I put a bill in one of my first sessions in the Senate that had a gradual change in what people would pay based on income. And so it went up to when people got to social security age, they went to a fixed payment system. And when they were younger with theoretically less money, a half fixed system. And then in the middle, when people are earning the most money, increase. So it was an income sensitive, but it was more of a short form bill. And we never, I was trying to remember, I think Susan Bartlett, nope, she was in appropriations but I forgot, I presented it at finance and we had a good time talking about it. That's an interesting concept. One of the things I would like to get my head around at some point is, you know, I know we all probably around campaign season, et cetera, you know, hear about these kinds of issues and how do we compare with neighboring states and that's something I would like to join fiscal to take on. They probably have the information.  Equalized pupil spending, et cetera, like in those states. Well, yeah, New York state is interesting because they don't second homes are very much taxed very high in New York state for education. Oh, that's interesting. I didn't know that. Yeah. I mean, so our state doesn't give a lot of forgiveness either, but at least it's within the commercial industrial, the non homestead home site, non property tax area, non home site, homestead. Senator Taranzini's comments brought back a lot of the memories of doing act 60 and gold tones. And maybe Jim will tell us more about that today or someone. Yeah, that's a perfect introduction to Jim Demeray. Jim, thanks for being with us, our ledge council. You know, this history I find is brought up regularly, whether it's Brigham, act 60, act 68, act 46, and we also know of a recent court case having to do again with religious schools and dual enrollment. So we thought we would have Jim come in and talk to us a little bit about each of these. And so, Jim, with that, thanks for being with us. We all, we know everybody wants to get to and watch likely inaugural kinds of things. So no pressure. You take the time you need and but we won't keep people too late, that's for sure. OK, well, terrific. I've got my IT assistant here, otherwise, it's my daughter next to me. Wonderful. OK, so trouble getting this presentation up, but I think we should be OK. So we're going to screen share and find. That's this one here and we also and then go up here. So I get the screens. OK, so thank you. Can everybody hear me? Yes, perfectly. Thank you. Yeah, great. OK. And can you see the slides? Yes, thank you. OK, great. OK. So for the record, Jim Daimler, let's console. So this presentation, Joe Campion asked me to discuss the rights case that came out last week on dual enrollment, but we can't talk about that case without talking more broadly about what the parameters are for using public funds to pay tuition to religious schools. So we need to start there to frame it and we'll get at the end toward the rights case or discuss that. So I'm going to start with the US Constitution and where it says about religion. So the two clauses says Congress shall make no law respecting and establishment of religion, so called the establishment clause. So pausing there for a minute. What that gets to is we're not going to have like England and Agrocon Church that is a part of the government. We're not going to establish a religion. I also go to the question, though, as we come on to about how much support can the government provide to religious organizations without running a fall of this prohibition on making a law respecting and establishment of religion. So it goes not just to establish a church, but also how much government support is permissible. The second clause is Congress should make no law prohibiting the free exercise thereof. So that one, of course, goes to we can't interfere as a government with the exercise of religion by individuals. So those are the two clauses we're going to talk about today. So these clauses apply to the states, not just the federal government through the process of the 14th Amendment. So Vermont is bound by these clauses and there's a tension between these clauses. So the Supreme Court has recognized a plan play in the joints between what the establishment clause permits in terms of support for religious organizations and what the free exercise clause compels. We'll get into that. So it's a command on the one hand, not to establish religion. And on the other hand, a command not to inhibit its practice. So, for example, a law requiring the hiring by the military a priest to minister to the troops may be viewed as a law respecting the establishment of religion because the government is hiring priests. But not making priests available may interfere with the troops free exercise of religion because they're out in the field and they may not have any other means in which to practice their religion. So that's an example of the tension we're talking about here between these two clauses. So first question is what does the establishment clause permit by way of government support for religion? In the leading case here is Zellman versus Simmons Harris doesn't choose Supreme Court. So Ohio established a voucher program that allowed taxpayers or taxpayer money to be used to pay tuition for both secular and religious schools. So the parents would we decide how to spend that money. A two percent of the participating schools were religious schools and 96 percent of students using the vouchers attended with the schools. The Supreme Court appell the program against the challenge based on the establishment clause on the basis that if a government aid program is neutral with respect to religion, and this was neutral because it was for both secular and religious schools, provides assistance directly to a broad class of citizens who in turn drug government aid to schools wholly as a result of their own genuine independent private choice. Then the program is not really subject to challenge under the establishment clause and the court imposed no restrictions on the use of public tuition funds by the schools so they could be used to fund religious instruction. So what we learn there is that on that first clause, the establishment clause, you can use is permissible to use state money to pay tuition to religious schools as long as the program is neutral and provides assistance to a broad class of citizens who direct the payments. OK. So we know it's permissible. The question next is what does the free exercise clause compel and what this gets into is the question of discrimination against religious religious programs or schools. The main case here is Trinity Lutheran versus Comer, which was a 2017 Supreme Court case written by Roberts. It's a playground case. So Missouri created this program to grant program to resurface playgrounds as for safety of kids and a church which operated a religious daycare program sought to get this grant funding and was denied because it was a church to brought a free exercise challenge and the denial of that grant for that that church or that church was based on the Missouri Constitution which provides that no money shall ever be taken from the public treasury directly or indirectly in aid of any church. It's a so-called no aid provision that's in many constitutions state constitutions. The Supreme Court held that this denial by the church's free exercise rights. So what it says is that the free exercise clause protects religious observers against unequal treatment and suggests the strictest scrutiny laws that target religion for special disabilities based on the religious status. So applying that principle, the court this court has repeatedly confirmed that denying a jointly available benefit solely on account of religious identity imposes penalty on the free exercise of religion and can be justified only by a state interest of the highest order. And the court find the Missouri's policy preference skating as far as possible from religious establishment concerns can qualify as compelling. So let me pause there. So we talked initially about the establishment clause does permit tuition, public tuition be used for private schools for a mutually designed program. What this is saying is that the state is compelled to provide funding to religious organizations. They can't discriminate against those religious organizations solely on account of the fact that they're religious. So if you're giving it those funds to a secular school for for playgrounds to do their playground, then you can't deny it can't be prejudiced and deny it to his school just because they are a religious organization. Very importantly, we'll come to this when we get particularly to Vermont's Constitution, the court distinguishes the lock case. In this case, this is a program by the state of Washington to provide scholarship funding to assist students with the cost of post-secondary education. It could be used to both secular and religious schools, but cannot be used to pursue a devotional theology degree. So it could be used of both types of schools. It can't be used to pursue a religious degree. The court, in that case, denied a free exercise challenge by an individual seeking a devotional theology degree, holding that the individual stand was daily, was not denied a scholarship because of who he was. He was denied a scholarship because of what he proposed to do. The funding and issue in Trinity was denied based on the church's status as a religious institution. So this gets into distinction between use versus status. So what this is saying is that you can't discriminate against a religious school solely based on a status as being a religious school, but you can pose restrictions on how that money is used by the religious school. So use versus status distinction is being drawn now under the free exercise clause. And very interesting concurring opinion by Gorsuch, I just wanted to read this with you. It said, the court at least opened the possibility a useful distinction might be drawn between laws that discriminate on the basis of religious status and religious use. Respectfully, our Harvard doubts about the ability of such a line. Does a religious man say grace before dinner? Or does a man begin to be able to enable his mirror? The distinction blurs in much the same way the line between acts and omissions blur can blur when it's still at too long. Leaving us to ask, for example, whether the man who draws by weighing the incoming tie does so by act coming upon the sea or omission allowing the sea to come upon him. Often enough, often enough, the same facts can be described both ways. OK, so we're still talking about the free exercise clause. This is the second case we talked about Trinity. We start with playgrounds, resurfacing playgrounds. Now we're going to talk about exactly tuition. You serve public tuition. So espionage of the Montana was decided in 2020. The opinion was written by Roberts. This is a case where Montana provided tax benefits to individuals who donate money for private school scholarships, scholarships for prohibitive families from using the scar of religious schools. This provision was based on the Montana Constitution, which bars government aid to any school controlled by a church. Another so-called no aid provision. Building on its Trinity decision, the court held that Montana's no aid provision violates the free exercise clause because it bars religious schools from public benefits solely because of the religious character of its schools, i.e. the status as opposed to religious use. Roberts wrote that some members of the court have questioned whether there is a meaningful distinction between discrimination based on use or conduct and that based on status. He said, of course, which is a good growing opinion. And he said, we know it's just the point, but need not examine it here. It is enough in this case to conclude that strict scrutiny applies because Montana's no aid provision discriminates based upon religious status. And then the court said that the Montana Constitution is no aid provision, which is added to its constitution in the second half of the 19th century. Many states add similar provisions, so-called many plain provisions, which spawn a bigotry against Catholics and that these provisions hardly invent events, a tradition that should inform our understanding of the free exercise clause. The court concluded that a state needs not subsidize private education, but once a state decides to do so, it cannot disqualify some private schools solely because they are religious. Gorsuch wrote a recurring opinion in line with the recurring opinion in Trinity, challenging the status versus use distinction. OK, now we're going to talk about the Vermont Constitution. I just lost my place. Here we go. Chapter one, Article Three, which says, no person can be compelled to support any place of worship contrary to the dictates of conscience. OK, so note the difference from the no aid constitution provisions like Missouri's and Montana's. Vermont's provision is based on youth supports worship instead of religious status. So this is where this youth versus status distinction really comes into play, because Vermont's constitution is different than the ones we discussed before. I note that Vermont's provision was part of its original constitution and not add later as was the case with the anti-Catholic blame amendments. The leading case we have in Vermont is Chittenden versus Department of Education. Decided by the Vermont Spring Court in 1999. Vermont Spring Court held that a school district violates the compelled support clause where it pays public tuition to religious school in the absence of adequate safeguards against the use of such funds for the just worship or instruction. So this was a case where Chittenden near Rutland is a tuition town and it was paying or wanting to pay tuition. I think it was the St. Joseph's in Rutland. And the court said, no, you can't do that. Not because of the religious status of the school, but because there weren't safeguards to ensure against the use of the funds for religious worship or instruction. So the question then is, will Chittenden survive the espionage of decision? Vermont's compelled support clause, as interpreted by Chittenden, bars the use of public funds for religious worship or instruction in contrast to the constitution to bar aid to churches based on status. But does this distinction matter? Robert's is hedging on that and Gorsuch is just challenging that. Vermont's compelled support clause was done part of the main plan amendments at the other six constitutions that were based on bigotry has its own unique history. Okay. So I'm leaving there, I must move on to dual enrollment. It's an open question right now as to what the Supreme Court would do if there's a direct challenge to Chittenden with the Supreme Court. We say that's okay because it's a use provision and that's okay under espionage or if it would say that decision doesn't matter anymore. So it's not not permissible. So it's so it you have to that and that's the case that you have to use state tuition for religious schools. Is that clear whether how they're going to go on that question at this stage? So it's not clear what the answer to this question is. So what about dual enrollment? First, what is it? So dual enrollment is taking a class for both high school and college credit at the same time. It's available to public school students to approved independent school students who are on public tuition and homeschool students. It is not available to approved independent school students on private tuition, whether attending a secular or religious school. Following the Chittenden decision, all children attending religious schools pay price. So I'll just note there, that's a fact, but under Chittenden it doesn't have to be a fact. If there was a system whereby the schools could ensure that funds weren't being used for religious worship, then under Chittenden they could use public tuition. So the Rice case, a group of Rice Memorial high school students, stood the agency of education, claiming free exercise class and equal protection class violations. I start thinking that denial of dual enrollment to Rice students is due to the religious status of the school. Last week in January 15, the Second Circuit Court of Appeals ruled in favor of the students, holding that the denial was due to the school's religious status. The court noted that in the more than 20 years since Chittenden where it's decided Vermont has not identified adequate safeguards to ensure public funds are not used for religious instruction. And moreover, the court noted that since at least 2010, the agency of education has frequently stated that public funds could not be used for students attending religious schools, a statement based on the school's status rather than its use. So I'll pause here and say that the record before the court in this case was not great for an argument that the decision was based upon use, not staffs, because of the fact that we haven't developed parameters to determine when safeguards are in place to ensure funds aren't used for religious instruction A and B, both AOE and the district involved here basically said we're denying you based upon your status. So the court concluded that the record on this appeal plainly evidences religious discrimination, sorry. The court also said that because our decision turns expressly on religious status and not religious use, we stress no view in this opinion as to whether Chittin' this requirement of adequate safeguards could, if applied, constitute a use-based restriction that survives first amendment scrutiny. So this case was decided by the federal court of appeals and if it's not appealed, then it would stand as law. If it is appealed to the Supreme Court and the court opposed it, it would be the law for dual enrollment or it could overturn it. So it's not quite clear, it's not done yet. I'm not sure it's going to happen on appeal or if it will be appealed. But currently the court has ruled that these students are entitled to dual enrollment. And that is the end of this presentation. So I guess I will stop my screen share for a minute and come back to you and see if you have questions. I'll just kick it off. So let me just run one scenario by you. A religious institution, a religious high school says, you know, we are not going to offer, we are not going to offer a senior history class or senior math class. In lieu of that, we want you to use your dual enrollment dollars. So in part they would be eliminating a position, a teaching position and saving dollars because students would be taking their dual enrollment dollars to CCV or somewhere else. Therefore freeing up funds that could be used for religious instruction, paying off a lawsuit, all sorts of different kinds of things, you know, paying the minister's salary. So is that what Chittenden was hoping? Is that what the kind of parameters Chittenden wanted? In other words, to say, Brian Campion, you're at Rice, Rice has to stick to its curriculum. You can use your dual enrollment dollars. That's fine. But what Rice is not allowed to do under these guidelines is in any way alter its curriculum to save money and therefore by allowing these freed up dollars to pay the minister's salary, pay off a lawsuit, whatever. Yeah, so that question conflates to two things. Actually, it conflates the establishment clause with the free exercise clause. And I know where you're coming from in this because in the old days under the establishment clause, remember, the question is, is it permissible for public funds to be used for religious schools? Okay. Not are you compelled to use them, but is it permissible to use them for that purpose? And we talked about that case. We said that as long as you have a mutually designed program and parents are making the choice, you are able to use public funds for religious schools. Before that, though, before that case, exactly what you're talking about was law, which was used to be a diversion argument, which is say, if you give money to a religious school, they can then divert funds because they have more funds. So even though it can basically free up other resources for religious worship. So under the establishment clause, it used to be that you couldn't do that because of the diversion argument that you're making. But as of 1990 or so, under the newer interpretation under Zelman, that argument is no longer in effect. So now diversion is gone as an argument. And now if long as your program is neutral and parents decide where the money goes, it does not violate the establishment clause. Okay. Chitenden is under the free exercise clause. So when do you have to pay money to religious school? When you compelled to do that. And what the court saying in Chitenden is under the mock constitution, you can use the money to go to a religious school. If the school has parameters to ensure that that money is not going to with this instruction. So if they could show a system that shows the money coming in from public tuition is going to pay for the gym class or the history class or some classes not religious instruction, it sounds like that might be acceptable. But no schools have done that. No. And no state hasn't developed that either. So there's been no guidance as to how that would work. Is that answer your question? I think so. I might come back. Give me something to think about center lines. So I haven't heard all of this before. So it's it's a lot. So but I guess my question is if you think about has has there ever been an argument in thinking about the dual enrollment program as the opportunity for the student and the child that the money goes to the child to go to college and that without it at whoever this kid is without it, then it's unequal treatment under the law. So could you consider the fact that the dual enrollment program isn't about the religious institution or the private institution or the public institution? It is about the child, the kid going to college and increasing our college entry for Vermont students and without that opportunity that that child receives unequal treatment. Yes, I think that though is one of a policy argument. So certainly from a policy standpoint, you can make the argument and there are lots of ways you could do dual enrollment from a policy standpoint. You could mean test it, for example, you can make it available to all there are different ways of doing it. The way Vermont's done it is to basically allow it for students on public tuition, basically. That's how we've done, but there are different ways of doing it. Interesting. I see other other hands. I'm sorry, Senator Chen. I'll go to your points as a chair, Campion, the way I am reconciling what we've just heard is if it's for the benefit of the school, if the school for their benefit asks or has the student take the course, that seems inappropriate. But if it's for the student's benefit, for their convenience, if they opt, if the power of choice is with the student and they're not being asked to for the benefit by the school, similar to how workers compensation works with work from home, if the employee is benefiting and the employee chooses to work from home, workers compensation doesn't cover them. But if the employer says, we need you to live from home, work from home, because we're not giving you a workspace, workers compensation extends to their workplace. So similarly here, I think it sounds appropriate if the student is choosing to go to to go to do a university, a public institution for this dual enrollment program, but it is not appropriate if the religious school is opting to benefit their curriculum by requiring or demanding the students use it. I don't know. Well, the way the program works is that the money goes from the state to the college. Right. So it goes to UVM or to VSC or even private colleges. So the money goes to the college and the students who are entitled to get that entitlement are ones on public tuition. That's how it actually works today. I can't I can't go into the analogy you made because I'm not familiar with it, but that's just how it works now. Senator Hooker, thank you. So if a student at Mount St. Joseph opts to take a course at Castleton, currently they can't or well, perhaps after the right decision now they will be able to to take that course. I don't I'm not familiar enough with the dual enrollment program to know what the parameters are. So and you've said that the money goes directly from the state to the college. So it seems to me that it really doesn't benefit the school unless we get into the complicated issues that Senator Campion brought up about diversion. But you've indicated that that's kind of been taken care of. So is there really anything that should preclude those religious school kids from benefiting from taking a course at a secular college as long as it isn't a religious institution as opposed to the kids who are on public tuition? I know that the way the program is written now, it says they have to be on public tuition. But is that the only as far as dual enrollment? That's all it is. It's taking a college course, correct? Correct. It's taking, I think, up to two college courses while you're in high school and getting credit for both high school and for college at the same time. That's what dual enrollment is. So so it may be cutting down on the costs at the it may be cutting down on the school's costs. If enough kids take these courses and they can, I don't know, cut down on a number of classes they have. Like, I don't I don't know how that would play out. It could be a benefit to the high school, for sure. And that benefit could be for secular or religious schools because there's no diverse argument anymore. So that argument's gone. So and for me, you know, I'm just learning about this as well with all of you. I'm wondering, so for example, it's in a way, let's take the law school suits before the Catholic Church, OK? If if you are saying if a school is saying we are for directing their students to take because it's dual enrollment, you get both high school and college credit if a school is eliminating a program and therefore freeing up funds because their students are going somewhere else, I see they're not getting the dollars directly, but the line item in their budget was now freed up to go toward other things to pay off a lawsuit, pay a minister's salary, do those kinds of things. I'm not saying I have an opinion on I'm just trying to pull this separation, you know, here apart and, you know, and just kind of understand it a little bit better. Does that does that make sense, Senator Hooker? Yeah, I mean that and I guess my question would be how extensive or expansive would the dual enrollment from a school have to be to affect such as change, you know? Yeah, that's that's a great question. I think that might be, you know, somebody would have to take action. In other words, if all of a sudden the school you referenced has, you know, 30 students in their graduating class and they're all going to Castleton for that one class and they've eliminated a position, you know, you can see where that might spark attention or perhaps concern, but I think that would take additional action from students or parents to actually bring it to the court's attention. Attention, what I was wondering in part in my question, is there a role for the legislature in any way at this point or should we be doing anything to protect, to put parameters, to put boundaries around how these dollars may or may not be used? And I don't know the answer to that question. And I think Jim referred to that when you talked about the Chittenden case and the fact that there were no parameters and that's why the court ruled the way it did. Yeah, there are a couple of things to mention. So on dual enrollment, you could take action to amend the statute and you have the court case, as I mentioned, it might be peeled so it's not final, final yet. You might want to wait and see what happens or you could take up that statute and think about how you want to frame it in terms of do you want to make it available to all students? Do you want to make it available to all students? But means tested. You know, so there are various ways to start thinking about dual enrollment itself, that statute on the question about the broad question about Chittenden and the whole question about use of funds by religious schools, you could come up with a statute that, for example, that that directs the state board of education to adopt a rule which defines basically the controls necessary to show that public tuition is not being used for religious worship. So you could actually have some definition behind that, as Chittenden suggested 20 years ago. So a couple of things you could do here if you wanted to take action. Helpful. Thank you, Senator Hooker. And could I just ask Jim to send Jeannie this presentation as well, because I saw on our website that there are only the two presentations on 60 and 46. She's got them all. I think so. They're all up. Are they OK? Thank you. Sorry. Thank you. That was helpful. Any other questions or comments before Jim moves on? OK. OK. I'm going to go back and screen share again. And grab the we're doing act 46 next, I believe. And OK. Can people see that? Can you see the slide? Yes, I can see. People hear me? We can. OK. Good. OK. So this is actually six. So let's go pre act 46. So there's an article written by Bill Mathis that was published in Vermont Digger. He made these points, which is that there was a so-called vicious act of 18 at 1892, which required towns, town school districts to consolidate the 2,500 boards into two hundred and thirty nine town and corporate boards. So by by a sweep of a pen, basically, that was done back in 1892. And to note their policy for a minute, we are so called Dylan's rule state, which means that the state has complete control over its municipalities and school districts are, of course, municipalities. So we can create them. We can merge them. We can we can eliminate them. And that's what happened here in 1906. Supervisory unions were formed. Push forward to we had the school districts being created. And then in 2010 as well, we had two acts, acts 153 and 156, which provide tax other incentives for school districts to merge. Then in 2015, Act 46 expanded on acts 153 and 156, providing tax and other incentives for school districts to merge and directing the state board of education to realign unmerged districts into more sustainable municipalities to the extent necessary to achieve the act's goals. So this was before it was as incentives only Act 46 was a carrot and stick approach. The goals of Act 46 were five on equity and educational opportunities to increase student achievement to maximize operational efficiencies to promote transparency and accountability and deliver cost at value. The structure of Act 46 was that first that that school districts cannot be forced to give up tuition or operating models. It said that its intent was not to close schools and encouraged a preferred government structure. And that structure was a merger of districts within a supervisory union or with a neighboring supervisory district where the combined combined group now merged was responsible for K through 12. Had 900 or more students and operates K through 12 directly or operates K through six or K through eight intuitions of the grades. So that was the preferred structure. And that was where you got the most incentives if you did that structure. Act 46 also recognized, though, that alternative government structures may be acceptable. Alternative government structures anything other than the preferred structure. And required districts seeking alternative government structure to do three things, one, to evaluate its current ability to meet or exceed the state goals. To meet the districts in the area to discuss ways to promote improvement in the goals throughout the region and three submit and alternative government structure proposals to the state board individually or with other districts. Act 46 required the secretary to develop a proposal to realign a merge districts into more sustainable models of governance. This proposal was presented to the state board by June 1 of 2018. And then the Act 46 required the state board to issue a final statewide plan by November 30, 2018 to merge and realign school districts and to advise your unions who are deemed necessary to meet state goals. And Act 46 prohibited the state board from forcing school districts to give up their tuition or operating models. So the results on the state board's merger order. Merge, and this comes from Daphne from Donald Saavage. She presented this to education a couple of years ago or last year. And she said that the state board went to order merge 45 districts into 39 towns to form 11 new union school districts and large two existing union school districts and conditionally require an additional four town elementary school districts to merge. That was conditioned in power approved by the other merging districts. The state board merger order did not change the government structure of 47 districts and resulted in a net reduction of 34 districts. So in fiscal year 16, prior to Act 46, there were 267 school districts and in fiscal year 20, after the approved mergers, there were 154. After the state board mergers, there were 120. And I mentioned that there were four additional additional mergers. I believe they did merge. I think we're down to 116 districts now. So there have been a number of attempts and some successes at Act 46 divorces. I'm getting this from news stories because there's no source of this information at AOE or Secretary of State. No dad there until later in the process. So this is based upon reporting by Vermont Digger and others. But first Halifax and Weasboro have voted to merge. So it was a voluntary merger and they decided to unmerge. And that was approved by the state board of education. So that's been done. Newbury was forced to merge with Bradford. And Newbury voted against divorce when it came up. So it looks like they're staying together for now. Westminster was forced to merge with Athens and Grafton. And Westminster voted to divorce. But Athens and Grafton, we need to approve that. And I don't believe the source of happened yet. Ripton voted to leave Addison Central. That was a voluntary merger. So now Shoreham, Cornwall, Millbury, Bridgeport, Southsbury and Waybridge will now each vote on whether to allow Ripton to leave. Tumbridge and Chelsea voted to merge, voluntary merger. And Tumbridge had a vote recently against divorce. So it looks like they're staying together for now. And then Bradborough, Dumberston, Gofford and Putney were forced to merge into Wyndham Southeast and have Bell items to approve divorce. So here's the law on divorce. We've got two laws and they both predate Act 46. And they're a bit not in conflict. They're different standards. So 721A is the statute of about withdrawal from a union school district. And it says a union school district that is a member of a union school district may vote to withdraw from the union school district if one year has elapsed since the union school district was formed. OK. And then 724 is withdrawal for a unified union school district. A unified union school district is one that came together as a merger of districts, either voluntarily or not, or ordered by the State Board. And it says a town or city corresponding to a preexisting school district that voted to form a unified union school district may vote to withdraw from the district of when one year has elapsed. So the difference here, the next page, is you have the standards being different. So for a union school district. It appears that a district can withdraw whether voluntarily merged or forced to merge. But for a unified school district, it appears that a district can withdraw only if it was voluntarily merged. And that's because, going back here, for a union school district, there's no condition about it having been formed by a vote. So whether it was formed by State Board order or by voluntarily by vote, it can withdraw it's been one year since it was formed. But this one says for a unified school district only can withdraw if it had voted to form the district. So that means that forced mergers can't use this section or that's how it could be interpreted. So we got a situation where the preexisting law, DAF 46, has different standards. And then an either case for either a union school district or a unified school district, on either case, all districts or towns in the union unified school district need to approve the members withdrawal. So what happens is, first there's a vote of the member that wants to withdraw. If that gets approved, then all the other districts on the same day vote to approve that or not. If they don't approve it, they can't withdraw. If they do approve it, it can move forward. And so if it moves forward, if they all approve it, then if the State Board finds the students in their withdrawing town or say, well, attend a school that is compliance with its rules for educational programs, the State Board shall declare the membership of this drawing town or city to be at an end. So the State Board's got very little discretion here. As long as the students are attending another school that meets its rules, it has to allow the withdrawing town or city to withdraw. And the State Board is not under law in making this decision required to take into account the goals of DAF 46. So a couple of issues here. One is we have two different standards for withdrawal. Don't really make sense, as I mentioned, because it will allow, for example, a union school district that was formed by State Board order to withdraw, but a unified school district formed by State Board not to withdraw. So that's an issue. And then secondly, the process for withdrawal involves the State Board, but having gone through all this to meet the goals of DAF 46, there's nothing here in the law that requires the Board to take into account whether those goals are met when that member district withdraws. I just want to pause there for a moment, Senator Perksley. Yeah, thank you. Jim, can you remind me the difference between union and unified? Yeah. So a union school district is like a union high school or union elementary school where various towns come together and form a union school district. So, you know, all kids going to grades 90, 12, go to Wissauke High School, for example, from those towns. That's a union district. A unified district is a district that was formed by merger and is responsible for K through 12 education. So when we go back, we talked about the preferred model. We had a merger with districts that were part of the SU with 900 students, et cetera. That would be a unified school district because it was formed by merger and is responsible for K through 12. Those are the differences. We're in a perfect game of follow up. No, I'm just still unclear, but I think I understand it's sufficient. Do you want me to go through that one more time for you? Would you? Yeah, sure. So because like if there are aren't there union schools that do K through 12? Yeah, there are. Well, part of the problem is with terminology here because a unified school district that's called the union unified school district. So the terms are confusing. But when I'm saying union here, I mean, in my example, towns might be responsible for K through 6, for example. OK, not responsible for K through 12. They are responsible for K through 6. They operate school for K through 6. But they decide to get together with other towns to form a union school district, high school district to educate 7 through 12. OK, so that is a union school district. It's not covering all grades. It's covering, again, 7 through 12, my example, formed by the surrounding towns to educate those students. A unified school district by definition came together by merging pre-assisting districts, first of all, which is in the case of the union school district that merged pre-assisting school districts to form one and that one school district now is educating K through 12. It might be educating K through 12 and more than one school. Yes. Yeah. Yeah. Thank you. I'm going to stop screen sharing now so I can see you. OK. Great. Other questions. OK, thank you, Jim, that we just wanted to get an overview. I know some of these things will all have to get, you know, return to at some point, but that was that was helpful. OK, should we go to the next presentation? I have one more question on Act 46. And that is, is that map, Act 46 map still up in the Education Committee room? I haven't been there in ages. Nobody's been there to find out. It was such a part of the committee room for so long. If you want to see that map, though, it's on the AOE website. Right. So I hope to get up there maybe next week and work a day from the state house. I'll check in for you, Senator. Or maybe you can meet me over there. OK, so I'll go back to screen sharing. And put this. Let's see. I had to see. OK. OK, so we're not talking about about bring them. But there is a line to follow here. And the line to follow is what was how to work for a barrier? What was being challenging, which was the foundation plan? What to bring and say? What does Act 62? I'm not going to go into detail there. Just one page. And then we're going to come on to waiting. It's because bring them. The fact pattern and bring them is not that somewhere there was happening in case, in the case of the waiting report. So there's a line to be drawn here through all this. So starting with the what was happening before bring them before bring them, there was the foundation plan. These slides here are borrowed from a presentation that Peter Griffin gave when he was a tax attorney here. So give credit for him for these first few slides. And and what happened is the state set a foundation amount. And this example is five thousand per pupil. And it's a base rate. And this example, it's one percent. And in this example, we have a town with a very small grand list, it's just an example of four hundred thousand dollars. OK. So what happened before bring them is that the town will raise at one percent, based on his grand list, four thousand per student, OK, which is below the foundation amount of five thousand. So the state then would give a foundation grant of one thousand to bring that school district up to five thousand. So that that's how it worked. When you add in two towns, you begin to see the equity issue. So you have one town with a lot of property wealth and one town with low property wealth. Let's assume that both towns want to spend ten thousand per pupil. Again, the site before the foundation plan amount is five thousand per pupil and the base rate is one percent. OK, so what happens here is that the property rich town, which has a million dollars grand list, can raise ten thousand per pupil at one percent. So there you go. No problem. Probably poor town can raise four thousand at one percent. It's getting a grant for the other one thousand. So how does it get up to ten is a question. So what happens is the town has to raise in green the excess amount to get up to ten. So it has to raise the amount in green here, which is five thousand per student. That results. In the property poor town, having a tax rate of two point two five percent. While the property rich town has a tax rate of one percent to raise the same amount per student. And that was the equity problem that was facing the brain court. Any questions on that before I move on? I don't see any. OK. All right. So the wrong Constitution has an education clause and a common benefits clause. The education clause basically is a right to education. So it says a competent number of schools ought to be maintained in each town, unless the John Assembly permits other provisions to the convenient instruction of youth. Two comments on that. First, it's unusual for states to have an education clause in its Constitution, but that's quite unique. Jim, can you enlarge in your your screen?  We're seeing all the slides at once. It'd be great just to see the one. Oh, or have some on the side. It would just be great to see that. I'm not sure I do that. Sorry. Whatever you were doing before. I'm not sure what I was doing before. That's fine if you can't. No big deal. Go up to where it says slide show way up above on the up up above. Right.  I keep going to your right. Keep going to your right. Yeah, right there. Yeah, I just click on that. Yeah, just click on it so you get your. And then you go to from current slide over on your right on the. Go up to your left. I'm sorry. I got my left and right picked up. Click on that one. Here we go. Thank you very much. Great. Oh, OK, thank you very much. OK. All right. So two things about this education clause. First, it's unusual to have one in the state constitution. There's no education clause in the U.S. Constitution. And second, the slowness about I found this on the web. Oh, sorry. My phone is going off. Second is, is that it talks about you have to have a school in each town unless the John assembly permits otherwise. So that's how we get to tuitioning. So the John assembly has a lot of tuitioning. So that's how we get to operating and tuition schools. Common benefits clause is a right, essentially, to equal opportunity. So says government is ought to be instituted for the common benefit, protection and security of the people, nation or community, and not for the particular moment or advantage of any single person, family or set of persons or a part only of that community. We put this together under the decision. There is there is a right to substantial equality of educational opportunity in Vermont constitutional right. OK. Brayham, which was decided back in 1997, held that the then current education financing system with its substantial dependence on local property taxes in result of wide disparities in revenues available to local school districts deprived children of an equal educational opportunity in violation of the Vermont Constitution. There are two levels of inequity in Brayham. One taxpayer inequity that town had to pay 2.25 percent versus 1 percent was led to an equal educational opportunities for students. The Supreme Court said that the distribution of resources precious educational opportunity may not have as its determining force the mere fertility of a child's residence. And the parties conceded conceded that the foundation plan resulted in unequal opportunities for students. But the state argued that this was justified by the state's interest in promoting local control. The Brayham Court rejected this argument, holding that the constitutional constitutional right to substantial equality of educational opportunity is essentially a state mandate that cannot be overwritten by local control. Therefore, the court held that to fulfill its constitutional obligation, the state must ensure substantial equality of educational opportunities throughout Vermont. Vermont's education funding system was substantially changed by Act 60 and 68. And the Vermont Supreme Court has not, in any meaningful way, analyzed the common benefits clause in connection with education since it should bring them. So we have no further precedent than Brayham to rely on. Act 60 and 68 retained local control over spending decisions but created a system of tax rate equity. So under Act 60, two towns with the same per pupil spending have the same spending adjusted tax rate. And two homes, one in each town, would pay the same property taxes if they had the same fair market value. And this leads into the weighing factors because there are many parallels to what's happening in this space with what happened in Brayham. So Chloe talked to you today about this, and I won't go into much detail, but just to highlight for you. We know that the property tax rate and the income sensitized rate are based on a school district's per pupil spending. And per pupil spending is determined by dividing education spending from the school budget, let's say 20 million, by the number of equalized peoples. Let's say 1500 per pupil spending of 13,333. If there were less people, so 1,200 equalized peoples, per pupil spending would be higher, 16,666. And there were more equalized people per pupil spending would be lower, 11,111. Actually, I've got one, two, many ones there. So therefore, higher equalized peoples equals lower tax rates, and lower equalized peoples equal higher tax rates. So the number of equalized peoples really matters in terms of your tax rate, and equalized peoples is determined by the weighing factors. So in order to determine equalized peoples, a number of weighing factors are applied to a school district's student count. The policy behind weighing factors is to provide more resources for school districts that have a relatively higher number of students that need those extra resources. So pre-K students are weighted at 0.46, about half of one person. Elementary and kindergarten students are weighted at one. Secondary students at 1.13, and students who are from low-income homes or English language learners receive additional weighting. Weighing is a zero-sum game. So, for example, a higher weighting for one school district with more students who are from low-income homes receives a higher weighting, so lower taxes. But that results in another school district with fewer of the separate students receiving a lower weighting. So it's all a shift between school districts. This weighing factor, if you have more students, which is less of certain characteristics, you're shifting tax rates among school districts. Note that the weighing system does not directly provide further resources for school districts that have a relatively higher number of students that need those extra resources, as will be the case with grant funding. So Chloe talked about that. Another way of pushing this is to give grants, which will provide funding directly for those students. The weighing system results in relatively lower educational tax rates and the ability of school districts to more cheaply increase education spending to provide additional resources. So it's creating more taxing capacity. School districts may choose not to provide additional resources, but instead benefit from lower educational tax rates. So there's a question that was not answered in the weighing report about whether, in fact, this tax system results in better outcomes for students. It definitely results in lower taxes. It's not clear that that tax capacity is being spent to help these students. Okay, so Act 173 from 2018, the weighing report found that the weighing formula does not reflect contemporary educational circumstances and costs, and that the existing weights have weak ties with any resources needed. The weighing report recommends adjusting the weight and adding new weights. We're going back to Brigham as our last slide. Remember that Brigham found two levels of inequity, taxpayer inequity, leading to unequal educational opportunities for students. Brigham found that the distribution of a resource that's precious as an educational opportunity may not have as its determining force the mere fertility of a child's residence. So the current weighing factors may result in taxpayer inequity because school districts receive a relative tax advantage or disadvantage from the weights, may result or lead to unequal educational opportunities for students because school districts which are most in need of additional resources are not gaining the tax and capacity to afford those resources. And this may result in unequal educational opportunities based on the mere fertility of a child's residence. So that's why when you hear, I'll stop my screen share. Brigham, that's why you hear that the weighing area is the next Brigham case because it has parallels to the fact pattern of Brigham. By that, Jim, a lawsuit is anticipated. Yeah, yeah, so that's what people make that connection. That's why, because there are factors there that do think up. OK, yeah, questions. We're going to get into this more on Friday when we hear the report from the weighting on the weighting study. We'll be presented to us. But any any questions at this point for Jim? In this, what was an incredible everything from the US Constitution to recent major education policy? Senator Lyons, please. So this is kind of a high up question. And it does relate to Act 60 and our common benefits clause. So going back to unequal treatment. When the Brigham decision was rendered, did it did it include overall spending or did it also dive down into programs? So I'm thinking of athletic opportunities. And I'm thinking of, I'll say dual enrollment, but maybe it would didn't get that discrete. But in terms of the decision, the Brigham decision, how far down into the school did it dive? It didn't dive down that far. And I'll say a couple of things about Brigham, because often I think it's been miscorded. So so first of all, Brigham was based upon gross inequities across the state for students and taxpayers. Right. So and that was just a given in the case. I wasn't going to argue. So gross inequities across the state involve both taxpayer inequity and student outcome inequity. OK. I've heard people say, well, every every town should be able to every school district should be able to tuition their students. It's it's unconstitutional under Brigham not to allow that opportunity for everyone. I've heard that it's unconstitutional for public for independent schools to take public tuition not to take special education students. OK, there are a lot of people who say based on Brigham, it's unequal, it's unequal. But remember that Brigham, as I just said, had basically basically gross inequity across the whole state on the tax side and the student side. So I think that's why I also mentioned that Brigham has no further precedents after it to interpret. So we only have that one decision. So I think people can easily say it's unfair or it's unequal. Therefore, by Brigham, I think it's a lot more nuanced than that. And I think the argument has to be much larger than that to maybe violate Brigham. Well, thank you. Other questions, comments. A lot to take in today. I recognize that I appreciate everybody's everybody's time and willingness to jump into both the weight weighting study, educational finance, as well as everything that that Jim has presented. Tomorrow, we are going to move on to our first bill, which will be presented by Senator McCormick. For those of you who are new to the Senate, again, we asked the presenter to come in, talk a little bit about the genesis of the bill, and then we'll have some witnesses and folks from the Agency of Education talk to us about civic education, where we're at in this state. And hopefully we'll have some time at the end of the committee to sort of talk a little bit about what direction people may be interested in going in with this or not. Any other final questions or comments for the day? Senator Hooker, everything all right? OK, OK, OK, you might have have a question. Thank you, everybody. Jim, thank you very much. I realize how much time and presentation, prep time, this kind of thing takes. It was well done and certainly help clarify a number of things for me. And now we have these resources to refer to. So thank you for your time today. But preparing for this. Senator Campion, yes, I will stay on. Do you need to have a comment for the committee? No, just for yourself and Jim to stay on. And let me know when you want me to stop the live stream.


Let's continue on and discuss some behavioral sciences. Specifically, we're going to discuss some studies. And we're going to compare and contrast six various types of studies. On this slide here, you'll see the cross-sectional study, cohort study, and case control study. The design of a cross-sectional study asks what is happening. This is going to look at the frequency of the disease and the frequency of the related factors or the risk factors that are associated at that specific point in time. This is like taking a steak and cutting it in half and seeing how the doneness of that steak is at that particular point in the steak. It might be different at various points, but at that one specific spot, this is what is happening. Cross-sectional studies measure prevalence. They can show a risk factor in relation with the disease, but they don't establish causality. A cohort study asks what caused the disease. This compares groups with given risk factors and given exposures to groups that don't have those exposures or those risk factors. So we can see in a cohort study if having a risk factor increases our risk of having this disease. It's associated with a later development. Is it associated with any development? These can be prospective, meaning we look ahead into the future or it can be retrospective, meaning at this point in time a patient has a disease and let's look back and see in their history do they have any exposure to a certain chemical or carcinogen or product or environment. Cohort studies will measure relative risk. So you can kind of remember that as the RT in cohort is translated into relative risk. So the R in relative and the T in relative. Case control studies ask what happened. This looks at disease groups and it compares it to a non-diseased group. What happens is there a risk factor that differs by the disease state. So seeing this group over here that has COPD, did they have a risk factor of smoking in the past compared to those other patients that don't have COPD? Do they have a risk factor of smoking in the past? As you see on this last line, the odds of prior exposure based on current disease. And this measures odds ratio. The three final types of studies we'll discuss are crossover studies, twin concordant studies, and adoption studies. This is comparing the effect of more than two treatments or two or more treatments on a participant. So patients will receive one treatment and then they will change to a different treatment and see which one helps them better. There is a period of time in the middle of that where there's a washout where they get rid of a medication and allow the body to process it out before we start another medication. One way to help with bias on this particular study design is we do randomize the order in which they receive these treatments. So one patient that's in the study might receive treatment A while the other patient receives treatment B and then they swap halfway through. Crossover studies have a strength in that they allow participants to serve as their own controls. So taking a medication might be a placebo and then taking the actual medication shows us what is the actual effect of this particular medication versus not having a true medication or is taking medication A that might be this current standard of care better or worse than taking medication B that could be a new medication. The twin concordant study compares the frequency with which a disease develops amongst monozygotic twins versus dizygotic twins. This is going to measure the various effects of nurture versus nature. This also measures heritability and an influence of the environmental factors. Finally, our last type of study that we'll discuss is adoption studies. This is going to compare siblings that are raised by biological parents versus adoptive parents. It is going to measure heritability and an influence of environmental factors. Do siblings that have similar genetic makeups do better in one type of environment or another? Is there anything that influences them in one direction or another?


Hey everybody, it's Brett, and today I'm super excited to show you our very last 2023 Jeep Wrangler Hi-Tide. We've gotten about 12 of these in, and we have sold every single one of them and barring a dealer trade. This is the last one that we are getting from the factory. I don't think they're making them in 2024. So this is the last chance to get a Jeep Wrangler Hi-Tide from Summit Automotive. They've been a very popular package with us. This one is stock number 23J360. I'm going to go over everything in this video, what makes the Hi-Tide package so special. We'll check out the original Windows sticker, and at the end of the show, or at the end of the video, we'll put all the lights on, and you can see just how nice and bright they are. Starting off with those lights, you can see that you get the LED headlamps, the LED running lights, and the LED fog lamps. You also get the LED lights in the fenders. You also get the gloss black surround on the fog lights, and it looks really good, especially when it's all lit up. I highly recommend any Jeep with the LED lights. The other thing the Hi-Tide package gives you is the decal on the hood. You also get the bigger wheels and tires. This one does come, the Hi-Tide package comes with the 35-inch Extreme Recon tire and wheel group. That also gives you a lift.  Starting with these tires, you get the BF Goodrich All-Terrain TA KO2s. They are LT 31570 R17s. You get these 17 by 8-inch beadlock capable wheels. Those are painted in granite crystal, looks like. Really good looking wheel on here. You get the fender flare extensions. That's to keep everything legal because you got the wider tires, and they got to be in line with those tires. So that's pretty cool as well. You also get the sandals and the shroud.  Nothing to do with the Hi-Tide, but you get the T-50, which is what Torx piece you need to take out these bolts, the Torx bit. You also get the rock rails, which normally only come on the Willis and the Rubicon packages, but they come standard on the Hi-Tide as well. Just coming around to the back here. The other thing that, kind of the thing that you don't even realize, this one has the color match hard top. That's also part of the Hi-Tide package.  I have it all broke down. It's pretty cool. So here's the rear gate reinforcement.  So there's a couple little Easter eggs here. You get the dog on the right says Ralph. And then there's a bulldog on the left. He says Louie. So left, right, Louie, Ralphie. So that's kind of cool. Anyways, you can see just how big that tire is and how altering that pattern is. You get the LED tail lamps. This one also has the trailer tow group. This one's optioned out exactly how I would option out one of these Hi-Tides. You get the tow package, four-pin, seven-pin wiring. And let's take a look at that original window sticker so we can check out all the options. And I'll show you just why this one is so great. So 2023 four-door Hi-Tide. Everything on your left is your standard equipment, the 3.6-liter with the 8-speed automatic transmission. And like I said, standard equipment is on your left there. Optional equipment starts with the Hydro Blue Pearl Coat, which one of my favorite colors on the Jeeps is 495. Customer preferred package 25D, which is the Hi-Tide package is $12,095. Everything you see here is part of that Hi-Tide package. And then down here is the technology group, which is $1,095, which gives you the front door passive entry and lock, air conditioning with automatic temperature control and the 7-inch TFT color display in the instrument cluster. Convenience group is $795, which gives you the universal garage door opener, cold weather group, which is $1395, gives you heated seats, remote start, heated steering wheel. That's $1395. Trailer tow group is $1195. 8.4 in premium audio group is $2295. So you get the factory navigation. You also get the subwoofer and back with that Alpine premium sound system. 8-speed automatic transmission. This one has a 272-to-1 select track full-time four-wheel drive system, which is 895 conventional differential front axle. And then the 3-6 you get there. Total MSRP is $615. If you want to get your summit price, rebates, and incentives on our very last Hi-Tide in the upper right-hand-part screen. It's a link to our website. It's also linked in the description below. 3-year, 36-bumper-to-bumper, 5-year, 60-power train. And so I broke down everything that the Hi-Tide package gives you. And if you had to add it to this vehicle. So you get the extreme recon tire group, which is $3995. The color match hard top, which is $2895. The anti-spin differential is $795. The LED lights are $1495. Sunrider top is $895. Tinted windows, $495. Rock rails, I can't even find a price on those because you can't add them to anything. They just come standard on the Rubicon and the Willis package. So I couldn't even find a price on those. Gorilla Glass, windshields, $295. All-weather floor mats, $170.  Because this is first and foremost a Sport package. So it wouldn't come with power windows and locks, but this Hi-Tide package gives you all that stuff. So total improvements would be $137. And you can see that this one, the Hi-Tide package, is only $12,095. So like a $1,700 value, which is pretty sweet. Anyways, Miles Brighalon, $2419 city, $21 average. I can tell you with the bigger wheels and tires, that's a little off. So just for full disclosure. Let's check out the back. Not much to see back here because it does have the Sunrider hardtop back here, or I'm sorry, soft top. You get the case for your front hardtop pieces. There's your subwoofer. You can take all these bolts out. We actually did a demo on how to take your hardtop off. That's in the description below. So check that out. You also get these seven slots on the back of the gate here. And then you get your JL badge for two-door, four-door wheelbase and overall length as well as water-forting. So that's pretty sweet. But I wanted to check out the inside. The thing with this one is that it's optioned out just right. You get the cloth bucket seats. It has the all-weather floor mats. That's all part of the high-tide package. But for me, if I was going to get one of these, I'd want the seven-inch LCD display. I would want the heated steering wheel. I'd want the heated seats. This one has that, the Bluetooth and Information Center controls, the leather-wrapped steering wheel. You get the audio controls in the back. This one has the 8.4, the better sound system, the remote start, AM, FM and Sirius. This one has the factory navigation system on it. This is the 8.4, 4C radio. So you get your navigation system there. You get your heated seats, heated steering wheel controls. The backup cameras on these are crystal clear. Love that Jeep's done that. But this one's just optioned out right. It's got the heated seats, the premium audio. All the other high-tides we've had either had the premium audio but no heated seats or had the heated seats and no premium audio, no tow package. Stuff like that. This one's optioned out perfect. So down here are your climate controls, volume and tune controls as well. Start, stop capabilities, stability control, select speed, crawl control.  You get the four up-fitter switches, part of that tow package group, the 8-speed automatic transmission, the part-time four-wheel drive shifter. Keyless entry with the flipper key and remote. Start on there. This one also has the mineral gray dash. And you can see it's actually just a little bit of metal flake to it. So that's really cool. That's my favorite dash is the mineral gray on there. And then you get your quick disconnects up here. SOS and assist, auto dimming mirror and your home light buttons. So I'm going to start it up. We're just going to leave it off. And then I'll turn off all the lights in here. We'll do a final walk around with all the lights on the Jeep because they are pretty impressive, especially in the dark. So just one second here. So you can see just how nice and bright those LED lights are. And like I said, I wouldn't get a Wrangler unless it has the LED light group. So that's pretty sweet. The one thing I forgot to mention is that this one does give you the Gorilla Glass. And if it's got the Gorilla in the windshield, then you know it has the Gorilla Glass. It's supposed to be a little bit stronger than the normal windshields and prevent chips and stuff. I don't know if that's true. Anyways, you get the LED license plate light, the normal halogen tail lamps. But yeah, that's pretty much it. Thank you so much for checking out the video. We'll turn all the lights back on. Well, most of the lights back on. And really a sweet Jeep. And like I said, this is the very last one. So unless we get one on dealer trade or something, we're not going to see these anymore, at least new. Maybe we'll get a couple in use coming up in the next couple of years. But anyways, thanks for checking out the video. Remember to like, subscribe, and share on the YouTube channel and to see more pictures of this Jeep or one of our other 550 new and used cars, trucks, SUVs, minivans, Wranglers, you name it. We got to go to that website right there, summitauto.com. Full pictures and descriptions of every single vehicle all at summitauto.com. And if you'd like to check out more HD videos, you can go to youtube.com slash summitauto. Click the bell notifications. You'll get updates on the videos I do each and every day here at Summit Automotive, as well as having access to one of the largest catalogs of vehicle walk rounds on YouTube. In fact, in a second, you'll see a link to subscribe to my YouTube channel in the upper left. A link to more Wrangler videos that I've done in the upper right. Almost 500 Wrangler videos up there. A link to this vehicle on our website in the lower left if it's still available. And a link to one of our latest YouTube videos in the lower right. Click those, check us out. We're super excited to help you with this brand new 2023 Jeep Wrangler four door high tide and hydro blue pro coat. Thanks again for checking out the video. Remember to like, subscribe and share on the YouTube channel. I really appreciate it. Thanks again.


Hello everybody, Andrew Maesky here with dental and mobile hygiene. So Rex is here with me. We're all decked out in our cool Halloween costumes. It was his idea. I think he looks very cool, doesn't he? Not too scary at all. So we want to talk to you guys about Halloween candy, okay?  I do, I eat candy. But there's a better way to do it. So the best thing to do is you want to eat your candy right away and then have water afterwards and then of course brush your teeth. Rex loves his toothbrush. It's nice and big because it can get all the way to the back, the front, the sides, everywhere.  And then 10 minutes later, you have another little candy. Then maybe an hour later after that, you have another candy. Well, every bite of that sugary candy could be causing you a cavity, literally. Whereas if you have all of it at once, it's just that one chance to really cause a cavity. You don't want to get cavities, but sugar is what causes cavities. So you want to limit that as much as possible. Candy, sugar is the worst thing to cause cavities. It can get stuck in there. So that's where the water comes in. Having water afterwards helps to neutralize those acids and those sugars in the mouth. More importantly, as well, of course, after the water, use your toothbrush to get right in there to get that sugar, to get everything out of there. So there's no chance to cause a cavity, hopefully not. So you need to do a good job with the brushing, have lots of water and use a good toothpaste. For my patients, I recommend different toothpaste for everybody because it does depend on your teeth. It depends on if you're cavity prone or not. Depends on if you have acidic saliva and it even depends on if you have thin enamel. So if I have recommended a toothpaste for you, if you've seen me before, definitely use it after you have that water. Make sure to floss and or use the water pick to get that sugar out from in between the teeth and even use a mouthwash. Everything you can to not get a cavity because it's very easy to just keep eating Halloween candy, right? So I hope that helps you guys. Rex says hello and he can't wait to see all of my little patients very soon.


Hello and welcome to the Grand Line Review, your source for everything One Piece. And today, after more than 700 video things, having been posted on this channel, exploring the various intricacies of One Piece, it's time to finally tackle the consistently intriguing topic of Gear Fifth. And to be clear, Gear Fifth has a pretty strong discussionary history within the One Piece fan base, and I believe the topic was first seriously brought up on April 27th, 2015, which was the release of chapter 784, which contained the full revelation of Gear Four. And after very briefly taking that in, people quite swiftly turned their attention to the future, and we now find ourselves five and a half years later, with the concept of Gear Fifth still yet to come to fruition. However, with everything we now know and have experienced since, I think we can give this idea a much more solid examination. Before we do though, I must say it's time for a quick round of gear racing, a very simple minigame, the rules of which are as follows. Here we have three elite racers who are going to compete in a contest of speed around this here track. And your job is to guess which one of them is going to win the race. If you guess wrong, then you will need to pay up by subscribing to the Grand Line Review. And if you guess correctly, then you get to stand on this fancy winners podium. But make your choice now, who will win this race? Will it be Afro Luffy, Nightmare Luffy, or Airhead Luffy? Please make your choice imminently because the race will begin in three, two, one, go. All right, not quite off to the greatest of starts for Airhead Luffy having not moved at all. Meanwhile, we have Afro Luffy out in front with Nightmare Luffy just sort of absorbing shadows and growing ever larger just behind him. But what's this?  Nightmare Luffy has now grown so big that he is larger than the course itself, thus leading to both of their disqualifications and meaning that by sheer default, the winner is Airhead Luffy, who still has not moved whatsoever. So if you chose either Afro or Nightmare Luffy, you know what to do, hit the funky red button and please do comment below if you are a new member of the Grand Fleet, welcome. But getting into things I do think it's important to first address the very potential reality that gear fifth may never actually exist. It's not the most fun of things to do and we will move on from this swiftly, but with one piece as it currently stands, we are rapidly running out of time for such development, leaving us really only with the possibility of Luffy busting out a gear fifth to use against Kaido on Wano, or for it to be something of a final form for the last saga. With that said though, going forward, gears may not be overly important in comparison to other aspects of the series. For example, we've now spent the last two mega arcs focusing on expanding Luffy's mastery of armament and observation hockey, neither of which have resulted in a new gear as of yet. And there is still the potential of exploring Conqueror's Hockey further or even the ever present possibility of Luffy awakening his devil fruit, which may very well signify that gear fourth is our full stop to Luffy, but perhaps continuing to expand horizontally from there with some new utility based forms. That's the really cool thing that Oda has done with gear fourth. He's given it a super long shelf life with all of the different incarnations, rather than making it a straight up one form power up. But when we're talking about gears in general, a good question would also be to ask, well, why would Luffy need a gear fifth? What would be the reasoning for him to take such a drastic step upwards? Because we can actually track this motivation through other forms. Gear second was developed as a direct response to encountering the Rokushiki techniques of CP nine. Those six abilities effectively turn them into superhumans. So Luffy just decided to do the same, most notably including Soru as a key component of gear second. And then the power development of gear second was necessary to overcome Cypher pulse Tekai technique. And then gear third was basically an expansion on that. It created a way for Luffy to have access to a maximum amount of power in order to break through the impossibly tough iron bodies. However, in the one piece world, this was still not enough because Luffy's speed upgrade was hard counted by those with observation Haki and his power upgrade was hard counted by those able to use arm and Haki. So gear fourths of various forms were a direct response to that. And honestly, with gear fourth, Luffy has more or less reached the pinnacle of reasonable power in one piece. I say reasonable because yes, there are still characters like Kaito, Big Mom, Whitebeard, et cetera, all those guys that exist on a God tier level. But by and large, Luffy is pretty much already sitting at the top. The only thing that truly separates him from a character like, say, Katakuri, for example, was an advanced application of Haki. But in terms of raw strength and speed, well, gear fourth was plenty to keep up with him. So we do need to ask ourselves, what overwhelming threat would constitute the development of a gear fifth? And currently, I only really see three potential answers to this. The first of which would need to assume that gear fourth is coming imminently in response to the overwhelming strength and speed of Kaito. In this case, Luffy's biggest obstacle is inflicting any actual damage on Kaito because his basic and even gear infused punches are pretty much worthless against Kaito's sheer bodily toughness. But we do have an answer for this in the works with Luffy's study of advanced armament Haki. In theory, that is supposed to provide him with the new found ability to face off against the world's strongest pirate, but there will still be quite a strength gap. Right now with advanced armament Haki, Luffy isn't really making himself stronger so much as he's developing a strategy to use his existing strength against Kaito in a situation where he is not just entirely nullified. That still doesn't put him anywhere near the league of the strongest creature in the world. So if gear fifth is going to be a basic strength speed upgrade, then this would be the time to do it. The problem being that I don't really know how Luffy achieves that. The only new feature Luffy has to service that evolution is the advanced armament Haki. And whilst I could certainly see Luffy creating a new gear fourth form to make the best use of that, gear fifth is much harder to imagine. And of course, just to put my bias out there, I'm one of those people who personally believe that Luffy will never be physically as strong as Kaito, Big Mom, the White Beards, the Rogers and all that. I've all mentioned God Tier characters and Luffy will just become the pirate king in his own unique way. Now, lots and lots of people disagree, which is fine because Wano is going to give us the answer to that fairly soon. Either Luffy will become the strongest pirate in the world right here and now to beat Kaito or he takes him down as part of a group and will never reach that level. It really is going to be as simple as that, which brings us to our next gear fifth idea because after the inevitable fall of the strongest pirate in the world, however that may happen, Luffy really isn't going to have too many problems responding to strength or speed. Every opponent from here on out is going to be empirically weaker than Kaito, which means that Luffy is more than likely going to be faced with developmental threats. And after mastering advanced armament Haki, there are only two other steps that Luffy has yet to contend with and one of which is the idea of advanced conquerors Haki. Now I'm not going to go too deeply into what this may or may not be, but given that the themes of the most recent mega arcs are furthering Haki, I do think it makes a lot of sense for our next arc to do the same with conquerors.  And then you have a potentially natural path for a gear fourth form, a natural evolution that incorporates all three brands of advanced Haki with the same sort of theory as applying basic Haki to gears, which resulted in gear fourth, which to be fair for a Wano gear fifth, I suppose you could do with just observation and armament. With that said, being forced to delve into advanced conquerors Haki, a concept that I will stress is not anywhere near confirmed to you know actually exist. Although there are very strong hints, but once again, this doesn't necessarily mean that Luffy would need to take that into a new numbered gear. It could once again be a utility form of gear fourth designed to make best use of that newly acquired skill. Because that's the problem I keep running into. Gear fourth is actually just so versatile that I can see scenarios where Luffy just keeps using and evolving it for the remainder of the series. And the only reason I can solely come up with for that to not be the case is because one piece is a story, a Shona manga story specifically and introducing a new numbered gear would be a great way to generate excitement and hype for some sort of final saga. And when I think about it that way, I go, yeah, Oda kind of has to do something like that, doesn't he? Because by that point, it would have been almost a decade since gear fourth was introduced and perhaps it would be a bit of a stale note for a climax to be based on. At the same time though, Oda really doesn't have to do anything or at least nothing that we can accurately predict. Maybe Luffy's upgrade won't have anything to do with gears and it'll be something entirely new. But assuming that it is, let's move on to the other remaining threat that Luffy may need to deal with which is devil fruit awakening. As of right now, Conqueror's Haki and Awakening are the only utility areas that Luffy can be outclassed in. Although I do have to say that Awakened Devil Fruit users really don't have a great track record against Luffy because he's too an O for that having dismissed both Dolphamingo and Kartakuri. To be fair though, they were both similar types of Paramesio users because discounting Kartakuri's special branding, they were both predominantly generation style users, meaning that they very much focused on conjuring a substance being mochi and strings respectively, which of course went on to have the effect of the user changing their environment into that substance. We haven't actually seen any other Paramesio Awakening outside of this specific sub-brand, which means that there is great potential to run into all sorts of Paramesio problems in the future with other fruits that may not subscribe to the generation style Awakening. And here I am specifically thinking about Blackbeard because he will be something of an ultimate threat and his Paramesio, the Gourgouronymi, is quite the troubling one. Although oddly enough, Luffy is practically built to counter it if his rubber becomes glorious enough to simply absorb the shockwaves. Still, Blackbeard continues to be a tricky one because he could also awaken his other devil fruit, potentially the Ami-Ami-Nomi. And if he does acquire a third Zoan-style devil fruit, then that could also result in an Awakening making Luffy triple outclassed and forcing him to evolve by awakening his own devil fruit, which may not necessarily result in his environment becoming rubber like our established Awakening, although we can't discount the idea entirely either. But if there was a gear fifth, I feel like this would be the most natural path because an Awakening would give Luffy access to an entirely new set of tools to craft it rather than sharpening the ones that he already has, which is what we're currently doing with Haki. And even if it did have an environmental-style effect, who's to say that can't be a gear? You know, gear fifth, bounce world or something. But I do bring that up because I know there can be some opposition to the thought of a new gear not being directly related to a bodily change for Luffy, which to be fair would also not be the standard Shonen thing to do, but then again, one piece isn't exactly your standard Shonen. I mean, I would love to see a gear that sees Luffy take more advantage of the battlefield than it does his own physicality, but at the same time, you could also achieve that with gear fourth and an Awakening combination. But there is at least one other idea out there, one that is much less based on the idea of Luffy responding to a particular threat. And this concept is known as gear reverse. And I do need to say that this is not a thought of mine. In fact, I'm not entirely sure where it originates from, but the oldest source that I was able to find was five years ago on Reddit by a user named LDR Blue. But they essentially just brought up the basics of gear inspiration being based on cars and the fact that cars have a reverse gear option available. So instead of thinking forward all the time, we could also think backwards, which I don't know, depending on your semantics, I guess would not technically be a gear fifth, but we are so balls deep into this topic now that we're just going to proceed. And to be honest, the first thought that always comes to my mind when I see a gear reverse style thing being discussed would be Gold Experience Requiem from part five of JoJo's Bizarre Adventure, which without going too deeply into it, because we don't want to do that, has crazy time powers and can revert anything back to quote unquote zero. And whilst we will certainly never go that insane in one piece, there are some potential Luffy style applications that can be taken from this, one of which I could see being regeneration. And in this way, I'm very much thinking about how Carter Curry makes use of his special paramecia, which can regenerate his body in a similar style to that of low gear foods. So with that in mind, a fun way to use gear reverse might be to have Luffy incur damage or an injury and then just restore his rubber body, reversing the damage. Well, maybe not by restoring, but reflecting something like the Mirror, Mirror, Know Me used by Charlotte Brulee, which just straight up reflects all damage, but that is even crazier speculation than I think we've signed up for right now. All I really know is that I do quite like the sound of gear reverse because it feels like a more unique solution than just amping things up again into gear fifth. Because once again, I maintain that apart from the God level warriors on the planet, Luffy is basically sitting at the top in terms of power already. What separates him now are utility pursuits, future sight, advanced armament, conqueror's hockey and unlocking a devil fruit awakening with all of them providing a potential avenue into a new numbered gear or a new gear fourth form or just a completely separate upgrade to be used in tandem with existing gear fourth forms. All of which are highly possible and I look forward to seeing what road Oda selects. But what do you guys think? Please do leave your thoughts in the comments below or even join my Discord server. And if you'd like to see more videos like this, then please do go and check out some of my other content or even subscribe to the channel for more glorious one piece business uploaded straight until YouTube feeds. But for now, this has been the Grand Line Review and I'll see you next time.


Hello, everyone. We're getting started with our next session. And as you can see, the title of the session is Identity and Genetics. And I think when Dr. Kiddles was referring to the next session, the next session, you'll see connections, he was talking about the connections between genetics and health, where you could really see that. But this is important because it's the connection between genetics and identity, which is a part of that whole global makeup of how you see yourselves, right? The genetics is a piece. What you know about your history, you see that all coming together. And then the interpretation and what you do. So this is going to be more of a cultural interpretation, biocultural interpretation of genetics and how people look at genetics as it relates to their identity. My name's Yolanda Moses. I'm a cultural anthropologist. And I stood on this stage a couple of years ago when the race exhibit was here. How many of you saw the race exhibit when it was here two years ago? It was here at the Smithsonian for six months. And one of the things we did with that exhibit was to try and link the history of the idea of race, the science of race in human variation, and how race is lived in everyday life here in the US as a result of that history and our understanding of human variation. So it was an integrative kind of approach. What we're doing in this particular session will have two speakers, Dr. Alondra Nelson and Dr. Sandra Lee, who is going to talk about genetics and identity from their particular perspectives. Dr. Nelson is going to talk about her research as it relates to genetics and identity from her ethnographies. And Dr. Nelson is going to talk about her research that's focused on the meaning of race and interpretation of difference in genomic science. So you'll see those things coming together. Then we're going to be sitting here on stage for our discussion. Thank you. So I'll ask Dr. Nelson to come forward.


It's The Cube, here is your host, Jeff Frick. Hi, Jeff Frick here with The Cube. We are on the ground in downtown San Francisco at the Clifft Hotel at this Dell 1510 discussion forum on big data. It's the second in a series that they did. They did Boston on security, today was on big data and we were hosted today by Susan Etlanger from the Altimeter Group. Thank you for hosting. My pleasure. Kind of a raucous crowd. It was a raucous crowd, you know, there are a lot, no shortage of opinions today. So what did you think? You know, I think it was fascinating because we're in a room full of people who care passionately about technology so unsurprisingly you get a lot of opinions that are informed by passionate love of technology but big data is a complicated topic. And it was a good conversation, I thought you did a pretty good job kind of roping everything in because like you said, there's a lot of people with a lot of opinions so you know, sometimes people went kind of crazy but that was the point, right? That's what we're trying to do. We like a little controlled chaos. So in preparing to come to this, I watched your TED talk that you did last year and congratulations, it was a great talk and there were some really interesting themes I wanted to follow up with you so I'm glad you stopped by. And one of them was really about, you know, we talk about the data but I just want to grab what you said was that it's really about the importance of critical thinking that without context what is the data? And you know, having a broad base of information, a broad base of social skills, a broad base of education are the things that people aren't talking about enough to add context. Yeah, I think, I mean it's a really interesting conundrum because when you think about big data it really is about technology from a technologist's perspective and we talk about how we process it and we talk about how we store it and we talk about how we share it and all these other things but what makes big data interesting or this idea that we call big data which is sort of an imperfect name for it is that it could potentially give us the potential to understand a little bit about the world that we live in so whether it's ourselves as citizens, ourselves as patients, ourselves as consumers that's kind of where it could go but we really talk about it in a very technology centric way. Yeah, and it doesn't seem like people talk enough about the context and enough about little fun things, you know, how do I have statistics, you know, change the scale on the XY axis and the slope of the curve looks really flat or really steep and so there's a lot of these kind of softer issues that I don't know get enough attention or are we just not far enough down the path or that will come, what do you think? Yeah, I don't think they're softer. I mean I think if you think about what big data is and the way that Gartner describes it, a lot of it comes from human expression, human speech, imagery, things like that and there's really no technology today that will take an image and tell you the meaning of that image, you know, we're further along with language but even when you think about language there are arguably a thousand languages in the world and even if you think about maybe say the top 100 or the top 50 from a business point of view words mean different things in different contexts and so this is why it's important when you think about big data that to understand a lot of it is unstructured meaning it just comes like a tweet or a poster, a blog poster, a news story or a chat log in a call center, it's just the way people communicate and pulling the meaning out is actually more complicated than you think. Yeah, it's my favorite example of kind of context is Saturday Night Live, right? Everything they say on Saturday Night Live is so politically uncorrected if you set it on almost any other forum you get in trouble but if you say the same words on Saturday Night Live, same words, everyone knows the context, it's a spoof, it's a farce, it's funny and it's taken as comedy as it's intended to be taken and it seems like that nuance is so so important just does not seem to be a big part of the conversation. It is, I mean if you think about for example a tweet, it's 140 characters and so constantly people are just getting themselves in trouble on Twitter. If you think about an article, a news story or an article or even an opinion piece, you have a little bit more time to upset everybody in your audience. Speaking of pieces, so I know you've got some new research out recently about what are we doing with this big data, give us a little update on what you did and what some of your findings. The thing I've been really focused on and the thing I'm gonna continue to focus on for the remainder of the year and probably the rest of my natural life is how do we extract insight from data in a real way, not just like somebody's age and how many times they went to the store and how many times they bought detergent and what could that possibly mean about them but actually real insights about people's propensity to buy, to be well, to get sick, to vote a certain way, to do all sorts of other things and so the insight piece is really important because it means that we have to think that business people need to think in a more sort of computational way to be able to communicate with technologists and technologists need to think in a more business oriented way so the insight is really important and then the other piece is how do we do that in a way that actually engenders trust? You're right, the trust issue came up a lot today and kind of this trade off between privacy and trust and giving me enough information in one of the younger people in the audience that I actually want to give you more information so you can give me better suggestions so it's certainly not settled by any stretch of the imagination and kind of the trade off of value for privacy too I think is very different based on generations and people's experience today. Or maybe just time of, you know, time of the day, time of life, where you are so if I'm walking down the street, you know, I sort of maybe expect there might be a camera there if I'm in a restroom, I may not expect there to be a camera there if I'm shopping in the grocery store, yeah, exactly, back to context or like, you know, you think about teenagers, teenagers want tons of privacy.  You know, you get into your 20s, maybe you want different kinds of information, different kinds of, you have different expectations so we have to kind of figure that out. Except the clown teenagers share more stuff than anybody and they shouldn't be sharing so tell your kids, be careful what they share. Because they're on Snapchat and everything's going away, right? Oh, that's right, supposedly right. So Susan, thanks for moderating the panel. Thanks for taking a few minutes with us. Good luck with the, how do they get the report? Oh, you can just go to altimetergroup.com and download it there. Okay, awesome. So thanks again. I'm Jeff Rick. We're on the ground at the Clifton Hotel in San Francisco at the Dell 1510 Big Data Discussion. Thanks for watching theCUBE.