In the record, I'm Peter Wach. I'm the deputy secretary of the Agency of Network Resources. Thank you for having me here today to talk about the intersection of two very important topics, climate change and activity. I'm going to start off with some general comments and then happy to provide some specifics in response to some of the language and then answer your questions. It's just a tip. One of the roles that I play in the administration is to observe that the governor's co-chair of this climate action commission on with Paul Costello and Ron Council on Rural Development. In that, we looked at the way in which the way we use our land can be a way that it's beneficial to mitigating the worst impacts of climate change. We focused on a number of different areas, but primarily on how do we promote dense, walkable, bikeable transit oriented development and how do we then also protect the natural working lands that are providing the valuable carbon sequestration work that puts our state ahead of many others in terms of its ability to mitigate the worst impacts of climate change. That group involves 21 members from around the state of various different perspectives. One of our recommendations was to support the work of the Act 47 Commission in addressing climate change through the activity process. So we appreciate the work that's gone on to date and are interested in continuing this conversation. I think there are, in my mind, there are three major ways in which Act 50 can play a role in how we address climate change. Primarily, I think the greatest tool we have is to help support the ability of our natural working lands to continue to do the important function they've heard. They do. You've heard, at least the Act 47 Commission has, I think, some of you have from Commissioner Schneider, the Commissioner of Forest Parks and Recreation on the value of our forests as natural carbon sinks and the role that having those forests stay as forests is critically important. Many of most of our forests in Vermont are privately held. They rely on the value of forestry operations that occur on that land in order to keep them enforced as, because there is constant pressure for development and for partialization and for those to sell it off as land that's valuable for where somebody might want to build a home or a second home or anything like. And so keeping those forests in forests is our number one goal from a climate change project. That's been a goal of the state from the Governor Douglas's 2007 Commission on. In H197, which the administration worked on, some of the language that shares those goals, there's a proposal in there to make it easier for forestry operations to be able to operate as the climate changes. You've heard testimonial here some more later today along the nature of getting logs out of the woods so that they can be turned into variable goods and other usable materials. There's a proposal in there in H197 that helps to address those. We think that's an important thing to do what we can to keep the market for forest products strong so that the back side of that is that all that land can continue to stay in forest steps. The other piece where I think that the same is true for our farms, I think there's been playing a vital role in the more work we do on farms in terms of water quality, the more carbon benefit we get. Many of those practices, the low till, no till, covercopping, different crop rotation pieces are sequestering more carbon naturally into our soils, which obviously is a benefit in one thing we want to promote. We're getting double bank for about, whether phosphorus investments and carbon work on farms. So I think the more we can do just like with forestry to keep those farms from avoiding development pressures that are happening elsewhere around the country and will eventually hit more in Vermont, we need to give them the opportunity to provide, to earn a living and I think the accessory on farm business piece that's discussed in 827 is a good thing for us to continue to work on. The second piece and something that is discussed in your video graph as well as 827 is the idea of promoting transit oriented and inciteable walkable development practices. We are greatest emission of carbon dioxide and other greenhouse gases is through transportation. It's 43% of our emissions across the state. The best car trip is one that doesn't have to happen. If we have communities where people can live and work and thrive and go to school and do all those things, then we have the ability to limit those car trips and ideally limit single eye can see vehicle car trips. There are lots of things that we're working on to promote the electrification of vehicles and buses and everything else to try to improve the overall efficiency of our system. But the best thing that can happen is to avoid those trips altogether. And so by, we think if we get the protections necessary to make people, to elevate what's currently provided by municipal review to exempt to designated centers as they go through that enhancement process from the activity process, provide one opportunity to streamline the burning process and help encourage that activity to happen in our downtowns and building centers and other designated centers. That to me is critical and one of our primary keys to getting through to meeting our ambitious climate goals. And then third piece is really where, which has been active 50s bread and butter for 50 years is about allowing our natural world to exist in order to be, to create resilient natural ecosystems in the face of the changing climate. We all know from our experience through tropical storm Irene that Vermont has not been spared the effects of the changing climate. And we see it more with more flooding happening on a smaller scale, but regular, more regularly than has occurred in the past. So promoting resilient development is something certainly that active 50 plays a great role and some of the changes associated with Criterion 1D to make, to align with the agency's agency and natural resources current look and how we regulate river borders and flood lines and the like. We think it's an important step. We also think there are other things that are important about the way active 50 interacts with a project in order to promote the best possible development online to make sure that that facility can continue to exist and doesn't hinder our ability to adapt to a changing climate. Those to me are the sort of three pieces in which active 50 can play a role. I think, and I appreciate the work that the commission did to look at what else might be possible. If we're all in this fight together, how do we all do our part? And I think that that's a good notion and one obviously was we look at new development, we want to do better than we've done in the past. We have lots of old housing stock, for example, that is drafty and needs to be weatherized now because people are burning fuel and just sending it out through the walls and not staying warm and emitting lots of greenhouse gases and losing lots of money in the process. There are lots of things like that that we're on and so we obviously want new buildings and new development to be better than what we see in the past. Before I go in any specific field, I'll stop there and answer any questions that anybody has. Do you have for the last three things that you said, the new development, let's do better exactly. What standard would you say? Well, one of the recommendations in the climate commission report was to set us on a path towards net zero buildings and that is something that the public service department who manages the energy goes from the state of Vermont has been working on. And so that type of approach where we help people save money through the operation, through the billing and through and not getting the current emissions that we don't want to see, I think is something that is correct. How do you feel about the language in the draft bill that talks about building codes? I think that what, just the addition of efficiency and the addition of the scratch code piece, I think we're comfortable with that. I think it matches some of what is happening already. It just gives it more weight. So the commission's happy with it or the governor at the commission? One of the other roles I play is sort of quarterbacking some of the administration's interaction with your work. And so yes, I can say that we're comfortable with that. Okay. Is that a base? Peter, what is the plan for Vermont and the older homes? There already exists, like I live in one that's been built 1835 somewhere on there. And it's exactly what you know, what you're talking about as a draft and all that stuff. We still have single pane glass for crying out. So what is the plan? Cause I've used efficiency Vermont already and I'm not too happy with that program. So I'm just kind of curious, what is Vermont's grant plan? I mean, so that the grant plan is at some level it is an individual responsibility to provide opportunities for grants and for low interest loans. Efficiency Vermont runs that program right now. Obviously you're not happy with us when we've talked about this before. I can't really speak to their management of that. Only we do, they have to meet certain requirements that the PUC puts on them. And certainly that's something that could be addressed if that's a widespread issue. But there are grants and loans available to people to help them. One of the things that we're working on, one of the recommendations in the kind of mission report was to provide more subsidy at the lower end of the income spectrum. Because right now we have a situation where for very low income Vermonters, up to 80% area median income, they're eligible for the state weatherization program. That program provides 100% cost payment for weatherization activities in those homes. But they don't typically only get to about 60% of area median income. Then that's when efficiency Vermont and the other efficiency utilities, so Vermont Gas, EEDs, incentives kick in at 80%. They're available to everybody, but generally speaking. But there isn't enough of a grant to make it so that people who fall in the sort of 8120 or 60 to 120 AMI can afford to take out enough loan to do a project that actually makes a meaningful difference. So one of the things that we're working on is trying to see if there's a way to work with the efficiency utilities, to put more money towards low income, low and moderate income Vermonters and maybe a little bit less at the higher income spectrum. Because those folks, we know folks who can see the clear ROI of a weatherization investment because you save money on all of your heating can see the value in that loan and can see the value in the grant and you don't need as much help to get there. So that's one of the things that we're working on. Okay, thanks. Representative Dolan and Anne LaFayette. Good morning. Good morning. I appreciate your comprehensive nature of looking at climate change. You talked about the importance of sequestration, forest, carbon storage in the forest. You talked about soil health and agriculture. All that is important. And then you talked about the importance of dense development to avoid necessarily to promote the kind of low automobile settlement patterns. I appreciate that. What we heard yesterday, and this gets into our comment from Representative Bates, what we heard yesterday was how important weatherization is in particular because of our older stock. And we're exporting, billions of dollars out of the state to be able to basically heat the outdoors with these drafty houses. And our weatherization from yesterday said that we're meeting about 1,000 houses a year when there's about 50,000 eligible houses under the current weatherization program, especially for low income.  If you allow me to finish. The point here was how important it is if we can weatherize our houses. How critical that is to make people more comfortable, to help people save money, to make our housing stock more affordable. And we're struggling with affordability in that state. So there's a win, win, win. And the carbon reduction aside, it has huge benefits for the homeowner, the renter, and the state. We also heard that the energy efficiency we've done 30 years ago has resulted in overall having the state of Vermont have a reduction by 20% of the carbon demand. Had we not done energy efficiency 20, 30 years ago, we would, our energy demand would be 20% higher. So how do we get there? How do we get there with a, and make this an absolute priority in a, you referred to a climate report. In my mind, this is an absolute critical part of a carbon strategy. And yet I don't see it necessarily in budgets that we have before us. When we know this is gonna make people more comfortable, more affordable and reduce our carbon. I don't disagree with you on many of those points. That when we talk about weatherization, the value to most remodernies is the carbon piece falls way down the list. And a lot of the low income weatherization work that we do is about making people more comfortable in their homes. Sometimes they're not saving that much money because they just turn the heat up because they can afford to turn it up and they're not freezing in their homes. The governor did include $500,000 additional for the state weatherization program in the budget adjustment which rolls forward as annual appropriations from the base budget. So there is some additional resources. We are in a budget constrained environment. There's not new money to throw around at things. And so we're doing the best with what we can. Senator LeFeyne, my question follows on one of them. Representative Nolan was asking that you said there were $500,000 in additional money set aside for weatherization. And that's the adjustment, the adjustment act? It's in budget adjustment, but my understanding it's in the part of budget adjustment that then carries forward into FY20 as well. What are we looking for this year, total in terms of spending on weatherization, you know? So that would essentially get us to about a little over $10 million for low income weatherization. That does not include the efficiency of Vermont and my guess, another NBD for rents. Is that flat fund in or is that an increase from last year? It is an increase from last year. How much? The $500,000. That's $500,000, is it? Representative Odie. So the number three important thing to you was allowing the natural world to exist for resilient ecosystems in the phase of changing climate. So for 1D you said to align with ANR's current look at the regulation of river corridors for best possible land development. So current look, what do you mean by that? Well, how we evaluate river corridors within ANR has been somewhat in conflict with the language within Act 250 and we want to online that so that everybody's working towards the same goals. So what is currently ANR versus Act 250? How are they different? So the language that you have is that the language that's in your committee bill is the way that ANR looks at river corridors and what looks like. Oh. So you like that. We like that. You like that. That was our language. Okay, seeing that I'm sure. And then for the number one priority, what do you like and not like about the draft language? Number one priority was to be... Was supporting the forest and the farms. Well, I brought up two examples of ways in which I think we need to promote the economic activity around that so that we can keep those lands in their current status. And they're both at age 197 or something. They're both at age 197. So you like that. Is there something in the draft bill that you don't like? We have also proposed a way to deal with forest fragmentation and increased jurisdiction in sensitive natural resources through age 197 that I think we prefer. It's language changes to criteria eight. And then a petition process to add additional lands with increased jurisdiction. And that's a process that we believe might be more effective. So those are your two big things for that? I mean, that has been the way we have discussed this for the last two years of this discussion. And certainly we would, you know, there are pieces I'm happy to talk. If you have questions specifically about parts of the committee bill, I'm happy to answer questions of those. And then number two, is there anything that you didn't like in the committee bill or it could be stronger than the committee bill to get where, because you didn't mention, I don't think age 197, when you were doing your presentation. So is there anything specifically you want to talk about with number, goal number two, transit oriented, bikeable, walkable? Well, I mean, I think everybody is working towards the same end there, right? How do we promote that? And is there a path to removal of jurisdiction in Act 250 that communities are doing the work necessary to have protections in place? And I think the only thing that I would recommend is that it be full elimination of jurisdiction if the work is done and that they're held to account to it. Because I think what we hear is that the specter of Act 250 can be something that holds people back, whether it's real or not. So when you say full elimination, if the work is done and they've held to account, been held to account, you mean, once you're done? If communities come in and they pursue the enhanced designation as part of, on top of their existing designated center process, and there is a robust appeals process for the downtown board, which I also sit on, then we believe that those centers should be exempt from activity. All right, thank you. Thank you. Representative Doolan. It contained in our committee bill for Act 250 talks about these critical resource areas. I'll find the number of them. And the interest is to identify and protect them the best we can. And you had talked about the critical importance for us to be thinking about climate adaptations through greater resilience, flood resilience. Flooding is probably our greatest risk. And although, I guess, there's a suite of other ones, but that's our most predominant risk that we face, extreme weather events. And we have heard that anywhere in the states, one community is experiencing one at a magnitude that's equal to a tropical storm or rain. And so, and those are real economic disruptions that we are concerned about, not just the damage to property, but also the damage to the economy and to people's lives. So it contained in our bill talks about river corridors. And you talked about how we supported the language generally to update the river criteria in 1D currently. But it also identifies river corridors for that very reason to improve resilience. What's your, do you have a comment? We have not formed a final opinion on this. But generally speaking, we're not in favor of including all river corridors in the state of the land as jurisdiction under a river corridor. And I think that is a high bar to get through as most of our communities are along river corridors. So as a trigger for universal jurisdictions. If I may follow up, already every municipality that wants and seeks insurance for flood insurance for a resident in their community requires having a flood hazard by law. They're already at the municipal level providing a level of scrutiny required to contact the state to ensure that they're being consistent with ensuring and compliant with the national flood insurance program. So the system's already in place. And if we're trying to provide a clear indication that these are hazard areas that warrant identification to build a very resilience for seeking, it would be in my mind, not responsible for us as a state to help identify and flag those resources. Well, we have identified and flag those resources. And as you said, the system is in place for that to be done at the municipal level where the interest is in making sure that they can still get flood insurance or protect those properties. So our point isn't that that's not needed. It's that it's being addressed in other ways. Act 250 is in the constellation of the way we oversee land use in the state of Vermont. And as you detailed very nicely, there are ways in which we are addressing those issues. And just one more follow up on the same thing. You were referred to a petition-based process. We had heard testimony a week or two ago about our existing petition process, outstanding research waters and wetland petitions and received information about the number of classifications to warrant that higher protection. We only have, of all the wetlands we have in the state, a petition process is only protected eight, eight number, eight across the state. And for outstanding research waters, we have only a handful, except for the Green Mountain National Forest. So we're struggling a bit with how a petition-based process can really help adequately and effectively protect these areas that are vulnerable to the impact of climate change and vulnerable. Because if we build on these areas, we are increasing the vulnerability and putting people in harm's way. And that's where we're struggling with how to keep people safe as we develop it into the future. So let me say two things. One, that we also kept the language in related to the petition process relatively open at this point, because we do know that we do understand that there have been challenges in the petition process in the past and we want to create one that functions. And so we're certainly open to discussions on how we might resolve some of those challenges. But that's sort of where we'd like to start and where we happen to have that conversation in theory. Thank you. And then to hand designations area. And neither, well, we got testimony yesterday that indicated we should have a requirement if in enhanced designations, if you're going to get a pass on Act 250, that projects include affordable housing. I know our town has requirements for that, for any build out, and that's a new idea for Act 250 in enhanced designations. How do you feel about that? Well, I have only been tangentially tracking some of the testimony and some of the discussion. Obviously, we all want to see more affordable housing happen in previous legislative sessions. You work to provide priority happening with an incentive in our designated centers. We don't, it's complicated to say whether or not, just having, you know, to open it up to the centers to if the protections are in place and it has a big process to have all developments see to receive that level of... Comprehensive job. Right. It doesn't make, does it hinder affordable housing? And I'm not sure that it does, but I'm not an expert on affordable housing, so... That's on your radar now. It's coming. Yeah, no, and we certainly get that in. Let's have that conversation for sure. I think we're seeing a lot of the development that's happening in our centers happen because there's money for affordable housing. You know, the bond that passed a little ago and there's another one in the works now have been incredible to spur that level of activity. See, you know, I live here in Montpelier. I see units going up all the time and that's really exciting to see. And the only reason why more than are happening is because the partners who are building them up, you know, are working on other things. So, I think it's great. Yeah. Back to critical resource areas for the river corridors. You said we just shouldn't be... You made a statement or something about we shouldn't just be doing that at carte blanche. And so then my tighten that down, if you would, please. If we made the river corridors statewide, critical resource areas, but tighten that down in the designated downtowns, villages and centers in those areas, if they then and remain true to all the others, other miles of river, that's a distinction from where it is right now. I certainly think that's a step forward, but I would just make everybody's aware that they drive the roads of Vermont. All of the roads and all of the development are right along most of our rivers. And so, even though that we want most, we'd like to see the development happen as much as possible in the designated centers. It's gonna continue to happen along where road and sewering infrastructure exists and to essentially bring everything that's on a roadway in between communities in debt and into jurisdiction. I don't think it's broken. I don't think we have the resources within A&R to do the evaluation on all of those problems. Thank you. Representative Fitch. I wanna go back to that efficiency remodeler. Does Vermont get a financial gain from that? Or is that just a separate business that we just say, hey, you can operate in our state? We provide them with resources and we hold them to account for how they manage the program and the results that they provide. So we don't get financial, like we don't have a financial, we don't get money back from them is what you're saying. We as citizens of the state of Vermont get money back. Like lots of public investments there. I can help you with that outside. Yep. Representative Domen, sorry. Coming back one more time to the river quarter as a critical resource area. We've seen data on phosphorus loading. That's over time. And where we had the heavy springs flooding and tropical storm Irving that 2011 spikes on phosphorus loading. And then we heard yesterday the day before my days tend to blend in. We heard testimony that what's working counter to our efforts to achieve our phosphorus controls through these restoration requirements mandated through the Federal Clean Water Act and the state clean water rules and laws. It's working against us are these extreme weather events. So here we're talking about resilience mostly for public health and safety today and economic disruption. But the other fundamental concern is the increased delivery of the very nutrient pollutions that we're seeing not only in Lake Champlain but the whole Connecticut River, the Men from May God. Every stream is seeing greater contributions of sediment pollution whatever's bound to that sediment across the state. And when we encroach upon a river corridor over time through development, we not only have we are putting people in harm's way but that fire hose effect in that river channel by forcing that stream to be kept within that channel is delivering a greater amount of varying nutrient pollution that we're spending money across all sectors to control. So even from a economic standpoint or water quality standpoint and not wanting to throw away money wanting to be targeted at it wouldn't you say as you said just similar to how you had indicated that keeping forestry and forestry and let the forest function for our economy but also for that flood storage and that water storage and that carbon storage is a benefit to the state. Wouldn't you use that same argument to say those four planes and river quarters capped to be able to disperse that erosive forces of high flow event is a sound use of those river corridors to keep us safe and to not work against our phosphorus reductions but to compliment and support our efforts to most cost effective reduce those pollution sources. As I've answered previously I do think that we need to protect those resources. It's a question of how and simply providing universal jurisdiction through Active 50 we don't think provides the greatest impact for the resource and so that is simply a distinction of how you approach it not whether or not those things are important to protect. Representative Terrence. I was gonna say to Peter was the the makeup of this committee most of these people or they don't want any growth or development on the rivers. We're just anti-development, here we go. You can take that back to the government. From there, thank you very much. I would like to say, I- Representative, you only have five more minutes in terms of our schedule. What if we let him out anyway? Yeah. What if we let him go? If it's okay with the Vice Chair I think the questions are actually probably more helpful than talking about any of the going through five minutes of some of the specifics of the day. Very well. Okay. Representative, go ahead. Anyone else? In terms of the bill, the committee bill there are some pieces of it as I mentioned. I think the issues related to energy and codes makes sense. We've talked about some things that we'd like to see added to the approach that's pursued. I think that they're, if the capability and development plan is going to be re-looked at, clearly having climate change being part of that is important. And creating our look at what the resilient landscape looks like. I haven't been part of the conversation about where you are on that front. I don't know if you've gotten there yet. Certainly, I think I do have questions about in I think it's a great change to the air pollution criteria around adding greenhouse gases. One major concern and two more of a question of how it might work. The first concern is the ability of so within the bill it currently allows the Secretary of the Agency of Natural Resources to name a substance that has a greenhouse gas, which to me makes sense.  We're doing that work regularly, coordinating with other states and with the federal government to make sure that we know that information. I do have a major concern that the citizen district commissions would also be able to say what a greenhouse gas is. That to me is not the appropriate role for a citizen panel and takes the technical expertise role of the vehicle away from it. So that is my major concern. And then I don't fully know how you would to go through an avoidance minimization and mitigation sequencing for a new development project related to greenhouse gases because it's feasible to avoid the greenhouse gases altogether by simply not doing the project. And so to what bar are we expecting advocates to be held? I guess would be my question to you so that I could provide more substantive feedback to that concept. What do you think a good bar, how would you make a bar? I have thought about it a lot. I have no idea, right? You have feasibility in there and what's feasible to one human being is different to another. And so I simply struggle with, since these are new things that are happening, thereby their nature going to create additional greenhouse gases. So how do we address that? If they are going in a downtown and creating affordable housing and creating mixed use opportunities that's creating good jobs in our communities and it is creating greenhouse gases but it might be offsetting something, it's offsetting through the use of, through people driving to that location that to me seems like a good idea. And so it's hard to, I struggle with doing the mental arithmetic around how you would evaluate that project and what we would be asking our fellow citizens who don't have this level of knowledge. I think you're gonna hear some testimony from Billy Koster later today from the agency talking about how it's done through the public utility commission process. I think that may be helpful. But there are certain questions about what that would fundamentally would look like on the ground. And to include the operations and the activities associated with the development. So the you and I driving to that location, how they're supposed to include that in their overall greenhouse gas emissions picture and deal with those from a permanent perspective is. Sorry, what do you mean by when I drive? So in the language in the bill, it includes not just the building and operations of it, but how people who show up there, if it's a building of a new store, right? How you and I driving to that store. Any customers drive. Right, any can drive. I thought you meant like people giving the permits. Not you and I specifically, but everybody. No, I thought you meant the permitting process. Okay, all right. So, yeah. So I have questions about how that might work. I'm interested to hear what the committee thinks about where that's going. President McCall. So I'll build on this conversation here and offer a suggestion for your consideration into the future pop quiz. I bet I know what you're saying. I'm not supposed to ask the question. I know what you're saying. Tilly, the UVM Medical Center was part and parcel of a huge new building in South Burlington that was off the bus route. And it created all kinds of transportation problems for people and ultimately they got together with the Green Mountain Transit Authority and created a bus line to there. So then I would suggest one way that we might interact to 50 review under the greenhouse gas require projects of a certain size. If they are not on a bus line, they need to locate on one or help fund an extension to their all earth renewables to that in Hinesburg actually that was the previous company in there. So how do you feel about some of that as a tool, as a possible tool, making sure it's on public transit to lower the greenhouse gas picture? I think that is a fantastic goal. I think one of the things that you're doing in the pro-suggest to make sure that it is that it doesn't prohibit access to those things, that it not only considers the impact on traffic and safety but also for car traffic but also for bicycle and walking and transit to go to the next step of requiring that projects of a certain size that are not on a bus route pay for the expansion of a bus route is, I think it's somewhat of a challenge. I think you're asking, well, for any number of reasons but I think you're asking the project to essentially fill the void that a transit agency hasn't provided and let me be clear on that. I think in the instance you're talking about because it was such a large entity, of course, Green Mountain Transit's gonna be interested where there is an opportunity to service a large number of people. If it's one entity on a stretch where public transit doesn't make sense and the transit authority says, sorry, we're not interested, how does that, and how would that work? It's very exciting to do something. But I think we certainly want to see more opportunities of public transit and more opportunities for sort of non-traditional public transit. We don't have a large bus riding culture generally in Vermont. But Ginny's some of the on-demand micro transit pieces that folks are investigating, there's hoping to put together a pilot project in the Montpelier-Burlin area right now on looking at micro transit. Something to be getting ahead of things a little bit but it's something that the local communities and the agency transportation and the GT are interested in because right now it's sort of, if we try to service as many people as possible, JGA has the sort of Montpelier circular that hits every corner of Montpelier but it doesn't really go anywhere directly. So it's not necessarily that convenient a ride unless you're willing to sort of sort of navigate the city over and over again until you get to your location. Thank you. Thank you Mr. Deputy Secretary. We have another witness waiting for us. I appreciate you giving me the time and I look forward to further conversations We will Mr. Pfeiffer, who's been your name and your affiliation to the record? Well, good morning, distinguished members of the House Natural Resources and Fish and Wildlife Committee. My name is Christopher Pfeiffer. I'm the Public Affairs Manager for Warehouser for New England and for the 2008, well, year 2017 I was the forest supervisor for our lands in Vermont. I've been a licensed forester and I've been in the forest industry for over 25 years. Thank you for the opportunity to provide some comments on the proposed changes to Act 250. I apologize, I was not able to print copies of my testimony for you today. I have emailed them so hopefully you'll be able to get them electronically. Do you want to show them by your screen? Don't have them electronically. If you would like to, sure. Yes, please. Thank you. There, that's the important one, let's get going on. I don't know what I have to take no time. I've already written down. So Warehouser owns and manages one of the 86,000 acres in Vermont in the Northeast Kingdom. 100% of our land is certified sustainable through the Sustainable Forestry Initiative or SFI. And our managed timberlands plan important role in Vermont's and the region's forest industry, providing timber for males, providing wildlife habitat, providing recreational access for folks to use the forest. Our land is under working forest conservation easement and it's also enrolled in UVA. We work closely with forest parks and recreation, Fish and Wildlife, Department of Environmental Conservation and managing our timberland and managing public use of our land. And our ownership includes over 9,000 acres above the elevation of 2,500 feet. None of our land will ever be developed with the conservation easement that's on it. So my comments today will focus on forestry. However, I think it's important to realize that maintaining healthy forests and a vibrant forest economy requires a permit process that encourages new wood processing facilities for everything from our low-grade wood up through high-value saw logs. This is something that's considered in H197, the other bill that's in front of the committee now, although it seems to be somewhat overlooked in the current committee bill. I'd like to describe some of our experiences we currently work through an activity permit process for harvesting and provide some observations and thoughts on how this process might be improved. In the Northeast, we're blessed with an amazing, resilient, renewable natural resource in the forest. The forests of Vermont are diverse. We have white pine, oak, and hemlock in the south. Our yellow birch, balsam fir, and American beech have been in the Northeast Kingdom. The iconic sugar maple groves and the borders of white cedar swamps and beech ridges down over historic farmlands that are now covered in birch and red maple. Our responsibilities as stewards and users of the forest is to ensure its health through sound planning and science-based decision-making. Simple, predictable, science-based policy helps us sustainably manage our timberland, maintaining a healthy and productive working forest. Unfortunately, the bill before you creates new hurdles to managing healthy forests. By proposing to greatly expand the jurisdiction of Act 250, lowering the elevation threshold for forestry from 2,508 to 2,000 feet exponentially increases the number of acres of forest land subject to Act 250 with no measurable benefit to the ecosystem. Likewise, placing critical resource areas under Act 250 jurisdiction duplicate the process required for many Vermont forest managers and results in the same protection already afforded the resource through UVA and current state laws regarding wetlands, water quality, and pollution. When I began managing timberland in Vermont, I was warned not to try to go through the Act 250 process. Foresters told me it was costly and it wasn't worth the number of acres that we would eventually be able to harvest based on a permit. Our new experience suggests this advice was correct. Since beginning the process in early 2018, we have well over 100 hours of staff time in the planning process and we're still waiting on answers for additional wildlife to allow us to put together a plan to submit for the permit. We're hoping to have a final approved plan to harvest by the winter of 2020. So two years at a minimum from permit, starting the process, not the permit itself, but all the preliminary work through to actually being able to harvest. We're not proposing to build any structures, just harvest trees, following proven social culture guidelines in order to maintain a healthy forest. It's not surprising that this expensive drawn out permit process discourages many forest landowners from attempting to manage forest land that's under Act 250 jurisdiction. Unfortunately, this results in the loss of forest health and vitality and the loss of revenue to the landowner and the forest economy. As warehousers began the Act 250 process for a portion of our timberland in East Haven, it became clear that many of the criteria don't really apply to forest management situations. And the district commission, the first ANR for direction and expertise on civil culture and wildlife issues. We were advised by the district commission to work with forest parks and recreation, and the district commission wildlife to come up with a plan that they would approve those agents, those departments, before submitting our application to the commission. I believe there's a way that you could think about simplifying this process while meeting the objectives of Act 250. The committee should consider removing forestry and forest management from Act 250 for any land enrolled in UVA. Since ANR is the de facto authority on issuance of Act 250 permits for harvesting about 2,500 feet in elevation, and applicants are directed to work with them to develop the plan that they submit for the permit. It makes sense to rely on ANR's expertise in their existing forest management program, UVA, to decide if a plan is appropriate. When Act 250 was passed in 1970, the UVA program didn't exist, the heavy cut law didn't exist. So we're in a different place now. We have different regulations, we have different programs in place. The UVA minimum standards for forest management require that landowners follow accepted scientific harvest guides, and implement acceptable management practices for erosion control or logging jobs whenever harvesting occurs. These practices protect soil productivity, and they protect streams of wetlands from sedimentation. Forest management plans that meet the UVA guidelines consider significant wildlife habitat, special places, sensitive sites, and they allow for consideration of ecologically sensitive treatment areas. Stands of trees don't know if they're growing above or below a 2,500 foot contour line. However, the decisions by foresters and landowners to forego harvesting above 2,500 feet because of the added cost and time has fragmented these stands, leaving the portion above 2,500 feet untreated and often in decline. Bringing forest land above 2,500 feet under the same planning process as the acreage below it would allow for continuity of management and encourage healthy, intact forest blocks. Incorporating the in-depth planning into the development of the 10-year forest plan for UVA would provide forest landowners with predictability and flexibility to respond to changing markets and weather conditions. If there are special conditions needed for forest land above 2,500 feet that are not already included in the requirements for UVA, these could be addressed through rulemaking by Forest Parks and Recreation. So obviously, this is a concept. It's not a fully fleshed out idea. However, I think it should illustrate that there are other options this committee should consider to simplify the process before moving forward with a bill that places roadblocks in the way of landowners who are keeping forestless forest. Promoting healthy working forests and a strong forest economy is a way to protect Vermont's ecosystems. Providing resilience to climate change and keep our forestless forests. Thank you, and I'd be happy to try to answer any questions. Representatives. So, see if I got this right. If you stop, we stop fragmenting by saying something different has to happen above 2,500 feet. Then you have a single forest that's managed. So, and you think UVA plus rulemaking through Forest Parks and Recreation would be enough. And do you think that, so let's say that I thought to myself, well, that sounds reasonable. Okay, do you think that it also should have a requirement that the land also be under easement that it can never be developed? Would that be like a three-part test that you would think about? So, in the way I'm thinking about this is if someone wanted to develop, they would bottom that process. This wouldn't eliminate the Act 250 process. This would just accept forest operations. So, because forestry and forest operations are meeting so many of the goals of Act 250, preserving these forest blocks, keeping them productive, keeping our working plans intact. I think that it's gotten to the point where the concerns for development around all the things that were just being discussed, transportation climate change, those are diverging further and further from straight forest management, parts to timber under specific guidelines within UVA. I don't have that, well, I don't want to be here. I thought I heard 9,000 acres though. Which things were never, ever, never, ever gonna be developed because of easements? On our property, none of that. On your property in particular. Yes, none of this.  Correct. So that's why I was asking if you have an easement that runs for the land with the land forever and it really can't even be developed going to Act 250, right? Because it runs with land forever. That's why I was saying if you had that easement, plus you took away the 2500 plus the UVA plus rules. That was my idea for a three-part test. I think that, obviously our situation is unique. We manage the former champion lands. We own the timber land portion of that. Former champion lands of the Northeast Kingdom were broken into three pieces and a conservation deal that, but part of the Munder Fish and Wildlife, you may know this already. No, I think you can tell me the story. I'm sure I've heard it. So Portion is the Conti Fish and Wildlife Refuge. Portion is state fishing name, Fish and Wildlife. And then almost surrounding that is the working forest and it was conserved as under a working forest conservation easement that's held by the Vermont Land Trust. Students by the Vermont Land Trust and Milton are also held with the Vermont Housing Conservation Board. There's also an access easement on our property, which is another layer. But so I'm speaking from a bit of a unique perspective from that point. We wanted such a large ownership of timber land with a large amount of land above 2500 feet, but also in terms of land that has an easement on it. That said, I don't think it's necessary to have an easement because when someone is in UVA, they have a lien on their property that that land cannot be developed. Even if they cut contrary to the forest management plan, that's considered development and then that land is excluded from UVA. So there are already mechanisms in the use value appraisal program to make sure that forest management is occurring, but it's considering these critical type of areas and that it won't be developed. If someone decides to develop, then that land automatically gets kicked out of UVA and would go through a development process. Likewise, I'm not suggesting that at least right now, and again, this is not a fully fleshed out idea, but that land, timber forest land that is not enrolled in UVA would be exempt from the activity process. I think UVA is the key here to making sure that the forestry and the other considerations are done well. So, Representative Smith. Yes, is all your land in the front end program? It is. It is. And you have a forest management plan that you follow that's approved by... Forest box recreation. Okay. And what is different between, if you were harvesting below 2,500 feet, what management decisions would be different just because of the elevation or if there is any? So there really aren't, you know, it's kind of to my point, these trees don't know if they're growing above or below 2,500 feet. In many cases, we have stands which are groups of like species and age of trees. That's how we categorize or look at our forest is these stands by age and species, composition and other characteristics. Those stands will start below 2,500 feet. They may have 30 acres above 2,500 feet and then 300 acres below 2,500 feet, for example. In the past, what's happened is landowners have decided that it's not worth it for them to manage that land, to do what really should be done from a sub-cultural forestry point of view above 2,500 feet because the value, once they put the time and money in to go through an activity process, there won't be any return for them. So those lands have been left arbitrarily above 2,500 feet unmanaged. And what? You have the same stand, the same tree growth characteristics. That said, there's, you know, there are considerations, wildlife considerations, high elections that really aren't forestry driven but they tend to be more habitat driven, things like that where we would look at seeing a software type or a different type of forest at those elevations. So have you had to modify a forest management plan because of that 2,500 feet?  We would, yeah, we would. Leaving that under UVA, that really wouldn't be allowed unless that area was enrolled as in the logical sense of the treatment area or an ESTA, so there's a special designation and in order to be enrolled as an ESTA, it has to be designated as either a natural area, critical habitat or threatened or endangered species, containing a unique, say, a fan or something like that. So you can't just arbitrarily, as a landowner, say, we couldn't say we're enrolling all this land, but we're not going to harvest like that. We'd have to have some special reason, some ecological reason to have that enrolled and not. Okay, and you also said that going through Act 250 was very expensive. Do they put just time in your management styles based on the same or do they put more restrictions on how you might manage a lot of jobs? The primary difference, really the silk culture, the way we harvest, the way we start looking at what's there and how to get the results you want from a timber point of view is no different below 2,500 feet or above. The primary difference, as I said, would be considering habitat, unique areas, things like that, and those are the discussions that we're having with Fish and Wildlife. We're working with, I think, five different biologists for Fish and Wildlife, each with the different species that they focus on. So the time is in the meetings, the back and forth, the site visits, and that's really where the cost begins to add up. Okay, so have you been through Act 250 before, or is this the first time? This is the first, we're in the process now. You said you were optimistic that within two years you'd be able to get through the process. I'm hopeful, optimistic. Sorry. So I'm trying to understand, so you haven't done this before, so you really don't know what kind of harvest and restrictions might be placed on the property? Correct, yeah. You know, I would say we're fortunate that we have 86,000 acres that we're managing, and that means there's a number, there's quite a few acres every year that are scheduled for harvest. So we have a little more ability to work slowly, carefully through this process. It's not the only land we own, or half of the land we own, or a third of the land we own. A small landowner would be in a very different boat if they had a third of their land above 2,500 feet, or under the new proposal, 2,000 feet. That would greatly impact a small landowner's ability to react to markets, to take advantage of the highest value for them. So how much additional land that you own would fall under if you went to 2,000 feet? I don't have that number. You don't? No, I would have to, that would be a GIS exercise to figure that out. Do you know of any other timber companies that have gone through act 250 in order to harvest timber? I know that the prior owner of that land went through for at least one area, and that permit is on record on Act 250's site. So that stays with that land. That 250 permit is kind of a... I believe it does, but I'm not sure about that. I'm not an expert on that. I know that permit has expired. It expired within a couple of years of us purchasing the property, so it's no longer an active permit. Okay, so... Representative Smith, just to maybe break the toast. Yeah, just for clarification, Red Bull from the Natural Resources Board. So permits that are issued for logging above 2,500 feet, unlike the vast majority of other permits are issued with an expiration date, and assuming that the permit is in compliance with the permit, that permit and jurisdiction over that track of the land will eventually go away when the permit expires. So just for clarification, that's how a lot of the permits work in Act 250. Thanks for the clarification. I have one more follow-up question. And if once we're at 250 and putting restrictions on that property so that it's not profitable or reduces the profitability for timber harvesting, would that in the future at some time, the company that owns it, would they consider that this isn't really a valuable piece of timberland farm that they may sell it? And I'm just kind of getting at it, they sell it. That opens a trigger to fragmentation and other uses of that land. So that's one more question. We don't have the opportunity to do that with our land because it's the way that the easement runs with the property and some of the restrictions under the easement. But I think your point is well taken and I do believe that private landowners, other landowners, I think this could be counterproductive in keeping forest blocks intact because one of the main incentives for landowners to be able to do that is to have some return as they do a harvest and if you can't harvest, then what is the value that you have there? Unless you're very wealthy and you can just afford to keep that land because you like it, you need to see some level of return. Okay, thank you. Does the view on the committee know what UVA stands for? Is that current use? Is current use, Michael, you wanna, Commissioner, would you tell us? Sure, the record Michael Snyder, Commissioner of Forest Parks and Recreation, statutory role in administering the, along with the tax department property valuation review the forest land category of use value appraisal. Also known as current use sometimes lands. It could be the Ag or forest. Yes, maple sugaring can qualify as either. I apologize for using the lingo without that. Yeah, without explaining it. You were just thinking, the burden is on you to get the permit, but then when you were doing the explanation of how it works, you get to ask the state, you know, what will work and they have biologists who are working and they're saying, oh, this is what's happening with this species, this is happening with that species. What if the state said to you, why don't you go and hire some biologists and give us a big report and here are the kind of biologists we want, one biologist who thinks this kind of thing, we want you to hire one biologist who's this kind of biologist and you would have to pay for all the biologists and everything, but in this way, the state is saying, okay, well, we've got all these people who do all this work for you, you just tell us what you need to know about how they impact on your land. So you don't have to wait, but you're not paying for the biologists. So that's kind of a positive. So we, again, the unique situation because of the size of our company, we do have biologists on staff that have expertise in these different biologists. But it would cost you to have them pulled off to do the work. And it is costing us, because they are on this project. Oh, they are? Fishing game asks a lot of questions. They don't just tell you. And I'm not sure if it would be a benefit to a small landowner or not to have the role of fishing game as you're describing it. It's not really a do this, this is happening. It seems to be more there trying to work out internally how to match sometimes conflicting goals on habitat or special areas or things like that. So I think that they could work with any agency to clarify some specific guidelines for areas that are sensitive. And then the landowners would know almost more of the check box. Like if you have this type forestry, what we do is we are basically creating and manipulating habitat as we do harvesting. So if you have an area that is important for habitat, forestry can play a real important role in that. And I think it would be very simple to give some guidance so that the agency had worked that out already amongst themselves. And then they provided that as a document that said in these conditions do this and that would make it in the 10-year forest management plan process a forester to take that into account or put the landowner to say, we're gonna harvest here, we need to consider these things and work that into the plan. And I hear that, but I also, that doesn't take, but act 250 saying here's what we really want you to watch out for. And then you're saying that you'd like more predictive of ANR. So that's a different thing, right? And then the other thing is if you've got biologists and they're all working together, how do you make something so certain if it's in different areas where it's, it could be one way or two that, like how do you make rules for all those different eventualities? Yeah, that's a good question. I'm not a biologist. I don't wanna stray into trying to answer questions that biologists should be answering. And I think it might be a good question for the wildlife of the agency to ask them, how would you approach this? My take as a forester is that they're not looking at conflicting recommendations on a specific species, but the fact that multiple species sometimes use an area, you need to be able to provide some guidance on what is most important. You don't need to be able to do that. The agency can provide guidance to landowners on, this is the species we're really concerned about, and this is the way. So for example, they have done that in the past with deer wintering areas. So what we often remember to do is deer yards, places that are heavily softwood dominated with thick, brown covered places where when you walk under them in the winter, there's very low snow. The deer all go there in the winter, they're really important places for deer. And so the agency has recommendations on how you manage and they actually have designated deer yards where on our property, when we manage in that deer yard, we need to consult with them to make sure that we're implementing harvesting practices that help that deer yard, not hinder it. So that's the type of concept I would have about these other habitats. That's very helpful to you. I have one question here. In the forest management plan that has to be submitted, is there reassurances that that plan will be followed? I mean, if you look at the industry's record, if it does not comply with what it says and what it's going to do in the management plan, is there any kind of punitive reaction by the state as the state can then take a very good look at what you are doing to make sure you are following? So I can speak to my experience with that and I'm sure that Commissioner Schneider can speak to that as well. But we work with the county forester. County forester has a responsibility to monitor that 10 year plan and to make sure that the landowner is following their plan, the specific silviculture of the harvesting that they said they were going to do and any other provisions of that. Does this include environmental values as well as ecological values? Absolutely. Yeah, and then those, there's protections, as I mentioned, outside of the plan. Just the laws and the rules in the state. So around wetlands, around streams and stream buffers. When you're in current use, use value, then the AMPs or acceptable management practices become mandatory. And so for us, we have to implement buffers on all streams. We have to use specific types of crossings if we need to process streams and impact that stream. Even temporary, just like a skid trail type with crossing. There's a lot of things that have to be considered and those are really outside of UVA. Can a landowner get kicked out of the program if he while age? That's what the statute says. And again, I would defer to Commissioner Schneider for the details. I'm just asking if a landowner could get kicked out of the program and follow his course management plan. Would you like me to address that? Yeah, well, yes, we should fight this. Sure, what do you need to? Yes, very definitely. Through our statutory role and program rules, we are required to make inspections, periodic inspections for conformance. And our foresters do that and they file a conformance inspection report. And on occasion when conformance with the Canadian compliance with their forest management plan, an adverse inspection report is filed and that leads to further process that can result in finding that it's a moving for removal from the program and notice of discontinuance and that can be appealed by the landowner, that can be in the hearing with the commissioner and it can also sometimes be adjudicated in spirit court and we've had several few cases that have gone to a Supreme Court where in every case the Supreme Court findings have held the state's decision to remove first statute landowners, parcels enrolled in the program, they were enrolled for failure to comply, they were removed from the program for five years, which means they go back to having more of taxation instead of use value taxation. And they pay the land use change tax, the penalty, which is significant. So the entire parcel is removed from the program, not being re-enrolled for five years. There must be a, what do you call it, I'm sorry, a mitigation plan for you to show that you're back in compliance to come back again after five years and all the while you lose the benefit as Mr. Fyfe identified earlier, it is considered development. And so when you violate that requirement, there's significant benefit, I hope that sort of takes the picture for it. And I guess to give you some perspective, it's not common, but it's not, I mean, it's not rare and it's not frequent, but we've had a number of them over the years, yes. Representative Schruer. Yeah, just to follow up on that, how often do you do inspections as it's based on the size of? Yes, sir, it was, it's based on, we have a statutory requirement to visit basically every parcel of every 10 years. So it just wants everything? It used to be, well, the requirement was more frequent. But we have almost 16,000 parcels, two million acres enrolled in the forest management, just under two million acres of suns, with 13 county foresters. You do the math, some of them have over 2,000 parcels, can't physically meet that requirement. And so it was, we were given a little bit more latitude. That said, there's common interaction among county foresters and landowners during that period, where it's not necessarily waiting for a 10-year inspection. That's the minimum, but I'm happy to say most landowners are fairly engaged and will call the county foresters with questions or something's going on in the woods and they want to hear about it or they have an idea. So it's not like there's no contact, but there is certainly contact at least within every 10 years in an official inspection. Yeah, you made your one point. So the other thing in the state of Vermont that's relatively new is we now have licensing for foresters. So foresters who are actually practicing in the state of Vermont need to be licensed. And to date, that hasn't, I think it's still building what that really means or how that tool could be used. But it is a tool that a forester can't go out and do unethical or unprofessional things. And so if you have a law or a management plan that says we're going to manage this one and you purposefully decide not to do that, I guess my point is there's another layer there of oversight where the forester who wrote that 10-year management plan needs to ensure also that the landowner is aware of their responsibilities and attempting to follow that 10-year management plan. Thank you. Take one more question then we'll move on to the next question. I just wanted to ask a question that's really not related to what we're talking about right now, but you must be quite pleased that the population of the swamp donkey up your way has decreased tremendously and not eating your young forest any longer. I would imagine that to be a swamp donkey being moose. Being moose, yeah. Well, I actually like moose. I like to see moose. But the level of the moose population was much, much too high. We were not having regeneration on- Because I had seen the devastation. It was just leveled. And those acres, the good news is are coming back with a lower moose population. Our regeneration is surviving. We're seeing new regeneration in those places, so it wasn't a total loss. We were pretty worried on what is the future of these areas, but I think we're more optimistic. And also the other piece of good news is there's still our moose in the Northeast Kingdom. Yes. And we still see them around in our logging jobs, so. But not to the degree they used to. Not at all to the degree. And there's some serious issues around moose that we're cooperating with the state to try to help figure out. Thanks. Thank you, Mr. Feig, for coming down. Thank you, and I appreciate that. If there are other questions in the future, I'm happy to try to help you. Thank you. Thank you. Next witness is Charlie Hancock. Please state your name and your affiliation. Next, for the record, my name is Charlie Hancock. I'm a consulting forester working with, or my company's name is Northwoods Forestry based out of Montgomery. I work with private landowners scattered across northern Vermont. Two other organizations I work with I'm on the Board of Trustees for the Vermont Land Trust and also serve on the Working Lands Enterprise Board. And I only mentioned those because they kind of help frame how I see the opportunity that's before this committee and everybody else in the state has regarding Act 250. I think that you've got some really great opportunities to both strengthen the mechanisms by which we can keep our forests as forests. But I think you also have a great opportunity to do some things that can help strengthen the working lands economy and really support it in a time when it needs that support. So I see this as a great kind of two-sided coin. I also want to just applaud your goals in addressing climate change through this process. Both the causation, things about emissions, but also in building resiliency through ecosystem protection and including intact forest blocks. I think that's really important. I think climate change is going to be a lens through which we're going to have to look at pretty much everything we do in the state in the future. So I'm here today in support of the effort to allow Act 250 to play. We need a more meaningful role in reviewing the impacts of development on forest land, specifically in strengthening the criteria to minimize the fragmentation of large priority intact forest blocks and connectivity areas. I spent a lot of work in the last biennium supporting H233, which unfortunately didn't pass, but that mirrored a lot of the same objectives. I do have a letter of support for that bill here signed by about 20 other licensed foresters, but I'll leave with the committee so you can review it in the future. I do think it is important though to understand that this mechanism of minimizing fragmentation in these large forest blocks is just one tool to ensure that our forests remain healthy and intact, providing the mirrored of ecological benefits that we want to see them do. In the future, as well as supporting a strong and sustainable working lands economy, strong land use policy through Act 250 needs to be considered in tandem with things like the current use program that we've talked about, efforts to support the working lands economy, such as your support of the Working Lands Enterprise Fund, efforts to local planning, such as Act 171, even things like succession planning in our state for landowners that are aging out and transitions we're gonna see there. And I do see Act 250 as having the ability to support revisions that will support the working lands economy, specifically in the wood products sector. Keeping a healthy fiber of wood products economy in our state is gonna be just as important as the land use policies that we put in supporting the efforts to keep our forests as forests into the future. So for that reason, I kind of consider my testimony to two different lenses. One is the importance of Act 250 as a land use tool to ensure that we keep our forests as forests, but I also see as an opportunity to strengthen our working lands economy. So regarding forest fragmentation, you know, why? We need to acknowledge and account for the fact that forest fragmentation is occurring in the state. A 2015 report from legislature, Vermont Forest Fragmentation Report. It's a great example of that. More recently worked by VNRC, their program tracking partialization over time has shown that this is happening and it's having a significant impact. There's folks that might say that something like this isn't really happening outside of places like Chittenden County, but that's just not the case. I can cite my own town of Montgomery where I serve as chairman of the select board as a great example. You know, between 2000 and 2010, we saw a 21% increase in population in our town. Projections made in 2013 are that we're gonna see a 12 to 17% increase by 2020. We've seen the impact of this growth on our own landscape. One example of this that I can point to is a developer in our own community who had a 200 acre parcel started out with a nine lot subdivision that over time increased to a 16 lot subdivision. And this occurred right off of Route 242 if any of you ever ski at J. That's right, we go up to the mountain. It occurred in one of the highest priority forest blocks and highest priority connectivity areas identified in that region of Vermont. So now we have a massive road system accessing 16 different 12 acre lots throughout this area, which used to be prime, intact forest, supporting everything from the wildlife populations we've discussed to the ability to provide a resource for the working life of the economy. So those are the things that we're actually seeing happen on the ground and they're happening in the rural areas where we don't quite often think about this kind of increased pace of development occurring. And with approximately 8% of Vermont's land privately owned, you know, the management and stewardship of these private lands will be essential if we're gonna maintain priority forest blocks and these connectivity areas between them. And we can define stewardship at a personal level, working with individual land owners to ensure what they're doing. We thought our objectives to resource protection. When we scale it up and think about stewardship on a statewide level, it's these tools like either zoning, like Montgomery has done, or with state regulations like Act 250, as we seek to guide how we look at managing these forests for our future. What these proposed changes will do, which I strongly support is to change the trigger to review, I'm sorry, to create a trigger to review and address the slow development that's been occurring, which leapfrogs the jurisdiction outlined in the original act. The historical patterns of subdivision, these slow and steady movement, which helped trigger the number of acres, the number of blocks developed in these areas within 10 years, as the present definition allows, is what is allowing for this historical slow perforation of our forests, and which are the biggest driver for our unconcerned forest loss and fragmentation in the state. Again, I'd say it's the example in my own community of Montgomery. Lowering threshold criteria would address the fragmentation that's occurring through development, and go a long way to help protecting those resources. Another point is that the existing criteria, A, in the act, is not sufficient to meet these objectives. The importance of these priority forest blocks does not translate to the existing definition of necessary wildlife habitat. It lacks the understanding of the broader impacts of unfragmented forests and what they provide. So changing the criteria, I think is also a very important step, which I would support in this bill. Another change is also the mitigation. Mitigation would allow for, if it is not feasible to minimize forest fragmentation through proactive site design, the bill outlines steps for encouraging this, but it would also allow for that development and have a mitigation factor on the back end of it. What this bill doesn't do, or what changes I don't think would do, is prohibit development in these forest blocks and connectivity areas. I want to see growth in my town. I want to see the population increase. I want to see young people moving in. So we want to make sure that happens, but we want to make sure it happens in a way that's planned. For active site design to minimize forest fragmentation and the negative impacts that they have on our forests. Now shifting a little bit to the working lands economy, as previously stated, the updates that you're working on for Act 250 also present opportunities for amendments to the act that support the working lands economy. As this committee articulated in the past, I think you want to encourage smart economic development specifically on our rural communities, which is my only Montgomery. So I want to take this opportunity just to present a few solutions that might be incorporated into the bill to support forest-based working lands businesses, while still achieving the goals particularly in the original act. These might echo some of the proposals that forest departments have put together in the past, so I'd encourage you to look back to those and encourage you to talk with Mike, as I'm sure you do a lot. They might also preview some proposals that might be coming from the policy committee of the Working Lands Enterprise Board, which I serve on. So look forward to that letter and also please rely on SAM as a great resource as well. You know, these working lands are critical to the economy of rural communities and to maintain the character of a multi-conic landscape. These industries are facing challenges, not only on our operational conditions, you know, the things about climate change, how that's impacting what we can do and where we can do it, but also shifts in commodity markets which are precipitated by forces that are well beyond our control, whether it's international tariffs or energy policy, then the differences between Quebec and Vermont. These are things that are totally outside of the control of our industry. And yet we see our industry exploring new ways of diversifying and expanding in order to add value to our products, to stay viable and essentially maintain a working lands economy in our state, which I think is really important if we're gonna maintain essentially the character of Vermont and what Vermont is. So four quick examples of I think some opportunities that you have as you consider revisions. These opportunities relate to jurisdiction under the act, the complexity of the existing permit system, the rural nature of forest products businesses and their impact to soils that articulate an existing criteria, and then tying back to climate change and its impact on weather and its relationship to timing for forest products operations and permit conditions that affect that. As far as jurisdiction goes, you know, by our very nature, forest products industry businesses and the supporting facilities are often located outside of the existing settlements or designated centers that we see and we talk about in land use planning. For these reasons, often the one acre or 10 acre thresholds we see in Act 250 review or such situations that might be created by the rural and working lands definition that you're working with that are applying to be applied to other commercial or industrial activities may not be appropriate for the forest products economy or forest products industry. For that reason, I urge the committee to support different jurisdictional thresholds specific to the forest products industry. For example, there are some proposals that were floated in the past about volume of materials processed or stored. So I would encourage you to look at those changes as a mechanism of, again, supporting this industry and the businesses that depend on it. Another example of an opportunity, I think, is around permit complexity. You know, the permit process itself is complicated and really complex and nothing beyond the scope or ability or capacity of the applicant. Costs and enterprise vastly more than the narrow profit margins that we're seeing in an already struggling industry. I'm sure you can ask Colleen years here today for experience with that. So I would support the committee to look at developing either twofold. One would be the potential for a process for expedited findings for forest product industry applicants, similar to expedited findings for downtown development that we already have. I'd also encourage you to direct A&R to develop guidance documents related to permitting for forest products industry in consultation with forests and parks and potentially provide a dedicated staff person to provide assistance to the forest products industry for people like this referred to as permit shuttles. They can be a huge help in helping people navigate means and outs of the permit process which can also often be not easy for lack of a better word. Another challenge is around agricultural soils mitigation. Serious burdens are placed on businesses that are trying to add value to forest products but the mitigation of operations on prime agricultural soils is they're presently considered under the act. You know, working on the enterprise board we've heard stories of processors through incurred costs of up to $200,000 are struggling with this. And again, when you have operations that are already struggling and don't have the capacity to cover the cost of this magnitude, they can serve as a deterrent to new investment. And simply by their nature, these businesses often cited in rural areas have no other land-based available if they want to expand their operations. And we also see these businesses as being essentially a conservation multiplier as it's been made countless times. You know, a vibrant working force economy and the ability to have that with processing industry helps support working forests, helps support keeping them in touch. So what I would support the committee in doing is working a lot longer lines with some proposals that Mike's job has offered to create a conservation credit system. Essentially, you know, accounting for the fact that these businesses provide this conservation multiplier in creating an alternative form of mitigation. Another area is limits to the hours of operation. And also, it can oftentimes be a hindrance to businesses that often have to be nimble in changing. And we talked about climate change again with our changes in weather patterns and just over the past couple of weeks we've gone from winter to what seemed like spring with rains and things like that. You know, we have to be nimble in changing to these conditions. And the variable on the ground conditions often precipitates rapid shifts in our operations. So then assessing the unpredictability of these weather patterns can create short windows of timeframe which we have to operate to essentially do the work we need to do. In shifting these hours of operation they can be in conflict with a Business Act 250 permit which can be a big hurdle or a significant hindrance to the business. So again, what I would support the committee in doing is looking at a revised permit system whereby a forest-based economy can operate outside of those standards for standard hours of operation as necessary given the conditions on the ground. This can be incorporated into a revised permit template for a forest-based enterprise to allow for off-hour delivery for certain products. And again, I would point to some suggestions that forest departments have offered. Lastly, two just quick points. One is something Chris touched on so I won't dig into it too deep. But I would, I'd really question the lowering of the elevational trigger to 2,000 feet. I think the objectives are good but I think that the impacts might not have been fully considered. And so for all the reasons that Chris outlined I would consider revisiting that. I would also consider taking a look at the critical resource areas definition. I think again, I think the objectives in defining that and looking at protections within there is a lot of the goal. I do think that as it's raised right now at least in the bill that I looked at it could create some issues. So perhaps look at things like the rare threatened danger database the state has for natural communities or other tools around resource mapping as a potential way to look at how you can address that rather than just the broad definition of critical resource areas. So in summary, the problems facing the wood products industry may seem kind of marginal. We need a scope of everything happening in the state or everything happening under Act 250. And certain examples might seem like one-off problems but I would urge you to understand that on an industry it's kind of on the brink of potential collapse that's not really hyperbole. Marginal issues can be a breaking point. And so take them seriously, consider them in your work. And again, I think that the opportunities that you have before you to kind of combine the objectives of conservation. Again, looking at maintaining these large tracks of upregulated forest need to be taken in tandem with the ability to create multiple small tweaks to support a working lands economy that depends on them. And again, which really defines our state. So with that, I'll end and I apologize for going kind of quickly, but I do want to make sure you guys can hear from Colleen because not only is she just an awesome person but she's got some great insight that she can offer. So thank you. Representative Odie, I didn't have a question. I just wanted to make sure we keep, we can get a copy of your testimony. Yeah, and I will, I will email a copy. I didn't actually finish it until about 10 minutes before coming in here. So I'll email you a copy today, certainly. I have a quick question. What are the impacts at 2,000 feet that you're talking about? So I think Chris, I would like- The detrimental did. And now I think detrimental as far as timber harvesting goes or detrimental to the permitting system. Everything, what you were talking about. Yeah, well, I think Chris echoed, I think the general concern that I've got as far as lowering the threshold to 2,000 feet because when you pull operations, well, basically, you lower the threshold, right? You've asked to increase the amount of rate of courage that might fall under the permitting conditions. As with Chris, I haven't taken the time to do the GIS analysis to see how much of a land base that would increase, but it would be significant. And just essentially it was what Chris outlined that when you pull that into the permitting process, you create a lot of hurdles, I guess, that you'd have to jump through in order to get things like your timber harvesting, the ability to conduct timber harvesting in place. And so I think those kind of hurdle-to-road blocks can be things that, as Chris outlined, can be increased cost to land harvest locally. So it's not really a bad thing for us to do, it's a bad thing for you guys. Because of the time factor. Yeah, well, so I think, I think the objectives by it are good, and again, laudable, I think that the impractice implications of it would be detrimental to the industry for the reasons that Chris outlined. Slowing things down, increasing costs. Yeah. Okay, thanks. Two things, thank you very much. You mentioned conservation multiplier as a way to tweak, change, maybe even substitute for mitigation. Could you flesh that out for us later, send us something that talks about it? Yeah, it's okay. Or can you just, like? Yeah, so I think the phrase conservation multiplier, just to, I don't think that's actually a tool in terms of thinking about how you can look at the impact of a business, the ancillary mitigation to ag soils. There are some tools that have been developed in the process of the forest parks have offered. When I think about a conservation multiplier, I guess I see that more as the ability of business, such as Paulines, to be in effect something that advances the goals of conservation. As I said before, if we're gonna advance the goals of conservation, keeping our forests as forests, we have to have the strong land use policy aspects of it, such as the things in the bill right now, looking at keeping intact blocks of forest to forest, but also keeping the working lands economy strong. If we don't have the ability to sell these markets, we don't have the ability to generate the income, to hold the land, to keep it viable, for those reasons. So the conservation multiplier effect is to say that it might not be directly looked at as something that supports conservation, but what products business does in fact, support those long-term objectives. So I'm guessing it's really a reinforcement of what we have now. If you gotta mitigate, and the only way you can do it is off-site, a two-to-one or a three-to-one or a four-to-one, that's really what you were talking about. This is not a new concept that you were promoting. It's not new and it's been floated for the past couple of years, and the last biennium things like this were considered. As far as that, the specifics around those kind of things goes, I can supply you later with some more details of what that proposal was. Okay, good. I would appreciate it. And changing to 2,000 feet from 2,500 or even a different elevation. If that were parsed out to protect the forest industry, while keeping, and at the same time, keeping other kinds of development, and the only reason it would be development under the forest industry is there are some roads that that involved, I think, but at any rate, if that was parsed out to protect the forest industry, and make certain that new homes and what have you, let me say forest and ag industry, but keep, but then recognize the need at 2,000 feet to add some more jurisdiction for other kinds of uses would you not support that? Yeah, so I think separating this out and saying what we're discussing in terms of forestry and ag, versus what we're talking about as far as other industrial, commercial, residential development needs to be really important. And so I completely think that, well, we might think about criteria or jurisdiction of figures for things involved with forestry or ag. We have to think of them differently when we think about the other kinds of built environment that would be fragmenting features. Thank you so much. Yeah. Representative Bell. Good morning. Hi. Very helpful. Thanks. My one question I'm struggling with, and maybe you can assist me, is what, and I think some of your response to Representative McCullis I think was getting us on track, but you had mentioned a couple of priorities and one of them being how to support the forestry markets. Can you elaborate a little bit more about what that looks like? Oh man, we could, how much time you got. I think that in terms of how do we support. Through this jurisdiction, through this discussion. So I think through this discussion, as far as the tweaks that can be made to act 250 to support the working room economy, again, they might seem like minimal things such as looking at the agricultural soils criteria and the impacts there. That there are small things that can basically ease permitting or reduce the financial impact of permitting on these businesses. And that's just one piece of a larger puzzle. So when we think about how do we support our forest products industry, or even our working lands economy, it's not just one thing or another. All these things are small things that when you put together and build up, they work together to really lift it up. And as far as like the tweaks to act 250 go specifically on permitting, one thing that we hear on the working on enterprise board is we consider these applications to help really amazing businesses expand, diversify, do things that might be those triggers that are gonna have the broader impacts in the industry. One question that comes up time and time again is whether or not they have their permits in place. And I always find that kind of interesting because on one hand, we have this organization of the state of Vermont seeking to help these industries and give them funds to really catalyze and help them grow. On the other hand, we have something that could potentially be detrimental to that growth. And so if we can tweak the permitting system in a way that still maintains the resource protections that we want, but does it in a way that reduces the burden on the industries, I think those two things together can really help advance the overall objectives of keeping a vibrant growing forest products or your working lands economy in general can't forget attitude.  I will email the testimony. And again, I will leave copies of the letter from last year. Again, it was referenced to 233, but many of those same principles translate into this bill. So again, I will leave this for you to consider as well. Thank you. Thank you, Charles. Thank you. Well, I don't have written testimony. It's all in my head in my heart as I came out of the warrior this morning. But I did make some copies concerning testimony last year at House Forest Green Ag. And I put a little piece of wood on the top so keep in mind that wood is good. I think that's our motto. You're the lady we see on TV all the time. Well, you just never know we're all here. No, I'm going to talk from my head and my heart because I'm going to take pieces from these documents that you can take home and the rules, but hit some high points and echo some of Charlie's thoughts on working lands. So as I mentioned, I dug out my notes. I'm calling Goodridge from Goodridge Lumber. I'm the oldest person at Goodridge Lumber. I operated with my three sons, Doug, Mark, and Brian. We have four other employees so we employ eight full-time people, one part-time office worker. We specialize in the production of white cedar lumber products from log homes to decking to v-group paneling. So get our raw material from within a 75 mile radius of the mill, grows in the Northeast Kingdom, mainly in Orleans and Caledonia County. This is our 45th year anniversary. So just if you want to subtract, I started when I was 10. Just to date myself. So we have a long history of working in that forest-related business in the Northeast Kingdom. 75 mile radius for our raw material and we work with 100 different landowners, loggers, foresters, and truckers on a yearly basis of all shapes and sizes from a forest landowner that has 25 acres and may be doing a little cutting and brings some cedar logs in with a pickup to a farmer that's doing a harvest, getting his fence posts, bringing his logs in to get dollars for his seed or his fertilizer for spring to more of a highly mechanized operation. So we try to provide that market in the Northeast Kingdom for those products that are harvested locally. And having been in the business for 45 years, all of these people have become like family now with a third generation. Hopefully going to have the opportunity to continue these businesses. And hopefully they will. As we mentioned, many challenges in the forest products industry, running a business with so many variables, very similar to ag with seasonal situations, high operating costs, insurance, global markets, and permitting and regulation as well. I will mention that it's critical in the forest industry that we have all those key players in place being able to make a living or we all go. If we don't have the sawmill to use the raw material, it doesn't matter how many logs they cut because they don't have a market. If we don't have someone doing management plans, we lose that piece of the puzzle. We need the truckers to get the logs from the landing to the sawmill. And we need that landowner. We need that landowner with the raw material who was able to get dollars off that property to support his way of life. And that's where it starts. So if we, if our deliberations on Act 250 and planning, we have to work together to figure out how can we make sure that that landowner is there?  My scare is that if they're not able to meet expenses and the land asset is all they have, you know what's gonna happen. They're gonna sell some land. And then that, who knows where that's gonna be? Is that gonna be development? Are you gonna find a person that's gonna carry on your traditions? So I think the best tool we have for forest fragmentation is active forest management and allowing these landowners to make an income, whatever it may be, whether it's maple syrup or Christmas trees or logs or forestry and ag is so important. So that's my key thing is as I'm looking, someone said, do you think there will be enough trees or do you, whatever, what are you having for your outlook? And my biggest concern is a change in land ownership. So I think it's vitally important that we keep those landowners able to make a living from whatever product that they have and generally those landowners want to keep their land intact. A little bit about myself, I was born and brought up on a farm, a 400 acre farm, which is still in the family. My mom is 87, still living in the same old. So a little stint teaching early education and then my sawmill career beginning in 1974, but not really strange at all because forestry and ag are linked together where the same, we work the land. And so I do have a passion for that and I guess I would say that any of these people that I've worked with that are in the business no matter what sector is a special kind of person rather unique and I think it would be nice if all of you could meet a few of them. But it's like a farmer, you don't have 95 hours, you're seven days a week, you're out in the cold, you don't know if the weather's gonna be such that you've gotta be down a few days. So they're hardy individuals and unique individuals. And if we don't have that type of person that has that passion and that strength, both in your body and your mind and their soul, are we gonna have a third generation? And one of the challenges that we have in the industry is who is gonna be, who are gonna be the next people that carry out the management of our forests. I'm on the advisory board of the North Country Union High School Forest Water Resources Career Center project. And we're looking at these bright young people, we do many educational activities at the mill having field trips and we've got these bright young people that wanna work outdoors, wanna work with their hands, maybe wanna carry on a family tradition. And so we work with them and then as a business person and knowing where we are in the industry on Tee to Re Ground, it's kind of a mixed feeling that I have. I hope we can continue having a vibrant forest economy, ag economy because these young people have the skills and the passion to carry on the traditions and they wanna stay in the area, raise their families. Our schools are declining in population. We need more people to stay here, have jobs, raise their family. We do have values here that may not be in your, you know, your dog market account. We tend to be very humble people that wanna make a living but if it comes to the point that the numbers are not adding up, decisions have to be made and they're not always fun decisions. I've seen in the last two or three years, I've seen companies downsize to try to keep ahead of things. I've seen the third generation coming up and the dad's saying you need to do something else because this is not gonna be a future. So that's pretty sad but it's happening. The average age of a logger or probably a saw miller is 55 or above. So who is gonna be the next stewards of the land? Good question. I do holds, besides my saw mill career, I tell everybody when I do hire them, I've done everything but I haven't done much sawing and I'm not on the log board but I have, you know, done my share and I guess that's why I have an appreciation for, for the business and all the people that are needed to keep a forest products going industry. So I do serve as the Vice President of Vermont Forest Products Association on the Vermont Storeship Committee, Farm and Forest Viability Advisory Board and I'm past president of the Northeastern Loggers Association so I feel that in serving these other organizations, I've taken my little business here at the end of Bailey Hazard Road East and I can share information about what's happening in Vermont and then take that and see what's happening in the Northeastern United States. So that's always been good for me to find out what is really happening. We started out in 1974 actually a little before thinking that it would be fun to sell logs for our own log home. So the commercials when you see the log home, you have to picture these people living in a mobile home thinking it would be fun to have a log home that did help these logger up back harvesting timber, took logs, bought a $500 sawmill. That wasn't worth much because the parts were all gone. I mean, we started underground. We were on less than an acre. Well, many years went by and we found out that we were supposed to have an Act 250 permit once we went over the one acre. Albany does not have zoning. So we embarked on the Act 250 permit process kind of backwards, so to speak in 2000, I guess it was 2013. And in your packet, you'll see the steps that we had. We had some very good experiences. We had some good helpers along the way. We had some that were not so good. I won't go over those stories, but very important that the district commissioners that go out understand the importance of bagging forestry, and they are there to assist businesses through the process. One of the things that was hardest to address was aesthetics, you know, one person driving by. I see a nice pile, log pile. The first coordinator we had drove in the yard as we asked for his assistance to navigate the Act 250 process and he thought it was quite an eyesore. I don't want to tell you where I thought I'd take him. But I said, well, that isn't what I see. So we went up through and luckily we hired our own consultant to help us fill out the permit. We had the information, we just didn't know how to get everything down in document form. So we went through the process. Luckily in our findings of fact, you will read in here that it was determined that wood product facilities, including a sawmill, a log truck, a log landing, all of these were not aesthetically unpleasing. It's who Vermont is. And those are all symbols of our culture, our way of life, part of our economy and what keeps our environment in good health and shape. So if nothing else, if the business was to close, we found out that we're not an eyesore. I think that's big. When you're having companies apply to form a business, it's very easy for people that maybe don't understand what we do and not everybody was born and brought up on a farm and understands what's happening. And maybe we've been a little behind the ball in telling our story, getting it out to people how important these businesses are in forestry and ag. But I was very pleased that we could establish that at least we weren't an eyesore. Prime ag soils, part of where the sawmill was on DMAT, was listed as prime ag. It did take us seven months to determine that it wasn't. Prime ag in the meantime is a small business owner not knowing, well, what does this mean? What does mitigation mean? You mean I'm gonna have to pay some money because this building is here? So I always said that agriculture and forestry were the same and if you were contributing to adding value to these forest products, that perhaps you better look at prime ag soils a little differently for forest-based businesses. Hours of operation, we were pretty good on that. The only thing was that we were not able to saw our plane on national holidays. Well, obviously we're not there on Christmas and years, but we did Columbus Day, we were President's Day, Martin Luther King Day. So those four days lost to production is about $25,000 to $30,000 worth of income. So that's just a side note that about timing, we happen to use white cedar, which grows in swampy areas. So our raw material comes in between December and mid-time. 80% of all of our wood has to be brought in from frozen ground so that we're environmentally sound and bringing it in. So we have to work with the weather, work responsibly. A lot of our truckers, 60% of their income comes in the rare months. So when we're talking about keeping these different sectors alive and being able to make a living, very important. The cost of us going through Act 250, it was a two-year process. Our main thing was the fact that we rented our log storage areas and in order to make sure that they were there for the future, we had to take time and luckily the landowners were willing to sell to us. So that took time to get everything surveyed, have our deans in place. Hiring our consultant, multiple other things, it was about $100,000, but I will tell you that we were helped out by purchasing that land to make us more stable because without log storage areas, there is no money in transporting logs even a mile up and down the road when you're talking about a million feet of wood. So they have to be close to the mill. We did receive a $30,000 grant from the working lands and as part of their support of our businesses, I can tell you that through the application process, they're very careful about wanting to make sure that you have a business plan. It's a process to get through, which is a good one. They're all looked at very closely for sustainability. And as Charlie said, it's a little amazing to me, and this is what we can all work together on, is when the Council of World Development determined that the working lands and the farms and forests were the core values of Vermont and where the working lands initiative sprung from that and then the working lands grant program, we're all working to this goal of sustaining and growing these important things in our state because that's who we are. And then it comes to the permitting process. So it seems like as we're working together for solutions, we need to align the legislature and their allocation of dollars to promote and grow these industries that the Act 250, we all know rules and regulations are important, but let's make sure it's not hindering that these dollars are used to the best. I did attend the Act 250 hearing up in your neck of the woods. There were a lot of people there. It was a little disappointing that we could not get to some of the real issues that were on our minds. We know that we all have an opportunity to write in written comments. I will tell you that people in the forest industry generally like to stay out in the log pile or the mill and do not like to attend meetings. You're lucky if you will have them read their newsletter and getting them to meetings is hard. And if they didn't get to the meeting to express their concerns, you probably won't get a written. So I did respond with my written comments which represent a lot of the thoughts from many of the people that I work with just that we need to make sure that we have a balance between environmental protection and economic prosperity. I believe those are the two on the pamphlet I read, those are the two key points of Act 250, protecting the environment and promoting economic prosperity. So make sure as we're working together and I'm thankful that you're allowing the forest industry to have input in this because it is critical. Because if we go, Vermont is not gonna look. Probably not in our lifetime, we're not gonna know to sit but I've had my grandchildren's, you wouldn't know to sit. So you don't find these people every day that are willing to perform the tasks necessary in all the sectors. I'm not an expert in urban development. I can tell you what I know about forest based businesses. And on the October 10th, you will see, I have written down better considerations, better recognition of the forest based businesses and the people who dedicate their lives working the land who need to be accepted, appreciated, valued and supported. A, A, Z, V, S. I like abbreviations so I can remember. Accepted, appreciated, valued, supported. And we can do that as a group. We can do that. We need to be more business friendly. I've also spoken to different people who have moved to the state in business. One specifically down in Wells River who jumped the river, had a wood planing facility. And I like to ask the question, how are you doing? How did it work for you? And he said that was the worst mistake he ever made. That's kind of disappointing. We need to do something to let investors know that we're here and we do want them, which I hope we do. Promote the development of markets close to the wood source, resulting in more dollars for all of the supply chain, providing employment opportunities and the environmental benefit of less carbon footprint while transporting products to market. I think, Ed, in your report, you noted the number of sawmills left in Vermont. What was that? It went from what, to 17 now? Quite 17, saw a million feet or more. So we are not gaming with based industries. When we were going through our Act 250 process, I tried to reach out to all these other mills to say, well, how did you meet this goal? Or how did, and what I found out was, since 1970, there have been few forest-based businesses, sawmills, apply for an Act 250 and get it. It just hasn't been. I said, well, what about all these others? Well, their grandfather, they're 31970. So they're okay as they are, but when we talk about this third generation coming up, if those family members want to, say, expand or change the mill configuration for more efficiency, safety, or whatever, then they will be in the Act 250 process. And many of them, and I can cite many up in our area, have just said, I think we've come to the end of the road. You don't have the dollars to go through the permit or do what is required, so they're closing. So we are seeing closures as they go into perhaps the Act 250 process. Strong forest products, industries that best safeguard against forest fragmentation. I've talked about the primary mitigation, flexible conditions, as Charlie mentioned. Winter months, as spring approaches, sometimes it's necessary for maybe the locks to be held all weekend to get them off the landing and stay on frozen roads. So, flexibility there during different seasons. Cost of operating a business are ever increasing, making it a challenge to keep the business healthy and viable. And if the permitting process becomes too restrictive through regulation or too expensive and cannot be completed in a reasonable timeframe, the project will not exist. It's not economically viable, so it doesn't matter how much you love those trees or how much you love this. It's got to be profitable. So, I mentioned about the 1970, so I look at it as an opportunity, as Charlie said, recognizing what our core values are, knowing that the wood industry is declining. And we hope through the working lands investments and maybe what we can do as far as the regulatory process, at least for forest and ag, maybe there's some tweaks that'll make it so that we can continue. That is the end of my story. Thank you, Colleen. We're running a little late, but we'll have a question before we start working. I appreciate your colleague card here, just the woods. It's Burr. And I hope you appreciate my campaign material. Oh, I love that. I love that. Give it to her. I'm going to take that back. What will we meet next time? Thank you. It's not a timber scaler. I think that is not white cedar, I think, but it is made in USA. I love that. Thank you very much. Any quick questions for coming every day? Five minutes? Yes, five minutes. It's a business question, so I don't know how this industry works. You said, if you're not working for those national holidays, that's more than 30,000 a day. How many days? For the four days. For the four days, it would be about four days. So how many days are you able to operate considering how, when you're pulling the logs off, where you can actually bring logs out of the forest because of the land being hard enough for? Yes, we need to be flexible in getting the logs into the yard. Once they're in the yard, then we can do our sawing schedule of the mill. So the mill itself is in a building where we roll the logs. That's any day you want. Yes, unless it's 30 below the limit. All right. But yes, the critical part is getting the logs from the landing, the land, to the mill across the road. And how many days a year are you able to do that day and night? Well, you have your month season. But you also have your ups and downs, like we have at this winter.  And every year is different. This year, we had winter come early Thanksgiving. So we're actually a month ahead. Now, we don't know. Is that going to continue through the 1st of April? I had so many days to think you'd operate. What was the worst year and the best year? Well, we can operate in the mill. It's the logging part and getting the logs from the woods. I guess I'm just trying to get at it. If you make the gross income, is it the gross income or four days of $30,000? Yes. And how many days would you be able to bring in that kind of income over the course of a year? I'm just saying if we could operate those four days, we'd have $30,000 more in the checkbook. So do you operate 365 minus four and then multiply 360 more times? No, it varies because we're seasonal. If it's a real pulse value, you might not have four days. But we saw a million feet a year. And we saw probably 5,000 feet a day, 5,000 to 6,000 feet a day. So it's hard to say how much per day, because some days are better than others. I'm saying if we could operate on a regular nine-hour period on those four days, that would be $30,000 of product that we saw in those four days. We do saw the rest of the year, but I'm just saying when we're talking about restrictions and we're talking about bottom line on income and expenses, just something to consider. So it's not like. My apologies for the waiters. We've been here since mine, so it's been a prank. I don't blame you. And please, if you have questions, just talk to her. Colleen, thank you for supporting me outfitter.