In this episode, host Daniel Raimi talks with Pilar Thomas, a partner at Quarles & Brady and a former official in the US Departments of Justice, Interior, and Energy. Thomas describes the complex relationship that some tribes have with fossil fuels, given that Indigenous groups have been heavily involved in the Dakota Access Pipeline protests, even while some tribes—such as the Southern Ute—have historically benefited from oil and gas development and have even pursued projects off of tribal lands. With many tribes now hoping to diversify their economies beyond fossil fuels and casinos, Thomas contends that tribes can leverage their unique ability to innovate outside federal and state law and build up more renewable energy infrastructure.
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- Many tribes are involved in oil and gas development: “For the most part, tribes that have oil and gas development support it. They make a lot of money off of it. It generates government revenues for their tribal government to provide programs and services and develop their communities and develop their economies. Those tribes are very keenly aware of how important those resources are to them and continue to take advantage of them.” (6:01)
- Tribes consider renewables for economic diversification: “When I was at the Department of Energy, [we] looked very strongly at trying to diversify and working with [tribes] on doing some renewable energy projects … I think what we’ll see is more tribes—especially the tribes with lots of revenue coming off of oil and gas—taking a hard look at diversification … The pandemic is forcing a reckoning for tribes [to say], “Maybe we shouldn’t have all our eggs in the casino basket.” That, I think, will lead some tribes into an energy transition.” (15:45)
- Unique legal status of tribes could bolster energy innovation: “Tribes are in a very unique situation to take advantage of their jurisdictional authorities, and their needs to devise new products, new projects, new technologies, and new models to help themselves. I think that’s, frankly, the only way out of their energy poverty issues. Everybody else is stuck with whatever the state will let them do. The low-income community in South Los Angeles is stuck, but tribes aren’t stuck … That’s the exciting part about what tribes can do.” (32:12)
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The Full Transcript
Daniel Raimi: Hello and welcome to Resources Radio, a weekly podcast from Resources for the Future. I'm your host, Daniel Raimi. Today, we talk with Pilar Thomas, a partner at Quarles & Brady and a professor of practice at both the University of Arizona and Arizona State University. Pilar is an expert on energy development and environmental management on tribal lands and has served in the US Departments of Justice, Interior, and Energy. I'll ask Pilar about a variety of issues, including how different tribes are approaching fossil and renewable energy development, how they're preparing for the energy transition, and how they are addressing energy poverty on tribal lands. Stay with us.
Okay, Pilar Thomas, thank you so much for joining us today on Resources Radio.
Pilar Thomas: It's great to be here.
Daniel Raimi: Pilar, we're going to talk about your work on Indian energy law and tribal, environmental, and natural resource management, and I'm really fascinated for the conversation. Before we get into details, can you tell us how you ended up working on energy and environmental issues?
Pilar Thomas: It's like a lot of things that happened to me in life. I just say, "Hey, that looks really interesting. Let me go try and do that for a little while." I'm a lawyer, but the law is my second career. I had a first career in financial services, and so decided to quit, go back to law school and work for my tribe, a member of the Pascua Yaqui tribe based out of Tucson, Arizona, although we have communities all in Arizona and in California. My key interest was really to work with my tribe and other tribes around economic development opportunities. In 2005, the Energy Policy Act of 2005 got enacted, and all of a sudden, the federal government was doing things out of the Department of Energy and the Department of Interior around tribal energy and around tribal clean energy.
At the same time, here in Arizona, Governor Napolitano at that time was also very engaged with tribes around energy development opportunities. For most tribes in Arizona, their big economic endeavor is gaming. While I practiced gaming, and worked with my tribe on gaming issues and other tribes, when I looked around and saw this new, renewable energy that had the federal government working with tribes more and nobody else working on that, all I could think of was, "Well, there's a lot of sun in Arizona, and solar looks pretty cool. Why don't we all have solar panels?" I've made it my life's mission to have a solar panel on every rooftop in Indian country, because to me, solar panels should be like refrigerators. That's how I got into it.
Daniel Raimi: That's so interesting. Well, they should be like refrigerators. I imagine because everyone should have one, not because they should be cold, right?
Pilar Thomas: Everyone should have one, yeah. A pair of solar panels should be just another appliance that you have to have.
Daniel Raimi: That's really interesting. Let's talk about that work now. We're going to touch on clean energy in a couple of minutes, but first, I want to ask you to start talking about fossil energy development. As some of our listeners probably know, there are 574 federally recognized American Indian and Native Alaskan tribes. Sometimes, again from my reading of the news and opinion pieces, occasionally people will make the implicit argument that all tribes are opposed to fossil energy development, whether it's coal, oil and gas, but of course it's more complicated than that. Can you help us understand the variation in attitudes that different tribes might take towards fossil energy production on their lands?
Pilar Thomas: Yeah. I think most tribes that have oil and gas resources actually have developed those resources. A part of that is a legacy of oil and gas development on Indian lands that was really promoted by the federal government back at the turn of not this century, but the last century—so the late 1800s, early 1900s, when oil and gas was discovered on Osage Nation lands, for example, in Oklahoma, Southern Colorado, and the Ute mountains. Much of that development is promoted by the federal government itself and certainly is a way to raise revenue for tribes and for them to use their resources. That legacy investment and participation in the oil and gas industry has just remained. As long as there's paying quantities of oil, oil and gas leases will be in effect on Indian lands.
Frankly, there aren't, except for a handful or maybe one or two, tribes that have oil and gas resources and refuse to develop them. Everybody else, and there aren't that many, but it’s maybe a dozen at the most tribes that have recoverable and exploitable oil and gas deposits. Now, of course, the hydraulic fracturing technology and horizontal drilling technology has increased the recoverability of deposits or made certain deposits actually recoverable now where they weren't before, so that has extended the life of those opportunities for tribes. But I think, for the most part, tribes that have oil and gas development support it, they make a lot of money off of it, it generates for them government revenues for their tribal government to provide programs and services and develop their communities and develop their economies. Those tribes are very keenly aware of how important those resources are to them and continue to take advantage of them.
Other tribes, for example, like the Southern Ute, have expanded beyond the reservation borders to get into oil and gas development off reservation land. They've leveraged their expertise in oil and gas development and operations and now invest in offshore oil and gas development in the Gulf of Mexico. They're in pipeline distribution and pipeline ownership. They're taking advantage of the midstream part of that. You do have a handful of tribes like Southern Ute who will go out and parry their expertise out off the reservation and doing that business and engaging in that business in the non-Indian world, as we would say.
Daniel Raimi: Right. That's so interesting. Maybe to go to the other end of the spectrum for a moment and touch on the Dakota Access Pipeline (DAPL) protests, which were such a huge news story a couple of years ago and centered around environmental concerns related to the construction of the pipeline near the Standing Rock reservation, can you give us a sense of how important those protests were in terms of galvanizing different tribes from across the country to protest that pipeline? Then, in addition, what, if any lasting effects, do you think it will have or is having today?
Pilar Thomas: Well, I gave a presentation on DAPL a couple of years ago, and I titled it "DAPL Changed Everything and Nothing at All." On the one hand, there was not a uniform view of Indian country on DAPL. For example, the Mandan, Hidatsa, and Arikara Tribes of the Fort Berthold Indian Reservation—who have the largest oil and gas play for tribes in the country on the Bakken Shale—that pipeline was going to be used to move their oil products to market. There’s not a uniform view by tribes of the importance; now, there is an appreciation, certainly, of the very proximate environmental issues that the pipeline could pose to the Standing Rock Sioux tribe given its proximity to the tribe’s reservation and given its, of course, path under the tribes’ drinking water source. That's a concern that tribes across the country share with energy infrastructure, especially pipeline infrastructure.
At the same time, you had lots of stories about pipelines blowing up and spilling, huge issues associated with the people who are running DAPL and other pipeline problems. That was something that certainly nobody wants to see happen, so an easy thing for tribes to be concerned about as well as others. Certainly, it heightened awareness of some of the major environmental issues and concerns that tribes have, but it really heightened an awareness of how tribes can influence off-reservation projects that might have on reservation impacts. While nothing changed for the Trump administration, I think, for example, in the Biden administration, we're going to see a return to a more considerate incorporation of tribes in off-reservation development. There's a need to move fast.
The Biden administration, for example, is promoting lots of transmission lines that you need for lots of wind projects and solar projects. It's unclear where they're going to be on pipelines. You still got to move oil and gas around. Yeah, he obviously is not anti-oil and gas, although there's been a pause of new federal oil and gas leases. This infrastructure is still necessary. It's still probably better than putting it in trucks and driving it around or rail cars, which we've seen can be just as dangerous. It's picking your lesser evil, and that's why it really hasn't changed anything at all either. It's not stopping pipelines. It's heightened the awareness of having tribes at the table when pipelines or other infrastructure is going to affect the tribe both on and off reservation. I think this administration will have a heightened awareness—DAPL was an Army Corps decision with some influence from Interior—certainly on federal lands, pipelines and infrastructure on federal lands.
Now, with Secretary Haaland coming on board, I think there's no doubt you're going to see more tribal participation, or at least an effort to get tribal participation and tribal equities considered, so that's changed. There was, for a moment, the belief that maybe you could get the big banks to stop investing in these types of pipelines, and especially pipelines where there's a strong objection from tribes or other Indigenous communities. We'll see how that bears out. I know, certainly a lot of banks are just moving to divest anyway. I don't think DAPL is necessarily the reason for that, but I think the anti-DAPL effort to divest from the pipeline investment itself might've had some slight influence. Citibank, isn't getting out of, isn't divesting of fossil fuels because of DAPL. It's divesting because of climate change, but DAPL is certainly one of those data points in that whole bigger discussion.
Daniel Raimi: Definitely a focusing event for a lot of folks. As you just alluded to, the Biden administration earlier this year issued an executive order that halted new oil and gas leasing activities on federal lands and that didn't ban new drilling on existing leases, but it stopped the new leasing of federal lands. After a little bit of initial confusion, they clarified that the order did not apply to tribal lands. As the United States and the world move forward towards ultimately a net-zero emissions future, to what extent do you think coal, oil, and gas–producing tribes are preparing today for that future in which their resources become less viable?
Pilar Thomas: It's hard to tell. For example, Navajo, for example, has a heavy reliance on coal, and the Navajo Generating Station (NGS) has shut down. Arizona Public Service Electric (APS) announced that they're going to get out of the Four Corners Power Plant, which uses coal from Navajo lands. In fact, Navajo stood up a coal mining company. It is entitled the Navajo Transitional Energy Company. That company is charged to look at how do we get off of coal, and so it wouldn't surprise me—given that NGS has shut down, and APS is about to shut down Four Corners—that there is a heightened need for that, from that company to other parts of Navajo. The utility authority has stood up a 50-megawatt solar project; there are lots of people running around Navajo, trying to figure out how to do solar projects, especially in the area of the NGS power lines.
You'll see a tribe like Navajo start to make the transition quickly, but they're forced to make that transition. The oil and gas tribes might take the same path. We'll see. Southern Ute, on the other hand, has an investment arm that has looked at investing in renewable energy projects. They have done some smaller-scale renewable energy solar projects on their reservation, one or two megawatt projects to start to at least move the reservation itself. It wouldn't surprise me that their diversification strategy, if they stay in energy, they will diversify into renewable energy as either investments or participants in projects or as developers. There are a whole host of roles that a tribe can play, especially tribes with access to resources. By that, I mean financial resources can play in that.
I remember when I was at Department of Energy, they had looked very strongly at trying to diversify and working with people on doing some renewable energy projects because as the Bakken blew up, and everybody was moving up there, they had to get new energy infrastructure. They needed new energy sources to run those oil and gas wells, and Fort Berthold very strongly looked at: How do we get into that business? So that's a diversification method or opportunity. I think that's what we'll see is more tribes, especially the tribes with lots of revenue coming off of oil and gas, taking a hard look at diversification.
At the same time, it's like a tribe should be doing anyway, right? COVID shuts down tribal casinos for two or three months, and all of a sudden tribes look around and go, "Oh wow! Not like the Great Recession, where I might've taken a hit on who comes into my casino. Maybe I don't have as many people coming in, but I still got people coming in. Now, I got nothing coming in." I think that even the pandemic is forcing a reckoning for tribes of, "well, maybe we shouldn't have all our eggs in the casino basket," and that too is a transition that I think will lead some tribes into an energy transition, whether it's oil and gas or whether it's casino. It's a single resource curse that some tribes are trying to get out of. That's a transition issue for them with a single resource curse that hopefully they're learning some lessons from.
Daniel Raimi: Yeah. That's so interesting. That point about economic diversification regardless of what your current bedrock sector is, the importance of economic diversification, especially for rural communities, is just so important in the energy transition context.
Pilar Thomas: Yup. Yup.
Daniel Raimi: One related question as we're talking about energy transition is the issue of renewable energy development on tribal lands. You're an expert on this and, as you know, wind and solar development, there has been some development on tribal lands, but it's been relatively slow compared to, let's say, privately owned lands and compared to the amount of available wind and solar resources that tribes have technical access to. Can you help us understand a little bit why wind and solar development in particular has proceeded relatively slowly on tribal lands?
Pilar Thomas: Well, I think if you're talking about big wind and big solar, there have been your typical barriers to development. You've got to have land in the right place. You've got to have access to the transmission system to get the power to the load centers. Tribes still, of course, have those same hurdles to overcome. For the tribes that do have great resources and access to transmission, and can get to a load center, then you tend to see that development happening. The wind project down at Campo Band of Kumeyaay Indians outside of San Diego, it’s a 55-megawatt wind project. The Moapa [Southern Paiute] Solar Project outside of Las Vegas, they're literally spitting distance to substations that go straight into California and have power lines straight into California. Those were the successful solar projects. There's a handful of solar projects around Nevada and other parts of the desert around the Colorado River, where you have access to some Western Area Power Administration lines.
Navajo, certainly for example, should be able to take advantage of their two sets of transmission lines that came out of NGS. One came south into Phoenix in Tucson, the other goes west into the Lake Mead substation, so it can take them to points west into California or into Nevada. That area will get developed because you have access to transmission, which has access to a load. But if you're out in the Great Plains, while you may have some pretty decent transmission assets or resources, they've had a harder time partnering up the better wind resources with access to transmission. The more you've got to build out your lines, the harder it is to do those projects.
There's a lot of projects that are looking now—Eastern Wyoming, Eastern New Mexico—where they're just building superhighway transmission lines from there. Your high-voltage, direct current lines like SunZia or TransWest Express out of Eastern Wyoming straight to California. No starting, no stopping, don't pass go, don't collect $200, and you can't get on it because it's too expensive and you can't get off it because it's too expensive. The transmission development itself also is a huge barrier. Where are the lines planned? Who's planning them? Whose lands are they on? You got a 10 or 12-year development timeline on transmission. Virtually every tribal project that's worth its weight from a commercial standpoint lacks the transmission. That's probably the biggest big wind, big solar development.
But having said that, there is lots of stuff going on that's smaller scale. A lot of rooftop solar, a lot of community scale or community solar, one-megawatt, two-megawatt, three-megawatt projects. Those are proliferating, I think, pretty decently around Indian country. You have maybe close to 75 or 100 tribes who have done some combination of pretty decent rooftop, solar deployment on tribal housing, for example. Some of that's been helped to a great deal by organizations like GRID Alternatives, which, in the interest of full disclosure, I'm on their board, but I worked with them before I was on their board, and they started off low-income communities and tribal communities in California doing rooftop solar there. You've had the Department of Energy’s Office of Indian Energy grant program, which is relatively small, but can turn out 10-12 projects a year, a million bucks a project. You can build a pretty decent size one megawatt project that can power lots of tribal homes or a tribal campus. Now, you're starting to see more microgrids get developed.
California has been really focused on doing microgrid deployment and has explicitly included tribes in microgrid deployment efforts. There's one tribe that has two operating microgrids in northern California, Blue Lake Rancheria. Then a bunch of tribes in southern California are starting to build out. They've gotten funds from the state and from the feds to build out microgrid projects. We see the smaller-scale, more self-use mentality of “we can power ourselves, we can help ourselves, it's going to save us money because I'm not paying the utility anymore. I've got maybe more reliable power on my reservation now, because I'm making that the local grid a little bit more reliable.” That's really where you see most of the activity happening. Two tribes are commercial scale, while 75 tribes are everything else. I’d take the 75 tribes over the two tribes when it comes to saying how successful can we be at deploying renewable energy?
It's certainly more beneficial to tribal members, for example, to have solar panels on their rooftops because they're the ones paying the electric bill. You get buy-in as well from your tribal community that solar projects or small wind projects are good for the community because they see the immediate benefits if you've gotten that metering, and my bill goes to zero because the solar project is producing all my power for me versus, say, the same tribe does a 20-megawatt wind project or 50-megawatt wind project and the tribe itself will collect rent, and it might even collect some taxes, but the tribal members don't directly see the benefit from that, except however the tribal government benefits them.
There are lots of tribes that had lots of commercial-scale projects going. They're hard, they're complicated, you need tax credits so the tribe can own it. Some of those take a long time and tribal members start going, "Well, wait a minute. Where is everything? How are we going to benefit?" I've seen enough of those projects die on the vine not because tribal leadership didn't want to keep doing it or there wasn't a hard effort to get it done, but because the tribal members go, "We don't understand this. You're going to use 2,000 acres of our land to do a project and we're not seeing any benefit out of?" You have some of that resistance from tribal communities. On the other hand, you put rooftop solar on their houses and they go, "Oh! Now I understand it. I don't have a bill." That's why you started to see a movement to smaller projects as well because there is a need to make sure that the tribal membership was directly benefiting.
Daniel Raimi: Right. That's so interesting, and it plays into another question that I wanted to ask you about, which is this question of energy poverty on tribal lands. Obviously, some tribes are quite wealthy, some tribes much less so, and so for the tribes where energy poverty is a major issue, can you help us understand what some of the causes are and also how things like deploying solar on rooftops can help address the problem?
Pilar Thomas: Yeah. Some of the bigger challenges around energy poverty on tribal lands really have to do mostly with infrastructure and a lack of infrastructure investment. Lots of tribes sit, for example, in rural co-op systems. Rural cooperatives trying to keep costs down don't always stay up to date on the latest grid technology. They, for example, don't always invest in their grid mechanisms, and so there are a lot of tribes sitting in those systems who have very unreliable power. That, to me, is an energy poverty issue. Just the same as tribes that aren't electrified at all or parts of tribal reservations that don't have power at all. Whether it's no grid or a poor grid, that creates, to me, an energy poverty challenge. I don't have access to reliable, affordable energy. If I don't have access to reliable and affordable energy, I've got an energy equity issue.
What can tribes do to mitigate that energy poverty, that energy equity issue? I think, as I was saying in my last comments about rooftop solar, community-scale solar, using their own renewable energy resources or even their natural gas resources, a lot of tribes that have natural gas where it may not make sense to try and develop it commercially because you don't have enough of it and the infrastructure to get it to market is too great, but it doesn't mean I can't produce natural gas and use it myself. All I need is a small little cleanup technology, a compressor station, and I can put it in some tanks and run it around town. It's not even just clean energy. There are a lot of tribes with their own resources that if they use them, whether it's biomass resources that I can turn into wood chips or that I can gasify and turn into power, or whether it's the sun or the wind, or I've got water, there's lots of opportunities to use our own resources to power and heat and transport ourselves.
To the extent that we, Indian country, have been relying on others to do that for us, that will, in many cases, result in energy poverty or energy inequity, because others look at it as a business and say, "Well, I can't make any money on selling power to the tribe or paying to keep the grid updated, so I'm not going to invest in grid updates." Or you might have investor-owned utilities (IOU), who look at everybody as a ratepayer and will invest in those parts of their infrastructure where the ratepayers are going to pay their bills.
Daniel Raimi: Right. IOUs just, sorry to interrupt, but IOUs being investor-owned utilities.
Pilar Thomas: Sorry. Right, sorry.
Daniel Raimi: Acronym alert.
Pilar Thomas: Sorry. When the market is controlling, whether it's a regulated market or an open market, it’s looking at it from their perspective. Lots of Indian country is not going to fit the bill for them on where they want to invest. What can tribes do to invest in themselves and to use power for themselves to overcome these energy poverty, energy equity issues? I think that's why there’s more focus on smaller projects, using your resources for yourself, trying to find methods and trying to find models for doing that, public-private partnership models, for example, where you can bring some additional resources to the table, especially financial resources. The grant program might give you a couple of hundred thousand, maybe a million bucks, but if I've got a $20-million project, then I've got to go find the rest of the money. How can I incentivize public-private partnerships to do that?
I think tribes could lead the way because of their governmental status and their jurisdictional status and their ability to innovate outside of federal or state law, because remember, the energy industry is all controlled by federal or state law, and mostly state law. If the state of Arizona wants to keep its head in the sand about distributed energy development, then tribes can lead the way in Arizona around distributed energy technologies and innovation, whether it's models, whether it's mechanisms, whether it's technology, because they don't have to worry about what the state law says. That's the other opportunity here around energy poverty is that as long as tribes continue to over-rely on utilities who are stuck in state law models or old Rural Electrification Act models, then tribes aren't going to be able to overcome energy poverty. They're going to have to take the bull by the horns, so to speak, and start to move on their own to use their own resources.
Frankly, I think that's the only way out of that issue. I don't see people like the rural electric co-ops and I'm sure there's some of them listening here, who are going to lead the way on this. They have had an allergy for lots of reasons. They're getting better, don't get me wrong. Lots of stuff they're doing around community solar and other renewable energy efforts, but they've really been slow on the uptake. The utilities, of course, fight everything because all they see is lost revenue. Tribes are in a very unique situation to take advantage of their sovereign authorities, their jurisdictional authorities, and their needs to devise innovation, new products, new projects, new technologies, new models to help themselves. I think that's, to me, frankly, the only way out of their energy poverty issues. Everybody else is stuck with whatever the state will let them do.
The low-income community in South Los Angeles is stuck, but tribes aren't stuck. They don't have to be stuck. That's the exciting part about what tribes can do with respect to that. Well, exciting to me.
Daniel Raimi: Yeah. Well, exciting to me, too, and I imagine to our listeners, as well. Well, there are many more exciting things that I could ask you about and wish I had time to ask you about, but they'll have to wait for another day. Let's go now to our Top of the Stack segments, asking you what you've read or watched or heard recently that is related to the environment, even if tangentially, that you think is great. I will just recommend very briefly a data source, because I know we've got plenty of data nerds like me listening to the podcast. If you're interested in this issue of tribal energy access, one really nifty tool is from the National Renewable Energy Laboratory. They have this online mapping tool called the Tribal Energy Atlas, which gives you an interactive map of all the renewable energy resources on tribal lands.
Now, of course, access to resources isn't the same thing as access to harnessing those resources, and that's what we've been talking about with Pilar, but it is a really interesting mapping tool to help you understand at least some of the dynamics at play on different reservations around the country. But now, I'll turn it over to you, Pilar, what's on the top of your literal or metaphorical reading stack?
Pilar Thomas: Well, I read everything that Wood Mackenzie puts out. Maybe that's a plug.
Daniel Raimi: That's okay, yeah.
Pilar Thomas: I will read just about anything from them. As a lawyer, I'm following all the legal rags, so anything that talks about renewable energy law, any legal issues associated with this new energy environment, I constantly, well for the lawyer in me, want to read about. If I want to try and understand broader trends, which when I talked to tribes and tribal leadership about what's happening I always put it in the context of broader trends, and this was maybe part of my Department of Energy training. The goal of the Department of Energy is to look around the corner. I'm always trying to figure out, "Well, what's around the corner? Where are things headed?" Indian country is always lagging behind, and so there's no sense in going down a path that everybody has abandoned.
Where is everybody else? How can we leverage either other people's experiences or other people's pains? I will read just about anything from Lawrence Berkeley National Laboratory. They do a lot of studies, some direct studies of utility models and distributed energy from an economic perspective. If you want to understand what's going on with rates and impacts on rates, which is almost always the number one objection to promoting more distributed energy is, well, you're going to shift costs from these people to those people. I'm always constantly looking to see what Lawrence Berkeley has put out around the utility industry and rates and what they're learning and what people are learning about this. I certainly will also take a look at the National Renewable Energy Laboratory. We used to have the National Renewable Energy Laboratory do all our work for us, and they still do a lot of work for Indian energy, so they're pretty reliable.
On the engineering side, I'm always looking at Sandia National Laboratories. I tend to go to the government agencies just simply because they don't have any skin in the game. Their job is to be as objective and informative as possible. They're not getting paid by advertisers or sponsors or somebody other than the other than you, the taxpayer. I try to go to the most objective resources that I can who can do a good job of explaining what's going on and why things are happening the way they're happening. That's the energy nerd in me.
Daniel Raimi: That's great and really fascinating recommendations, lots of reading for our listeners to catch up on. Pilar Thomas, once again, thank you so much for joining us today on Resources Radio. We really appreciate it.
Pilar Thomas: I appreciate the time, thank you. Thank you for the invitation. Great to talk to you guys.
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