So they're being informed present center parent is out sick today Let's get started as we have plenty of work to do this morning. So I wanted to welcome to the committee Messers Chapman Schwer and Redmond. Thank you gentlemen coming in You were saying you well the three of you and you're just gonna we don't need to do it in sequence However, you want to use the time, you know the agenda. We want to go through. There's a lot of PFAS work We want to check in on right. So there's a lot of work we're going to try and inform the committee of in a relatively short period of time We sort of switched back and forth. So we thought it'd be better since we're setting sort of together here anyway to just Talk to you from here So for the record match at the general council from the agency and natural resources So I'm just going to give a brief overview of what you told us we needed to do last year And sort of of where we're at so Last year you passed act 21, which basically did a number of significant things It required sampling of it both sat set an interim standard for five PFAS compounds It's 20 parts per trillion It's required sampling of all public community water systems and non transient non community water systems Which are basically your traditional of what you think of as a water system But also schools condominium associations places where where people stay and drink the same water for extended periods of time And that total population In terms of number of systems approximately 590 systems So then you also require that the agency adopt an mcl for the five PFAS compounds develop a plan to For how we might regulate water quality standards with respect to PFAS and then develop a An inspect or a a statewide monitoring plan for PFAS in the environment So just sort of next lecture So just to give you a this is sort of an overview of what we did with respect to the Sampling plan so we were focused on sampling in public community water or public water supply systems We do limited amount of surface water sampling We tested Landfill leachated all of the line landfills in the state We did a significant cross-section of wastewater treatment facilities looking at both the influent the affluent of those systems And then we looked at electroplating and car washes as to Sort of high priority industrial activities. So next up. I asked what's the electroplating We're like the chrome finishes Vehicles, right? Okay, thank you. I have a product And wastewater treatment facilities that was influent affluent and the new sludge Did we also look by legend? So what and we'll get into more detail on what the results were with each of those Okay for the record, brian redmond. I'm the director for the drinking water and groundwater protection division in dbc I'm going to cover briefly the results of the Monitoring at the public water systems as required under act 21 This first pie chart is showing The results at the water systems themselves As I just stated earlier, there's approximately 590 Water systems that have tested under act 21 In addition to that we've required testing of out-of-state bottled water that's approved to for sale in vermont And that that testing is is ongoing. We've established a slightly Later deadline for the receipt of those samples Oh June if you could just go back real quick. What this pie chart is is saying is 505 Water systems that sampled were the results were non-detect So overall, uh, we were we were pleased that our caseload Was was not as significant as it could be With that said the next piece of pie there the 85 are the number of water systems where we saw detections of One of the 18 p-fast compounds Under the act the act directed us to sample For the maximum number of p-fast compounds possible That's more than the regulated five in vermont There's a total of 18 compounds that are analyzed under epa method 5 37.1 So that 85 represents 85 water systems where we found at least a detection of one of the 18 compounds analyzed under the method The 55 represents the number of detections that we saw Under epa 5 37.1 of the regulated five compounds. We had 55 water systems in the state That had a detection of one of the five regulated compounds The smallest slice of five is The number of samples that a number of water systems where results are pending We had very high rates of compliance with the monitoring required under the act We believe two of those five That the lab results are still pending and we're working with the other three water systems to gain compliance with the requirements So just a tremendous Rate of compliance more than we typically see What's the low threshold for non-metallic? The minimum reporting levels two nanograms per liter or two parts per trillion The four are the impacted public drinking water systems you can go to the next slide June We had four systems that exceeded The interim 20 parts per trillion standard and are placed on the do not drink notice Those are the not holly school that that for the academy the killings in mountain school in the fiddlehead condominiums those Each of those four water systems have followed the mandate of issuing the do not drink and have provided users with bottled water in the interim emergency response Each of the four entities have engaged the services of a consulting engineer and are currently working on both short and long-term solutions for their water supply We're still waiting for the engineering analysis in most of the cases in general the agencies Alternative where feasible is finding a source of clean water that could be Drilling a new water supply source that could be improving the existing well or connecting on to a different well Let us test it clean. Where's kids in the country? That is a daycare in dober Okay, the reason for the asterisks there is their initial result was exceeded the 20 parts per trillion The act requires confirmation of that the mean of those two samples drop below the 20 parts per trillion So we have required that the issue public notice letting new users know Of the situation and they're on increased monitoring Are you in a position yet to see what's going on these places or you're still doing the engineering So, I mean, I think what you're looking at is for the sort of what is the source of PFAS I think it's fair to say that there's no obvious source that we've looked and the investigations are ongoing Another item in in the realm of public drinking water under the act is establishing a maximum contaminant level for PFAS The agency has filed a proposed final rule with el car. I believe it's on the agenda for the committee on february 20th The revised rule sets the maximum contaminant level at that's at the same as the interim standard And it's a lot of health advice we have 20 parts per trillion for the regulated five compounds Established as a maximum contaminant level goal of zero We require it within the rule we require EPA method 537 or an alternate as approved by the secretary There already is new EPA methods That have that have been released since the time we filed the rule One of the big is the ongoing monitoring framework for public drinking water systems So the rule establishes an ongoing monitoring requirement for public water supplies For testing for PFAS out into the future It establishes technical standards for treatment our standards for treatment Specifically granular granular activated carbon Really wasn't where they need to be so we have Especially for treating a compound of this of this nature. So we've made some modifications to our technical standards And finally provides the health effects language that we've developed in close concert with the Department of Health Including the do not drink language Okay, I'm taking over now for the record. I'm Chuck Schwerer. I'm the director of our waste management prevention division And I'm going to focus on the testing we've done in the waste streams as well as the wastewater treatment plans Which are part of that I'm giving you right off the bat of what you're going to find with the Um Slides going forward and there's a lot of technical information. I'll try to go through it quick But clearly if you have any questions, let me know But the big takeaway is that we detected PFAS and nearly always sampled And I think it was a little surprising to me But what we found was the largest loading into landfill was residential source materials Which I'll go into that so things we throw out every day Um are contributing to the to the PFAS in the leachate And just initially our our belief is that to solve that part of the problem. There's really no Easy solution and and we can talk about that My next big So this was work that Cassella did and they not only Uh Did waste that was coming in but they did do Some targeted sampling at different sources In regard to what we found oh, please back one. Yeah, I think where do we go? Yes, thank you. Um for the wastewater treatment plants. We did find PFAS coming in the influent at nearly all wastewater treatment facilities that we tested Including ones that accepted landfill leachate and industrial as well as ones that didn't And not surprising we did find that the highest concentration of influent were at wastewater treatment facilities that accept landfill leachate not a surprise as part of The permit that we issued news for bond or cassella to expand coventry we did require them to look at Two on-site treatment and two off-site treatment methods for landfill leachate the good news was there are technologies out there that can treat it the bad news is Very very expensive And it didn't necessarily deal with the entire problem. There were unanswered questions with residuals What do we do when we if we concentrate all this PFAS out of the leachate? Where do we take it? What's the best way to treat it? So there's still some science that needs to catch up with us But uh, at least initially there is some good good news that it can be done. It's just whether We as a state want to spend that kind of money Are there I mean, I guess it's worldwide challenge or at least countrywide, right? So are there There are other jurisdictions that are ahead of us technically and we can see Not answers not that we found but we're still looking at that and I'll give into that report a little bit farther down And we can talk about that so moving on to the next one just real quickly we To to reach these conclusions. We relied on reports that news from odd did which I mentioned they tested the Different materials coming into the landfill the state Sponsored an evaluation of landfill leachate wastewater treatment plant influence affluent biosolids and sludge We hired a company called weston and samson And then lastly cicella hired brown and called well to do the evaluation of the treatment Methods that I just talked about so we'll quickly review that as we move forward So now to get into a number of Bar charts where we'll take a look at the findings Of what came into the landfill The and what's really important to know when you're looking at these is the right left hand column of concentrations So by far this is in nanograms for gram or parts per trillion and the two Well, no, it's in per per trillion. But if you look at the Top two thousand that would be two parts per billion I'm not sure if I follow So just in terms of scale if we think about our health standard as for drinking water as 20 parts per trillion The far right column is reaching two parts per billion or a thousand times more than a part per trillion So we're seeing the the real takeaway is we're seeing very high concentration Of p-foss containing products in bulky ways and textiles Like furniture mattresses clothing things like that that kasella tested had very high concentrations if we go to the next one This was what they did we don't In in order to protect their clients kasella did not give us the names of the particular companies that they sampled but they did sample municipal sludge and industrial sludges that they accepted the landfill So again looking at the Scale on the left were up to 350 part per trillion so You know almost in order back to less than what the bulky material showed But the takeaway is we were seeing p-foss compounds in those materials as well We go to the next one This is just a continuation of the sludges and industrial In municipal sampling that kasella did So if we move on to the next category We looked at construction and demolition debris including carpeting We know that a lot of carpeting has the stain resistant treatments on it Yes, exactly Yeah, so we So again the big bars represent Detections in that waste and Here we're up the highest bar is up to one part per million or a thousand parts per trillion So again pretty high concentrations of waste that we bring to the landfill On a regular basis P-f-o-s and that is the predominant material in the scotch guard The thing she's throwing your dryer in there You Softener I mean boy, I tell you we're finding it almost everything so I wouldn't be surprised if you do but I don't know that to be the case Yeah, that's a good question. Chuck before you want to make a quick question Earlier on you were talking about the communities the country kids craft very better. They're all being notified as everybody in Yes All this the user the requirements for distribution of those to the users on the water systems themselves, okay And then so those folks are In contact with the health department For monitoring and all this kind of correct and my team is In fact, senator brain's question about figuring out the source Our team is really working hard to do that and I know richard who's yeah spent a bunch of time He's been to two or three public meetings in mount holly Okay, we're doing some extensive sampling there this week to try to figure out the source Okay, there is a nearby fire department, which could be a source But at this point it's way too early to say that's that's a country kids country Or whatever it was in the craft's very fire district that's all still between 15 The day of skill they all know craft very craft very was done on 20 parts per trillion So, um, they are now collecting A next sample for that we put them on quarterly monitoring Okay, and so the results of that sample will find the mean between those and that will determine it They're on the state mandate Okay The people have been aware so they just go to the doctor and be tested. Yes public notice is a is a feature Excellent So this is there's a lot of different Um Ways that were sampled here waterproof coating surface coating cosmetics food packaging the list goes on But again the takeaway is at varying concentrations pretty much almost everything except for those few to the far right We had some level of detection With The wire manufacturer and feeding the the highest concentration which we've known about we've looked at wire coating That was the the site impound all right And we've looked at a few other wire coating locations in the car Yeah, it would be the coating for either But again if we go back to reminding ourselves of the scale even though we detected it this is 80 to 100 so it's in the The slightly lower category versus the textiles of bulky waste we can go to the next one So one question before you move on and set coated paper so tons people pick paper disposable products because they Is that still the standard Coating on all like paper plates paper cups all that sort of stuff or are there companies that are switching over to other I'm guessing that it depends on the company There are certainly some companies that are trying to make sure they stay away from people So there are alternatives at this point I think it's I think it's fair to say that we can't say with the level of like precision whether Consumer products have done away with PFAS or moved to a different PFAS that's sort of like outside the bandwidth Of what we normally test for great. Um, right I think that's I think that's the challenge that we have just another chemical that we haven't found yet Correct the the shorter chain PFAS that they're saying is better because it doesn't accumulate in the body as long But I don't think the science is out there. It's really safer. Right. Right. Okay So that's sort of undetermined at this point. I think we just we don't have enough information to really say They have a This next slide is kind of an interesting one what we tried to do with this is not Look entirely at concentration, but look at the mass. So we know what the concentration is then how much volume is being Brought into a landfill and we've had some waste composition studies over the year that My team has been involved with so using that data We tried to look at what is really the biggest mass loading into the landfill and its textiles Bulky waste and carpeting. We're really the three big ones And then if you look way to the left the municipal and industrial sludges clearly are still a significant contributors, but A fair amount less than the other three Sorry, what do you get what bulky is means? Well, let's say like mattresses carpets Furniture Carpet separated out Yeah, and carpet is separated to the right And this is That closing clothing. Yeah, and they also looked at like there was When the material was dumped on the tipping floor if they found like a big umbrella Like a patio umbrella. We know that's treated So they were definitely looking for ones that we suspected would be a source Which made some sense. So I know they did cut up some umbrellas It did find some Gore-Tex material When they did the testing so I mean in a sense it was targeted for but yet it it was quite informative as well We go to the next slide. I'm now going to look at The analysis for the leachate So this is just a so if you remember back in 2018 we did one round of sampling We have five landfills in vermont four closed and the news vermont remains open that we capture and Require the disposal of the leachate at wastewater treatment facilities So in this next sampling round we did eight different sampling events And we wanted to see if there was Much variability in what's being generated at these landfills And this is just by the different compounds So the very top is the total fee PFAS the next one down is pfoa And you can see the rest my I say it's not quite as good But really what that told us is even though the top line does show variability if you look at by the individual compounds It's really pretty consistent in my opinion and It's showing that our you know what we throw out in landfills has these compounds and they're pretty much We continuously leaching out into the leachate And then this took a look at the different sampling events that we did you'll notice there's only four on there We had Problems getting access to the more town landfill So we had had sampled the more town landfill in the past and they refused to cooperate With us in the study. So we went ahead without them But you'll see chitin in solid waste clothes landfill city of burlington news vermont and randolph And I think the surprising thing is the fact that randolph was the highest We're not a hundred percent certain on the reason for that Although there are some reports in our files that shows that some ways from bennington Uh kemfab sanko bay and went to randolph and that could very well be a source We had off was one of the first of the landfills that realized that That the practice of putting dirt on top of the landfill every night And then doing it again every day that was open was filling up the landfill with a lot of dirt So they changed their policy and said they would take They take A trash can as far away as burlington and other places So they could fill it all up without and get more in it instead of having to Put that dirt on it every night and this is when landfills were We're closing and trying to get more stuff in that In in them without Yeah So this was just another way to look at the The line chart I showed before to highlight that pretty much every one of these landfills that are producing michet do have any fast compounds in them I'm not going to repeat it If we go to the next one So now we'll look at what we discovered in the influent effluent at the wastewater treatment facilities And this next graph is a lot to absorb But I I shared it because it shows all the different Wastewater treatment facilities that we tested so that's really the takeaway And the fact that as I mentioned earlier the wastewater treatment facilities that accept leachate That's really the highest concentration That had the highest concentrations in their facility and that would be malchillier and newport We also see I think it's Burlington and Brooklyn with relatively high so we're still trying to figure out what that ultimately means But it's sort of a good breakout and the way these So may I ask so i'm just looking at newport compared to bennington So newport is showing a higher concentration Just in the in the influent effluent Bring the effing correct, okay both So the influent is the white bar Yeah, and the Let's call it red for valentine's day the red bar is the effluent and the The range of the sampling because we did eight different events are the colored pieces and then if you see those bars those are the 95th percentile for statistics purposes. So not being a really strong statistician Let's stay away from that, but really you can see the range And and with bennington it would be interesting We haven't done that to look at what the the results would be Before we did all the treatment because there used to be private wells that had high levels that would discharge to the sewer system So we saw some pretty high levels in bennington initially But now that we have them all on clean water We have seen those numbers come down and I haven't Done that look to see but I'd be surprised if Bennington wasn't all up to higher if we threw in prior to the work we've done This new port includes Are any samples taken when they were accepting Leech aid Seven of the eight works that they were accepting leech aid So there's only one round of sampling That was After they stopped accepting so we're going to continue to monitor that to see if we start to see Trends going down which we would expect to see but we really didn't see that with the one sampling event It was lower, but it wasn't significantly lower So the take home said No surprise they're accepting leech aid then you end up with the influence levels Significantly higher, but there's but there's a background level of PFAS and influence everywhere Right, and I have a Figure to kind of show that we go to the next one So before we go on is that why we both Montpelier and Newport are higher because they both accept Other inputs or this isn't just coming from the city of Montpelier and the city of Newport Montpelier is is interesting because it serves as a hub for the treatment of A lot of the saptage that gets pumped out of the individual homeowner of wastewater Ways where I know Newport takes a fair amount of smoke right and we've seen that there are relatively high concentrations in single family home So this is necessarily reflective Again handling the sludge. I think it's I think Again, I think one of the things that's really hard is to take limited data sets and then leap to Conclusions, I mean certainly leech aid I mean I think it shows a trend that if if facilities accept leech aid they're higher than those that know But everybody has PFAS in it and with Montpelier I think you know it is somewhat unique in how the facility operates and you kind of have to factor that in When you look at Montpelier, that's correct. If we go to the next one that kind of Shows it so the first bar on the left again The colored section is the the range the low and the high for the eight different rounds But you can see that that is Montpelier and Newport and The next one is all the Facilities that accept leech aid the next one is they don't know leech aid, but do have some industrial sources So there are some industry that could be contributing and then the green one way to the right Our wastewater treatment facilities that have no leech aid and no known industrial sources contributing So as Matt said even if you get take out the the sources that we know contribute There's still is PFAS coming into our wastewater treatment facilities from our residential use And to try to fully understand that is something we're working on. I can say we don't fully understand what's contributing to it There you go I like it Okay, next one Is uh looking at so look so we know the material comes into the plant at With some varying concentrations. We know it will accumulate There are have some affinity to accumulate in biosolids, but we also know that the wastewater treatment facilities aren't really designed to remove the PFAS So we see some Coming out of that effluent And it's the same breakdown of the different categories the mount pillier newport Other all of them that accept leech aid and then the leech aid with industrial and then no industrial And if we think back to our and this isn't parts for trillion. So if we think back to our drinking water standard The green one is discharging below 20 The next two are below or slightly above 40 and then the next one is at 80 to 90 at the high range So it's above drinking water standards We know no one's drinking what's coming out of a tight better wastewater treatment facility but at the same time We don't know if the constant loading of PFAS even at those very low concentrations are Contributing to a problem say in fish or other aquatic biota But we do know that it's going into surface waters that are then drawn from For drinking water We do but then we also have tested. Yeah, but then we've tested the drinking water Right, right With the sampling at mount pillier. We did do three separate rounds of above stream and below stream And not surprising when they were not detected because we know it's low concentrations being heavily diluted. Yeah That still doesn't mean it's not an issue But at least from a drinking water perspective for now for now, right, but it'll continue to build up Over time wherever we put it We know that at least the PFOS Will bio accumulate Do we know at what levels in fish we don't have that data? I think the other thing just to sort of note an anticipated question if you go back and look through this I mean you will notice that the influence data is lower than the affluent data and While we don't know with certainty what is going on our working Understanding is is that it's likely that wastewater treatment plants are taking PFOS compounds that we can't detect and breaking them down into PFOS compounds that we do see so there's some Longer change. There's some longer change. Well, it's probably we're not sure And I think that that's again. I think it's something that we've sort of flagged as Uh something we need to do additional work and figuring out how this is what's happening So 20 20 parts per billion as a Safe drinking water standard, but that was evaluating. I'm just turning them over what The risks were associated with it. Was it that in exceedance of that they had potential as a carcinogen or rata gen or Disruptors, I mean, I don't know what are we saying? 20 is a threshold Well, so so so basically it's it's looking at non-cancer in points and it's primarily kidney kidney function and there's I believe some Fetal development functions that it's like and I think that's the big one and um It's a chronic exposure level looking at the most sensitive populations for purposes So again, we're not looking at acute Sort of in points. We're looking at chronic That so and are you evaluating it or is the department's health evaluating as endocrine disruptor? That's one of the known impacts in the health department has Factored that into their calculations for sure just because this summer we in the single use products work From dr. Meyer down I think at John's Hopkins anyway, you get the citation but he was He in passing was trying on PFAS and That as an endocrine disruptor that it wasn't they thought the safe the highest Was a one-tenth of one part per trillion So a far lower threshold and it just made me pause and say, okay We're using a threshold And what are we not evaluating for what other sorts of health risks? So I I think there is some emerging information on PFAS's effects on the immune system and potential adverse effects I I think that is emerging and I don't think that it's been sort of uh, I think we're waiting on places like ATSDR and others to finalize their research and I I think that the health department once it gets finalized will take that into consideration with respect to their standards Thank you Excellent, please So sludges and biosolids So again not surprising For facilities that accept leachate had the highest concentration of the PFAS compounds It's the average sum of five so The same three kind of categories the ones that accept leachate the ones that accept industrial and then the ones that don't have either and A takeaway is just as we reported before higher for facilities that accept leachate, but still present in Facilities that don't accept leachate And you know brent superior translation to what? That's really no that's really So if we go to the next one so this looks at Sampling that was done by cicella Sampling that was done by us and then our to put some context in it We threw in our background study that we did So if we started with a background study first we collected it was really part of our work in beddington to understand Uh what background was and so we collected throughout the entire state. It was about 69 67 samples in town Common areas in places where there wasn't an obvious industrial source And in every sample that we took we found some low levels of PFAS generally speaking in One to two part per billion range And so then when we look at the sampling that we did which is the middle column of PFAS of the sludges of all those different wastewater facilities that I listed before We had the highest concentrations of the different compounds with PFOS being really the highest for really all three And then the sampling to the far left is the sampling that cicella did for sludges that came in So we do know that it isn't sludges. It's in the part per billion range Which again if our standards part per trillion it's a thousand times more, but it's still Part per billion I still consider a low concentration, but it's there So Last year when we talked about the possibility of a moratorium on spreading sludge all those kinds of things we thought were going to hold off We're going to get some information Is this the information that is this where we are sort of at with regard to The information that we need to make those kinds of decisions or is there more Out there that's being done that this committee needs to have a look at Yes, so this is just looking at the sludges themselves So what we've done my group has done is it's gone out and we've done some initial sampling ourselves at facilities that accepted The biosolids and then we've requested all any Of the facilities the properties that we've permitted that they do the sampling We have not gotten all the results in The ones that we've gotten in shows some properties are showing very little impact And a few are showing some high levels of impact in groundwater The good news is none are showing any Contamination to drinking water wells Which is really the biggest exposure route that we're want to be protective of But we have at least one property that we're concerned about that we're asking for it's By the monitor barns in Richmond and they take both municipal sludge as well as septage And there were some fairly high levels of soil and groundwater But we know that we're spreading it, right? I mean we know that through this process we are spreading PFAS is Throughout the state and we as a state have to just determine whether or not we go Continue that practice or find a better way to manage these I mean, I think that's I mean so you're I mean that's what we always you're talking about And I'm just maybe you can help me and just to get At what point do we as a committee start to say and you've found it now I mean it's everywhere and are we're making a situation maybe worse? Do we want? You know just help me sure so obviously that's a policy question, right? The committee can take up when it feels it has enough information the agency is Is going out as check set and looking at both soil and groundwater results from places that actually land apply So that we can have a better understanding of whether we're having accumulation in soils And what impacts we're seeing in groundwater. I think the challenge is You can't stop accumulating sludges, right? That's a fun. It's a process of of operating wastewater treatment facility and the The alternative management options for them are relatively limited. It's incineration and I would just Yes, that's what happened with Well, I'm trying to say I think the agency would voice a concern about any incineration of sludges Either land application Taking them to a landfill for disposal there And I guess your other alternative is just out-of-state shipment to any of the similar issues. So I think We're still trying to come up with both Let's go to the what the problem is, but I think we're also in the process of evaluating several options that we can do regulatorily to try and both improve our understanding and minimize impacts And well, I'm we're not prepared today to sort of make any sort of decisions as to how we're going to move forward yet And the way I'm feeling and it's just is that I think we all know that this practice we can't This needs we can't continue We've got to manage it in a better way We've got to make that decision sooner rather than later in terms of how are we going to manage this most effectively and So I feel like, you know, we're postponing. We're postponing. We can get more information and I Respect that and we're trying to understand the gravity of the problem, but we know it's a big problem and And to me it's it's can we manage it within our facility state or can it go somewhere else where somebody can manage it better? And I can just weigh in I think that's an excellent question I think what matt said is really the crux for me in my program is if we say no to land app and we know there's a lot of positives for adding biosols as a soil amendment Is the alternative that we're taking it to More protective and we don't have that answer and I know that's what we have to strawberry But I might argue is putting bringing it to the landfill. We've just looked at the leachate numbers Maybe is not a better Right alternative. So then again, I think you have to come back to this committee and say how can we help the landfills In a way to make that process better. I mean it is this is complicated stuff and it's going to be a tough decision It's going to take some money, but I think we're just Putting it off and putting it off Can I I want to do a math check on myself here? So we're looking at a scale of parts per billion So if we went to our drinking water standard of parts per trillion that 20 for instance becomes 20 000 parts per trillion, right? So it's a thousand fold over You know, I just want to which is a little hard to imagine to see I see why you need to draw it that way otherwise, it's completely off the charts, but it's I'm wanting to check my math and two It it looks sort of reassuringly like the other profiles, but it's really an intense source of PFAS compounds, right? It is definitely accumulating. Thank you. Next so this is just a little summary of the Report that the that can sell the news remote did They hired Brown and called well to look at the two onsite to off-site And we've just highlighted some of the Challenges when we've asked them to look at that. What's really important is to understand. Okay. What level are we treating to? What is the discharge standard and without a water surface water quality standard? Which we don't have yet. It was somewhat difficult in this research to to figure out exact costs um The other real challenge with leachate because it is a very complex matrix and and Highly organic material actually treating it is pretty challenging So understanding exactly what makes the most sense in a cost effective and environmentally effective way was one of the limitations that Brown called well highlighted And that as I mentioned earlier, there's they still in these reports didn't really resolve the final What do you do with the if you concentrate a solid or a liquid with highly highly? Concentrated PFAS What do we do with that and they didn't really answer those questions So what we are doing as a as a state program? We have some very talented people in house, but I don't think we have the full expertise. So we've asked For an independent analysis By a third party to review their report To look at in the cell report. Did they look at all the options? Were their assumptions, right? Are their costs, right? Did they miss some critical components of it? And we've just recently Closed our request for proposal process. We got a few Proposals in and we're hoping we'll be able to get Contractor on board quickly to start helping us go through that Report and I think it's safe to say no decisions On what direction we go at least at an apartment level. We'll go forward until we get that review done If you want to add anything to that Is that a report that you Can send to the committee? Absolutely, right? The analysis of yes Of our independent third party or the brown and bald law The one you already Yep, that is available on our website. I'll send you the link to it And then just lastly Matt mentioned in the beginning the other thing We look we were tasked to look at as part of our statewide sampling plan was car washes and electroplaters um So we've in both cases we've identified what we consider to be the highest risk Car washes in other words what car washes are located in locations where there's Private drinking water wells in close proximity So we did testing at 17 of those of which we detected PFAS at four locations With exceedances at two and this would be in brown water And The good news Like the biosauce land app is we did not see any impacts on the surrounding drinking water supplies So we know it's there. We know it's impacting brown water, but we're not necessarily Seeing the human exposure The same can be true with electroplaters We detected PFAS at two of the five locations that we have sampled Uh in both car washes and electroplaters, we're still working on getting additional testing data in both were More challenging than we thought because we didn't necessarily have evidence of a release So when we're asking for this testing, we're truly asking and not requiring other law So not everyone has been openly willing to allow us to do this testing. So That's why we have limited Facilities tested so far but we're continuing to work through that And and should have more data as this time progresses So are any of these facilities Do they have alternative Processes or chemicals they can use and are they interested in or willing to make changes or Absolutely excellent question. It's something that I wish we all knew more of as what are the safer alternatives I will say there's a lot of attention Regionally and nationally to understand that so we can try at least in part to educate consumers and businesses for safer alternatives, but we don't Me personally, I don't feel like we have that information yet to really like some of these that are marketed as safer Are they really safer do they still have florida and compounds in it? I think we're finding many still do Well, even if they're completely different compounds if we if we don't have a history from them and there's not been a lot of testing We still don't know if they're safer So then Quit moving off the slides, but quickly giving the committee an update on the water quality standard report and the status of that So we also put out a report with respect to the water quality standards And basically the in summary Uh, we found that there are significant data gaps that need to be filled in order for us to establish a water quality standard For the five PFAS compounds. There's no data available with respect to bio-cumulation of these five PFAS compounds in ecological And there's insufficient toxicological ecological toxicological data for Three of the five PFAS compounds It's relatively it would be a relatively significant cost to fill those data gaps somewhere in the range of Three to six million dollars In lieu of doing that the agency is recommending that we set a fish consumption advisory much like we do with mercury We do have sufficient data to set fish consumption advisories and so we're in the process of developing that and then doing the Including PFAS in the fish tissue sampling regime that we do as an agency so that we'll have an understanding of what levels of PFAS are in fish tissue and whether we're seeing them rise to a level That we have a human consumption issue associated with them in addition to that And I think it sort of flows through a lot of the things that we spoke to We're also looking to develop a working group in concert with municipalities to basically make an effort to Identify industrial and other sources discharging into wastewater treatment facilities and whether there are feasible alternatives or treatment alternatives for those industrial sources So that you basically can address them before they get into the wastewater treatment facility And lastly continue our collaboration with New EPIC which is the regional organization of of clean water administrators throughout New England and and EPA To try and get some of the science pushed to a point where we can move forward with standards Send over a memo to the committee with timelines for these when you have quite a few moving parts And so if you could tell us for instance, there's also the study related to can we regulate as a class, right? Sure So if you could give us timelines, I'm guessing Gantt chart style, there's things going on now. There's things that haven't started yet There's things that are going to be going on for years It'd be helpful just to see How that work is unfolding Thank you Senator So on the fish thing that I'm guessing that The fish would be affected only really in the big lakes much more than they're affected in the upland lakes You know, I don't think we have enough data to derive conclusions, right? I think the the challenge is PFAS and particularly PFOS bioaccumulate and differently than sort of like the other bioaccumulating constituents that we see it doesn't go into fatty tissue it goes into Bloodstream and muscular tissue So it's really different and I think it's posing some unique issues for our aquatic ecologists to try and So I just don't want to That'll be an interesting story to follow We did just for knowledge in Bennington, we did tests of fish and the predominant contaminant there was PFOA but Not surprisingly what we found in the fish tissue was PFOS No, it was bioaccumulating Where were you looking from? Yeah, from where we don't know if you have anything that was upstream So is that upstream or downstream of the other contamination is what I'm wondering Well, I mean the the challenge with PFAS is that we're finding that aerial Is that fairly significant? So a lot of reason upstream Okay, so dependent on what way the wind was flowing. Yes, gotcha So following up on this so if you're taking those fish from the Walloon Sack River Popular fly fish in the spot for the state Isn't there a connection between the Walloon Sack and the Bennington, uh, wastewater freedom I would imagine, I don't know where the discharge point is I don't know where the treatment point is So can you find out yet? I'm not sure The the levels that we found were considered to be Well below what would be a concern to the health department Right, so that was the good news the bad news. It was there Like if there was good news at the time, they didn't felt feel it But at a concentration that was of a health concern Right, and I think you know again kind of going back to the We don't understand the ecological toxicity to fish So I mean yes, we're focused right now on human consumption and the effects on the human But the impact of we're not we are equally concerned about Fish populations the diversity of fish populations and their ability to basically function properly And that that's another sort of facet that we look at when we're setting the water quality standards There's a lot of missing data. It might make them more waterproof Make some harder to catch because That's what I was going to say with the fishermen that I hang out with we don't really have to worry The limits that we eat it's more about can you catch an affair? Evaluate pyrolysis Pyrolysis is a low oxygen burden So Or any I have Hearing about this being destroyed by high temperature combustion, but That my concern is about what's happening Along with that combustion, but is that something you're looking into? So I I think it's fair to say no We are not we are not doing any of the basic research associated with the Effectiveness of treatment technologies. It's sort of beyond A&R's capacity to look at those sorts of things. I guess I would only add Ah, there is at this moment you guys correct me if I'm wrong as of recently There is no validated testing methodology for looking at air emissions across right, so Again, I think this is the challenge with the emerging contaminants is that we we don't have a Qaqc epa approved Um air emissions Testing methodology yet, so we can't say I don't feel comfortable sort of definitively saying that these Tests that we may have seen from a certain facility that says it's fine Are our courtroom defensively and at accurate from a lawyer's standpoint? Great well And we've run over a little and this so thank you for coming in and giving us I can see you've done A great deal of work since we last sat together talking about this last year and appreciate all that diligent effort and We'll come back to this. I think the open question for the committee is is there anything else that we should be doing? We don't want to just be hyper reactive. We also want to Be you know appropriately assertive in trying to address things as To the limits of what we know is uh, you know Practical or feasible Pushing and I think the response is is that we we've spent a lot of time gathering data If not had it long enough To give you good sort of science-based Solutions for what you should be doing with it and I think that that sort of are What's sort of on our task list right now is really trying to understand what this data is telling us And whether it's sufficiently represented and then what sort of policy solutions you should be drawing from it I think my other question would be is there Back to how landfills using is is there a land for is there technology out there? That's more sophisticated more advanced than what we're seeing Here in the state of Vermont You know we keep talking about right, so it's like going somewhere you know if New york state can handle it better without polluting without us without us creating a terrible problem from new york state Perhaps we should be thinking about that I don't think there's I mean, I know a lot of No, I know how is there a technology goes to shat again new york, and I don't know if There has situations. Yeah, are we just like importing their groundwater there? That's what I'm wondering. Yeah, I don't know Yeah, right. I'm again. I think especially with landfilling chain. I think everybody The the regulatory community is identified as it's an issue. It's a challenge. It's something that we're going to have to deal with I think We have a report that I said we're trying to evaluate and then Reach conclusions means moratorium doesn't seem to have worked right in a way. Did it create more of a problem then? Yeah, I think so because they're Level that they picked was so low. It was below like our background. Okay And I think they so it's so they picked a higher level. Maybe they're moratorium may have And they found work workarounds. So although it's the level that you maybe we can hear from me But I mean just to see get a sense from their folks sure we can or we can provide you to some point a summary of what May's program is The rest of the committee is going to take up a collection and send it right They've been trying to do that for you Right main friends Thank you all well, it's great. Thank you for your time. I mean helpful. We have in There's In the building in s267, there's a bill that proposes to change the Standards in the renewable energy standard Was the bill started in natural resources and energy? We committed over to finance that wanted to get Head start on it. It's still in finance, but we know the bill will be coming back to us. So we wanted to get educating ourselves on some of the implications of Proposals in that bill someone asked me why I was a sponsor if I wasn't sure that I wanted to do everything in that It was a way to get Conversation going get some ideas on the table and now we need to do our due diligence Figure out What the implications of an act in any or all of those provisions are? And to help us do that we wanted to speak to people or in the business of dealing with generating and moving energy around so I'd like to get started this morning. Mr. Would you join us at the table? That's morning My name is Hans. Where do you make? manager's system planning Velco There's that Velco for the last 20 years and 10 years prior to that it was the Boston Edison which was a vertically integrated utility Since then this quite a bit of change in the industry which was regulated Get a lot of gas right now units are being hired The grid is becoming more more renewable That's happening really rapidly in Vermont. We've seen a great logic in solar TV and other resources and Velco is here to To help to ensure that the system remains reliable as we do it We pay attention to our resources how they are performed and that affects how we design the grid So that's always all about reliability reliability and defined by NERC, credible publicizations regional recommendations and to do that we have a control center in our Ruffin We develop a long-wings plan every three years and perform annual assessments for inert standards We also manage the Vermont system plan for the the SPC And I would begin by saying that our policies are are working We've seen a great drastic change in our load In Vermont. We've seen the solar TV affecting Reducing our peak demand It's also reducing the load in the middle of the day quite a bit. So that's actually a Part of the fact on this slide here, it's written the numbers every year For instance, 2015 the midday load dropped by 37 MW 2016 and dropped again by 35 MW and picked up from 1769 and also flooding these These values on this current year and the last measurement was in 2019 where The load in the middle of the day dropped to 300 MW in Vermont And we have a system that I call a thousand MW system at peak On a typical day, we're about 650 MW so that we're Really low and it's getting even lower as we go along and we project in 2003 to I looked up a presentation that the department gave that actually Stating that we need about 25 MW a year to meet the tier of new requirements today And if we just plot that 25 MW per year Vermont the entire state load in the middle of the day would be about zero And it's like in 32 and I Actually believe that it will have been earlier than that We could have more than 25 MW per year as we go along just to the market forces And if you look at this in terms of the load shape Typical day in April or May And I'm planning from 2015 to now The middle of the day load Tends to be about 600, 750 MW And it's been dropping over the years And 12 you can see some interesting things as you look at these shapes in 2017 for instance The load in the middle of the day was lower in a nighttime load That was the first time this happened in Vermont And they're continuing to drop below The 2019 or 30 MW And that's certainly below the nighttime Nighttime load and and the reason for that is solar PV It's no other no other reason for that And if I project what will happen in 2013 We'll see that go drop to zero MW in the middle of the day But it will not have any impact at the peak hours That is at 8 o'clock at night or 4 o'clock in the morning There's no sun, right? So these loads will remain as they are today But the middle of the day will drop significantly That's the effect that we're projecting As we go to the next slide This is showing how we Serve low in Vermont on a peak hour Whether it's this winter peak Or the summer peak And this is showing that over 75% of our supply Comes from outside of our borders We import that power through our transmission ties Whether it's from New York, Canada, New Hampshire, Massachusetts And the internal resources in Vermont are mostly renewable Look at the wind, solar or hydro But depending on the time of the peak Which is late at night From 6 o'clock to 9 o'clock We have very little solar at that time It's a little bit of wind We even have storage For the first time we had storage, shoving, load In Vermont Around the peak hour That's 6 MW and that's winter And about 1 MW is summer And this is going to grow I'll go to Paul Let's talk about our long winter plan So we published the plan every three years The last plan was published in 2018 What we found in analysis Is that we're going to continue to be reliant On our transmission grid To import power particularly at the peak hour And because our resources are intermittent They're weather dependent Or that's hydro Wind or solar We are going to continue to use our transmission system To serve our load in Vermont And in terms of the peak Our forecast is showing that At least in the year term In the last 10 years The peak load will stay constant Or even drop Because of even solar PV And other things we're doing Like energy efficiency Demand response Low flexibility So we don't force any needs To upgrade the system For the purpose of shredding load But in terms of integrating new energy Depending on how much is actually added to the system And where it's located There may be a need for transmission grids And we may be able to reduce that need By doing things like load management Storage We could try to optimize the location of generation To align with capacity The transmission grid capacity We can use even curtailment to some extent That's the least cost option So we've tested Two scenarios in our long-range plan We've tested primary main watts Which we think are future natural Market forces are current policies That's probably what the look of the transmission is going to be And we also tested a thousand main watts That is to be consistent with the solar pathway study That GSC conducted under DOE contract Now we'll go over the results A little later in the presentation So if you go to the next slide What we found when we tested 500 megawatts in Cremantle In Vermont We found that our system losses increased Typically when you add generation on the distribution level You expect the losses to go down But there's so much generation That is additional flow on the system to support that Additional flow results in additional losses And so to compare a system without generation Reliable of PV and with generation It's like a snapshot The only thing that we changed was the amount of solar The impact is an increase in losses on the system That's a quick question The 500 was chosen how Does that reflect on this term Relate that part of like an energy plan that the state has Or that That it reflects our current policies The tier one part of the reds It also uses what we call a payback model That takes into account the economics of solar installation As we're trying to model customer behavior Based on the perceived economic value of solar And that model suggests that In 2028 or so There will be about 500 megawatts of solar in Vermont But it's a natural economic payback model So the 1,000 megawatt is not a That's a forecast It's a high solar scenario Then to test the system In a way that is stressed So that's beyond what we think will happen To see how the system will perform And what we found is that the Constraints that we have today In another portion of the state An area we call Sheffield Highgate Export Interface Which we've never heard of before Shea for short We found issues in other Vermont With all this collapse Which is sort of a blackout We found lines Transmission lines overloaded Exceed their capacity And that would extend further south Into the Georgia area As you add more and more solar And so at 1,000 That's even worse It went even further south Towards the West Beltman area So a significant transmission Grid impacts Which could be addressed in several ways And we've looked at those Ways in our long-range plan We looked at So the transmission of grids We also looked at storage As a sort of non-transmission Alternatives to resolving these issues And what we also did In our plan Is to indicate where Solar or generation Could be installed in Vermont Without or at least The minimized grid impacts And so that we call that Transmission system Hot hosting capacity And we'll show you that map Here as well And the I'm guessing that Whether it's a 500 or a thousand Depending on the increments That you're injecting And the number of locations You're injecting It has an impact On the whole system as well Right? Right So Your model Walks through More concentrated Versus more distributed Exactly Location is very important It's So you have to match the The amount that you're adding To the system To the capacity of the local area And as we talked about Storage As a potential solution You usually talk about Battery storage But there's other means Of providing the same Same service Essentially what storage does Is it moves energy On one part of the Look curve To another part of the look curve So it's essentially Flattens-available look curve You can do that with Load management for instance Or other technologies So it could be batteries But also it could be pump hydro Or other things like that We can use storage to Provide market benefits Participate in energy market With the right capacity Or frequency regulation Velco has looked at storage As a potential Transmission asset And currently the rules Don't allow us to Put storage in our transmission rates First there's not all of that This is actually It's actually being discussed now There's a case in front of first To talk about storage As a transmission asset So we'll continue to follow that And really When we use storage The attributes that are I think are needed Is for drop The cost of drops The cost is very high Currently We would need a long term Storage in longer than four hours A one hour storage Or two hour storage I think will be sufficient To address the Concerns that we're trying To address here And if you exercise storage quite a bit It's kind of like your Your battery and computer As you use it a lot It depletes And you have to replace it And so great storage is the same thing If you exercise it quite a bit Frequently if it loses Charge and And you have to replace it for Within five or ten years And like everything else When storage is Is connected to the grid through Inverters like SOLIDMV and other Other generators And what we recommend is Anything that generation That connects to the grid Has to provide great support To be able to support voltage Provide frequency support And that inner storage And you can dispatch it Based on unit needs So that's critical for For storage to be successful And what's the Sort of roles and responsibilities Between Velco And the distribution utilities In terms of storage And is that Why might a Do you have a storage Versus Velco have storage And how do you Square those two relationships So they're not just coming At you to do it Or you're not coming On them to do it for instance Right, that's a great question Velco being a transmission only Utility There are certain Parameters that we have to follow For instance, we do not use storage to Participate in the market We're not allowed to do that We can't use storage for energy Or for capacity We can use storage to support Operations Meaning if we have a transmission Line or a substitution That is deficient In terms of its ability to sort of load Instead of placing a transformer Or upgrading a line We could install storage To provide the capacity that we need So we can use storage specifically for System support And utilities And use that for other means And if they're readily integrated They have to have a To use storage to reduce their load And use storage to To provide energy Or capacity for energy regulation And that's actually occurring today And so this slide here is slide nine Talks about the analysis that we did In our low energy plan As we What we did here is that we compared Transmission capacity To the amount of generation that would be Added in certain parts of The state We divided the state into 16 different zones And these zones here are of those that are Limited in terms of their capacity You know, Newport and Highgate Are located in the Shia area That we were talking about St. Albans is just below that And so when we compared the amount That wants to connect to these areas To the transmission capacity And if we're going to dissolve these constraints with storage We're able to estimate the amount of energy That would be required to be charged Or absorbed by storage in the capacity that we need And the numbers that you see in red Are the cost estimate To install these storage devices Adding all these numbers We see that the cost would exceed about $500 million And I think that's probably a lower number Than what will happen to reality Because we did not try to size the storage device Through taking into account State of charge management Whether you want the storage to be at 10% normally Or 50% normally And so the amount that will actually connect Will be larger than what we have here in this table There's a lot in this slide You can look at those a little later I've actually included a link If you wanted to see how these costs were estimated You can follow the approach there as well Just want to briefly talk about the constraint area In Northern Vermont The Shia-Tan Highgate Export Interface This is an interface that ISOD Mainland manages To ensure that system capacity is not exceeded There's quite a bit of generation there It's over 400 megawatts of resources Including the ADC converter And only about 60 megawatts on P About 30 megawatts on average And so the transmission capacity is not sufficient To export the excess power to other parts of Vermont And generation is being curtailed By ISOD Mainland When there's excessive generation in Northern Vermont I use that slide as a To introduce what we discussed in a long-range plan In that when we model 1,000 megawatt In the month of solar PV generation And we don't do that in a way That minimizes system impacts We've found that several lines on the transmission system Will exceed their capacity And they're shown here in orange Especially the western side of the state From Highgate down to West Portland will be affected And there are a few things that attract that So it's generation up north But also what we're importing from other parts of The system from York From PV 20 pie And from Canada From the Highgate converter These are injections from the north They're also causing issues With generation And the shear area The boundary of that shear area If we don't do things smartly If we don't install storage in the right locations That area will drop further south You get additional constraints Being other resources today That are not being curtailed Will become Subject to curtailments by ISO Like the Neal Drameter In Burlington Or the Berlin Other parts of the state will be curtailed And will the ones that are already being curtailed Be curtailed more? Potentially, yes Yes, definitely So that's the impact that we saw This is so If we simply look at those lines And transformers that are overloaded And we fix those with transmission upgrades And we reconduct their lines Provide additional capacity Then the cost estimate for that work Is over $300 million So you upgrade all of those lines Sorry, is the best cost Would that be entirely Velcro's cost? Or is there an ISO count for you? Excellent question Because these overloads Or system concerns Are related to generation And not load Being customer demand Transmission upgrades would be a Vermont cost ISO in New England does not consider Generation constraints As a reliability concerns That needs to be mitigated The reason is generation is a Is a comparative sector They're allowed to compete For transmission capacity So the more competition The lower the price So customers in theory Vantage it from competition But if you're the owner of the generator That's not such a good thing And it's complicated in Vermont Because Vermont utilities are vertically integrated Whereas elsewhere in New England Are either transmission only Or transmission and distribution Do not own generation We have a different paradigm here in Vermont Whereas generation constraints Are actually a bad thing for customers To Vermont as well What I have here on the slide Is our projection of what A doubling of Q2 Mean for the load shake in Vermont And flooding again The load in Milva Day In April or May And when we double Q2 We will see negative loads In Vermont as a state I'm not sure what that means I mean, does that happen Before So perhaps there will be a structural change In the markets for thyself To make this work I'm also providing on this slide The activation that I did To reach the amount that we think will We will need over a thousand nanowatts Of generation We double Q2 Depends on the technology that we use Whether it's solar or wind It depends on the capacity factor Of the resource I'm assuming about 50% Fast and effective for solar And if you follow all the calculation here We believe the amount of generation needed Will be over a thousand nanowatts It could be 1200 But in general We're talking about a thousand nanowatts of generation To support the Q2 requirements Is there a Currently, is there a cost-effective way To capture that sort of belly In the graph And carry that power over To pull the peak down Right or left of it Especially to the right of it There is several ways to do this Immediately think about storage As the solution Store the energy In the middle of the day And move that over to nighttime But as you look at this slide For instance, the amount of energy Would be pretty large And so In the end an hour of storage Or 12 hours of storage is necessary We need five, six hours of storage To do that Yes So storing it in the middle of the day And moving it to the nighttime Do you mean moving it to the evening peak Or do you mean Nighttime after dark From eight o'clock, nine o'clock, ten o'clock So it's a Okay, talk to me Even if you talk to me, yes Yes And then in the end there are There are, you know, storage is starting A way of doing it You can also move load Move consumption To the middle of the day You know where it's You can begin So you eat your house earlier Than you would You know, you can think about that Right And this slide here Is showing the amount of Generation that Vermont can accommodate And it's showing that Different areas of Vermont Have different capacities In the southern portion of the state You can enrate more More generations And the northern portion of the state For instance, in the southern area The amount is on the order of 225 mW But as you go north Towards Newport, Highgate You're in, you know, 10, 15 mW So if you want to Minimize the amount of Transmission operating to any Anything, courage Generation development Further south That's where the capacity exists So it's This is showing our ability to Accommodate transmission of the line And those numbers Are based on some Assumptions that I would say Are optimistic Or some of them are actually unrealistic I'm going to pick a few On the next slide Just to show you what that means In our analysis We decided to Keep our time closed at zero Earlier in one slide We're importing from Canada Or importing from New York We said let's keep those at zero To make room for Distribute generation in Vermont So every Mawak that we import From New York And a few between the lines One Mawak less That we can install in Vermont The other thing that we would point to is When we did this analysis We assumed that there would not be any Transmission connected generation Those parameters that are for jurisdictional That would be dispatched Like the extra 20 Mawak solar Project in college We said none of those will connect Which is not very realistic At least there will be one more That will connect with Vermont And any Mawak From those resources that connect with Vermont It's one Mawak less That can be installed at a distribution level We also made the assumptions Around the distribution system capacity We said anything that can be done there Will be done The system will be upgraded To accommodate additional And we know that certain areas in Vermont Where the system upgrades will not be Either cost effective Or a way of us all being concerned So the 1000 Mawak of capacity for the state Based on transmission capacity Is an optimistic number We think it's actually less than that We'll be taking into account The way that the system operates Is taking into account that we You see import power in Vermont Throughout ties And there will be additional So logic generators that will connect On the system that will tick up That will absorb some of the capacity That will not be used for a distribution test And to conclude I would say again that Reliability is really important to Valco And for us this means That we work really hard to enable The state goals We want to do energy increase But in a way that reduces grid impacts There are ways of doing that This is certainly a good management The storage There may be a need to reinforce the system But we'll try really hard to minimize that And what we're saying here is that Location matters So pay attention to location If there's a way to coordinate Generation additions in Vermont We would encourage additional generation In the southern portion of the state Where there's a set of low portion of the state The next version of the plan Which doesn't The long list plan will be in 2021 And we've actually started this analysis With working with our Load forecaster consultant Itron to help us forecast solar PV Forecast electric vehicles Heat pumps We're working with the Vermont system Plane community to do that And whatever we end up In terms of the rule That's here 10% or 20% And whatever that is We're going to make sure that the system is Plane design, viably And we'll work with Vermont to make sure that it happens And that it will happen That is my testimony Any additional questions? Well thank you very much My turn is over Thank you very much Yeah, really well done Thank you Good morning Thank you for having us this morning So again my name is Josh Kassomye I'm the Vice President of Chief Innovation Officer It's been on the crowd We're responsible for our power supply The engineering team And the innovation work that we do Our background is about electrical engineering And we're meeting today as well Hi and thank you for having us I'm Doug Smith Chief Power Supply Executive So I basically focus on power markets On behalf of our customers Trying to find sources of power At the lowest cost we can And to get the most value out of them And that's how to keep power costs low So that's the type of thing I and my team focus on So a good day for us Just to get a little tangible flavor Is if we make a good choice Like on when to buy electricity For this winter or next winter We buy it before the market goes up Or we wait When the market goes down That's a good day It's like a decrease to our rate So that's what that's a version Of what success feels like to us And the kind of things that we work on All right so Just wanted to talk a little bit About the risk builder We just got some today And hit on three points One is just in terms of Of as Mr. President said before The success of the policy so far And the amount of solar that's been deployed Tier two and tier one have worked Also talking about tier two And the doubling being supportive of that With while also seeing the opportunity To expand the types of resources The sizes, the geographic location Do the types of things that Will avoid some of the concerns that Mr. President raised as well Around also around cost Also around seasonal capability Renewable for wintertime That sort of thing And finally tier one And I mean as some folks know We've committed to 100% by 2030 As well so we're supportive there I just want to talk about some Of the flexibility that we see That's tier one So just starting with How successful the programs Have been in the last solar Continues to be very strong In G&P's territory I believe in other DUs as well But from a both Of net metering as well Of non-net metering It's just a chart of deployment Over the last number of years You can see in 2019 With both net metering alone In 2019 it was actually a little bit Higher than 2018 But when you include other projects A non-net metering standard offer Some of the PPA or power purchase Type solar projects in the larger ones Exceed in 2017 and 2018 And these are solar systems That have been installed Actually online in the territory There's a lot more in the pipeline Or in development permitting That sort of thing And I just add If you this the shape of that chart Looks a little different From some that you may have seen In 2019 it was a pretty big year for us One reason for that may be That some of the public databases Are a little lag Fourth quarter is usually a big year In Vermont for solar completions And 2019 is no exception So that may not have shown up On some earlier charts Which I don't think they had the advantage Of complete year of data yet So then as we look across the country And where does Vermont rank This is a snapshot of basically The amount of distributed solar Against our peak demand Sort of setting up our ratio there And again as you can see Other than Hawaii or GMP's territory And this really just carried through In Vermont has been a leader in this one Which has been great Does the types of things that Mr. President raised By knocking down the peak I mean prior to the solar we have The peak used to be in the middle of the day And early afternoon Is now shifted to the evening hours And in the wintertime In the state where they're here And just in terms of Distributed generation growth When we think about DG In the pet distributed generation That's the smaller projects That are distributed across the grid Everything from the cow power To the bio digesters On farms to solar And as you can see Really what over the last few years The solar has been the thing That has been working well Through tier two We'll get into Mr. Smith will get into A little bit more About how we think of that From a power supply portfolio And why just relying on one resource Can raise concerns From again to the grid perspectives A little bit similar to what Mr. President and what we're talking about Mr. Smith will talk about The impacts like power supply portfolio But just thinking about like anything Having all of it in one basket At a point Can raise some issues on the system And it's something we need to think about Especially the seasonality When I think about the importance of renewables Knocking out carbon from the system We get an issue in the wintertime As well that we need to really be thinking about If I could just add A lot of folks ask Why is that? Why is it overwhelming the solar so far? It's not like the utilities Or our public service department Or others are against other distributed resources Here in Vermont Not at all It's just that many of the others Digesters Small win They each have factors That tend to limit Their practical ability To get built limited fuel Limited number of suitable sites It's not that they're not wanted There tend to be factors That constrain how fast they can grow up That seems to be the case So you just saw the chart on the map On the right as Mr. Prenzome pointed out And Bella was looking at it From the transmission level And we have to look at it From sort of the next layer down The distribution level Which are the poles and wires That feed the homes and businesses And so in addition to the Expanding congestion That can occur at the transmission level We also have underlying distribution What we call sub transmission Or the middle level of transmission Constraints This is on the left Is a snapshot of GMP's Solar map that we published Show when it comes to siting We hope this gets used by developers And folks that are looking for sites That may be a little more conducive To siting or less costly But the red and the orange And the yellow sort of represent Circuits on our system Where the solar is actually starting To bump up against the limit Of the entire substation Which is a pretty big limit That means that you've got enough solar To essentially go in the reverse direction And hit the limit of a substation And so that's just what this shows We're thinking through like Okay, how as if it were sort of a Solar only approach in the future How much more cost could be showing up there Driving the cost So that's a big piece of why we think About the system and the immune system So Velco's work was very helpful In that regard Looking at the compliment Then for looking ahead At the what ifs that Mr. President They worked through That's really helpful context For planners and others in the state To figure out how to get more renewables in Very helpful So Mr. Chair, before we move on I mean that's one of the things I've been talking about for several years now As we as a state I'm from the Shiai area And so I know all the issues up there Yet developers are still proposing projects up there It makes my head explode And I think we as a state owe it to the electric rate payers To do something about where we're allowing Developers to put more developments Because it certainly doesn't make sense To put them where you guys are pushing up Against your limits or in the Shiai area The whole idea of distributed energy Was to get it close to the end user Or needed to be So we didn't have to build new poles and wires That's true And as we've been thinking about In terms of the actual doubling of tier two Even the size and location For the potentials of the existing tier two The same continues to grow That as in-state distributed But the second piece of tier two Having more flexibility That matches what other states are doing Or could even be outside of Vermont But it's still driving new Incremental renewable generation Giving us a larger swath of opportunity For generation including sources That are better in the wintertime It's a sound observation that you made I would just support Velco's point That there are things that we can do In terms of encouraging in-state generation In different locations That will tend to not aggravate Or bring on costly grid impacts That'll require some work Some changes in incentives and guidance To where projects are located But that may well be worth it As informed by that Velco work And the other thing I'd add is There are options Mr. President may talk about storage There are other ways As some states have reduced Or curtailed He called it the output of renewables If the need for new transmission Is driven by only a very few hours It may be cheaper to actually Sacrifice a little bit of renewable generation Rather than paying a quite costly upgrade So it's all just about being thoughtful Or something else Yes, sir One of the things we're working on The hope is we continue to see electric vehicles Take old and grow And if you can do things like Charge them in the middle of the day Creates a load in the day And actually helps us It's another form of storage essentially But we're thinking a lot of other Different opportunities there as well We get a bunch of solar in midday So take advantage of that Does your map guide the rate Which projects are, well, costs Let me think For energy generated in a solar ray Is that rate reflective of the location So for instance, are there If you're proposing a project in a red zone Regardless of the precise location you choose Can you not get a preferred location rate? As I understand it, currently the preferred location Piece of it, it does not actually refer to Distribution constraints It's been more about brown fields Not that type of geographic So as I understand it today No, that's not the case This does, however, the intention is It should give a developer indication That if I'm in a red zone compared to a green I could expect a higher interconnection cost To be close to an interconnect rather than rate That's correct That's correct Yeah I mean, I think the goal And the conversation we've been on for years Is that the real world costs and constraints Should be brought into the math Of deciding what gets billed where And what it's paid So far in my view it hasn't worked And that's why I think we as legislators Need to give weight to the green areas They shouldn't just be looking at brown fields In a constricted area of the grid We're still seeing people apply for development In places that we know are completely constrained So I think the market is not going to Straighten itself out without some policy change Yeah, and I think back to the flexibility You know, thinking about flexibility in tier two One of the under net metering That's correct And net metering rates are set fixed There are siting adders, subtractors Outside of net metering in a PPA That will actually show up Because somebody who has a higher interconnection cost Is essentially going to have to charge a higher PPA Which may make them a little less competitive Than somebody else So it can show up in projects of this scale And that type of thing But you're absolutely right I think there's currently some time to So, Michelle, take it over to Mr. Smith To talk a little bit more about just the impact On power supply and the day-to-day management of that Thanks So, as you, Madonko, with us is discussing So what was the big source for us? On a sunny day It's actually our biggest single power source now Like bigger than any other power purchase agreement, for example But that is what has sunk Part of this chart here is to contrast the difference This is two consecutive days on last August The first one has a yellow is solar production From the fleet of resources that Josh showed earlier It's net metering as well as power purchase agreements The state standard offer program It's basically the sum of all that And the maximum production is in the low 200 megawatts On that particular early afternoon And so what the implication here is When we design a power portfolio Power markets are quite volatile So part of what our team's job is We can arrange a set of power resources That matches when Vermont needs the power Approximately it insulates us From what the ISO New England market is doing Shorted using natural gas or surpluses Whatever it insulates our cost from that Turning to the choice we have here If the 1000 megawatts are a bit more statewide That Mr. Presme was talking about We think that number is a reasonable estimate If that unfolds in Vermont We will be looking on the sunny days At having hundreds of megawatts of power More than we need during the sunniest hours And that's not a catastrophic thing But it means we will be selling that Into the spot market often at a loss Another example the following day The 21st of August that was a cloudy day We only got I don't know Something like a quarter or a fifth as much That's two consecutive days This illustrates how on a cloudy day And in the evening peaks on that Senator McDonald asked about earlier Vermont we have a big buyer in the power market This is if we are overly reliant on one source The solar and that's really just the point We want to make it Relying on solar to the exclusion of other sources Can have some costs and also some challenges In managing the power and the cost for our customer A diversity in renewables Either through technology or location can help them The contrast is the blue line here This is the Hydro-Quebec The long term power purchase agreement from Quebec GMP is a major purchaser along with other Vermont utilities My point here is just to indicate That from a source like that That's supplied from a fleet of resources It can be basically scheduled in a firm way And it's a healthy complement against a lot of our renewables Wind, hydroelectric, solar, the group They have intermittent output to different degrees So from a practitioner perspective It's helpful to have some amount of our power From a firmer or more steady resource So we each touch a bit on this theme of flexibility This slide will try to tie it together So we've talked about how presently Res Tier 2 is largely a distributed solar requirement I've given an estimated range here As you know, the bill features gradual increases In the Tier 2 requirement I took the last year 2032 to give you a sense of magnitude And we set a range of $15 to $25 million a year Of extra cost to Vermont customers If Tier 2 as it's just presently defined were double I set a range because it depends on a number of uncertainties Future solar technology, the policies here The grid cost that Velco talked about But I'll just give you briefly on what the range represents Currently, net nearing as you saw on the chart earlier Is dominant solar source here in Vermont It's larger than the sum of the others That's a pretty high-priced form of solar If the increase from 10% up to 20% Is met substantially with that That will produce higher costs than I've shown you This range assumes that only a modest amount From none to like 10% to 15% of the increase comes from net nearing If it were like half or all net nearing It'd be higher than that range The range Or exceed your 25% you're saying That's what I'm saying The lower end of the range here assumes that nearly all of the increase In Tier 2 is met in state solar But in the most competitive way we can Like power purchase agreements Think of a competitive procurement And those projects would be sized from a megawatt to five megawatts And it assumes that there's not There's only a little bit of the increased grid cost That Mr. Presome talked about The higher end of the range assumes that a bit more of the supply Is met from net nearing Which has a higher price per kilowatt hour And it introduces about a second per kilowatt hour And probably a little light on that But of grid costs that are reflective of the type that Belko talked about It's so this is an indicative range to give you just a sense of magnitude And the rest of the slide basically amounts to We hope the opportunity to do better in terms of flexibility We think we can get a lower cost and a better fit With the power needs If we can choose from different sizes of projects Different technologies Including some out of state Similar to what the prominent renewable requirements in the region Other state renewable portfolio standards feature That gives a good deal of flexibility We hope to beat those numbers And I think the odds of looking back and ending up on the high end of the cost Are lower if we have a greater flexibility I guess that's our thematic message of how we would hope to Have flexibility to procure these increasing requirements So you know essentially as we look at And we've looked at tier two as the new renewable tier It's been a new distributed generation tier You know as Mr. Smith mentioned Building flexibility into any expansion there would be important And in the meantime we have tier one the existing So the rest of our portfolio doing everything we can To make that renewable with existing resources Again as I said we've committed to moving 100% by 2030 So obviously fully supportive there The concern we have with limiting any one resource Isn't so much about doing more with any one resource It's just about the message it sends to the region That has those other sources And if you take one of the other players off the table It can disadvantage Vermont from a cost perspective So that's really on the tier one side I mean our goals need to move very quickly there And keep that get that to 100% Stay there while we continue to grow the new incremental renewables Which need to happen and continue to have an impact But just back to the flexibility Not sending a signal to other suppliers That there's one major player that's not there anymore Just to put a point on it In this region the supply of hydroelectric It is finite and the other states particularly Massachusetts And Connecticut are getting more heavily involved In goals kind of like our tier one They call it clean energy in some cases But the point being they're focused more and more On limiting the making their portfolio more renewable And limiting the emissions as well and getting more So there's more competition for the smaller hydro Than there used to be So one quick question is that in general I always think of the design goals for your system Is to maximize reliability at lowest cost While limiting environmental impacts And so if you're going to 100% renewable by 2030 What does that do to does that add pressure on the cost side Or do you speak to that point? Well I mean so it's a good question And ultimately it obviously depends on If we have any restrictions on how to get there Any requirements but no from the 100% standpoint Being able to source it from existing Does it's minimal in the cost pressure From a grid standpoint it's again it's existing So there isn't really any additional concerns On a grid constraints or costs And then obviously in the carbon standpoint What it will be it'll be renewable So from that perspective Continuing to have the flexibility That we have today under tier one It would be minimal in the cost Thank you very much Good morning, thanks for having me Thank you, my name is Craig Keeney I'm the manager of power planning at tomorrow I'd like to call up with me today as Andrea Cohen Lisa Morris also from VDC We appreciate the opportunity to come here Talk to you about our perspective on the proposed S267 Just to give you a little background on VDC For what it's worth we are all familiar with VDC It's up to you Okay so it's time to hurry up I mean just given how much time we have I think it's the chair Okay Just hurry up to the data on VDC Outreach us and make sure to turn this over Okay fine So we support the concept that we need to reduce Emissions both in Vermont and worldwide But we want to do that in the multi-concept Back to the post office And at a quickly level In fact our board of directors Currently is discussing whether they Would want the co-op to exceed the current Red requirements and if so by how much and what cost So why is cost such an important issue Because of the 10 pounds in Vermont With the highest power level VDC serves eight Of the five counties with the highest power level We serve three So we have a lot of customers Who are struggling to make their monthly bills And make ends meet on monthly basis So that's the perspective we're coming from I'd like to talk to you and walk you through quickly What our current power supply makes it Not showing up very small Not large in the screen But in 2009 the top pie chart So in 2019 all the energy purchase We made on behalf of our members What the fuel source is About 70% of that was renewable About 85% of that was free If you include the nuclear contract So that's the sources of the power Our goal is to meet the red requirements At least the top Or at least the top way possible So trade regs Sell excess regs And we meet the regs to the 55% Even though we have more regs To do, we couldn't retain more regs and do that But by selling the regs We reduced our cost by $1.8 million last year $128 million $1.8 million $1.8 million So chart two showed where we ended up with that power supply After trading on the regs And we were 55% renewable And 2.2% of that was the distributed energy So next chart three This shows where we are right now With the committed resources Compared to the proposed Or the current tier two requirements And the proposed tier two requirements So I want to just walk you through that Give you a lot of information From my X axis Has each year going out through 2013 The columns The stack columns are Committing resources From tier two requirements And each of those are PPAs that we have With developers Except for the top, below Which is net unit And that net unit Obviously that net unit hasn't been built yet But that's our projection That it used in 2019 In a greater resource point The solid black line Is our projected tier two requirement under the current regs The dash is under the proposed regs So what does this take? Under the proposed regs Assuming that unit comes on as we think it will We have enough resources right now To meet the proposed regs to 2030 So what's that mean? So how will that What's going to be the impact then Compared to going from the current regs to the proposed regs It's primarily going to be We're going to retain low regs And not be able to sell as much And a lot of cost Just to make sure I understand For the net year in component That stacks well above the solid black line Because that creates an opportunity For you to do some reg sales For instance, like you're saying That you were able to bring in $1.8 million That then you could apply to lowering your energy costs For your customers That could, am I understanding that right? And then As a result of the net year? As a result of reg sales You're able to generate income That reduce your net cost of power To your current customers That's correct Okay And then if we go to the solid line You're short of You're short of what you would need to have So you'd have to be acquired You're knowing of a reg sales opportunity You're going to have to be purchasing Is that going to happen? Is that what the going above the Your total supply indicates? I'm not sure how to read the dotted line Yes, okay So let me walk through the dotted line So this dotted line shows That let's look at only the Let's take the blue line That's net meter Okay The dotted line shows that even without net metering We currently have enough resources To meet the proposed tier two requirement Until 2025 Okay And then beyond that We would need something In 2026 we would be short Without a net meter Because the dash line goes into the blue So net metering wouldn't be helping us then The confusing thing to me about net metering is You may be able to get the recs But net metering is still extremely high cost power So how does that affect the price to the rate pairs? Well, good question That's the table Okay, I don't want to get that Well, I'm sure on time maybe we should go there So turn to the table There are two tables Table on the left shows the cost of EDC If we met our short following tier two At 9 cents a kilowatt hour Which is if we were to enter a PPA With any developer that's not going to be on the show And you see in 2032 The total increase in our cost Is 2.3 million The chart on the right Shows if we were to Eat our shortfall at 14 cents a kilowatt hour Which is actually a little bit below the current net metering rate That's 4.3 9 million So an extra 2 million through 8 pairs Yes, but you heard Mr. Smith saying that just a few minutes ago That his range was 15 million to 25 million For a GMP We don't want to age their size You multiply by 8 You get just about his range 16 million And this doesn't take into account the constraints In your service area, does it? That's correct But the two bullets below that Yeah, I explained that this does not take into account Any of the infrastructure across the collection Or below the sub-transmission system that Mr. Cassini is talking about We will eventually have those constitutional and it does not have those So likely if we added this much net metering to that system It seems to me like we would be forcing more curtailment Of the larger producers That is correct without a bigger transmission system Right There we go Just do it What I think I learned today or was more clear was when it comes to Upgrading our transmission system for distribution to ISO share I think it was your testimony When it comes to upgrading our system to get generation out It's solely on us That's correct And I know that's sinking in a way that Some of this wasn't as clear as it has been So when you're curtailed You either, as Senator Rogers says Deal with oversupply Possible oversupply and net metering And or you find a way to market some of your electricity Yes, and to do that we're going to have to upgrade the system There's more of a fashion light bulbs in the kingdom so we can burn some I will ask a question about electric vehicles when it's appropriate We only have 10 minutes, I'll ask it now Washington Electric is the most similar to your co-op Washington Electric is not curtailed Washington Electric has slightly fewer houses per whatever Yet Vermont Electric Co-op has the lowest subsidy cash subsidy for electric vehicles Which and it is the most constrained area in the state Were you to go in and say we need a rate increase because we're getting squeezed Why wouldn't the PUC say We're not giving you a rate increase until you start subsidizing electric vehicles in a way that So you can begin to sell some of your constrained power But why are you so reluctant to Invest the money to sell your constrained power and to sell the power between midnight and four o'clock in the morning that if sold Would reduce the electric costs of all your rate payers. Why are you stuck on not being able to deal with that today? I'm going to say it's not a fair question for Craig because he's our power supply guy and we Want to make sure he gets through the tier one and I'm very happy to come back and talk about our tier Perfect, thank you valid question. I will point out those If these This chart here that shows our tier two requirement It includes our projection of electric vehicle adoption, which I've been told is Faster than any other utility is assuming right now Will be heck of a lot faster if it And then I'd like to make One more point before we move on as I understand it Also the constrained power You can get The the big wind or the hydropofect or whatever else is being constrained up there A lot of that is less costly power than the new net metering That is shown in your graph coming on with me. Yes Okay, so um who are on the last two witnesses I would Say can we reschedule rather than ask you to rush go triple time through something What we want to slow down enough to make sure we Understand the What we're working our way through is there's some complexity and nuance. They just love hanging out here So I So knowing that we have five more minutes, there are things in here that you want to draw our attention to before we adjourn for today Sure, two things one thing we skipped we Turn the page from where we are the top Chart there shows different topics table from the department public services 2020 you know energy report and it shows Cost comparison of different carbon With the most So we have time to look at that walk through that and we think that's important because the You know the cost is big concern to us The other thing I point out that the only the only two tier two options on there. I don't want to highlight any yellow On the bottom part of that page is A little discussion about our community solar project that we have that is similar to net metering Except that vc developed it. We're able to bring in a line. It's really cheaper than net metering but Members aren't able to put it on the net meter on the roof Have been able to take a grand Can you explain just a little bit about how I mean this could have been a facility You build your own generation and you're simply the off-taker from your own facility. What's the relationship between buying sort of creating this and supplying your Your system and then customers buying into it Trying to understand what Compared can you contrast that with traditional net metering? so We could have put it in our own resource mix, you know every member We open it up for members who won't specifically want to support the power Which is similar to that here except that it's much cheaper than this Did you want to add anything? Yeah, just up because it's market-based. We went out to bid. We got competitive rates We're able to negotiate that and leverage that you know like us You know purchasing on behalf of our members. We're able to negotiate a better rate So you're not the owner so that The facility for you are we are now Owners we have a ppa basically Senator and one more thing before I go on I think I've pointed this out to the committee before because I've tried to get Net metering down to the 150k w but I see in your chart the net metering up to the 5k w Is much more costly per savings on carbon Is that am I reading that correctly? Yes, unfortunately, this is a chart from the department public service So i'm not exactly sure how they came up with the values, but It is Just conceptually Less expensive per unit to build a 150k of each project than it would be able to buy k Interesting. Yeah Uh, it's every now and then I want to apologize to in your call She we've been talking about electric vehicles since and she has told us that If the bell um fun electric co-ops has been working on maybe adjusting that that subsidy and I didn't I want to recognize that That's being worked on. That's my apology. Thank you All right, so um We are being called to the florida And um, if unless there's one more thing you want to say before we ramp up. Yeah, just Okay, I'm tired and you just Just summarize what I just said I guess like the only one point we do not We do not support the provision that would limit our ability to Or any resources we could serve the rest of the capture That i'm important just the limits are negotiated. All it can do is There's a tier one, uh If the hundred percent by twenty thirty components, is that a are you Find with that cost can you manage that or is that a stressor to your system? Well, what i'm hearing is that tier two is more of a cost than tier one discussion. Yes, so If you turn to these tables The tier one cost impact is the left most Cobbled In each of those tables. So it is the smaller impact Okay, great We're going to condition on it right now, but that's an indication how much we've got So thank you again and to witnesses we didn't get to appreciate your flex building and we'll schedule time next week With that we are adjourned Thanks very much everybody