Which of the following people is considered highly compensated for the $2024$ plan year?

a$.$ Rachel, a $1\%$ owner who earns $$80,000$ per year.

b$.$ Phoebe, who earned $$195,000$ last year and is the ${40}^{th}$ highest paid employee of $100$ employees.

c$.$ Ross, a $20\%$ owner who earns $$24,000$ per year.

d$.$ Joey, a $4\%$ owner who earns $$45,000$ per year.