Bill Loveless talks with Richard Nephew, a Senior Research Scholar at CGEP and the lead sanctions expert for the U.S. team negotiating the Iran nuclear deal, on a new episode of Columbia Energy Exchange. Richard is the author of a new book from Columbia University Press, The Art of Sanctions: A View From the Field, which outlines key concepts and guidelines for developing sanctions and interpreting targets’ responses to them.
Among many topics Bill and Richard discuss, several include: insights from Richard's new book and how to effectively design and employ sanctions; the future of the Iran Nuclear Deal; whether U.S. sanctions on North Korea are working; how energy interests factor in to U.S. sanctions policy; and the outlook for future sanctions on Russia.
View the full transcript
Bill Loveless (interviewer): Hello and welcome to the Columbia Energy Exchange, a weekly podcast from the center on global energy policy at Columbia University. From Washington, I’m Bill Loveless. Before we get to today’s episode, a program note. This will be our last conversation in 2017 as we prepare to take a break for the holiday season. But we’ll be back again on January 1st with a new episode. In the mean time, we wish all our listeners happy holidays and thank you for tuning into the Columbia Energy Exchange.
Now, on to today’s program. Our guest is Richard Nephew, a senior research scholar at the center and the author of a new book from Columbia university press called “The Art of Sanctions -- A View From the Field.” This book is truly a view from the field as Richard was the lead sanctions expert for the U.S. team negotiating with Iran in 2013 and 2014. In fact, before joining the center, he spent more than 10 years in the U.S. government as director for Iran of the national Security Council and deputy coordinator for sanctions policy at the state department.
Now in his new book, Richard offers guidelines for developing and applying sanctions drawing on U.S. experience in recent years. And it couldn’t be more timely with tensions over Iran, North Korea, Russia and Venezuela drawing even more attention to the sanctions decisions of the U.S and other countries and the significance of energy trade and shaping these policies. Richard and I caught up at the National Press Club Library in Washington.
Richard Nephew, welcome to the Columbia Energy Exchange again.
Richard Nephew (Interviewee): Thank you. Thank you for having me.
Interviewer: It’s good to have you back. Sanctions is so much in the news these days, it’s a very important point of discussion as we look at the United State policy ongoing with Iran, with North Korea, Russia, Venezuela. And your book, The Art of Sanctions comes at a -- it’s very timely. This discussion comes I think at a very important time to help us understand better what are sanctions and how governments use them and what's the most effective way to use them or not. But I’d like to start with simply having you describe your role in the United States government regarding sanctions policy, especially when it comes to Iran.
Interviewee: I started off working in the U.S. government on nuclear proliferation issues and ways of preventing at the department of energy. And overtime, one of the ways that we were seeking to prevent Iran from acquiring nuclear weapons was through the use of sanctions. So, I came into it as it were through the backdoor of nuclear proliferation. But, but the tie 2011 had rolled on, we had spent a lot of time investing in sanctions, but hadn’t really broadened them to the economic sectors in a major way.
And that’s when I was asked to come to the national Security Council -- President Obama’s White House to help orchestrate a strategy of really applying more aggressive economic sanctions against Iran. And then I had finished up my term in government as the deputy sanctions coordinator for the state department where our responsibilities for sanctions were broad across all the various different sanctions programs.
Interviewer: But you were on Iran, you were the sanctions expert for the team lead by Secretary of State, John Kerry working on the negotiations with Iran on the treaty.
Interviewee: Yeah, that’s right. So, I was asked in part because I was familiar with the secret talks process that it started from my time at the National Security Council. I was asked to join first that process to have an initial agreement with Iran and to the joint plan of action by November 2013. And that naturally then progressed to a role as the lead sanctions expert for the broader -- national sanctions discussion with Iranians from 2013 until I left government in January 2015.
Interviewer: But let’s talk about the book. You say for sanctions to work, one must actually know ones enemy better than the enemy knows itself. So, for the United States, has that been the case with Iran, with Iraq, with Russia?
Interviewee: I think we’re getting better. And I think we’re starting to apply regional expertise and financial expertise and subject matter expertise in a much more effective way. But, I certainly don’t think that’s where we started. I think most U.S. sanctions programs prior to the last 10 years or so relied on fairly thin veneer of understanding of what was relevant and what was important to the countries in question.
And the tool itself ended up being either very, very narrow and very -- kind of ineffectual, focused on things that were much less germane to the country in question were so broad, like in the Iraq example where you don’t need a lot of expertise because you're just showing off an entire country’s economy from the outside world. So, as sanctions have been forced to be more targeted and more efficient and more effective, part of the outcome of Iraq was that the broader sanctions were just wasteful and a humanitarian disaster.
You’ve had to get smarter and more efficient about how you're doing -- which naturally that argues for more effective tapping into regional, country expertise as well as subject matter expertise.
Interviewer: Because, you say that sanctions will likely remain an art form. I find that interesting in your book. They require flexibility, adaptability, intuition, what did you mean by that?
Interviewee: So, this is the -- the flipside of the understanding of the country is having to be very careful about how you apply sanctions to make sure that you're being efficient and effective. But you don’t really know before you start. There's any number of circumstances that can come into play that change the original opinion about what was going to happen and this is in large part because the other side gets about -- it is attempting to evade your sanctions, it’s attempting to refute them.
And so for sanctions to be effective, you really do have to have someone responsible for them that is able to anticipate what an adversary will do, but also respond to it and respond to it in a fairly swift footed manner.
Interviewer: Well, I know you mentioned of a case of Iraq, the United States approach didn’t work. It didn’t work well as we saw. What was the mistake that was made there and how did that experience compare with say, Iran when you began to work on the sanctions policy involving that country?
Interviewee: Yeah, I think our mistake was twofold. First, it was that, we didn’t appreciate the degree to which we had applied such sanctions that there was nowhere for them to go. We had put the max amount of pressure on Saddam Hussein within a couple of days of the invasion of Iraq, rather the invasion of Kuwait. And so it wasn’t in a position really in the international perspective to ratchet up as he did certain things. It was just simply one massive sanction that was already in place.
And that made it much more difficult for the international community to register its concern with Hussein, but also to reward him and to change the character of the sanctions regime so that it could be responsive to the situation on the ground, both good and bad. The second problem is we had a very confused set of objectives for the sanctions. And no one was really sure what we were trying to do and when we could declare a victory.
From every practical perspective, the sanctions actually worked magnificently. They prevented Iraq from reconstituting its weapons of mass destruction programs as well as to threaten its neighbors which was a key aspect of sanctions. But for many observers, the only satisfactory outcome was Saddam Hussein being toppled. And I don’t think that set of objective was shared internationally. They may not even have been shared within the United States.
The result of course was that when the Bush administration decided to invade Iraq, there was widespread international objections to it. There was confusion as to what the outcome that we actually sought through the entire effort was intended to be and there was a disagreement therefore about how effective or efficient sanction had actually been and whether or not they needed to stay.
Interviewer: And so, then when you began to work on Iran or when the United States began to work on Iran, did they take that history with Iraq and sanctions and study it and see what lessons could be learned in working with the other countries, the P5 Nations to try to strike a deal with Iran?
Interviewee: Not at first. I mean I think the funny thing is that we got to a much more efficient way and targeted way of applying sanctions against Iran because we couldn’t get international support for broad sweeping sorts of sanctions. I think if the bush administration had been able to deliver oil embargo on Iran in 2004, they would have done it. And we wouldn’t have had a careful methodical increase of sanctions pressure. It was the international environment that forced it upon us.
But in some ways, that can be helpful for imagination because it lead the treasury department to think of new ways in which we could apply sanctions that would minimize some of the unintended consequences for the population as well as permit a strategy to be developed that would increase international support for the effort. We were forced to work with the international atomic energy agency to demonstrate that Iran was up to no good, but also meant that our sanctions a posture, had a lot more support internationally, it had more resilience as Iran duct and weaved Iran international response.
So, from that perspective it may not have been where we started. But I think it was advantageous to us in the long run.
Interviewer: What you say of the Iran deal that it was effective. Obviously you worked on it, you were a key player in the negotiation of that agreement. And you say it’s effective because it put a break on to Iran’s nuclear program, though it didn’t address the ballistic missiles that Iran has been developing or its support for groups that threaten the stability of other countries. What makes the Iran deal effective?
Interviewee: I think it’s a couple of things. I mean on its face, the nuclear provisions are effective because you’ve got very aggressive verification or a transparency tools in place. So, it allows you to check that the commitments Iran has made is actually fulfilling. But, I think the second piece is that we leveraged something that Iran desperately wanted which was sanctions relief or something that we desperately wanted.
And so from that perspective, what was I think so important about the agreement is that it used every bit of these natural self interest to try and make an agreement that would have some staying power. And I think that you can even see that in the Trump administration’s approach to this day. There’s no question the president opposes the nuclear agreement; thinks it’s the worst deal ever amongst many worst deals ever.
But at the end of the day, the deal remains in place I think because the U.S. government hasn’t been able to answer a very simple question. How do we get the same nuclear benefits without the JCPOA? And until they’ve come to that kind of answer, I think they're going to feel that it’s better to stay with it than not. And that I think is the same thing that’s keeping the Iranians onsite as well.
So, everyone’s self interest is I think pushing them to agree to stay with the JCPOA even if there isn’t a lot of satisfaction with it.
Interviewer: You don’t think there are many other options?
Interviewee: No. I think that the idea of sanctioning Iran until it gives up more is implausible and I think it pushes back on what Iran’s positions have been. And I think that the Iranian’s themselves have got plenty of ways of putting pressure on the United States by refusing to go along with any renegotiation effort. So, I think that -- at this point, it’s better to stay in it and to see whether or not we can improve up on it in the long run than to try and threaten them with any kind of actions from the outside.
Interviewer: But what would it mean for the U.S. sanctions policy if Washington, if the Trump administration were to walk away from the deal?
Interviewee: I think beyond the specific Iran and regional issues which would be generated, those are I think quite significant and quite profound. I think the larger problem is it would damage the U.S. ability to use sanctions into the future. The idea of sanctions is that they are premised on it. You impose costs until you get policy change and then you relieve those costs. And it’s that quid pro quo that is really so important to sustaining the use of sanctions as an international tool.
If you didn’t have that, you would have a number of countries around the world saying so why are we signing on to this initiative, what are you intending to get out of it, don’t you intend to abate and switch the, fill in the blank, Venezuelans, Russians, anyone else that you might choose to sanction if you do what you did with regard to Iran. And that’s to say nothing of other hotspots like North Koreas. So…
Interviewer: I was going to say, and that very question is arisen, right, in the case of North Korea -- you know, some would argue that what is in it for North Korea to get into sanctions discussion with the United States at the same time as Washington is resisting the Iran sanctions.
Interviewee: Yeah. I think to me, it’s beyond that as well. It goes to the longevity of any kind of agreement outside of an administration. If U.S. foreign policy is going to flip 180 degrees every time there is a presidential election, then I think that is going to call in the question our ability to negotiate any kind of international agreements. There’s always going to be changes. And I think elections do have consequences, presidents are entitled to run on their foreign policy.
But, I think that particularly in cases involving sanctions relief, it doesn’t just damage the ability to conclude agreements and to have agreements walked out of. But it also damages your ability to have multi year strategies that use sanctions as a tool.
Interviewer: Let’s talk about North Korea. I mean is there any points in applying more sanctions to North Korea at this point?
Interviewee: I think there is, but it’s not with regards to the nuclear program. I’ve become convinced that we are not going to get the North Koreans to give up nuclear weapons or to give up their ballistic missile program. I think they pursue these activities for a reason. We might have shifted their security calculus a long time ago. But we’re past that now. And I think that if you're a North Korean strategist and you're talking to the boss right now and he says, so, how do I protect my country? Do you think I’m better off without these nuclear weapons? I think you have to say no.
The question now is whether or not the U.S. would invade if they do have nuclear weapons or conventional artillery pointed at Seoul. So, I think from my perspective, sanctions may have outlived their usefulness in terms of putting pressure on North Korea to denuclearize. That doesn’t mean they can't be used to try and arrest North Korea’s nuclear program through arms control arrangements or they can't be used to deal with other problems, like even rights where I think there is still some utility. But this idea of just sanctioning North Korea until it gives up nuclear weapons at this point, I think is past us.
Interviewer: Well, outside of North Korea, Russia is under the most pressure now from sanctions. What impact of sanction had on Russia, its leadership and its industries?
Interviewee: I think sanctions have definitely put a crimp on Russia -- were certainly effective in 2014 in putting a lot of pressure on the Russian economy, you know, taken in combination with the collapse in oil prices, it was a one two punch where Russians weren’t in a position to sell a lot of oil to make a lot of money, but they also weren’t able to get a lot of debt and be able to deal with the shortfall that way. So, from that perspective, I think they’ve been effective in applying economic pain on Russia and main Russian economic actors, spanks -- but also on Russian oligarchs.
Now that said, it’s not been sufficient to be able to push the Russians at a _____ [00:16:28] and I don’t think frankly it ever was going to be. To me, I think the question now -- the degree to which Russia believes that the status quo is going to persist or not persist, get worse if they don’t make some sort of resolution in Eastern Ukraine which thus far has not really been manifested. So, to that end, I think the Russians are feeling the pinch. I think they're feeling that they are constrained in many ways, but it’s not been sufficient.
Interviewer: You know, energy often enters the picture here and all of these discussions on sanctions, especially when you talk about Russia or Iran, in the case of Russia, it seems as though they’ve looked for alternatives, right, since the sanctions have been imposed by the U.S and the European union. We seem them turning -- looking increasingly to China.
I read just the other day where there’s an LNG project, the Yamal LNG project in the Arctic and Russia that has received substantial assistance, financial assistance from China and effectively helped the Russians work around sanctions in terms of getting financing. I mean to what extent does the potential for Russia to pivot make it more difficult to continue to apply sanctions that are based on energy?
Interviewee: It absolutely does, but this is part of the reason why I said in the book that you have to have sanctions where it’s flexible and adaptable because it’s a little bit like pouring water on to a table. If there are any holes, water is going to find a way through. And I think one of the preconceived notions about sanctions is that the U.S. or major international partners apply sanctions. And that means that money or that activity is just frozen for all time and there's’ no way for it to get unencumbered. That’s of course not the case.
And there are many of ways between smuggling, invasion or just finding new business partners in which sanction parties can try and find a way out. So to me, it’s less of an issue of -- is that going to happen because yes, it absolutely is going to happen. It’s about what we do when it does happen. And whether or not you can enlist international partners to prevent some of that backfilling and some of that spillage out of the sanction cordoned area, to that I don’t think we’ve done a very good job of that at all in last year.
I think that the Trump administration has made pretty clear it doesn’t intend on enforced Russia sanctions seriously. And so from that perspective, yeah, it’s absolutely very difficult to try and police that up. It doesn’t necessarily have to be that way. And I think a different approach to sanctions enforcement could certainly have precluded -- some of those steps already have been taken place -- any ones to come in the future.
Interviewer: So, it’s a work in progress. Sanctions are a work in progress.
Interviewee: Oh yes.
Interviewer: You need to continue to stay on top of them. You need to make adjustments, tweak them.
Interviewee: Yeah, I’ve often compared to them a shark. A shark has to keep swimming, otherwise oxygen doesn’t come in. It’s the same thing with sanctions. If you just leave them in place as they are, you have to assume that your opposite numbers are irretrievably stupid or not interested in their own self interest that they wouldn’t try and find ways around. I don’t think it’s ever been the case.
Interviewer: I want to get back to the round again -- the potential implications of the Trump administration’s position, to resistance to the agreement and potentially it’s maybe a decision down the road to pull out of it. What effect does that have if the U.S. were to turn its back on this agreement, what impact would it have, not only on Iran, but I mean also on other countries that are looking to begin to work with Iran, to begin to do business deals with Iran?
Interviewee: I mean the sanctions that were turned off as a result of the nuclear agreement were all about foreigners doing business with foreigners, from a U.S. perspective. U.S. embargo has never touched really, aside from very minor things dealing with food items, carpets and simple aviations imports. So, from that perspective, if we were to walk away from the JCPOA, we would have to by our very nature of our sanctions start targeting foreign business interest in Iran which means going after energy sector companies primarily, but also industries and banks that are starting to nose around inside of the country.
So what that means is, one of really two things happens. Either they stop doing business in Iran which case they suffer some consequences especially if they didn’t set up their contracts right and the Iranians were able to claim damages or they persist in doing business with Iran and then the U.S. is faced in a choice doing imposed sanctions against major international energy firms or do we let them do what they want to do and then our sanctions look rather foolish and lose a lot of credibility internationally.
And so it’s -- really it’s not just one decision that has to be made by the Trump administration. I think they need to make two. One is what do we want to do about this JCPOA and two, do we feel comfortable with dropping the hammer on a lot of companies including those with substantial interests in the United States if we don’t get what we want.
Interviewer: You know, their Total, the French oil and gas major -- its CEO said the other day that they would have to review the terms of an Iran gas project if the U.S. were to impose unilateral sanction on Tehran given Total’s assets in the United States. So, I mean is it fair to say that for some countries, this is worrisome right now in terms of what they may have to do or not do?
Interviewee: Yeah. No, I think it is. I mean look, if you invest substantial money into Iran and then you have the four move underneath you, you have to recalibrate what you're doing. And I think even more importantly if the United States is willing to move so dramatically against an agreement it signed, in one place, if you're a foreign energy company, you’ve got to be looking at a number of other different situations in which U.S. sanctions could also potentially be in the offering and start to question what is the U.S. going to do here, what is the U.S. going to do there.
So, I think part of the result of all this is going to be a confrontation between the United States government and other governments. It’s hard for me to see the French government in particular taking the Trump administration’s decision like that lying down. I think they’ll want to respond. And there are instruments in European Law to do so including by imposing penalties on the U.S. and U.S. companies. So, this isn’t just an issue of one company’s investment into a problematic place.
It is potentially a broader discussion that will need to be had about U.S. investment decisions about where our companies are invested and what their risks are if we start taking action in these areas.
Interviewer: It’s interesting. You mentioned banking before. And I was listening the other day to an event up at the center on Global Energy Policy on your new book and Jackie Shire, a former member on the UN panel on experts on Iran said that banks are the tip of the spear for sanctions. And she suggested that policy makers those working on sanctions get to know that better, learn more about the implications for banks. I mean would you agree with that?
Interviewee: No, I very much agree on that. I actually think that the last 10, 15 years have opened a lot of policy makers’ eyes to the degree which they don’t understand some of the industries that they're potentially targeting with sanctions. And I think one of the nice things that I’ve started noticing is that a lot of former sanctions, officials at the treasury department and state department are now spending some time in academia.
They're spending time with consulting firms and they're spending time at banks and industry. I think that’s useful to the extent that they can bring that kind of advice and that kind of knowledge back into the government. I that it will help to make decisions a little bit more responsive to the industries that are in question, not to covet out of their interest, but at least be aware of them and to be able to calibrate some of the decisions that are being reached.
But I don’t think that’s a place where that needs to stop. I think that we need to have a broader review of how sanctions decisions are made in the United States. And I it needs to start with some analysis about the industries both at home and abroad that will be affected by sanctions decision. We should look at things like sanctions impact statements, just like you would have environmental impact statements before you start taking some of these decisions as well as other types of regulatory rules, reform and draft procedure.
So, to me I think that this speaks to a broader issue and a broader interest on the part of the U.S. government which is to make itself smarter on all the industries that are affected by sanctions decisions.
Interviewer: Do you think there’s any risk of a flight from the dollar?
Interviewee: Yeah. I mean I think flight from the dollar, but even lesser manifestations of that, de-risking behavior in general. The number of banks that might look at New York and say, you know, we don’t need to have a lot of assets here. Maybe, we don’t want to find ourselves so subject to New York financial regulators. Maybe we need to diversify our risk and the same thing with companies in terms of their structures and how they operate with the U.S and within the U.S.
I think there is a very high likelihood that we’re going to see a much more multi polar global economy in the future which is going to have its own pressures on who does what to whom and where. But I think that we’re not helping ourselves by making the U.S. economy more difficult and cumbersome to work with.
Interviewer: In Venezuela, the president Nicolás Maduro is announced his plans for digital currency, crypto currency called Petro to get around some of these financial restrictions and sanctions. But yeah, there’s some talks in maybe some other countries over time might consider something like that. I mean does that then add still another complication to policy makers looking at sanctions and considering their financial impact?
Interviewee: Yeah, absolutely. Crypto currencies are a big question mark when it comes to sanctions enforcement because the end of the day, a lot of what we’re still about is applying pressure on governments to make policy changes. And it gets a little sticky, gets a little different if you don’t have those kinds of more traditional financial systems. But I think there is maybe an exaggerated amount of pressure here and difficulty here. At the end of the day, this is what we’ve seen with Bitcoin and other things.
There are a very few goods that you can buy with Bitcoin straight out, right. If you try to go and buy a taco, you're going to need to translate that into dollars at some point. I think from that perspective, it suggests that there are still going to be interactions with the traditional financial system that I think are going to create an opportunity for sanctions pressure points. That doesn’t mean that we don’t need to be adaptable and look at the way in which things may change because they may change rapidly on this.
But I do think that we might be overestimating the degree which some of the more traditional approaches to banking and finance and the movement of money and value are going to change.
Interviewer: You know, back at the topic of energy, does the increase in oil and natural gas production in the United States provide Washington with more leverage in promoting -- developing, promoting and enforcing sanctions, especially when they apply to a country’s oil exports, say Iran?
Interviewee: So -- I think they could, or it might not too -- in Russia too because there’s a lot of discussion over supplying Europe with natural gas. And we’ve got a lot of it here too. Yeah, yeah -- I think it certainly could play a role here. The problem is U.S. has traditionally been pretty bad at doing export promotion when it comes to things like energy. It’s just not something that we typically do well, especially not in coordination with other foreign policy issues.
It’s something that Hilary Clinton noted when she was the Secretary of State that we’ve not done a great job on and she actually pushed it as part of the new diplomatic review that she established.
Interviewer: And the Trump administration has made it an issue as well, I mean an advocacy issue for itself to promote the export of LNG in particular.
Interviewee: Yeah. And the problem that comes along with that -- because it all makes sense and I’ll even say that for the Trump administration too. I think it’s a sensible kind of thing to do, to advance you to this industry. The problem with it comes just as we’re seeing right now with Russia which is that by pushing U.S. natural gas exports, the questions that might come up -- so you're trying to put pressure on Russia because of Russia and bad things that the Russian government is doing or are you doing it just because you want to make some money?
I think that mixing of motivations is somewhat problematic with respect to U.S. foreign policy. Certainly, it requires a transition. You don’t think about other country’s governments as having policy ambitions that don’t involve their economic interest, you wouldn’t think about China or France. But we traditionally, at least try to present that sort of image. So, I think that makes that more difficult. Coming back to your core question of does our energy abundance make it easier to apply sanctions, I think to some extent it does that we now have got another supply that potentially could be tapped into.
But to me, it’ a broader issue of are there non-volatile country supplies out there. In the case for instance Iran, we didn’t anticipate that we had a lot of shale oil that was coming on that was going to help make up the market offset losses for Iran, it just so happened that that was in fact the case. And it made it easier to swallow Iran sanctions. To me, that’s where the U.S. energy abundance comes from is it just puts more supply on the markets such that there is no one particular place where a shortfall can be that damaging, especially from sanctions.
Interviewer: And that would apply as well in the case of Venezuela.
Interviewee: Yeah. Absolutely. No, I think the more places you have where they can put energy on the market such that we’re not dependant on any one particular single point failure, to me that’s an efficient engineering system regardless.
Interviewer: Richard, what should we be looking for now and the coming weeks?
Interviewee: Well, I think a couple of things. First with regard to Russia sanctions, we’ve not heard the end of the story. The political incidents in Washington definitely are going to be pushing more Russia sanctions from congress. I think the fact the Trump administration hasn’t done much with the sanctions that it has is only going to help that. So, I think you should expect to see there to be introduced in congress, new sanctions against Russia and against Russian energy that are going to be pushed by democrats, but also by republicans throughout 2018.
I think you might see that come do ahead in early summer as people are looking to close out votes before they go off to their district to get reelected. I think with regard to Iran, there is a reasonable chance that the waivers that allow sanction rates to flow will be canceled in January. They're up for reauthorization around the 12th or 13th of January. But I think more than likely, they're going to stick around through at least the first couple of months of 2018 because the Trump administration doesn’t yet know what to do with the fact that the decision in October was agreed with a whole lot of congressional response.
So, I think from that perspective, we’re still a little bit up in the air as to how Trump intends to respond to that.
Interviewer: Well, there’s a lot to be watching in these weeks ahead on a number of fronts, both Iran, Russia, North Korea and perhaps some other countries as well. So Richard, again, thank you very much for being here on the Columbia Energy Exchange.
Interviewee: Thank you very much for having me.
Interviewer: Once again, Richard’s book is “The Art of Sanctions: A View From the Field,” published by Columbia University Press and part of the Center on Global Energy Policy series. For the Columbia Energy Exchange, I’m Bill Loveless with a reminder that this is our last episode of 2017 as we take a break for the holidays. But we’ll be back on January 1st. For now, season’s greetings to all.