Good morning and welcome to the Vermont Legislature's House Committee on Environment and Energy. This morning we're going to continue taking testimony on S5. And we have with us the Attorney General, Jerry Clark. Welcome. Thanks. Thanks so much for having me. I am here to answer questions about the role of the Attorney General. I think generally, but specifically vis-a-vis this body and appreciate the opportunity to come and provide that information. So just a little bit about the Attorney General's office. We basically are the lawyer to the state, and we have about 150 people working in the office. And we're twice as large as the second largest office by a statewide elected official. We are the largest. We have 96 lawyers. They do all kinds of things. You can imagine whatever the state needs. We kind of do it. So an interesting, fun fact about the Attorney General in Vermont is that it's created by statute, not in the Constitution. In most states it's created in the Constitution where it's created by statute. Very helpful because you can look at the statute to see what the AG is supposed to be doing. Helpful, especially if you are a new Attorney General looking for what you're doing. So in Title III, Section 158, specifically, the Attorney General is obligated to come and appear before the legislature when they ask the Attorney General to do so. So to answer the question of should the Attorney General be appearing in front of this committee, weighing in on a policy, quote, policy bill, the answer is yes, they're obligated to do so by statute. Also, one of the divisions of the Attorney General's office is the Civil Division, which represents the state when the state is sued. So if someone has a contract to speak with the state, we will represent the state. If someone has an employment dispute with the state, we represent the state. I think you know where I'm going. Someone sues the state saying that a law you all pass is unconstitutional, we represent the state. I'm kind of lawyer what I'd be if I waited until I appeared in court representing the state to say surprise. I thought this was unconstitutional the whole time but I didn't tell you till now. So of course we're going to come in and we're going to tell you our feedback and opinions about whether or not a bill would be constitutional or not constitutional, or ways to make sure a bill is the most constitutional bill we can think of, etc, etc. We always try to make ourselves available and you will see me and assistant attorneys general in the building provided the feedback that you all need. I should clarify that of course you have your own lawyers, and that is legislative counsel, you have an attorney client relationship with those lawyers, not with us unless you know you are individually or suit or something like that and then that develops but just to clarify you definitely do have your own lawyers with that relationship. That's really all I wanted to say on the matter of the role of the general I was just closed by reiterating what Laura Murphy who is here assistant attorney general and director of our environmental unit said which is that we do support the clean heat standard, and urge you to pass it. Thank you for coming in and as a committee that doesn't often, you know, invite or hear from the attorney general's office that's why we wanted to hear back from you to understand that so the legal context is very helpful. I'm happy. I could go on and on and I know you have a lot to do today and especially as I which goes on and on. So I, I don't want to belabor the point but I'm also more than happy to talk anytime about the attorney general's office and our role and what we do and all the divisions because I kind of love it so I love to talk about it so you just let me know if you ever want me to come back and say more. And I guess I'd be curious how you with other committees who may hear from you more often. I mean how. How do you interact with them, like, yeah. Well, I would say there are there are certain committees in this building I'm going to say commerce, especially where there's, if you're looking for a consumer lawyer or an expert in consumer law in the state of Vermont, like almost every single one of them is next door in my office, or has been at some point in their career. So, you see us a lot on those issues because we truly are the subject matter experts for this committee you have a lot of subject matter experts at and our, in addition to our office. So, you might not see us as much but in commerce, we always show up because we know that there's only a handful of places besides the attorney general's office where that. Representative Smith. Thank you. Thank you attorney for being here today. I have a long question, and hopefully will require a short answer for it. Okay, I'll brace myself. We have heard testimony that the lack of labor force means meeting the that the lack of the labor force means meeting the goals of the global warming Solutions Act is going to be impossible. The word impossible was used. But where does that leave us in regards to the lawsuit provision of the GW SA that says anybody can sue the state of Vermont. If we don't meet these goals, the Senate heard testimony from the conservation law foundation that they are prepared to bring suit. Can we win that suit. What I'm going to say is the global warming Solutions Act is law, right, and it has instructed all of us to work together and the climate Council did a phenomenal job in a short amount of time to provide a climate action plan. Clean Heat Standard was obviously in the forefront of that plan, and that I was privileged to present once to I think that was their first meeting. I was so impressed with the thoughtfulness that with the questions that I got after my presentation, and also just having read the plan I was so impressed with all of the work that went into it. So I would say your question skips a few important steps which is this is the law. We have a plan on how to move forward to meet the mandates of the law. And what we should be doing now is doing the best that we can to put, I mean, I'm telling you what to do but this is my take, putting in place the best policies because that we can so that we can meet the obligations of the clean heats of the global warming Solutions Act. And I know that Laura, who was here testified more in depth. That's not really why I'm here today. But that would be my take and answer to your question. If we don't you feel we, you will win the lawsuit. Well it depends on what you do. I mean if you don't know anything on this bill I think it's going to be a little harder. And I hope you pass this bill because I think it's going to make it easier. You're welcome. You others have questions for the Attorney General, Representative Morris. Thank you Madam Chair. Thank you Attorney General for coming in. You say you're supporting s five from your office.  Are you supporting the 70 cents a gallon administrative there's certain components of that it's complicated. Can you define or break down a bit of what you are supporting and that's why you know I don't want to really get into a lot of the details. I know that we have tried to be helpful with regards to the constitutionality and those kinds of questions. So today I was asked to come in to prove to answer the question that was asked that Laura was not able to answer when she was here. I don't want to get into the details. Today. On that I'm not prepared to get into details on that. If you have specific question I can speak with Laura and then circle back with you like in the hallway. As I sound. Sounds like a good answer than all I'm going to get this morning so. Hey, welcome. Thank you. On that note. You've indicated that the Attorney General's office supports S5. It's going to hurt a lot of people that cannot afford to pay more money for heating fuel for gasoline. How can you support something like that. I was asked to defend lawsuits brought by the state as I just described and as you mentioned there are entities to work with threatened to sue over the Global Warming Solutions Act and over specifically, or I should say in addition, this bill if passed. You know, I'm really focused on the job that Vermonters hired me to do, which was to be their lawyer. And I am always mindful of the impacts that our decisions and our office and this building have on all Vermonters, including Vermonters who struggle to make ends meet. You might not be aware that our office also plays an important role with assisting folks who are in that position. We have rules and laws on the books related to, for example, propane. We provide services to 15,000 Vermonters every year at our consumer assistance program many of whom are marginalized in some fashion, whether it be low income or what have you. I always think about when we make policy they're always on my mind, I grew up in a rural place. I, of course, I'm familiar with and friends with the people you're describing. So it's not something that I don't consider when I take a stand on a policy, and certainly have them in mind. And I know the different action plan I think there was a whole subcommittee to address some of the issues that you've described. So I have put my faith in my trust in all of the people who work so hard on creating that plan. And I think the work that this body did last session is a testament to the work of that, of that, of the climate action. Council of the climate council and I think that you know you're seeing it once again here where there's so many people have so much knowledge and including on the topic that you raise, which I think is very, very important, but shouldn't preclude this committee and this body from passing a bill that's going to meet the mandate or attempt to be a part of the solution to meeting the mandate of the Warming Solutions Act. Yes, thank you for coming and joining us here today, and you wouldn't be here if there wasn't some conflict over the policy. Some of us actually think we have to pass this because of the doubling of fossil fuel prices that we're seeing and volatility in the market that is hurting rural and poor Vermonters. However, that is not my question for you. When you talk about supporting or not supporting, what is the basis of your support? It's my understanding that it's been the constitutionality, whether or not you feel it's a law that can be defended. Not the case or is that Well, of course, that's why we have come in specifically in this committee as a leader, as a statewide leader, as I've just articulated, I mean I support this in part because I have put my feet in the process that this body has created which was to create a climate council and that climate council worked collaboratively for, you know, a significant amount of time and continues to work to create the proposals that you've worked on, including this one. Thank you so much for joining us this morning. It's my pleasure. Happy to come back if you have any other questions, and I will talk with Laura about your question. Thank you. Thank you. And we might take you up on your offer of the primer on your office and at a future time.  That'll be good. Thank you. Thank you. All right, next up. Yeah, Richard coward. Welcome back. Good morning. I'm Richard. This is Richard coward. I'm principal at the regulatory assistance project. And I'm a member of the Vermont climate council, but I should make it clear that I'm testifying on my own behalf really based on my experience. On the Vermont PUC in on climate and energy policy generally, and on the climate council. So, I'm here I want to be really clear. I'm here in support of s five. And I want to answer some important questions that have been raised about s five. But I'd like to start by recalling why we're here, as the attorney general just did. In recent weeks, you've been spending a lot of time working on this bill and hearing a variety of many different points of view. And that's terrific because it deserves careful study, of course. The goals are important. Tackling the fossil fuels problem is something that we have ignored for far too long to giant problems. High and volatile fossil fuel costs, and the climate price and the climate prices are not going away. And waiting another year, another two years, another five years is not going to make those problems go away. Every year of delay every month of delay will cost for monitors more and dollars, and it will cost all of us in environmental harm. We have waited to act. We have had climate study after climate study this legislation this particular legislation in last year's version and this year's version have been studied and crafted amended and I'm happy to say improved. In three houses, it's already a year delayed. I hope you will be able to advance s five soon. Starting with my main message. Okay. I'm going to follow that up with four observations, and then get into questions. The high level top line messages are that we have to remember that high heating bills are out of our control. Unless we reduce our reliance on fossil fuels. Many of the clean heat alternatives are less expensive, and they're more local. So we need to create a structure to make those better choices available to Vermont. Just on I woke up on Monday to hear that Saudi Arabia decided well oil prices were tending a little bit lower so what were they going to do about that they got together with like four other countries and decided to cut back production so that we on the other end of the production would have to pay higher prices we can't control that. But we can control what we choose to heat our homes and buildings with that's point one point two if we leave it to the voluntary market alone affluent people will be able to change. But low and moderate income for monitors will left will be left behind in less healthy homes with higher fuel bills. We need a structure some kind of performance standard to ensure that low and moderate income households are not left behind. While people have means can pay to insulate their homes install heat pumps, whatever. Third point, the clean heat transition is inevitable. You know the writing is on the wall for fossil fuels, because climate change. And the someday we are going to have to make the transition. It's going to cost the longer we wait to get started. The more it will cost to meet our legislative climate commitments, and the harder it will be to build the businesses and the workforce that we need to get the work done. And finally, last top line message for anyone. This is a complicated matter. I appreciate that. And I appreciate that, you know, I've had the opportunity, along with, you know, other members of the buildings task force, climate council, the working group, etc. Other professionals, you know, to work on it for a long time. So, and here it is, you know, and your play. But as you consider passing out this bill remember before this act takes effect and before it is implemented. Implementing rules and an economic analysis will be presented to the legislature for review and approval. The check back provision so called check back provision is in this bill. There, there are perhaps dozens of questions that are in your minds that you would like to see more information on, but you're going to have that chance. I've been asked by a variety of people to address some of the major questions that are kind of out there for you and for others second. So, I'm happy to take questions but I'm prepared actually to sort of tee off or tee up to the major ones for you. So, the five, and I happy to provide my view my answers on those five questions. Question number one, I've been asked by a variety of people. Why don't we just enact a fuel tax. So, this is like taking you back to conversations that have occurred in this building over. I don't know, decades really. A question that comes up all over the world all over the country, when my organization talks to government. Big picture, there are three big policy approaches that you can take to reducing fossil fuels, the use of fossil. There are carbon taxes, or fuel taxes. There's cap and trade. There are performance standards. And we and Vermont have considered all of them. Some of them numerous times taxes and cap and trade work by pricing, raising the price of fossil fuel consumption and global experience shows us that this has three problems. The first is that in the housing sector in the building sector in particular, there are substantial what economists call market barriers to prices having the effect that we would like them to have to change behavior to induce building owners to create their buildings or change out their furnaces or what. If we, this legislature commissioned a study on resources for the future, I don't know, three years ago, four years ago now, that looked at this question and they reported back to you that it would take an unacceptably high price for price alone to drive change. And this is pretty much true everywhere, by the way, this is not unique to Vermont. Second problem with using taxes or cap and trade for the purpose of raising prices is that the price may be known if you set up a tax, the price may be known but the quantity of emissions reduced isn't going to be known. The Global Warming Solutions Act requires that a definite amount of emission reductions occur. And it's going to be very hard to know, first of all, the price, I believe would have to be too high. Secondly, you wouldn't really know you're going to meet the target. The third issue is that taxes will yield government revenue, which in some, some people view as a positive thing, and that could be useful. But will that revenue lower heating bills and will it lower carbon pollution? It won't unless the funds are spent strategically. Will it be spent to lower emissions? I think the policy and government would be responsible for spending that money and ensuring that strategically valuable portfolio of resources is invested in in order to lower heat bills and lower pollution. Tax revenue has to be appropriated year after year. The level of certainty can you have that we're going to be able to appropriate enough money to do all the work that has to be done and ensure that it is done and ensure that that money doesn't end up paying for something else. If the goal is to reduce carbon emissions. Just as a thought experiment. Ask yourself, how have we done on renewables? We're once done really well on. Because we have a performance standard. Not having to pay for our renewables by government appropriations. And so the performance standards of course, but they supplement the performance standard that is the main driving force and so the performance standard on the industry is what's driving change in renewables. It's what's driving change in energy efficiency. For anyone concerned about the complexity of some of the. And I want to say, I really appreciate that because I've been deep in the weeds on this bill. So I get it that there's a lot of issues there. The good news is that they're there because they're solving the concerns that have been raised throughout the whole process. And the bill as it stands now has features in it that I think are terrific. It makes it longer, it makes it more complicated, but they're terrific features. Imagine instead that you was appropriating the money to do this job. Wouldn't you have to answer all the same questions. Wouldn't you have to answer how many heat pumps are we going to pay for how many weatherization jobs. How are we going to score or count the GHG reductions from wood heat versus heat pumps. All of those questions don't go away. Just because now the government is spending the money to do the job, and they become political questions, not scientific questions. This legislation asks the PC to make these decisions based on scientific evidence about how many tons of PhD reduction you get from a certain kind of measure. If those decisions are made in the appropriations process. It's not going to be scientific. It's going to be political. This is why we have a PUC and I speak from experience that this legislature a century ago created a PUC for a really good reason. And in this legislation we asked the PUC to do its job with respect to this new area of work. Finally, I'd like to make a point about business certainty. We know we need the workforce. We need contractors who are prepared to hire people for a career in clean heat. Performance standard with with a lifetime provides certainty to the business community that this work is going to continue and it's not going to be subject to next year's appropriation debate. And the same is true for young people who may want to get into this work as a career. Both from the business side and on the workforce side, a performance standard with a long term trajectory provides the certainty that we would need to build the businesses to do this work. Thank you. Now, next question is, we've heard field dealers happily saying that they're getting into the heat pump business they're getting into the pellets business as I heard. I know people who are getting pellets from warrants or energy co-op for example. I have heard somewhat conflicting stories on this topic. On the one hand you hear, field dealers are already doing that we don't need a law because it's already happening. And then on the other hand you hear, oh my God, you're going to make us do it and it's going to cost the fortune we can't possibly do that. So both of those things can't be true. I suspect that the reality is somewhere in the middle. But clearly, if you want to look at the data, we are not on track to meet the GWSA goals today. What's happening in the market today is not close to meeting the goals that this legislature adopted in the GWSA. I will say, I mean, I pause to say, if in fact, field dealers and others are able to deliver what's needed to reduce emissions and reduce bills without this law, I'm totally happy. All the law provides then is a guardrail, a way of measuring our progress and to ensure that we're going to stay on track. I don't think that in fact we're on track. The data are present are showing that and the most credible data presented to the Climate Council is that we are on pace to meet about half of our goal with respect to cold climate heat pumps by 2030. We're about 90,000 heat pumps short, if you extrapolate current trends. We need many, many more times hot water heat pumps than we are installing today. We need three times more weatherization jobs than we're delivering today. And at least 15,000 advanced wood heat systems, beyond what we're doing today. So the we're not on track. The good news is that under this legislation, we would create a trajectory that would ensure that repeatedly do you see would be returning and asking the question, how are we doing, how are we doing. That's what we need. As we do with renewables, and as we do with energy efficiency, we keep coming back and asking, how are we doing, what can we do now, how do we improve the program. Let's stay on track. A related question that has been raised is, how can the obligated parties plan if they don't know what the price of credits will be this deal dealers are asking how can I plan if I don't know what the price of credits is going to be. Well, first I find this to be a surprising question. But it has an easy answer a relatively easy answer. It's a surprise coming from an industry with such volatile prices. Field dealers are veterans of not knowing what the price of their main product will be. One of the problems we're trying to solve here is that fuel prices are volatile and hard to predict. The price of clean heat credits will be a relatively small fraction of the total cost of and of a fuel bill and of that volatility. The, and it will be much more predictable. If you look at section 8124, it creates a three year planning cycle, and a 10 year look ahead at the level of clean eat credits that would be required. So, there's a projection for the purposes of planning built into the statute. In section 8125, which describes the default delivery agency, or agent will set a per credit fee on a three year period. It's right in the statute that field dealers and anybody else who wants to know what the price of credits are going to be with would face a price that is set for them on a three year basis. And this is kind of what we do for energy efficiency. We have a three year planning period energy efficiency programs. That would follow a potential study, a plan and a budget. So look at section 8125. And for any obligated party who thinks they don't want to go through the DDA, the default delivery agent, they can do it themselves, and they can make their own business plans about how many customers they want to provide different kinds of fuels to, or different kinds of services to they can do it themselves they're not obligated to go through the DDA, the DDA just gives them a solid option to fall back on. Question for does the affordable heat act provide benefits to commercial and industrial customers and small businesses. Any suggesting that the AHA is just about residential customers is just flat wrong. The definitions make this clear. The inventory in Vermont is is very well documented, something like 46% of total fossil fuel use thermal fuel use in the state is commercial and industrial sector so it's about half and half half residential FC and I are there opportunities to save fossil fuel in the commercial and industrial sectors of course there are. There's weatherizing the buildings, there's improving the heating systems, there's improving the water heat systems for restaurants that can improve water heating, dishwashing cooking. Dishwashing usually isn't thermal so I should pause on that one. Any other thermal compliance and the energy star program efficiency Vermont there are lots of places where those advanced electrically based appliances are rated made available, you can get rebase for buying. Here three projects in Vermont have included examples like line extensions to sugar makers, who are burning fuel oil, but could be converted to to boiling with electricity. There are other probably other line extension opportunities out there. I've heard of some that aren't thermal, but some of them would be thermal. Dairy operations like those participating in cow power and others can capture and use manure based methane to displace fossil fuels and earn clean heat credits. Anybody running, you know, a restaurant or small business has plenty of opportunities to take advantage of many of the clean heat measures that your home or my home could take advantage of. Industrial buildings and processes are even are more unique. In doing, they would qualify for clean heat credits, certainly for the building. And also there are electrical technologies that are often inherently more efficient than fossil counterparts. And in this frame it's also worth noting that the federal tax credits that are now available for doing this work in commercial and industrial settings. Federal IRA tax credits can be quite beneficial to businesses, particularly if they're paying the labor force. The prevailing wage requirements that are that give them I think a five times enhances their benefit by something like five times. So the tax credits are there to not leads to the next question. Why shouldn't we just rely on the federal funds instead of enacting our own statute. Good news here. This is really terrific news. So we should regard this as, wow, there's wind in our sales for doing the work that we want to do. There is federal grant money. That's coming to Vermont about $30 million for weatherization and 30 million for electrification. And we should use the money for clean heat. Absolutely applied, particularly to low and moderate income households. This federal money though, would only pay for a fraction of what we need. We're talking about the grant money. It would pay for approximately 3000 houses low income houses weatherized and maybe adding heat pumps to 4000 to 5000 moderate income and low income households combined. That's a pretty small fraction of the weatherization gap. That's a small fraction of about 80,000 households that we're facing now and a heat pump gap of 90,000 heat pumps. There's also some positive news. So I'm going to say that's great we should take advantage of the of those funds, but it's not an excuse to say oh well job done. We should have tax credits in the IRA relying on the tax credits alone would be a huge missed opportunity, because we'd still be burning one thing we'd still be burning more fossil fuel than than we should want to pay for. And a lot of federal tax credit money would be left on the table. Yeah, those of us who've been looking at this think that the tax credit provisions as I say are wind in our sales it gives the AHA a big boost, but only in coordination with a state program that actually takes advantage of the tax credit opportunity. What do customers really need in order to take advantage of those tax opportunities you know the customers need technical assistance they need some hand holding they need a somebody like efficiency Vermont who creates the efficiency excellence network of contractors that people can trust to get this work done you know you have to create trust in the market as well. And it's going to need additional support financial support in the form of rebates to those customers in order to really take advantage of the federal money. Tax credits only help if you have a tax liability. And it's worth remembering that 40% of Vermont households actually don't have a federal tax liability. So, relying on the federal tax credits to serve low and moderate income households is just not. It's not a realistic strategy at all. And as I said even for the able to pay households, the existence of a trustee network, a workforce. Additional state rebates and partner with the federal rebates in order to accelerate progress. That's all needed to even for the able to pay market. So the bottom line, my bottom line on this is that instead of providing a reason to walk away from the affordable heat act federal funds and the tax credits provisions in the IRA, offer a solid reason to enact the bill as soon as possible. So we can start taking advantage of the tax credits as soon as possible and bring down that money to Vermonters. Reliable estimates that I have seen, calculate that a failure to enact a policy that would take those tax credits off the table and bring them to Vermont families. Failure to do that will leave $240 million in federal tax credits. It would have been available. It would have been intact. So, and now I'm, thank you for your patience as I go through those questions. I'll close with this. I'm optimistic about this bill, because it does two essential things at once. The legislation will lower Vermont's total heat bill by billions of dollars. The most credible analysis received by the climate council. I think I said this previous way. Found that on net Vermont heat bills would be $2 billion lower on account of the measures that would be installed between now and 2030. And on that, the savings would only continue to grow. We need to get Vermont homes and businesses off of fossil fuel roller coaster project, we're changed to world oil prices. We need to get, we need to get our heat from sources that are less expensive, less polluting, and more within our control. And that is what the legislature requested, required frankly, of us fall in global warming solutions act. And finally, climate change is not going away. We're spending a billion dollars a year to import also fuels that we know that responsibly we shouldn't even be burning. You need a performance standard to help us all to change that practice. Thank you for your testimony. That was very helpful. And I do hope you'll submit it in writing to us. We can have it for reference. Yes, sure. I'm happy to do so. And I, I sort of want to apologize for going on but I know that you all are facing tough questions and I wanted to try and answer. I think you, you have done a good job at that. Thank you. I have a question for you. Tony, yesterday that the way that life cycle analysis is structured in the bill doesn't actually account for the carbon emissions from wood. I would like to know what your thoughts on that are thinking about different versions of the of the bill would be treated as it is treated in the Vermont inventory. I'm going to do this bill. I should pause it. Review, whatever that tells me anyways I should review it. I'm sorry, because there are two different versions of into two different ways to interpret the legislation one is that the life cycle analysis of the body biomass would be treated the same as other fuels. The second is that it would be treated as wood is treated in the Vermont inventory process which is run by the NR. And before I answer this question I just want to make sure that I'm clear on those two different interpretations of the language. So how is it treated in the Vermont inventory. Well the Vermont inventory starts, it looks at the forest and not to trees. The forest in Vermont is a net sequester of carbon on an annual basis. We're sequestering more today in the forests of Vermont, then we're removing from the forest. It's a net negative. And because it's a net negative, it, the activities that are part of the removal process the harvesting process whether it's for energy for anything else is treated as well. It's all net negative. So we're not going to look at individual trees and say well that tree just got harvested so that's a negative. But that's a bad environmental outcome, because it's part of the larger process that altogether is sequestering more than we're removing. That's been the policy of the state of Vermont up to this point. And not forest and not the individual trees. There are lots of arguments in this area that tend to look at trees and not for us. And they tend to also treat forest management practices elsewhere in the world, which, you know, clear cutting the Amazon or whatever. Just like 1000% different from the way we do forest management in Vermont. And so the arguments get very confused because of for those two reasons that there's this distinction between individual trees are individual harvest events on the one hand versus looking at well they're in the context of a much larger forest that over time is continuing to sequester more than we're removed. That's in a nutshell that's how the inventory is conducted in Vermont. But as we ramp up our use well first of the how much of the wood we burn in Vermont is actually from Vermont. And then as we ramp up our use of that. Even if today we have forests that are sequestering in the positive. But as we, you know, harvest them and use them to a greater at a greater rate, you know, is that accounted for in this for incentivizing conversion to. To eat with wood. It would be counted for in in Vermont inventory on that. I think the question, there are like a whole host of questions embedded in your question. I want to be careful in, you know, sort of being so how to say this being really strictly plugged into this evidence on this. At our current rate of wood burning in Vermont. We are, in my opinion, not in any danger of taking what is a net sequestration rate and reversing it. The, we actually import a lot of wood into Vermont, which is surprised me when I looked at those data for construction, more than for anything else. And the, but if we want to enhance the Vermont. We actually need to be responsible methods of forest conservation and forest management. We actually need to. We actually need to ensure a healthy forest economy working landscape forest. I'm personally very much in favor of land conservation and I don't mind conserving permanently substantial fraction of our natural lamps. I think there's legislation, you know, that would do that. But in order to have working for us. We need a healthy forest economy and we're going to continue to use wood. And frankly, I think it's kind of easy for Vermont to say well we're not going to cut any trees because we think they should all stay standing but we're going to import our trees from Georgia. We're going to be lumbered from from out of state. So I should pause there and, and I would also note for the purposes of woody biomass energy for heat, let's say the quantities that we're talking about are well within the distribution rate that Vermont is experiencing and has been experiencing if we are in no danger of cutting down Vermont's forests to heat our buildings.   That's one thing. And that's the analysis of that. So it was your opinion, and then you also said current rate but if we're going to increase our rate. I'm just wondering who's monitoring that and the the agency of natural resources has this information, and the Energy Resource Center has information like this. So, but here's here's the economic point I wanted to make that nobody manages forests or to burn them in this region. The wood that is burned in Vermont is a byproduct of managing forests for much more valuable saw loss. It's basically a, you know, if you ask the forest or, you know, are you going to manage this for, you know, energy crops the answer is going to be well no there's not enough money in it. I'm managing this woodlock for saw logs. And when we're in this, when we're doing thinning in order to release the better trees to make better saw logs. Then we have something that we can sell for firewood, or if we had a more pellet manufacturers there we'd sell them for pellets maybe. And, but it's a byproduct. It's a low value byproduct. It's not something that's going to be become a big business to cut trees for heat. No, that's I'm happy to get back to you and you know with. I want to be clear here. I've told you that my opinion based on what I've been told, I don't have the data in front of me. Happy to provide data. That would be great. I would appreciate that. Thank you. Representative Smith. Thank you. Thank you for your testimony today. You obviously are well experienced in this field that you're discussing today. And I was looking at your bio and you've done extensive work in Belgium, and, and some in Germany, am I correct. That fair to say, yes. You know how much the price of gasoline is in Belgium right now. 591 a gallon, and it's 557 in Germany. And that concerns me a little bit about what people may be paying down the road for fuel pricing. Okay, two responses. The first is this bill is not about gasoline. It will be later on down the road, I believe. Well, not in this legislation. gasoline is, and I guess I should also make it clear I've been asked the question. What about off road easel for tractors or construction equipment, things like that. Those are not thermal applications. And under the definitions in this legislation, they're not covered. This legislation doesn't affect that. Yeah, I think, and it's well energy prices in Europe right now are extremely high. And they're suffering, frankly, from the fact that they were reliant on imported gas from Russia. The main war has interrupted that supply. Their response to it is actually to work very hard to aggressively install heat pumps, because they don't want to be reliant on volatile fossil fuel imports. I have one other question if I may. You've indicated to me, we have a concern with the labor force. We have a plan that would up the labor force to accomplish this by 2030 to achieve this goal. No, I don't know. I don't know as anyone does. I don't have that plan. I believe it goes without saying this is a really important issue. And there are initiatives underway to enhance training and to create the workforce that we're going to need. My point here is to say that this is kind of a chicken and egg kind of problem that if you don't have a policy in place that businesses believe is real that will create a market for this work. They're not going to hire people. And if they're not hiring people, then young people aren't going to go into the business of becoming a heat pump expert or installer or a weatherization contractor. And so I think a parallel effort has to be made with community colleges, technical college, etc, to expand the workforce. And I also think that fuel dealers. And this was my hope when the climate council was considering a clean heat standard. Our hope was that existing fossil fuel providers would say here is a great opportunity to clean heat business. To sell pellet stoves to install pellet stoves to get to install insulation to install heat pumps change their business from relying solely on selling a commodity fuel, get into the clean heat business. It's ironic to me, this is just me speaking personally, that this conversation began by basically trying to create a pathway to the future for businesses that are pending on whose business model is selling a commodity that is expensive, volatile and polluting. It gives them an opportunity to change that business to a clean heat business that has a future. And I I wish that more of the fossil fuel providers would embrace that opportunity. And frankly, I think that they will once the law is enacted. But right now they seem to have a preference, mostly to stick in the status quo. All right, I think with that I'd like to take a break. Questions. Did you want to. No, go ahead. Thanks, rich. This has been really helpful this morning number of these questions we've been hearing here and other colleagues in the building. I have two questions for you. One, going back to the tax credits and the effect of the federal funding tax credits now. So it's been my sense that having that that availability that infusion of funding and avail availability to draw down additional funding that that has a positive effect on kind of the slope of the credit price or would be expected to for our fuel dealers that that's going to likely help credit prices be lower as we start. Yes. Can you just can you explain that. So, no question is for that. Sorry that it seems to me the real question is, what does it take to help enough for my customer to make the changes that are needed to reduce reliance on fossil fuel. Okay. Yeah, when we've learned this through the energy efficiency programs, you know, like what does it take to get to people to replace the refrigerator. But, you know, and to install a much more efficient one. And over time we have experience with that question, you know, when we started out it seemed like it cost a fair amount and then over time we realized. Probably maybe you heard this from the efficiency for my but one of the modifications they made in the program early on they would, they would offer rebates to you and me and everybody else to replace your fridge. And those things were cost effective it was good thing to do. Perfectly good thing to do. And of course I forget how many what the rebate number was. But later on they discovered something that that when Vermonters would go to buy a fridge that this clerk on the sales floor would wouldn't point them to the high efficiency fridge. They would point them to the one that they that they were promoting that week or whatever which wasn't necessarily the best one. The efficiency of Vermont changed their model. They gave a bonus to a clerk on the shop floor who was selling the fridge, if they sold a high efficiency fridge. And it turns out that instead of spending 50 bucks or more. That if they gave 25 bucks to the sales clerk for steering of Vermont customer to the high efficiency which was the one they were recommending because it would save money. They could get more sales. So, here's what I'm getting I'm leading up to the question is, what's the lowest cost that we could have to pay in order to help customers make the efficient decision. And now let's look at a heat pump rebate. If helping Vermonters to to pay the capital cost of installing a heat pump requires a certain upfront rebate and we're doing that today. That that a certain rate. Tomorrow if that customer can also get a federal tax credit of Vermont rebate can be small. So, and we're not that clean heat program isn't paying for the federal tax rebate. We're only paying for whatever the margin is that is required. To help the customer make that choice, and that will likely include the cost of customer assistance, showing them what the choices are helping them make a choice helping them install it making sure the contractor does it right. There's some administrative and support services that go along with that. And so that would be part of the program cost. The amount that we would have to put on the table to make that change goes down. So I just, I'm trying to be really clear here. And again, if we fail to do that, we're leaving that federal money on the table. Having to provide more. And we would have to provide more or we just would have slower progress. And five years from now, we'd be sitting here thinking about, oh my God, what are we going to do now because we're behind the eight ball. My last question is, can you in this I've heard from folks outside of this room, some concerns about, can you define a thermal sector, and what fuels, people are concerned about the fuels and what does the thermal sector include. I think it's in the legislature. It is, it is in the bill folks are concerned about so you've talked a little bit about this. Right. Other uses, like making a restaurant or restaurants or this type of thing. It includes heating appliances that are used to heat buildings to heat hot water to cook food. And they're all they're also some commercial and industrial processes mostly industrial process, but does that include off road vehicle use it doesn't include transportation fuels. We're trying to be clear about that. And I apologize, I should have built right here and I could read you the definition. Okay, and, and love the peace, the PC, I think it's coming tomorrow but you know specifically we've heard you know died died diesel for off road vehicles. That is not the thermal sector that is transportation fuel. I mean, it's taxed as a transportation fuel we have a very clear pathway to collect those taxes that we know very well it's transportation fuel. Thank you, representative Logan and then we're going to take a break. Thank you. Thanks, rich representative Kate Logan from Burlington. Nice to meet you. This is not about the policy in particular more about the process of implementing the policy, developing the regulations. I know that the Climate Council had a lot of discussion about equity and justice related concerns with every recommendation that it made in the climate action plan. I'm curious to hear if there are specific demographic groups or segments of the Vermont population that you feel the PUC should be very intentional about engaging when developing regulations. I want to do one of the important specific improvements in the S5 this year was to make explicit something that was implicit in the House bill last year, and that is the affirmative inclusion of low and moderate income households in the performance standard. That is substantial fraction of clean heat measures must be delivered to those households, and that they and and low and moderate income households are defined in the legislation. And in addition, a sub half at least half of the measures that are delivered to those households have to be installed measures that are predicted and they're predicted because it's kind of logical to lower heat bills over time. So they're going to get long term lower bills because they're going to get these measures and the legislation also requires that a pretty robust public process be undertaken by the PUC that maybe what you're moving to that would include all parts of the state, urban rural and would include hearing from, you know, minority and historically marginalized and overlooked members of society who have typically not participating in this kind of process and the Vermont law on this point, I mean, I think this merges quite nicely it messes quite nicely with the inclusion and equity provisions that are generally applicable now. That didn't used to be applicable. Climate Council was strongly in support of that. It's included in the bill. It's included in the other legislation. I'm I think it's in there. I'll put it that way and I I think the legislature's been really clear about it. All right, Representative Papp and then we do need to move on. I just want to ask whether you have any thoughts on the issue of who the obligated parties are in this because as you know, in terms of being defined as importing into the state. Some are wholesale companies have depots within the borders of Vermont and retail dealers pick up their fuel there and others basically I think mostly because of location across the border and to a nearby depot in the neighborhood state and so you end up with both retailers and wholesalers as the mix of them. Yes, and for commerce clause reasons, we were advised by the Attorney General to write to build up and that was what the Senate. My, so my opinion is that the under the commerce clause, that's the way we need to write the bill. The, the good news is that this version of the legislation and it's just another change that's occurred this year has strengthened the role of the default delivery agent, quite substantially. The, so that any, let's just take a, the example you're kind of alluding to is a small fuel dealer for whom this legislation would seem to impose a burden. It doesn't need to do that extra work, if they don't want to, they can assign their responsibility to the default delivery agent. And you know this is somewhat similar to what we have in efficiency Vermont today. Efficiency Vermont is there to deliver energy efficiency services from the utilities that didn't want to do it. And that turned out to be most of them. The default delivery agent in this legislation could deliver services on behalf of those smaller companies if actually for the bigger companies whoever decides to let them do that work. I mean, I think that's an adequate answer, frankly, because the alternative is to create an unlevel playing field for it. If you exempted field dealers who went out of state to get their own fuel, compared with those who went to a bulk tank in Vermont, then you have a price differential that would be unfair and it would you'd be in sending people to go buy the fuel at a state, or directly out of state. It's all coming from out of state. I understand it's the commerce clause that is defining what, you know, how we have to define things in this case. That's a sort of that's a consequence of having to deal within that within that framework. Yeah, it's it's it's a practical legal requirement. And I believe at creating the default delivery agent provides an answer to those who, you know, basically don't want to get into this clean heat business they just want to continue to run their trucks. All right, I think we're going to take a break until 1025 great we're going to reconvene our meeting and continue talking about as five and I believe we've invited you also to join us to give us an overview of the potential study idea that is in the bill. Mr coward and then also we'll hear from David Westman. And then we'll talk about the efficiency Vermont on that following your testimony. Okay, thank you, Madam chair, and one of the enhancements in this bill has has been to make explicit the so called check back provision and make sure that at the time the legislature will be looking at the proposed rules that the PUC is asked to create that time. You would also have available to you as, in fact, they would want to have available to them. And this is something called a potential study for clean heat measures, and I should emphasize this is something that the legislature may very well be interested in, but even if the legislature weren't interested in it. The way the this process is, is set up in in the legislation, it would be done anyway. It is customary for those who are implementing energy efficiency programs, for example, complicated energy efficiency programs to do potential studies in order to better design a program of works. So the legislation requires that a potential study be prepared, and by the Department of Public Service and presented, you know, as part of the process of developing the work plan for the default delivery agent. It also requires that that potential study, you know, be available alongside the rules when it comes to the legislature. And what is a potential step. It's, it's doing the best job we can do figure out. Two things. What's the, or maybe even three things like what is the potential in the physical world for making the changes that the legislation, excuse me, or the performance standard calls for. What is the actual, you know, if it were energy efficiency what's, what's the potential how many light bulbs are there in Vermont and what could we save if we change that, and that kind of a question. With respect to heating it's how many oil furnaces over 20 years old are there in Vermont, and, you know how soon could they be replaced and how many of them are going to get replaced anyway, that's a physical question. An inventory kind of question. Then the next question that follows that is, what is the technical it's called the technical potential for replacing those furnaces. Let's say what I'm using furnaces as the example but you could ask the same question about weatherization in different kinds of buildings. What is the technical potential for replacing those furnaces with cleaner heat solutions. And in that instance, you need some understanding of what the building stock is like are certain kinds of buildings where it's either easier or harder to replace an existing furnace with a cleaner solution. But that gives you the technical potential which is often pretty large compared with what you're really going to be able to get. The next question is, well what's happening already in the market. How much of that technical potential is already being taken care of and this is the topic that we touched on earlier this morning. So, there's some fraction of the technical potential that is going to happen and you build that into your program design and work off on top of that. And then the third question is, what do we think our program can deliver in addition to what the market was going to deliver would be expected to deliver. You go from technical potential to asking what's happening, but what the program design would have to deliver. And then the last, not the last question because you can model. You can, you can always ask more questions, but the program designers will then ask, how much will it cost to meet the program goals. Using the, you know, the appropriate strategies that both try to reduce costs and try to meet other program goals I mean in this case we have program goals to deliver installed measures in low and moderate income housing. So that has to be factored into the what does it cost question and the. So there's a program design and what does it cost and that becomes kind of iterative in the, in potential study to a degree, you know, you can model these things to death but generally, it becomes an art, kind of at the end to say well realistically in this experience, I think we can get a sales rate or penetration rate of this amount of heat pumps, or this amount of water heaters in the housing stock in this part of Vermont, and at some point, the potential study, you know, says well I think that's a pretty good number, or the modelers who are doing this, you know, based on experience have come up with an answer to the question, how many units do we think we can get. And what do we think it would cost to do that. And maybe that's I should stop there and just take questions if there are more questions to members have questions. Yeah, well, a little bit of a clarification so we're not, no it's a question.  Greatest extent possible. So, it's my sense that this study, this potential study can help us really scale and understand the scale of what's possible, and I think that's important. When we think about the testimony that we have heard from the Secretary natural resources about what is statutorily required. She's provided some testimony about what it will take to meet our green or GS WSA goals for 2030 that has that number, the potential impact of that number has been pretty widely circulated from our tax base. This potential study, I think, allows us to look at, okay. Do we actually have the staff workforce do we actually have homes do we actually have the materials to meet those goals and if not what what can we do and then as you've testified earlier. Let's go back and check. Next year with the PUC what is the progress that we're making is this changing our overtime that we continually come back to that and check with that North Star being what's in statute the goals, and then this being something that helps us temper that with what's possible or understand better what's possible. Am I understanding that correctly. And the, it's important. Well, I'm going to say to two things that I think will sound inconsistent and I apologize, but you use the term North Star and that's a good way of thinking about the legislature has adopted ambitious mandates for under the GWSA. This legislation has written is written to make it possible to achieve a mandate. Yes, veterans in the energy policy world will know that it might. We might be pleasantly surprised on the one hand as we have been with renewables that the costs came down rapidly and performance became a lot easier, certainly then I expected when I was a regulator. And great. We sometimes we get good news. On the other hand, maybe the potential study would reveal that it's going to be difficult, particularly in the early going to, to work at the pace that we had hoped at which point in the legislature would get to decide whether we should change to the trajectory and start out slow. I think that's an appropriate legislative role and on the other hand, I wouldn't want to make that decision now because you don't have the information. Well, and as part of this we know that the other body, the governor staff asked for a half a million dollars and additional staff at the department to ensure that this is a quality product because we're charging the Department of Public Service with doing this does that seem like an appropriate number and staffing level for this type of analysis that we're looking to have done. It seems like a pretty big number to me, but I'm I come from the nonprofit advising world, not the for profit consulting world so I think you might you might ask other people about that price but I guess I would say that, you know, there are other aspects of this work that that right now we're not investing enough and then, for example, I think, as a state we need to launch a more of a workforce development program with training at community colleges, etc. in order to for the entire climate transition, not just for the clean heat portion of it. That's an aside, I guess, you know, in answering that question, but that the Department of Public Service could look at that question as part of the potential study and therefore that might be a reason that they're thinking of a bigger budget. Okay. Thank you. And I know we have also Dave Westman who also has some specific language I think. And I would say on the real details of the potential study efficiency Vermont is one of the best sources anywhere in the world on this topic. And sharing from them makes a lot of sense. If you want more detail, I'm happy to help but right now I defer to them. Great. That's a great segue for us to thank you for your testimony. Thank you. And we'll invite David Westman who's joining us soon. Good morning. Morning. Thank you for having me here this morning and thank you for letting me testify remotely in the interest of reducing greenhouse gas emissions. For what I hope will be a short and friendly amendment to my testimony provided last week so for the record my name is Dave Westman. I'm the director of regulatory and state agency affairs for efficiency Vermont. And the testimony that I provided last week is still what efficiency Vermont is suggesting and I submitted additional as I said friendly amendments to S5 section 8125 the default delivery agent for the committee's consideration specifically on this topic of the potential study and identifying within this within this budget category of S5 exactly how that potential study should be looked at specifically using some specific terms that we would expect to see as a result of that potential study being technically available maximum achievable and program achievable. So we're going to take a look at some of the global warming and thermal resources, and including a comparison to the legal obligations of the thermal sector portion of the global warming Solutions Act, and considering market characteristics for the delivery of clean heat measures within the state. Specifically, whether that workforce characteristics are capable of meeting both consumer demand and towards meeting the obligations of the global warming Solutions Act so I think that this is very consistent with the conversation that we were having with the committee and this supplemental testimony I think is right for your consideration but I'd be happy to answer any questions. Thank you for this representative. So this is on our website I don't know if you maybe could walk us through it. One thing that I've noticed Dave is doesn't explicitly give us a date. I would like to talk to us about whether or not that's intentional. And so why, and if not, what an appropriate date that aligns with the rest of the bill would be for having as potential study done. As I read this section of the legislation, this is a recurring clause where every three years the Public Utility Commission the department and the default delivery agent, as well as other stakeholders would be reviewing the proposed plan. So I did not think to put a specific date for the first potential study, because the assumption would be is that effectively July 1, which this date is specified as being the initiation of the proceeding. And every three years. At least every three years as Tom now are testified to last week. The potential study could be part of that consideration and so I did not think to put a specific date by which the potential study should be done. But your point is is well taken and in fact in our efficiency world. We do have obligations for when that potential study is done in the context of our demand resource plan. I don't know that we need statutory clarification on that but generally speaking we like to have that potential study. So in advance, if not more before our demand resource plan is filed with the commission as a proposal. Generally that happens within a couple months of each other, but we've been working on it for many months and so my thought would be is that if the default delivery agent is named in February, that the potential study should be done shortly because almost immediately the default delivery agent would need to develop their plan. And that plan should be very much informed by these results of the potential study so if you're looking for a timeframe it would be around the time of the first check back next year. I have another question for Ellen. So we have legislative counsel in the room, who had actually flagged this issue is something that the committee might want to consider. So I would just, if we could comment here by legislative counsel to talk about the kind of vagueness that this leaves what we have in here. Can I just say I would like to ask Mr Westman a couple questions before we go there if you know, so I just to help me understand this efficiency of our mind. Sounds like you have utilized a potential studies in your work but do you perform them and are they something it sounds like well just answer the part first. No we do not the Department of Public Service hires a third party contractor to complete that potential study. And we have members of our team who are subject matter experts planning specialists who review that work and are part of the development but fundamentally it's a third party entity completing that task. It is not efficiency. And are they often done annually. I mean I guess in this instance are you saying it would be done every three years as part of the three years cycle but yeah, that would be my understanding yes we do not we do not do a potential study every year. That would be very costly. The potential studies completed every three years, prior to the filing of a demand resource plan proposal by the EU's. Thank you. Members have further questions for Mr Westman before we invite legislative council right Ellen would you join us for a few minutes. Sure, I do have to go but I'm spending most of the afternoon with you so I can come back can I ask a question of Mr Westman first Ellen check out the office of legislative council. Do you have any sense Mr Westman of how long it takes to conduct a potential study. I do roughly about a year to nine months to a year. They can be relatively technical. They can involve a lot of back and forth and various iterations. So for example our team started working with the department. I'm going off of memory here but roughly around April to May of last year. We saw a first draft in approximately early November. The final draft was filed with the Commission in January of this year. Okay, that was my only question but I didn't know if anyone else had questions, because I will be here all afternoon. Just my question around, you know, do we need date so Mr Westman is indicating that because this is part of the normal procedure we may not need a date. You know, there's a little bit of contention it seems between the legislature legislative branch and the executive branch around this policy. So it seems like we might want to be providing as much clarity as possible for the executive branch that's, you know, a concern or a question I have so happy to have you come back to this later this afternoon. The date is a thing I just want to be clear we need it, or we do not. It's restrictive or it's supportive. So I had raised this issue because I do think, and this is definitely a policy decision. But because the whole legislature will be evaluating the clean heat standard program and totality in January of 2025. This does seem like it's something that would be helpful in those considerations. But I want to, you may want to consider if you have having a date so that it is available, at least sometime during that session so that it can be part of the conversation on whether the clean heat standard rules should move forward. Thank you. To support what Ellen is saying. I think that in order for the default delivery agent to begin its work on program development, and even larger picture program costs that the commission would then have to report to the legislature. I fully on board with having a potential study be identified well in advance of January 2025. And before that second check back my understanding is that there's a timeframe for February 2024 report that would give the legislature an indication of not not only the scope of work and the findings of the of this proceeding, but in order for that DDA work to actually begin in earnest that I would, I would strongly urge that the, that the committee consider a date in 2024 as part of that. Is it possible that we would want an initial deadline for the initial or time a date for the initial potential study and then language that indicates that it's a part of the normal. There are drafts developed in a potential study, yes, and a, a good potential study will seek stakeholder feedback on technical matters. And generally, I, I, I think that any potential study should should hear feedback and have a clear response to that feedback and so a draft potential study would be a reasonable expectation. As to the timing of when exactly that could be developed and the, because it would be contracted through the department, I would refer you to probably their timeframe for when the Department of Public Service thinks that something could get implemented. All right, further questions. Thank you for joining us. Thank you. Numbers. Thank you. I know you have someone else to go. I'm coming back potentially around 1140. If that would be helpful. I think we should go for right now I think we're essentially for 10 minutes after the floor. I'm not sure I tend to says. Oh, okay. Okay, I think. Because there will be some floor. And so I would say, Yeah, so let's count on 10 minutes after the floor members to reconvene. We have Ellen and another one other witness for that. And then we'll see you then I think that will be fine. Okay. Thanks. And members have discussion or questions that they want to bring up now. On the overall bill. Yeah, I would like to discuss something. It hasn't been brought up. If I may. Vermont is a recreational state. This bill perhaps will affect recreation in Vermont. And I know the backlash to the to it is going to be people that want to recreate Vermont will will pay whatever they have to pay and that that's the answer that I've heard from people in favor of S5. We have a lot of voters we have a lot of ATV years and a lot of snowmobiles that come up from down country. And anybody had any discussion about what the repercussion could possibly be as far as recreation in Vermont. I don't think it's been talked about. So I guess I, are you are you saying this bill is not addressing transportation fuels. So I don't know, is that your concern. I don't think that's going to go up. But we all know that. Not because of this bill. I mean, it could go up for other reasons. This is. Well, it could. Well, if you want to go further, there are people that have homes up here that will be coming up. I've got it right in the corner of my road. People from Connecticut bought a home. Yeah, we just heard. Once again, 19% of our housing stock is folks who. It just hasn't been talked about. And I know. Fuel prices have fluctuated since I can remember. I can remember my father talking about fuel prices in 1973. They've gone up and they turn this packet on a little bit more up north. They come back down again so it's fluctuating a lot. And I don't know, I just got concerns about, you know, about the whole bill, about what people will be paying. Representative Clifford. Thank you, Madam Chair. So, what we've just been talking about the date for the study. Is that study that that's the people of all like the stakeholders is that correct that would be doing this study. That what I just heard. Yeah, but what I think you just heard was that when they do a potential study, it does include outreach. Yes. Okay. So that would be that part in the bill. That the an hour conducts that study. Oh, GPS. Okay, okay. Representative Logan. Thank you. Just to follow up on that. I've been familiarizing, re familiarizing myself with how act. 154. The environmental justice legislation. It's not set to implement until 2026 environmental or let me get back to the page. The environmental justice advisory council and the interagency environmental justice committee were to be convened, or have already been convened, apparently. But the recommendations for how to implement the act. So I'm not going to say that it's not going to be implemented until 2026. So, I'm hearing that, like, for example, the potential study, etc. You know, this, you know, the outreach process is going to have to be conducted in a way that's in compliance with act 154. But there is no obligation. I'm trying in a A lot of folks have reached out to me with concerns about a community engagement process. And so it does seem like we need to say something more about how the potential study and the PUC regulatory development process needs to be conducted. But it will all take place before 2026. And maybe something as simple as just referencing act 154. Yeah. And, you know, not in compliance, obviously, but just following the recommendations. I don't know what to say, because we don't have the And then there's another bill that's not being taken up until next year. Well, it hasn't even been drafted yet about, you know, compensation for participation in processes like this. So we're kind of. Yeah, we're, we don't have anything we can point to as the standard. Yeah, that's already And we can ask the council where she would recommend and how, but yeah, I think I get your point. Okay, thank you. That's good. I wanted to also come back from a moment to kind of the North Star conversation that we're having before which, which, you know, is this policy is connected to. That's the goals that we put into statute and the goals are put into statutes are from the Paris Accords, which the governor has committed the state to both in 2017 and again, 2021. And, you know, what this, what this policy is doing is connecting a mechanism that allows us to continually review how we're doing. And getting there it supports the transition between our supports are smallest fossil fuel dealers I believe in helping them transition, as well as we know that folks with means we've heard testimony about this are already transitioning this make sure that we're bringing those folks along. So, you know, with our commitment, our repeated commitment to the goals in the Paris Accord. And with the effect of that there are a lot of other countries and states that have also made those commitments. And so, you know, there's a lot of other government action that is taking place, both in our country and in other countries that is working to meet those emissions reductions. And I believe very strongly. Well, I believe a couple of things very strongly first of all, I think, actually, we all really care about not harming rural and poor monitors with these policies and protecting them as much as possible and sharing their warm. And I believe that not implementing something like this that helps us kind of connect and continue to reevaluate really exposes us to more risk from the actions of other countries and other states, they, we are tiny. They are moving markets, they are moving markets, they are changing the trajectory of labor of training of material supply chain. And so, I'll come back off the soapbox but I wanted to just remind us that those goals that are in the Global Warming Solutions Act where they came from that they're not just our goals. There are hundreds of parties that have committed to those goals that are acting that action is changing a lot of things that are going to affect our monitors. And we've committed to those this is a mechanism that allows us to engage really thoughtfully and actively with progress towards those goals instead of kind of haphazardly and what do we have left. Now consideration for are we bringing along the lowest income folks, how are our field dealers doing. Are we starting to clear cut trees. This kind of helps us kind of connect all that so I've done that chair promise. Sorry. Yeah, just to add to that I noticed like here from the Department of Public Service a lot. You know, safe, affordable reliable is what we want from our energy sector. We also really do want equitable, and we know to have a gesture that won't happen unless we have a front and center. So, to me this is an opportunity to bring that to life in a way that hasn't been able to yet. The other thing I heard yesterday. That was because about prioritizing weatherization. I wonder if the committee had thoughts about that because I think about just the different types of housing people and the quality and the cost of, you know, we do have pretty stable electricity prices. But you still don't want to be more than you have to. You know, that's something that would happen on the DDA level to prioritize, you know, to make sure that weatherization steps don't get missed. We all have fun about that at all. Yeah, and I think it was testimony that we got that had some specific suggestions around that and we're going to look at timeline. Let's say I've counseled this afternoon but also going to walk through tomorrow's timeline, but today's walk through today. Anyway, what we have on the our web pages the latest draft with some of those changes that have been brought to us so I would hope and suggest that perhaps since we have a little time right now. Want to read through the latest draft so that you can be ready to talk about incorporating those changes that are in here but also others that you may have on your mind so when we do that this afternoon. Sure.  We can talk about that offline it's pretty easy to do. Yeah, do that. Yeah. Any other discussion type questions before we break for the morning. Representative, exactly. Not so much a question. It's just commenting. We heard a little bit earlier connection between the inflation reduction act, and the, and the affordable standard that we're talking about it. I'd really like to know more specifically about what we expect that that relationship to be like and heard about my federal money potentially being left on the table. And I'd like to help us not do that. And I'd like to know really more specifically about how that would work, and also about the, those, the tax credits and that federal bill. I think what we heard today was that that if we didn't do this that people who don't pay federal taxes, not be able to benefit from the bill but I want to make sure that that's really true. So I'd like to have some collaboration that that's really the case. I know sometimes federal taxes. You can still get reimbursed even if you don't pay federal taxes under certain types of credits. I think JFO can help us to put someone in. Yeah, representative. Yeah, I think JFO but also, and of course he's welcome to say no, but I'm guessing that efficiency Vermont has been digging into what the IRA offers and whether or not they've Westman would care to answer any of that. I think he has any information. And if he doesn't obviously should just arrange testimony. Yeah, we can, we can arrange. All right. Other thoughts. All right. Thank you all. We will have adjourned for the morning.