By KEITH RIDLER
Associated Press

BOISE, Idaho (AP) — Two electric utilities and a federal energy agency with millions of customers in eight western states have reached a tentative agreement centered on a new energy transmission line connecting their power grids.

Idaho Power, PacifiCorp and the Bonneville Power Administration announced the complex proposal Wednesday ahead of the expected 2026 completion of a 500-kilovolt, 290-mile transmission line from eastern Oregon to southwestern Idaho.

The entities said the Boardman to Hemingway transmission line will help them meet increasing demand and support their clean-energy goals while increasing the reliability and safety of the region’s transmission system. Energy will move in both directions on the line.

The agreement still needs to be finalized and approved by regulators.

“This arrangement paves the way toward a promising and economic solution for serving all of the participants and supports efforts to meet the region’s clean energy goals,” said Kim Thompson, Bonneville Power Administration’s vice president of Northwest Requirements Marketing.

The Portland, Oregon-headquartered BPA is a U.S. Department of Energy agency that markets electricity generated at 31 hydroelectric facilities operated by the U.S. Bureau of Reclamation and the U.S. Army Corps of Engineers on the Columbia River and its tributaries. It also markets power from the Columbia Generating Station, a commercial nuclear facility north of Richland, Washington.

The BPA markets the energy to public utility districts, municipal electric utilities and rural electric cooperatives in eight states.

Boise, Idaho-based Idaho Power is a public utility that operates as a state-regulated monopoly. It has about 600,000 customers in eastern Oregon and southern Idaho. Most of its energy is produced from its 17 hydroelectric facilities on the Snake River and its tributaries. The company plans to phase out coal-fired power by 2028 and provide only clean energy by 2045. The new transmission line is a key part of that strategy.

PacifiCorp is a regulated public utility with two operating divisions, Pacific Power and Rocky Mountain Power, that combined have about two million customers in Oregon, Washington, California, Utah, Idaho and Wyoming.

PacifiCorp would benefit with the deal by improving its ability to move power into its central Oregon service area. It will also acquire Idaho Power transmission assets across southern Idaho that will increase the company’s ability to transfer power between the eastern and western parts of its service area. The company’s long-range planning includes significantly expanding its wind and solar energy, and battery storage. The company is looking to eventually move away from coal energy in the 2040s.

BPA is guided through statutes created by Congress. Idaho Power and PacifiCorp are both regulated by state utility commissions in the states they operate as well as by the Federal Energy Regulatory Commission.

Notably, the transmission line connects deeply conservative Idaho with the more liberal Oregon.

Idaho Republican Gov. Brad Little, a rancher, has publicly recognized climate change, and his recently released proposed budget includes money to deal with those realities on state-owned land.

Oregon Democratic Gov. Kate Brown, as a member of the Western Governors’ Association, has pushed to improve the region’s electric-vehicle charging infrastructure.

Under the proposal between the three energy entities, PacifiCorp will own 55 percent of the new transmission line and Idaho Power 45 percent. BPA is transferring its ownership interest in the line to Idaho Power and will not participate in its construction. BPA will acquire transmission service over Idaho Power’s transmission system, including the Boardman-to-Hemingway line.

The proposal also includes the transfer of some assets between Idaho Power and PacifiCorp that each entity said will strengthen their systems and provide access to key energy markets to meet growing demand.

“This agreement solidifies and simplifies a path forward for a project that will help us continue our century-long tradition of reliable, affordable, clean energy,” said Mitch Colburn, Idaho Power’s vice president of planning, engineering and construction.

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Auburn, Wash.-based engineering, planning and environmental services firm Parametrix this month opened an office in Bend.

The office, at 595 S.W. Bluff Drive, is the firm’s second location in Oregon; the other is in Portland.

Eight Parametrix staffers are working out of the Bend office, and two more will soon join them, Parametrix spokeswoman Kami Matiatos said via email. The Bend-based staffers specialize in civil engineering, site development, transportation and land surveying.

The Bend office will be led by Barry Johnson, who has more than 29 years of experience in civil design and land development. Before joining Parametrix, he led the Bend office of design firm WHPacific. Other lead staffers at Parametrix’s Bend office include Jim Frost, a senior engineer and client manager, and Andrew Huston, who will manage land surveying projects.

Expansion into Bend will allow Parametrix to diversify its customer base, Matiatos said. Firm staffers have already worked on numerous projects in Central Oregon for clients that include the city of Bend, Sunriver Resort, Brooks Resources Corp., the Bonneville Power Administration and Crooked River Ranch.

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The Bonneville Power Administration, which itself turns 75 this year, celebrated the 75th birthday of the Bonneville Dam this past weekend.

The BPA is a large part of the identity of the Pacific Northwest. The federal agency was created by Congress in 1937 with the construction of the hydroelectric dam. The agency’s purpose was to sell power the dam generated at the cost of production rather than for profit.

Now the BPA has 31 federal dams on the Columbia Basin, including 11 on the Columbia River. It’s one of four regional federal power marketing agencies in the U.S. Department of Energy.

At the anniversary celebration, an actor portraying President Franklin Delano Roosevelt delivered the same speech the real F.D.R. made at the dam’s dedication on August 20, 1937.

According to a BPA:

Since then, much has changed. The Northwest economy has expanded a thousandfold. People use electricity to power gadgets that no one would have dreamed of back in the ’30s. What hasn’t changed is the source of our power — the mighty waters of the Columbia — and our commitment to the public good.

The BPA has been criticized for how it has handled the effects of dam construction on Native Americans and salmon populations. The agency has since started programs to address these issues.

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In an effort to resolve a heated dispute with renewable energy producers that began last spring, the on Tuesday released a new plan to manage the region’s electric grid when supply exceeds demand.

But regional wind advocates say the plan is inadequate, despite changes made since a draft was released in February.

When heavy rains and snowmelt runoff created a huge surge in hydropower last spring, the BPA faced an oversupply of electricity that could have overwhelmed the grid. The federal agency, which owns about 75 percent of the region’s high-voltage transmission system, resorted to unplugging wind turbines because spilling excess water around its dams could have harmed salmon in the Columbia River.

But in December, the ruled that the BPA erred when it cut off wind production. This week, the BPA proposed a monetary settlement with the wind producers in an effort to meet FERC’s nondiscriminatory transmission tariff requirements.

The BPA proposes to cover half the cost of damages incurred by wind producers. When turbines are turned off, they lose the value of production as well as federal production tax credits that accrue only when the wind farms are generating electricity.

The immediate losses to hit wind companies last year amounted to approximately $10 million, according to data compiled by the .

Under the new plan, the BPA’s first course of action during periods of excessive power generation would be to divert water through dams’ spillways rather than power-producing turbines. But environmental rules restrict excessive use of spillways.

The agency would then offer low-cost or free hydropower to replace the output of thermal and other power plants. If supply still exceeds demand, the BPA would again unplug wind farms and other generators; but now it would pay for lost revenue.

The agency expects that amount to be approximately $12 million a year. Depending on weather, that amount could jump to $50 million or drop to nearly nothing, according to BPA spokesman Doug Johnson.

Wind advocates contend that the plan sidesteps what they see as a deeper problem: The BPA doesn’t treat power from other generators as it treats its own hydropower.

“The concept they’re suggesting does not ensure fair treatment in the future,” said Cameron Yourkowski, senior policy manager covering transmission for the Renewable Northwest Project. “The issue goes beyond this high-flow, spring oversupply re-dispatch situation. We want to know the basic principles established for fairness on the transmission system are being followed.”

The BPA tweaked its plan based on comments it received before Tuesday’s deadline. If FERC were to accept the plan, known as the Oversupply Management Protocol, it would be in place for one year instead of three years, as proposed initially. The BPA also would hire someone from outside the agency to review the amount of money it would offer to curtailed wind producers.

Kevin Lynch, vice president of external affairs for , said the revised plan includes only marginal improvements.

“The filing really misses the mark,” he said. “(The BPA) has a commercial interest in the way power markets react to supply and demand, and that vested interest in the outcome colors their decisions on curtailment.”

And the problem of oversupply is not likely to go away, according to a new analysis issued by the . Between April and June, the Pacific Northwest could exceed the market demand for electricity by 300,000 megawatt-hours, or enough to power approximately 100,000 homes during the same three month period.

While the problem has many industry stakeholders calling for long-term solutions, the BPA is standing behind its one-year proposal.

“For the time being, this is the best way forward,” Johnson said.

But significant spring over-generation could occur about once every four years, according to the council’s analysis, and in some years the excess could soar to 1.2 million megawatt-hours. That worries wind interests.

“We’re not convinced that (the BPA) will make decisions in a nondiscriminatory manner this year (because) they discriminated against us last year,” Lynch said. “We would be much more reassured if the federal regulator were overseeing those decisions.”

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The Bonneville Power Administration is planning a $428 million project to improve an electrical transmission line that runs through the Columbia River Gorge.

The transmission line, the 3,100 megawatt Pacific Direct Current Intertie, delivers hydropower and wind power to California. It also carries electricity north to the Celilo Substation in The Dalles, its northern terminus.

Proposed improvements would increase the line’s capacity and strengthen it against weather and other forces that have caused increasing outages since the line was built more than 40 years ago.

The BPA is beginning a mandated environmental review process and will decide later this year whether to proceed with the upgrades. If the BPA decides to go forward, it will put the project out to bid toward the end of 2012, BPA spokesman Doug Johnson said.

The contractor would develop a detailed project schedule, paying special attention to the procurement of the specialized equipment that is needed for the upgrades. Production lead times can be as long as two years, so accurately timing the orders and product deliveries is critical.

Construction is expected to start in early 2015 and finish in early 2016 if the project moves forward.

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Renewable energy developments in the Northwest may soon benefit from more flexibility in the transmission planning process.

The past several years have been marked by an increase of wind power developments, partially because of laws requiring utilities to add renewable energy to their portfolios. The Bonneville Power Administration, which controls three-quarters of the Northwest’s high-voltage transmission lines, has been working to figure out how to prepare for the new wind power.

But not all of the projects that generated transmission service requests on the BPA’s lines will come into fruition – a reality that the federal agency is now addressing in new ways.

The BPA in 2008 implemented a program to track interest in its transmission lines with a process called Network Open Season. When an energy company decides it wants to use the BPA’s transmission lines, it signs a Precedent Transmission Service Agreement and makes a financial commitment. Developers can enter into these agreements before, during or after their projects are constructed. They can defer transmission service for up to five years, but those agreements – to this point – cannot be modified or terminated.

Approximately 60 percent of the requests for transmission service since 2008 have come from wind developers – a total of 11,722 megawatts. The BPA responded by planning to add four major transmission lines to accommodate the potential energy developments.

But the complex planning process can require years for both the transmission lines and the wind developments, and in the meantime the economy has worsened, the queue for transmission service has lengthened and the renewable energy market has changed. Although developers signed the transmission service agreements and provided financial commitments when they requested service, BPA spokesman Doug Johnson said that some developers this past summer expressed uncertainty about going forward with their transmission requests as planned.

Confidentiality agreements prevented Johnson from sharing the names of those developers.

“We have been wondering how much wind in the back part of transmission service queue may or may not materialize,” he said. “We want to build the right project in the right place at the right time, and we need to know what the folks on the generation side are planning so we can come up with the right path forward.”

The four proposed transmission lines would cost the BPA a total of $787 million. After meeting with developers and other regional wind interests at the Northwest Wind Integration Forum in June, the BPA asked developers if they would be interested in terminating or modifying their transmission service agreements. In total, developers expressed concerns about 3,028 megawatts, and caused the agency to reconsider one of the four major transmission lines, as well as the terms of its contracts with developers in general.

“Given the current economic slowdown, it seemed prudent from both BPA’s and the wind developers’ perspectives to reanalyze the situation and consider whether or not to make that investment in specific transmission projects now or to wait and see how things change in the future,” said Cameron Yourkowski, senior policy manager of the Renewable Northwest Project.

The BPA in March announced that it would build the 40-mile Central Ferry-Lower Monumental line running through eastern Washington, but has slowed its construction plans. The $90 million project would provide 1,595 megawatts of new service, the vast majority to accommodate wind power. But the BPA decided not to move forward with preconstruction work based on its conversations with developers.

However, the BPA has moved forward with construction of the Big Eddy-Knight project, a $185 million, 28-mile line that will move electricity across the Cascade Mountains, from the west to the east.

“We had good certainty that all the revenue would materialize, and it made sense to build (the Big Eddy-Knight line),” Johnson said. “But we got some indications from customers with (service requests) related to the Central Ferry-Lower Monumental line that did not have as much certainty.”

Nevertheless, the BPA is bound to transmission service agreements with other developers. One, Puget Sound Energy, recently completed assembly of 149 turbines at the Lower Snake River wind farm near Walla Walla, Wash. The BPA built the Central Ferry substation to accommodate the wind farm, which is expected to come online in April 2012, but the specific line that will carry the generated power is not determined yet, according to PSE spokesman Roger Thompson.

“We are obviously interested in the Monumental line that is on the planning horizon for BPA,” he said.

The utility has a contract with the BPA that promises 250 megawatts of transmission capacity, although the project could generate up to 343 megawatts.

“They’ve expressed confidence that they’ll be able to provide the capacity we need,” Thompson said.

The BPA is analyzing customer feedback and developing new cost projections for each project, taking into account the potential terminations and modifications to developers’ service requests. The agency on Wednesday plans to release those assessments as well as refined principles of the Network Open Season process as a whole. Its goal is to complete the reform process by the end of the year.

“The (Network Open Season) policy is working well and I hope it will prove flexible enough to accommodate major changes in the economics of projects and the demand for energy in general,” Yourkowski said.

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The Bonneville Power Administration is tentatively set to begin construction Sept. 19 on a 28-mile transmission line. The line will run from the Big Eddy Substation near The Dalles to a new substation four miles northwest of Goldendale, Wash.

The project is within the Columbia River Gorge National Scenic Area, so the plans have gone through extensive public review, beginning in June 2009. The final plans are the result of hundreds of comments that assessed the impacts of three proposed routes.

BPA claims that the 500-kilovolt line will provide up to 100 construction jobs, including local electricians, carpenters, welders and other Oregon trades workers. The project will cost approximately $185 million and is financed in part with borrowing authority included in the American Recovery and Reinvestment Act.

The U.S. Forest Service will conduct a consistency review of the final plans, and construction will begin after contract terms and other permits and approvals are granted.

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Public utilities in the Pacific Northwest will be challenged to maintain rates they charge customers after the Bonneville Power Administration last week announced that its wholesale power rates would increase by 7.8 percent, effective Oct. 1.

The BPA said it is increasing rates to cover the costs of repairs at aging dams, fuel purchases and repairs at the Columbia Generating Station nuclear plant, and fish and wildlife conservation.

Nearly all of the 115 public utilities in the region buy power from the BPA. Each one will determine how much, if any, of the BPA increase to pass on to customers. One key factor likely will be how much power each utility acquires from the BPA.

For most regional public utilities, power purchases from the BPA represent a large portion of their total costs, according to Kevin O’Meara, deputy director of the Public Power Council, an advocacy group for publicly owned utilities.

The Umatilla Electric Cooperative, a nonprofit utility that serves approximately 10,000 customers in Eastern Oregon, buys all of its power from the BPA. If the UEC were to pursue rate increases, they would be determined by a board of commissioners after Oct. 1 and not impact customers until early 2012, according to Nate Rivera, a community relations representative for the utility.

Because the UEC is a rural electric cooperative, Rivera said its rate increases mostly impact the agricultural community.

“The difference between a farm making a profit and having a year that’s a loss is a very small margin,” he said. “Their cost to get water supplied to their land is a large part of their expenses, so if their rate increases, it shrinks their margins.”

The Eugene Water and Electric Board purchases approximately 80 percent of its power from the BPA, and expects to hike its rates by about 2.1 percent in response to the BPA’s plan, according to Joe Hardwood, external communications director. EWEB’s largest customer class is residential, so it will foot most of the bill, he said.

EWEB’s financial team is examining its individual contracts to determine any possible rate changes for industrial clients. Hardwood expected any increases to be approximately 2 percent.

Clark Public Utilities, which serves 180,000 residential and commercial customers in Clark County, purchases approximately 60 percent of its power from the BPA. However, communications manager Erica Erland said the BPA’s rates do not necessarily correlate directly to Clark Public Utilities’ rates.

Utilities in Oregon also are facing rising rates because of the state’s renewable portfolio standard, which took effect this year. The RPS, passed in 2007, directs utilities to meet a portion of their electricity needs using qualified renewable sources; the amount is determined by the utility’s size.

The RPS for Oregon’s largest utilities starts at 5 percent in 2011, and increases every five years to reach 25 percent in 2025. The standard for other electric utilities in the state, depending on size, will reach 5 percent or 10 percent in 2025.

The Umatilla Electric Cooperative, in particular, could see a huge jump in costs over the next few years because of the way the state defines “small” and “large” utilities in regard to RPS. Development in Eastern Oregon has increased the region’s energy load, so the UEC could be placed in the same class as Portland General Electric and PacifiCorp, which each serve more than 500,000 customers.

“The state policy has us in a really difficult position,” Rivera said. “Any economic development in our region could be potentially damaging to us because it would force us to increase our rates. We want jobs to come to this area, and if state policy hamstrings us on that, we need to educate the Legislature and let (it) know how it’s impacting the region.”

In the last legislative session, the UEC and Eastern Oregon lawmakers pushed for bills that would have granted the UEC an exception, but they weren’t passed. Rivera said the UEC will continue to fight for an exemption, although the region’s designation as a “large load” is still uncertain.

If growth in the area were to slow or the rest of the state were to grow faster than expected, the UEC might not supply 3 percent of Oregon’s total electricity sales, which is a “large” load according to the Oregon Department of Energy.

However, Amazon.com is building two data centers at the Port of Morrow and one at the Port of Umatilla that will significantly impact the grid.

If the UEC were designated as a large utility, it would be responsible for increasing its RPS from 10 to 25 percent and the additional $56 million in costs would have to be spread around a relatively small amount of customers.

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Activity within the northwest transmission system this season has sparked widespread debate, culminating in complaints against the Bonneville Power Administration‘s decision to curtail wind production. This week, the BPA and others issued responses to the wind-industry’s complaint.

The heaviest spring runoff from the Columbia River Basin since 1997 caused a surge in hydroelectric generation in May that overwhelmed regional demand. There was no agreement among industries as to how to handle the issue.

The BPA, which controls about three-quarters of the regional transmission system, curtailed wind production during off-peak hours starting in mid-May. The curtailments ended on July 10 and, barring an “unexpected event,” will not resume, according to BPA spokesman Michael Milstein.

“We were glad to see it was a limited impact on wind,” Milstein said of the approximately 6 percent reductions in scheduled wind production. “We know there was an impact in the end, but conditions are such now that it looks like there will be more flexibility in the hydro system, and demand has been increasing somewhat as well.”

But a coalition of five companies filed a complaint against the BPA on June 13.

“BPA has unilaterally broken (its) wind energy contracts,” said Jan Johnson, spokeswoman for Iberdrola Renewables. “They are using their monopoly control to break contracts and seize transmission rights for their own economic interests.”

Johnson contends that because the BPA replaced renewable wind with hydropower, which is not considered renewable, some of Iberdrola’s customers may not meet their renewable portfolio standards.

“We already paid for our transmission rights,” she said. “BPA seized them so they could send their hydropower to our customers. Will customers continue to purchase wind power from the northwest if they don’t know if they’re definitely going to get it?”

The wind coalition’s complaint was filed with the Federal Energy Regulatory Commission, and charged the BPA with violating the Federal Power Act by requiring wind farms to shut down operations. The group includes Iberdrola, PacifiCorp, Horizon Wind Energy, Invenergy Wind North America and NextEra Energy Resources.

The BPA on Tuesday responded to the complaint with a 554-page document that interested parties are still combing through. Ultimately, the response calls for the complaint to be dismissed. The BPA also defends its Environmental Redispatch policy, which is the strategy that allows the administration to replace scheduled generation, such as wind, with federal hydropower under certain system conditions.

For wind companies, however, the policy amounts to discrimination. “Curtailing one generation source in favor of another is discriminatory behavior,” said Paul Vogel, vice president of communication and public affairs at PacifiCorp.

Vogel said PacifiCorp’s complaint is not based on the financial impacts of the curtailment – wind is a relatively small part of PacifiCorp’s energy holdings – but on the principle of the matter.

“For us it’s an issue of being able to count on and rely upon contracts and making the system work the way it needs to,” he said.

The BPA maintains that because of its various legal responsibilities, wind curtailments were necessary for the reliability of the transmission system and to reduce harm to endangered species.

In its response, BPA argues that sending more water through dam spillways would increase dissolved gases that could harm the aquatic ecosystem, particularly salmon, trout and whitefish.

Five salmon advocates on Tuesday filed their support of the wind industry’s complaint, though, arguing that there is no scientific support for BPA’s claim. The organizations include Save Our Wild Salmon, Idaho Rivers United, American Rivers, the Pacific Coast Federation of Fishermen’s Associations, and the Institute for Fisheries Resources.

Also, the Oregon Public Utility Commission on Tuesday filed a statement supporting the complaint against the BPA.

“We believe they have picked on wind generators, and the customers we represent, including Portland General Electric and PacifiCorp, are being hurt by these policies,” said Bob Valdez, the OPUC’s public information officer. “Rather than BPA’s unilateral approach, we think they should be exploring other options to find the cheapest way to deal with this issue.”

The BPA last year began public discussions about too much generation, Milstein said. “We weren’t sure when, but we figured there would be a high runoff year and we would encounter these sorts of demands on the system,” he said.

Milstein outlined a couple of proposals the BPA is considering to better manage the situation in the future. Upgrading the pumped storage project at the Grand Coulee Dam in Washington is one way the BPA could handle grid fluctuations caused by wind.

Grand Coulee already has a pumped storage system, which uses excess power to pump water uphill from a low reservoir to a high reservoir during periods of less demand. Then, when demand is greater, the system runs the water back down to the lower dam, generating power as it flows. Milstein says the facility is getting old and the BPA is working with the Bureau of Reclamation to see whether an upgrade would be useful in high runoff situations.

The BPA also is looking into ways to create demand during periods when energy needs are usually much lower, specifically between midnight and 5 a.m., which were the hours of the wind curtailments. Milstein cited a pilot project with a large farm near Richland that has switched its irrigation pumping to work at night rather than during the day.

Iberdrola and many others in the wind industry are calling for negative pricing, which would require the BPA to pay the wind companies for the time that generators are shut down, thereby replacing the production tax credits and renewable energy credits that they would have received from the government.

The BPA’s response to the FERC complaint provides arguments against paying negative prices, however.

Regardless of the ultimate result of the complaint, concerns about integrating renewable energy into the transmission system will continue to be an issue.

“The FERC complaint will decide some very important issues,” Vogel said, “but we’re all in this region together and producing for the northwest. We need to work together to find solutions so that we don’t find ourselves here again.”

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“Rather than being an environmental issue, the policy is a classic case of anti-competitive and discriminatory behavior by a utility with a conflict of interest,” said Rob Gramlich, senior vice president of public policy at the American Wind Energy Association.

Ouch.

Wind energy industry folks have been sniping at the Bonneville Power Administration for weeks over the BPA’s creation, and practice of a policy to shut down wind farms because of an “oversupply” of energy.

Because there’s so much rain and water melting off of snow pack, or the official term “unusually high seasonal river flows,” BPA’s dams are producing too much power for the grid to handle–unless it asks wind producers to shut off their turbines and let the water do all the producing, BPA says.

In “good water years” in the past, prolific hydroelectric production has meant shutting down other sources of energy–nuclear plants and so on—but it hasn’t been a big problem because those energy sources can shut down their apparatus without losing money. The problem with doing this to wind producers is that those plants make money from production tax credits—which they only get when the turbines are running. AWEA says the policy could cost wind producers tens of millions of dollars.

So the wind industry is not happy with BPA—probably the understatement of the year. Here’s another choice quote in response to BPA’s policy, which was released in a document called an “Environmental Redispatch.”

“BPA really ought to call this the ‘Anti-Environmental Redispatch,’ since it makes no sense environmentally and flies in the face of the agency’s obligation under the Northwest Power Act to promote renewable electricity in the region,” commented AWEA CEO Denise Bode in a statement last week. “Yet the agency chose to ignore its statutory duties and Obama administration policies, and instead to illegally promote its own narrow economic interest over meeting its contractual obligations with private renewable energy companies.”

BPA has asked wind producers to stop producing for a period every day since May 19, sometimes multiple times a day (you can see BPA’s updates ). BPA says there’s no other option; they say pouring water over dams instead of sending it through turbines would harm salmon. The wind industry wants BPA to find another solution and is prolifically quoting a salmon protection organization that says BPA’s concern about danger to salmon is misplaced.

There’s no real resolution in sight for this conflict: both sides claim to have the greener answer, and while wind has recruited some big names like and Sen. Jeff Merkley to its side, BPA ultimately holds the switch.

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