Foreign-Trade Zones (FTZ)


[ Music ]>>Welcome today and
thank you all for coming. We’re going to dive right in
because we actually have a lot to cover and there’s a lot of interesting information
after this also. So what are the basics? The FTZ program actually goes
back to 1934, as Joe said. It was during the New Deal. Of course, there was a lot going
on with tariffs and whatnot at that point and this was
a means that Congress saw to really encourage activity,
employment and, eventually, manufacturing here
in the United States. The program actually
has quite a history. Essentially what it is, a foreign-trade zone is
a place that’s designated by the Foreign-Trade Zones
Board, activated by US Customs and Border Protection — and
we’ll get into what that means in a little — but it’s really a
specific location here in the US where different customs
procedures can be used. And those customs
procedures mean that you can really delay the
customs entry on merchandise. That’s the quick summary. We’re going to get into what
that means possibly for you as a company in terms of duties
and the potential savings that it could involve. But essentially,
that’s all it is. It’s a place here in the US where special customs
procedures can be used. The idea behind the
program initially in 1934 and still now was to encourage
activity and investment — employment — here in the US that could otherwise be done
abroad for customs reasons. And it’s really, I mean,
that was the original purpose and that’s still what
we’re trying to do today. So we kind of summarized
and we are going to get into the details
of each of these, but FTZ procedures
allow activity here in the United States. And first of all to
— I don’t want anyone to get the wrong impression. Foreign-trade zones
are very much a part of the United States. Merchandise that goes into a foreign-trade zone has
not been entered for consumption but it has been imported
into the US. So these are locations
here in the US, once again, simply where special customs
procedures can be used. You can defer that
customs entry. US FTZs are very much though
within the territory of the US and subject to all other
federal, state, and local laws. So some of you might’ve
heard about say, for example, free-trade zone programs
in other countries where there may be
different labor laws or different tax
laws that apply. And so I’m sorry to tell you that is not the case
here in the US. It really is simply about
the customs procedures, the timing of the customs entry. But all other federal, state,
and local laws do apply. So I hope nobody gets up
and walks out right now, but it is an important point. And it’s a common
misunderstanding that people think a
foreign-trade zone is say, outside of the US
somehow or, you know, outside of an agency’s
jurisdiction. So we’re going to — we will
talk about the benefits, don’t worry, but I want to
get that out there up front that this really is about the
timing of the customs entry. So before a company can
actually use the FTZ — you know, I mentioned before that FTZs are locations
designated by the FTZ Board,
so that’s step one. Before the FTZ can be used,
it has to go through a process of activation with US
Customs and Border Protection. So step one — get it
designated; step two — activate with US Customs. CBP is actually the
agency that’s involved in the day-to-day oversight
of the FTZ activity. My office has the
very lucky position of dealing with the theoretical. You can have a FTZ here, you
can do this type of activity — but we’re not the ones on the ground handling
the day-to-day oversight. That’s US Customs and
Border Protection. So step two with the FTZ is
applying to CBP to activate and be able to use the FTZ. And all FTZ activity
that remains under US CBP supervision. So anything that goes into an
FTZ is done with the, you know, through CBP procedures. Anything that goes out of an
FTZ is through CBP procedures. And I’m sure the good
folks here in the center of the room can tell you
more about those details but FTZs are also open
to spot checks, you know? It’s something to
be aware of, again, as you’re considering
the program that the facility remains
under a customs bond. And so you are — the
way you track inventory, what you bring in,
where everything is, how you’re accounting
for it is very important in the FTZ environment. So the way the FTZ
program is structured — and again, this goes
back to 1934 when Congress set
up the program. They created the FTZ
Board and the board — I’m actually on the board staff. The FTZ Board itself is
the Department of Commerce and the Department of Treasury. I’m with the staff of the board. We’re located in Commerce. But the way it works after that
is the board designates public or public-type organizations
to act as something we call
FTZ grantees. And the grantee is
the local organization that manages the zone. And all authority from the FTZ
Board goes through the grantee. In this area, it’s
the City of San Jose. So Joe is your face for the
FTZ grantee here in San Jose — in the San Jose area,
I should say. But the grantee is then
responsible actually for acting as a public utility, providing
zone services on a uniform basis to companies in a region. So the grantee’s also the
one that markets the zone. The grantee of course is not
the one handling merchandise or, you know, concerned
about that type of thing. The grantee is the
one that makes sure that companies can access
the program in their area. In order to use an FTZ, you
as a company will need to work with your local grantee, either
the city of San Jose here in this area or in most,
actually, customs ports of entries, there is a
grantee and an FTZ established. So if you’re in a
different area, there’s probably
already a grantee there that you can work with. You might be able to work with one even a little bit
further if there’s not. But in most parts
of the country, now there is a grantee
established, a zone you can use. And you would need to work
with and through that grantee to get access to
the FTZ program. What can you do in a zone? The FTZ Act itself
has a whole list of the specific activities
you can do. The important things:
warehousing, distribution, of course that type of
activity, manufacturing, production (you’ll
hear us call it). What you can’t do is
the important thing — no retail trade. So these are not
duty-free shops. You also can’t live in an
FTZ — if you would want to. But basically anything
else in the course of normal business activity
can be done in an FTZ. If you’re doing anything that
falls under our definition of production, which is
essentially does it change the HDS classification
at the 6-digit level, then you need specific
authority from the FTZ Board. If you’re not doing that, if
you’re simply say warehousing or you’re running a distribution
facility, you need designation of your site from the FTZ Board, and you can then apply
to CBP to activate. But if you’re doing any
production activity — and again, for our
purposes, that’s anything that changes the classification
at the 6-digit level, then you need specific
authority from the FTZ Board. And we’ll talk about
how to get that. If you’ve heard about
the program in the past and lengthy application
processes, book-length, year-long process, the
good news is it’s nothing like that anymore. But first of all, why would you
want to do this to begin with? What are the benefits? So we talked at the high level. FTZs are places where you
can defer US Customs entry. What does that mean
for you as a company? It means if you’re operating
a distribution facility, you bring merchandise
into your FTZ — and again, when you
bring it into your FTZ, you’ve not filed
a customs entry. You have not paid duty. You’re doing something
called an admission. It’s coming into the US, but
you’re not filing an entry. You can store it in your FTZ
and you don’t file the entry and pay the duties
until it leaves your FTZ for the US market. So especially if you
have high values — and right now it’s not
uncommon to have high duty rates on some components —
you can defer the payment of those duties. Until you file an entry, it leaves your FTZ
for the US market. If you re-export
the merchandise, you’ve never filed an entry. So you never pay the duty. And of course, if you’re
operating a distribution facility — I’m just using
that as an example right now — say you have customers
in Canada, other places, this can be your
distribution facility for the North American market. Bring merchandise
here, defer the duty on what you’re ultimately
bringing into the US market, and you never file an entry or
pay duty on shipments elsewhere. So that could, especially now with components having
some higher duty rates, that could be a real
benefit for some companies. Traditionally, the
biggest benefit for companies has been what we
refer to as the inverted tariff. Now if any of you have actually
seen a printed copy of the HTS, the Harmonized Tariff
Schedule, the document that sets the duty rates
for anything that comes into the country —
if you print it, out, it’s probably about this thick. It was a few years ago that
last time I saw a printed copy and it was three volumes,
about this big each. I don’t know what it
would be right now but it’s a long document. There’s a lot in there. And it’s not uncommon for
there to be situations — unintentionally, of course —
where there’s a higher duty rate on a component that you need in your manufacturing
operations compared to what you’re producing,
your finished products. And if that’s the case for you
as a company, what you can do — and again, this does require
approval from the FTZ Board — but what you can do is
bring in those components into your facility, combine
them with domestic merchandise. And when you ship them to
the US market, when you file that entry, you can
pay duty on the value of those foreign components at the lower finished
product duty rate. So it’s a bit of a
complex situation. But if you can imagine
say you’re making cars, have a 2.5% duty rate, does that
apply to electric vehicles also? It does. So your cars
have a 2.5% duty rate. I know that is the case. I’m going to make
something up now. But say your — this is
not going to be true now — we’re going to say radios
because it’s easy to imagine. But say you’re bringing in
radios that have a 5% duty rate. You bring it into the FTZ, you
manufacture it into your car. When it leaves the
FTZ for the US market, you can pay the 2 «% duty rate
on the value of those radios because it’s been
manufactured into a car. So you can see right
there, again, depending on your industry, depending on what
components you’re using, there could be real savings. And the reality behind
this is, most companies that are importing components, they’re importing
some components. They’re using others that
are sourced domestically. We live in a global economy. There is a lot of sourcing
that does occur from abroad and it’s very difficult
for a company to source everything
domestically. We recognize that. The point is, we would
rather have you conduct that activity here than
say go to another country, make your finished car, and
pay 2.5% on the whole thing. We want you to do it here, employ US workers,
US value-added. Do the activity here so we can
give you the same customs tariff situation as if you were
conducting it abroad but you’re employing US workers. So for most companies,
if you’re manufacturing, this is where the
big savings are. But again, it does
vary by company. So you will need to take a
look at the specific things that you’re bringing in
and the duty rates on those and the duty rates on
what you’re producing. Now, very importantly, what I
want to point out here before, once again, anyone
gets too excited, the little asterisk we
should put at the end of this that this really applies to those unintentional
duty situations. So in that long and
complicated HTS Schedule where those situations
just happen to arise that there is a higher duty
rate on your component compared to your finished product,
where this cannot be used is where there are intentional
duties placed on things. The obvious examples there of course are antidumping
countervailing duties, Section 201, section 301 — 232,
excuse me, also, the big ones. Those actually —
anything subject to any of those measures has to
be placed in special status when it goes into the FTZ. And that status locks
in its identity. So even if those items are
manufactured into something that is not subject to
those duties, you still have to pay those duties
when they leave the zone for the US market. Now that’s again
for the US market. If you’re exporting
those, then once again, you would never have
filed an entry. So if you are subject to any of
those types of special duties and you have any exports, the
FTZ could still be an option. And actually, we’ve heard
from companies recently that have started using
the program simply to defer those duties because
they can be quite high. But the FTZ cannot be
a loophole around them. So we’re here to
help US manufacturers but we can’t be a loophole around very intentional
government policy either. All right. A few other things to mention. So there are logistical benefits
that companies can achieve through the FTZ as well. In addition to — what we’ve
heard from some companies is that their insurance costs
might actually decrease because they’ve gone through
the activation process. Their processes are secure. Their inventory is
very controlled. But beyond that, there are
actually some procedures that you may qualify for,
such as direct delivery, which could — with CBP again. And they can actually answer
more detailed questions about these than I can. But basically, your product may
be able to move more smoothly and quickly to your
facility from the port and you may also qualify for
something called weekly entry, which means that instead of filing one entry every time
something leaves your FTZ (and of course paying the associated
merchandise processing fees and any broker fees) you can
set up a process with CBP so that you only file
one entry per week. So one merchandise
processing fee, one broker fee for the week. So for some companies, again,
if you meet the criteria and it’s approved by CBP, there can be some significant
savings there as well. Luckily, the last bullet here
does not apply to California. So there are a few states left
that have an inventory tax, and merchandise in an FTZ is
impacted by the inventory tax. And it’s actually much simpler
for you to access the program without that because there are
some specific things that have to occur to make sure that,
say local school districts, are not that negatively
impacted by the FTZ. So the happy news we can
share for you here is, you don’t really have to worry about that last bullet
here in California. It says it’s a benefit, but it actually does make it
a little bit more difficult to access the program. Another important thing
— and this, I think, is a little bit lesser-known
benefit to the program, we call it the production
equipment benefit. So if you have an FTZ and
you’re set up for manufacturing, you have what we call production
authority from the FTZ Board, or you’re in the process
of applying for it and you’re constructing a plant
or you’re expanding a plant, you don’t need any
separate approval. You can bring in any
imported production equipment into the FTZ in FTZ status
— assemble it, test it — you don’t have to file
an entry and pay duty on that production equipment
until it’s ready to go into use. So again, if you have a large
plant with a lot of equipment that say you can only buy from
overseas, this can help you to defer the duty
on that equipment or possibly even reduce it. And again, because of that inverted tariff
we were talking about, there might be a lower duty rate
on that equipment as assembled than in the pieces
that it was brought in. So if you’re — again,
this doesn’t apply just to new plants, but if you
have an existing plant and you’re expanding it, you
know, this could be either way. But obviously, if it’s new
construction or a new plant, you know, this could
be a real benefit. We’ve already touched on this but why does the
program exist generally? The idea of course we said
was to encourage activity and employment here in the US. Facilitate international
commerce, I think is also stated
in the FTZ Act. Keep things moving. Help encourage and
attract activity here, really that we’re
open for business and business can
operate smoothly here. So come conduct your activity
here in the US instead of doing it abroad, really
that’s what it comes down to. I talked a little bit
about the structure. And I don’t want to steal
Joe’s thunder later. He said he was going to talk
about his role as grantee also, but I’ll just give
you a quick background because it is a little
bit hard to visualize and it sounds very bureaucratic. We’ve got this board and
then we’ve got Customs and we have all these
organizations involved, but this is just a quick
summary how it’s structured. So the FTZ Board — and again,
that’s the Secretary of Commerce and the Secretary of Treasury
— is at the top there. So my office would be a
little box off of that, you know, where there’s staff. But the FTZ Board grants the
authority to organizations — that’s why we call
them the grantees. In this case, the
City of San Jose — and the City of San Jose
manages the zone locally and provide access to
companies in that region. So the grantee is next,
below the FTZ Board. The operator is the company
that’s holding the bond with CBP. So an operator may be
processing its own merchandise, which we’ll get to
that on the next slide. But basically, the operator
is the one that’s responsible to CBP. They’ve gone through
the activation process. They’re holding the bond. And they’re doing that under
the authority of the grantee. So to be and FTZ operator,
you’ll actually enter into an agreement
with the grantee to essentially use
their authority. At the very bottom here, what
we have, we call the user. So the user is essentially
the one that’s benefitting from the FTZ, probably the
owner of the merchandise. The user could be the operator. So you could be an operator
processing your own merchandise, in which case, you
know, you’d be that one over on the far right-hand side of the screen we’re looking
— the operator/user. You’re processing
your own merchandise. You have the bond with CBP. But you could also be
acting as operator, say a logistics company,
and have multiple users. Again, that’s perfectly fine. It’s actually not uncommon. And in that case, it would
be this box over here on the left-hand side where you
have multiple users underneath the operator. So there can be different
ways of structuring the FTZ. Even in one zone, there
can be different setups for different companies. You might hear some of
these words getting tossed around though so I wanted to make sure you
knew what they were. So the process has changed
pretty dramatically in the past about 10 years in terms
of accessing the program. When I started out in this
office, it was not uncommon — a company wanted
to use the zone. They’d come in with what we
call a subzone application to have their facility
designated. It’s about this thick. And they’d submit it to us and
we’d say, great, we’ll get back to you in about a year. It didn’t work very well. And it was actually — we
didn’t do many of these types of events because, well, you can
imagine what the response would have been. Very simply, it just
did not work. And there were different ways
we tried to get around and tried to do things on a
quicker basis and, quite frankly, it was a mess. We needed to make
changes and we did. About 10 years ago, we came up with something we called
the Alternative Site Framework. And of course, the
only reason it has that name is there’s the way
things had always been done (so we call that the
Traditional Site Framework) and we gave grantees this
option of using this new format, this new structure
really for their zones. What it means essentially is that the grantee has done
a lot of the work up front. So what used to take all those
steps we would have to take because the FTZ Act tells
us we have to take them, the grantee has done
that up front. And that means that
when a company wants to use the FTZ program, the
grantee has done all the work. There’s very little left
that needs to be done. We can designate a
site or a subzone, essentially the same
terminology, designate something for your company when
and where you need it in a very quick and
simple process. Again, for really
reasons of evolution and how things have developed
throughout the program, you’ll see the phrase
“usage-driven site” and “subzone” kind of
used interchangeably. Unfortunately, we have
two terms from them, how things have evolved. If we were designing
the program from new, we would only have one term. But if you were a company that
wants to use the FTZ program, you would either have
a usage-driven site or a subzone designated for you. The process is the same. What you can do in
it is the same. There’s really no
substantive difference. It’s just the way
things have evolved. You can call it whatever
you want. And anywhere within the area
that the grantee has designated, the FTZ Board has approved is
what we call a service area for that zone. You can get your
site designation from the FTZ Board
within 30 days. And I can say this on behalf
of my colleague, Chris Kemp, that would handle
your application, we both have a similar policy. If it’s on our desk,
it’s complete. It’s not going to take you
30 days to get a decision. You know, he’s out
of town right now. So if you submit it,
he’s back in the office in about a week-and-a-half,
I think. So you might have to
wait a week-and-a-half. But we both have a pretty
strict clean desk policy. So if it comes in, we’re
going to get it back out to you as soon as possible. It says 30 days, it’s probably
not even going to take 30 days. So it’s a very simple — I think
we have a slide — oops, okay. We’ll go back to that. But this shows you really
what we’re asking for. What’s your company name? What’s the address? The acreage? Do you have the right
to use the site? We need a map. You will need to talk to US
Customs and Border Protection because we need to know
that they would be able to oversee the site
— and that’s it. Send that in to us and we’ll
get it right back out to you with your site or your
subzone designation, and it’s really that simple. I’m going back up to
that slide I skipped. And again, I won’t
hover on this too long because I think Joe is going
to cover something similar. But you might not be able to
read most of it, but at the top of the screen, it’s the service
area for the San Jose Zone. So anywhere within that
area, you can use this quick and simple process —
have it designated. If you’re not within
that, don’t worry. We’ll talk about
that in a minute. The rest of what you see up here
is what appears on our page, our website, that provides
information about each zone. So Joe’s contact
information is up there, but just to give you a summary,
you know, this information is up there on our website
for all zones. So if you have facilities
located elsewhere, this information is available — the same information
is available on those zones as well. Now, you’re looking at
that list and saying, gosh, it sounds great but I am
just outside that area. That’s called the service area. What do I do? First of all, don’t panic. It’s not quite as simple,
it’s not quite as short, but we’ve still drastically
shortened the process even without being in
the ASF service area to bring designation
to a company. So if you’re outside the ASF
service area, we have to do — it has to be called a subzone. And it’s either a three
or five-month process. Otherwise, the information
we ask for is the same, except that we also need the
legal authority for the zone to submit the application. So that’s one of the things
that’s already been done, that the grantee’s already
done for their service area. So if it’s a subzone
outside the service area, it’s one of the things
we need to cover. Unfortunately, the way
our regs are structured, there’s also a fee for
those types of applications. And there’s not a fee under
the service area but there is if it’s not under
the service area. Those are really the
only differences. Otherwise, it’s just
a few months longer. We will have to open a
public comment period for these types of applications. We usually don’t get comments
on this type of thing, but it is a step that we
will have to go through. So we have the site designated
or the subzone designated, but you’re also going
to be manufacturing. What do you do then? So it is a separate request
but you don’t need to wait. So you could actually
start your Request for Production Authority (we
call it) from the FTZ Board, you can start that at any time. You don’t have to have your
subzone designated yet. You can start this request
whenever you’re ready. The Request for Production
Authority is a 120-day process with the FTZ Board. So again, production in the FTZ
world, what you need authority for is anything that changes
the HTS classification at the 6-digit level. That of course was going to include any traditional
manufacturing, but what it also includes is
things you would not think of initially. So you’re say a distribution
facility and you have some clients
that have asked you to do a little bit of
a different activity in your warehouse
for them this year. They’re bringing in bottles
of liquor and some glassware and they say, hey, can you
just bring these into your FTZ, put them in a box
together, so I’m ready for the holiday season. I can get them out
to the stores. Sounds simple. It’s going to employ at least
a few people — sounds good. That is actually production
activity in the FTZ world because you’re bringing
in the liquor bottles and you’re bringing in — you’re
importing in this example, you’re importing
the liquor bottles and you’re importing
the glassware and putting them
together in a box. And when they leave
the zone, they’re going to be classified as the liquor. So you could actually
be reducing the duty on that glassware. So it’s not — people think
of production activity, that’s you know, a big factory
— it’s not necessarily. If you’re reducing
the duty rate, you’re changing the HTS
classification on those items, that is something that you
do need production authority from the FTZ Board. So just be aware. It’s not — you know,
there could be situations that you wouldn’t
initially think of where you do need
authority from the FTZ Board. If you do, it’s okay. Again, it’s not a
really lengthy process. It’s 120 days from the time you
submit the application to us until the time a
decision is made. And there’s not much
to this request either. So, you know, the steps we
have to take into account, we will open up a
public comment period. And we will just discuss briefly
with industry specialists within Commerce, but that’s it. And the information that
you have to submit to us, it’s really, again,
your company. Where are you located? And then we’ll ask for a list
of your finished products, so that’s what leisure zone,
and your important components, what goes into your zone? And that’s all we’re asking for. We’ll go through these steps
and, if we don’t see any issues, then we’ll say go ahead
and do it at day 120. Now, if we do see issues — so
that’s that 120-day process — if we do see issues, then
we might have to bump it to a longer process
but in the history — so these regs have been
in place since 2012. I think we’ve had 300-some
Requests for Production Activity and about 10 that we’ve
said we need to review this through the more
detailed process. And it’s usually pretty
predictable industries — manufacturing textiles has
always been very controversial in FTZ environments. So, I mean, for the most part, companies get the
authorization within 120 days. And if you give us a
list of say 20 components that you’re importing and we
have concerns about one of them, we’re not going to say
no to the whole thing. We can say yes, go ahead
and do it, but for this one, you have to put in
a special status. So you can’t reduce
the duty on that item. So you know, don’t
be afraid even that the whole thing’s
going to get denied. You know, if there
is that concern about one little product, we can
just authorize everything else. So the timeline overall
is pretty simple. And again, these processes do
not have to run back-to-back. They can run at the same time. You can get your
production notification in before your subzone
application. You can have them
running at the same time. You can do the subzone first
and the new production. So it is two processes, but
they’re both pretty simple and, you know, you can
start either one of them whenever you’re ready. So within the service area, 30 days to get your subzones
say designated, and 120 days for your production
notification. The reality is, most companies
can’t be activated with CBP in that time frame anyway, that
it’s going take longer for you to get all the requirements
that CBP has. So while your applications
are being processed by the FTZ Board, you can also
be discussing the activation with CBP, getting ready so that when you have the authorization
you’re, you know, as ready to go as possible and can get up and
running as soon as possible. So you’re designated, you have
all your approvals in place. CBP has approved
your activation — no, sorry, didn’t look too
carefully at the slide. So you get your designations
in place. Then you apply to CBP
to actually activate. I hinted at that it was a more
involved process with CBP — and again, they can
answer details on that. But basically, it will involve
background investigations on key employees. CBP is going to take a look at
the inventory control system that you’re using, make sure
that everything can be tracked from the time it comes to
the zone through the zone, through any processes
you’re doing in the zone, until the time when
it leaves the zone. Of course, they’re also going
to look at the security in place at your facility and now
you’ll need to post a bond and have a written
procedures manual. Hopefully, there’s
no questions on that. Otherwise, I will
defer them to CBP. But otherwise, once you’re
approved, you’re up and running, you’re using the FTZ, there
are a few things you will need to do — and Joe mentioned. There is an annual
report to the FTZ Board. We take all that
information from you — you’ll actually submit
it to Joe. Joe will submit it to us. And we’re required — again,
this comes down to the law — we’re required to submit
a report to Congress so — we’re required to do it but I think it’s
actually very helpful. You know, without
that requirement, it could be difficult to get
everyone to submit it in, but it’s really useful
to have information about what’s happening
in the program. So the information you submit
there is actually really, really important in terms of how
the program is being used and, you know, helpful for
you as a company also. You can take a look at the last
year’s report and see what types of companies are using it. Is this something
that might benefit me if all my competitors
are using it? You know, it’s helpful
in that sense as well. On an annual basis,
you’ll also have to do what’s called a
reconciliation of your inventory and report the results
of that to CBP. But again, they can give more
information on those details. So a little bit of background. There are zones in all 50
states and Puerto Rico. Puerto Rico is part of the
Customs territory of the US. More than 500 subzones,
far more sites than that. We had 3,200 companies using
the zone in our last report and about 450,000 employees. So there is a lot of companies
in this country and a lot of employees — these
are just the employees in the activated
areas of the zones. So if you’re designated but
you’re not using the zone, we’re not counting
those employees. These are the ones from,
again, the activated companies. This is the employees
in that area. So the numbers are pretty big. I should actually
run the statistics, but I think that $670 billion in merchandise handled
through the zones. In terms of the foreign status
merchandise coming into zones, I think it’s about
10 to 12% of imports into the country are
coming through FTZs. So the numbers are pretty big. And we had about 87
billion exported last year. These are just a few of the
largest users in the program. One of the changes we’ve seen
as we’ve simplified the process to get sites designated and
to get production authority, you know, quicker and simpler
for companies, we’ve seen a lot of smaller companies
enter the program that really could
not in the past. So they’re not necessarily going
to be reflected in this list. But we have seen a huge
growth in the number of small companies
throughout the country that are using the program. So again, if you don’t see what
appears to be your industry on this list, you
know, don’t worry. It doesn’t mean that
there’s not a benefit there or not savings there or it’s
not something that you can do, but this is just as background. These are some of the
biggest users of the program. I’m not Chris — but I did want to give you your
regional contact. So my colleague, Chris, is the one that would be
processing your request, you know, your site,
your usage-driven request and really knows the
details of each zone in this region far
better than I do. But like I said, I’m not going
to hang up on you if you call. So you know, contact
anyone on our staff. We’re actually a staff
of 10 people total. So you know, we’re a
pretty tight-knit staff. And you know, if you have
questions about anything, you can contact any of us. I don’t know how much time we
have for questions but happy to answer any questions. Sorry about that.>>Thank you so much, Liz. [ Applause ]

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