb market design, and lazy regulation.
But now it can all end well, like it did in Disney's The Parent Trap, when the twins switch places and the SEC reward pays FERC's penalty... and they all live happily ever after.
My challenge partner, Ali Haverty, reminded me this morning of a Facebook meme
we shared months ago. It's a photo of two owls on a branch, and says, "Sometimes I just want someone to hug me and say, 'I know it's hard. You're going to be okay. Here is chocolate and 6 million dollars.'"
And that's what we got. Of course, the 6 million dollars belongs to the 61 million ratepayers in the PJM region. Our personal share is probably about a nickel.
On Monday, FERC ALJ Philip Baten issued his ruling on the PATH case that was heard back in the spring.
Ali and I were seeking the refund of just over $6M in expenses for the purposes of influencing the decisions of public officials that PATH incurred and recovered from PJM ratepayers in 2009, 2010 and 2011. Judge Baten ruled that all of the expenditures were not recoverable in PATH's rates and must be refunded.
This is my favorite part:
As a general proposition, the cases that are discussed above suggest that when utilities are seeking selection or CPCN approvals from governmental entities, the utilities should rely on the established governmental approval processes to persuade the officials and not indulge in collateral efforts such as public education, outreach, and advertising activities. If a utility should rely on these collateral activities while pursuing selection or CPCN processes, then it will risk the chance that these costs may not be recovered from ratepayers. If the selection or CPCN application has merit, the governmental selection process provides a sufficient vehicle for the utilities to present their engineering, marketing and economic studies and thereby hope to merit the vote of approval from these officials. In this regard the PATH Companies spent over $8 million on attorney fees to prosecute the CPCNs before the respective governmental bodies, which begs the need for these collateral expenses.
The judge's decision must now go before the Commission, who may affirm or deny, in whole or in part. That decision is several months down the road, at least, and requires another round of briefs.
Meanwhile... more chocolate. And champagne. And music. Let there be music!
More silly utility "educational" seminars. This one came in the mail yesterday. The Financial Accounting Institute has invited me to attend its Utility Finance & Accounting seminars in Las Vegas.
Well, woo hoo, party in Vegas! Except this party costs $1995, plus travel and expenses. Sad face. I guess I'll just have to learn utility finance & accounting on my own.
FAI will be teaching its students all sorts of utility accounting concepts, such as how to tell the difference between capital and expense, and "motivations of managers and top management with respect to the issue." Wait... let me guess, it's because capital expenses earn a bit, fat, juicy return? Therefore everything should be capital?
But here's the best part of the whole seminar... one of those really great "role playing exercises." Who doesn't love a good role playing exercise to introduce just the right amount of realism into your learning experience?
The utility can never be sure their position will prevail? Well, then the utility isn't doing something right! See section about "ethics considerations" where you can learn about unethical behavior at some utility companies. I wonder who's going to play that role?
Why should certain costs not be included in rates? Because they're below-the-line costs. Will FAI be providing some sort of effective strategy for the "utility CEO" to use to argue that below-the-line costs should be included in a rate? And since when does a utility CEO or CFO actually show up to argue anything during a rate case? For that matter, when does a consumer advocate or large industrial ratepayer show up to argue that below-the-line costs should not be included in rates? FAI can probably dispense with those roles entirely and replace them with a couple of honey badgers.
Now that's realism!
Who's a key transmission challenge in the Midwest?
You're a key transmission challenge in the Midwest! The biggest "challenge" to building transmission in the Midwest is the people who are expected to sacrifice their businesses, their homes, their retirement, for benefit of the illusive "communities that have a strong demand for renewable power."
Electric Utility Consultants, Inc. (EUCI) is having another "educational" shindig to discuss you "challenges," and once again, you're not invited.
On November 9 and 10, EUCI will be gathering its fattened cows to the trough in Indianapolis to be "educated" about the following:
Transmission as a Market Enabler: Today's "conservative" approach to transmission planning exposes customers and other market participants to greater risks and costs because by understating the benefits of and risks addressed by transmission, valuable investments in transmission facilities are either not made or delayed.
This session will address a study paid for by WIRES, "The Voice of The Electric Transmission Industry." WIRES is made up of corporations who stand to profit from building new transmission. Apparently we're not planning enough transmission for their balance sheets. Awwww.....
But then there's this:
State Regulatory Viewpoint on Transmission Developments in the Region
State Regulators will share their perspectives on:
The role of stakeholder involvement
How different states are looking at the challenges involved to collaborate with other states
The benefits and challenges that competition for regionally cost-shared transmission projects creates for the PUCs and the ratepayer.
Adam McKinnie, Chief Utility Economist, Missouri Public Service Commission
Did anyone tell EUCI that the Missouri Public Service Commission recently denied Clean Line's Grain Belt Express application for a 700-mile transmission line through the state? Fun times! I hope they're planning to create some space between that guy and...
KURT ALERT! Amy Kurt, Clean Line Energy Manager for the development of the Grain Belt Express Clean Line, will be "educating" participants about "The Challenges of Renewable Energy Integration," including the sub-topic "Maintaining grid security and reliability while integrating increased penetrations of renewable energy." I wonder when Amy got her engineering degree that qualifies her to expound on grid security? Maybe she's been doing it online, in secret? Or maybe Hans Detweiler taught her how to be an "engineer?" At any rate don't let Amy sit with Adam at lunch! "A" is for awkward!
Participants will learn about "Embracing New Communication Technologies." Good to see that Amy isn't teaching this one, because her communication skills haven't been working too well on the people of Missouri. Did I mention that the MO PSC denied the Grain Belt Express application Amy "managed" because its benefits didn't outweigh the harm to Missouri citizens?
So, what "new technologies" will be embraced?
Communicating with the public is a critical element to successfully building new transmission line projects. Strategic communication requires teams to go beyond traditional outreach tools by embracing new techniques including zip-code targeted social media ads (Facebook and Twitter), electronic communication, videos, online comment collection, and Story Maps. For the busy public, an online open house provides access to open house materials, information videos, interactive maps, and input opportunities. With tight project budgets, it's time to embrace new tactics to communicate and stretch dollars and gain the input necessary to identify smart routes and communicate with all stakeholders throughout the project construction process.
What? No unit on using change.org
to send supportive (but off-topic) comments from your Mommy and Little Sis into a regulatory process? Well, maybe there's a role for Amy after all!
Unfortunately, the "busy public" interested in transmission isn't interested in a corporate-slanted version of web "facts." The "busy public" gets its facts from equally busy "public" opposition groups... live and in person, via email, via social media, etc. Hot time in the ol' tool shed tonight! Nobody trusts the corporation to be honest, with good reason.
Don't miss Amy discussing:
Illinois is home to two of Clean Line's projects, the Rock Island Clean Line and the Grain Belt Express Clean Line. The Rock Island Clean Line received its regulatory approval from the Illinois Commerce Commission (ICC) in November of 2014. The Grain Belt Express Clean Line filed its application with the ICC this April. This presentation will provide an overview of Clean Line's approach to developing multi-state, direct current, transmission lines to deliver renewable energy to market.
Sounds like a real party, doesn't it? Unfortunately, it's going to cost you $1195, plus travel and expenses, to get inside. But who needs to get inside to be a "challenge?"