 Well, so thank you very much for coming in again and for also turning around another draft and short order. So the committee should have a copy of that number 2.1 S49219 dated 6.22 PM. And that was the result of having sort of conversations back and forth with various people when I sat down with Mr. Grady and said, OK, based on what we heard yesterday, here's my thought on how we might integrate some of this work and put things together and come up with an extract and keep moving. So I'll call it a bit of a hybrid between S49219 is introduced and information that we got out of the draft that we have to yet stop. And I think if you could walk us through and help us see the, if you can do this on the fly. So are they compare and contrast how we amalgamated the two? Sure. So on page 1, line 1, section 1, there is a finding section. The alternative language you saw yesterday did not have a finding section. This finding section is based on S49 as introduced. It effectively remains the same as S49 until page 2, line 8, where what you are specifically directing the state to do or what the state should do is being changed because the substance of the bill is being changed. You're going to require ANR to adopt by rule of maximum contaminant level prior to adoption by rule of that MCL, the prior public water systems to monitor for certain PFAS chemicals and respond appropriately when results indicate levels of PFAS in excess of the Vermont Department of Health advisory level. You're going to have ANR adopt the surface water quality standard under their proposal, not the proposal in S49. And then you are going to authorize the agency to require any permitted facility to monitor for any release of chemical that exceeds a health advisory issued by the Vermont Department of Health. That was in the proposed language that you saw yesterday, which I believe ANR supports. There is an additional section that's not noted in the finding section. It is related to reporting back to you regarding the monitoring of the landfill leachate. I believe the landfill in Coventry. And I will get to that when I walk through that section. Any questions? So yesterday, there was testimony from the agency specifically that they did not like the concept of setting an MCL in by statute or amending a rule by statute to include an MCL. So instead of setting the MCL and consistent with some language in the alternative language that was given to you yesterday, what the language in front of you today does requires beginning September 1, 2019, and every six months until adoption of the rules under section three. And those rules are the rules for an MCL, which was in the proposed language yesterday. The agency is saying that they will adopt an MCL for the five noted PFAS chemicals. But until that time, beginning September 1, 2019, and every six months until adoption, all public water systems in the state shall conduct monitoring for the presence of PFAS contaminants and drinking water supplied by the system. Now, I defy PFAS contaminants for the purposes of this section as those five specific contaminants. I had them not defined, and I was listing all of them whenever PFAS contaminant is used here. It really breaks up the flow of the system. It's a little hard to read, aren't it? I can already feel a floor report will be easier to deliver. But in terms of keeping it, so later on, though, we do get back to talking about the broader range down to the bottom. Well, that actually is not in the language today. That's something I needed to note for you about whether or not you wanted it, because this is based on that concept of monitoring that was in the proposed language yesterday. But this is just limited to the five. If you want to go broader, you have to reincorporate the language from yesterday, and I will show you where it is. That was me unsure of what you wanted last night when I was drafting. So I left in a subsection where there's a certain piece of subsection to our mind. I'll point it all out. So I mean, I would like it broader. I mean, I know this, so I can't think about it, but. My sense is what we're bootstrapping ourselves with the file we know, saying we know there's, well, potentially thousands more, but testable 33, 34, whatever it is, and then through another test up to maybe 60, so let's start looking more broadly, even if we're only regulating to the five we already have health advisories for. This is my sense of where we were. Okay, thank you. So on page three, line 13, if monitoring, the interim monitoring indicates presence of any PFAS contaminant individually or in combination in excess, the Vermont Department of Health Advisory level, the public water system shall notify the agency other results the agency shall direct the public water system to implement treatment or other revenue to reduce the level of PFAS in the drinking water, and I need to check something. Those are 20 parts for true, it is 20 parts for true. All right, so moving on to page. Can I pause for a minute? So on that section, this in fact story happened, as in essence in like Poundall, is it Poundall that has a municipal water supply that is now being treated for a PFAS reduction to the 20 parts of trillion or less. I didn't want to specify or I didn't think you wanted to specify what the specific treatment or remedy would be, because it's going to be, I would think unique to each system. But I thought the agency was the one that should direct what that should be. Sure. Consistently, we're still relying on rulemaking to do a lot of work, but it's no detail. Okay. All right, and then on page four, line one through four, it's a public water system, so you need to say something about providing public water if it's exceeding that health advisory level. So page four, during treatment or implementation of another remedy to reduce PFAS contaminants and drinking water, the public water system shall provide potable, public water through other means to all customers who use this other system. Is that not already public water? You're not in the water supply rule right now, right? And the water supply rule date that is in certain places, depending on what the contaminant is, et cetera, et cetera. There is something of this requirement. We'll keep going, and I'm guessing we'll have some comments from Mr. Scott. And Mr. Duncan, thank you. So, all right, moving on, section three. This is the language you saw yesterday, and that I'll turn to a proposal on or before February 1, 2020. A&R class, the final proposed rule with Secretary of State Nalcar to adopt an MCL for those five PFAS substances. Then they will have that notice process for regulating PFAS under the water supply rule as a class or subclasses. And then page five, lines three through 12, on or before March 1, 2020, they either file that proposed rule or tell you why not. And then if they're gonna file a proposed rule, it needs to be done by December 31st, 2021. Although we have the list of five here, because it seems like it's such a fast changing world in terms of what may be measured and regulated, is there a way to say that if in the next year, Department of Health, for instance, finds a sixth that it feels it can define a health advisory for, we open it up so that we keep pace with the following signs. I think you could give the Secretary discussion to do that, or you could provide a standard for the Secretary to do that. For example, a standard would be other PFAS chemicals for which the Department of Health has issued an advisory level in that timeframe, or other PFAS that the agency has determined are measurable and should have an MCL, something, you know, there's, or you just say, or other PFAS chemicals designated by the Secretary, just give them a discussion. Well, since we are already actively editing, let's pause and just chat with you and comment on what we're struggling with. Leader? Do you want to comment just on this issue, or? Yeah, just on this issue while we're going by trying to figure out how to flag it. Well, I mean, I think the agency has the discretion right now to adopt MCLs. And I think that, you know, I think that our practice, and I think that we would follow it in this instance is, you know, in the future is that if the Department of Health thought there was sufficient information to establish a health advisory, we would then take that in either make it a groundwater enforcement standard or adopt emergency rules making it a groundwater enforcement standard, and then we would evaluate the need for adopting an MCL. And I think that what we would likely do, and I think this bill gives us the authority to do it, is we may require a cross section of sampling to see whether there are issues. And if there are issues that would prompt us to move forward the MCL adoption process. And if there were immediate threats, we would also have the authority to basically require some action to be taken in response to those immediate threats while the MCL process is going forward. That's kind of, I think that this bill gives us all the authority we need, and you don't, you don't per se need to do anything in addition to that. And why one would, and I guess I would only say, why one would treat PFASs as different than chlorinated solvents or, you know, other dioxins or other derivative breakdown products is. Which we would act on. Which we would act on as well, right? Like these are all things that we sort of evaluate and I think this bill tells us to evaluate in how we move forward. So you're laying out a framework, sort of guiding the agency on what policy you want us to take with respect to monitoring and moving through contaminants with respect to. And I guess this is a longer response, but I guess if we can certainly periodically report back on what we're seeing as a result of the testing that takes place in, what is it, section seven? I think in my sense is that while we recognize you're the authority, and I may seem a little redundant, but we're trying to compel the use of that authority to go ahead and set the levels and giving that there's the ability to take a health advisory and turn them into an MCL with respect, you know. I think I'm wondering and some other people are wondering why we haven't chose to do that. So this is the previous section says let's wire something in place for the interim and then let's compel an outcome through rulemaking without tying anyone to some sort of artificial predetermined outcome. And this last question is if we learn more along the way, can we just make sure the language says please bring us in as well so we don't find ourselves a year and a half from now saying too bad we wrote this too narrowly as well. Is that it? Yeah, I would just, I mean I think that in section seven including requirements or a standard for when, you know, section seven already has the requirement to come back and say this is how we're going to respond when we have a health advisory and no MCL putting in a standard for when they would move forward. I mean, I think that would be the section that you would add language like that because I think that it's not just PFAS if we're trying to get it, it would be really where the health department has said there is a, we're concerned, we're setting health advisory and that could be PFAS or otherwise. So like this issue for coming back at it and we're generally in section seven, does that provide you with clarity for editing? Well, I don't think you want any evidence right here or right there. So moving on. So I think you're on page five, line 18, section four. This repeals that interim testing requirement that's in place beginning September 1st and then six months thereafter until the rule is adopted. So who's on? I'm sorry, which one is it? Sect five, page six. This is the language that was in the proposed alternative language yesterday about A&R and developing surface water quality standards for PFAS. That include at a minimum standards for the five and PFAS class of compounds or subgroups. And then they have final rule by January of 2024. Page six, line 17. This is the language the agency put in about having a investigation of potential sources of PFAS contamination as part of the investigation they shall evaluate a representative portion of public water systems for the total oxidizable PFAS concentrations. And they shall initiate implementation of the plan to early later than July 1 of 2020. Well, I think I understand better about it. I mean, my understanding is the total oxidizable PFAS concentrations testing sweeps up the broadest number of PFAS chemicals but it's not, doesn't deliver specific data. So part of our goal is to fill in the data gaps. Do we need to say anything about like the 537, not one test, you know, as many as many specific PFAS chemicals as possible shall be assessed as well as then casting the broadest net even though it's not specific to say what's out there beyond the ones that we can name. And that was my under concept of what we were aiming for. The investigation is revealing as possible. Well, one of the things here is that there's no timeframe, it's just initiation. So I don't know if you want a timeframe. So if there's no timeframe and this is ongoing, that method of testing or alternatives to testing might come up and I do you want to somehow limit the agency on what they're, I'm thinking of 537. 537.1 is supplanted by something, you know what I'm referring to, 537 in here. So I'm probably not the person to ask about what the testing should be or methodology or standard for evolution of the methodology. I'm not, I don't know the answers to any of them. Well, Senator, go ahead. I was just gonna say, we want this broad, we want this, I'm a little confused by the different, you're talking, Mr. Verde is talking about putting a date in there, but wouldn't this be ongoing? And that's, I guess I'm. All right, so this feels like a second one. There's some more work on it, but I think. Well, that's a question because it was more a question I was gonna raise for you on page seven, line six, about that authority for the agency to require any permitted entity to implement conditions. If it's ongoing, it should probably be in statute. And if section six is ongoing, then it should probably be in statute. If you don't want to put that timeframe on it, then it should probably be in statute. Yeah, I mean, so I'm thinking a lot about this. I was imagining, for instance, that we would start this investigation process that would start increasingly filling in the data gaps that we've been talking about. And then we would get some sort of regular updates. The agency would be using that data, we'd be using that data, and just trying to make sure that we keep sort of ratcheting our way up to regulating what we know enough to regulate. So I would think we would need to do some kind of reporting. As you say, it would be ongoing, not, I don't, my sense is, unfortunately, we're gonna be finding out about these things for many, many years. So I don't, it seemed like it would be prudent to have it be an ongoing process. And maybe a series of check-ins, I don't know, but I, you're right. I mean, seems like so. Do six and seven kind of work together? Because you have authority to investigate, right? You get to go out and say, there's PFAS contamination, but then under seven, should PFAS contamination or any CEC contamination, right? So I think that the thought is, is that the agency both plans to do and needs to do an investigation of potential sources of PFAS contamination. And that's, we're going to do that, frankly, whether it's in legislation or not, but having it in legislation is not a bad thing. And that we're going to, I mean, that's sort of the short term. It's, there's a lot, I mean, I keep going back and this is, I think, to what I've said yesterday in the findings, there are a lot of sources of PFAS in this state or potential sources of PFAS in this state. So, you know, I think it's developing a plan to look comprehensively at those sources and sort of go through them bit by bit, source by source to determine the scope and extent of the problem. I think that section seven gets into how we would do that and specifically subsection, C of section seven gets into how we would be looking for that in the broader suite of contaminants. So this is PFAS specific, the other is broader in its scope. Yeah, I just, I think it might be helpful to clarify. I think that under section six, there were two, there's two different sets of data collection. One is this larger investigation to look at multiple sources. That will be ongoing over time. The other critical piece that we can do now is test water systems for the maximum number of PFAS. So we had proposed a deadline to have that testing done by July 1st, 2020. And it would be the testing of water systems for the maximum number of PFAS, we're between 35 and 40. And you could draft it, you know, basically saying the maximum number using standard laboratory methods because that does change over time. That data collection, the water system data is going to be really important in order to have that process, that public process about whether we regulate as a class or subclass. So having a deadline and requiring public water systems to test for the maximum number by July 1st, 2020 is important because that will feed into that notice process. And that was the subsection that I removed that I didn't know if you wanted because of section two. So I'm gonna have a note to myself to reinsert that. Okay, then you come to page seven, section seven. That's the interim environmental media standards. If there's, the secretary may require any permanent identity at a facility to implement conditions. If there's a health advisory has been established for a constituent there. And the secretary determines that their operation of facility discharge admission or release may result in an imminent and substantial endangerment of human health. We have this sunset in here, the next sentence. Well, it's really a duration of that condition. The concept at least in my opinion is that the agency will have authority under existing law to require a permanent standard or to determine whether or not there is no longer an imminent and substantial endangerment to human health. Because if they didn't even do something permanent about it if there was no ongoing problem they would still have two years, right? If it's admission from an air source they have the ability to respond to that. If it's a hazardous materials release or it's a material that is not a hazardous material they have the ability to list it and then regulate it. If it's a discharge to waters the discharge to water authority is very broad. It's any pollutant or any waste I should say. And so that would cover it. I really think they have the authority to under existing law once they've identified an issue and determine that it's still gonna be ongoing and imminent after that two years use their existing authority to address that issue. I was just gonna basically agree with Mike. I mean, this is intended to give the agency the time to go through both an analytical and a public process around listing these emerging contaminants in the various rules that we have that regulate these media sources. So whether it's gonna be a criteria pollutant under the direct discharge program or whether it's gonna be a groundwater standard under the groundwater enforcement programs. But it allows us to deal with both monitoring and figuring out what the source of the problems are and then also taking sort of emergency response efforts to the extent that we've identified something that represents a risk to either human health or the environment. So it's basically, I mean, it is what it says it is. It's interim authority. It allows us to do things while that word in depth process is pending so that we're not coming in doing a lot of emergency rules as emergency contaminants are moving forward. And Senator Rogers point is a good point as well that in two years you have a lot of ability to respond legislatively, which you did with PFOA. And so if you really need a response, you wanna weigh in with authority or the agency needs authority, you have that ability. And the lines 19 through 21 on seven, those do sweep up chemicals of emerging concern. It's any contaminant, not just. It's contaminants and drinking water for which a health advisory has been established with no MCL. It's pretty much anything where there's no MCL. So there's maybe 100,000 come cores probably. But the section is for which a health advisory has been established. Oh, it has been established. Back on some heat. Oh yeah. So we limit ourselves a lot. Okay, then the new section that replaces the section in S-49 about treatment of landfill, leachate containing PFOS. It is a directive that A&R shall submit to the General Assembly or report regarding management at landfills of leachate containing contaminants of emerging concern. The report shall include the findings of a leachate treatment evaluation conducted at any landfill in Vermont. And I believe there's one going on right now. And A&R's assessment of the results of landfill leachate evaluations and A&R's recommendations for treatment of CECs on leachate from landfills including whether the state should establish a pilot project to test methods for testing or managing CECs and landfill leachate. So this was a change from the most C-605 yesterday. From the alternative language? Yes, yes. Because, and just I don't know if everyone on the committee is aware of my understanding is that as part of the permit issue for the Coventry landfill there's a requirement for CACELLA to lead an independent investigation of methods to treat leachate from the landfill. So there's at least that investigation going on. I don't know if there are others, Mr. Chairman. No, not at all. And as people pointed out, I'm sorry, Senator Rogers. So in sub two with agency natural resources assessment the results, would that mean they would be telling us what was in that leachate? What is the assessment of the results? I think it's really A&Rs, and I passed this by a couple of A&R people and maybe what they're intuiting they will be doing. But I think they're gonna get those findings back. They're gonna look at those findings and see whether or not that they consider if the findings to have a show of concern, show an issue, something that needs to be addressed, et cetera. And then recommend- I guess I'm just wondering there's no direction in there for what they're supposed to be looking for. So I guess I'd like to hear from the agency exactly what they're looking for. Is it broad spectrum, are they looking for everything or are they looking for certain things? How would the agency look at that? So the requirement right now is for the landfill to evaluate onsite and offsite treatment options for treating leachate. So it's not a chemical specific but rather a treatment specific analysis that we've asked them to look into to basically look at. With a focus on PFAS, but in all honesty how you treat PFAS is likely going to pick up. How you have the sort of common treatment techniques are going to pick up a lot more than just PFAS when you treat landfill leachate. So we're not testing it? Oh, we're testing. You're testing what is coming out of the pipe after whatever process they're putting it through. So this is sort of a feasibility scale analysis of treatment. So I think there's a number of things there. We already test. There's a number of onsite monitoring wells. There's testing of leachate and there's testing at the wastewater treatment facility. So there's testing that takes place as far as sampling for results at all of those in all of those areas. What this particular analysis is is an evaluation of alternatives with respect to treatment of landfill leachate for CECs at the site and then frankly offsite as well. I guess what I'm getting at is if we're testing to see if there's gold in the afloat and we say, no, no gold, it's good to go. What else is there? Not being tested for that's there. That's what I'm wondering and how do we get at a broad spectrum test so we know exactly what is there and what is coming out in the treatment and what is it and is going back into the surface water and I guess that's my concern. I don't know that in terms of the permit and the testing paradigm that it requires. Does it address Senator Rogers' concern about being broad spectrum? Well, the permit requires testing over a suite of candidates. You know, I think I'm interpreting Senator Rogers' question of trying to identify the unknowns and basically and I think I would need to talk with folks who have a deeper understanding of this and I do Senator to actually ran deeper than I do as well. Fair enough. And to try and get to that. I mean, I think that's the, any of these complex media like landfills or wastewater treatment plants have a number of different things going on in them and it's hard to sort of isolate even through a broad sort of testing like what it is that we're dealing with. I don't wanna get in because I'm certainly not the expert on chemistry and how a chemist interprets the analytical methods coming out of the machine button. They're very, these are very sort of complex matrices to see things in. So I would need to talk to people about how they screen and what sort of screening techniques are used. I know that we do some, whether it identifies everything. I mean, I think the fair, I mean, my fair response would be it probably doesn't. Right, and that's, so my concern is do we know enough about the unknowns right now? And should we be looking closer and figure out the unknowns that are flowing out to the surface waters? And I'll get you a response. Thank you. We're gonna get you coming back to this bill on Friday. So if that's something you can look into between now and then, that would be great. So should I note what I'm gonna mark up? So I'm gonna put it in a committee amendment format because right now it is not. Okay. I am going to. I'm gonna pause, anyone in the committee do not wanna put this into a committee amendment for the bill on bill? And on page seven, I'm reinserting the subsection B regarding the testing for all compounds. And that's really it. One question that came up, I'm gonna be talking about it. So back and forth to the section five, page six, on or before January 1st, 2024. My sense of the committee is that we're looking to do something sooner than five years out. The sense of what I've heard from each of the resources so far is that it's a lot of work. There was an EPA action plan on PFAS that they're delivering results, I think, in 2021. Is that correct? Yeah, they are gonna determine if available data and research support the development of Clean Water Act section 304, ambient water quality criteria by 2021. So one thing we discussed yesterday, and mine is marked up this way, was to go to 2022 to give agency a year to use that information as part of its own work. Senator Kemp. So I'm just looking over at Matt's agenda. So you were the one who raised the concern that the time frame that we gave yesterday, it was almost, you could get it done almost under the wire, not exactly, but it was more realistic. This you just feel. So my reading of that is that EPA is going to look at the existing data to see whether they do anything, not that they're actually going to do anything. And this has been kind of the way that we've seen EPA respond to PFAS. They do studies to see whether there are additional studies that are necessary. Well that's exactly their purpose. They said that the purpose when adopted by states and tribes is water quality standards. Criteria can be used to set permit limits on discharges to a water body if a water body requires PINA. Right. So my reading of that is that they're going to look at existing data to see whether they move forward, not actually moving forward, which means that they'll have basically what we're proposing to do by 2020 in concert with the rest of New England done by 2021. And then if they don't have a timeframe on how long it's going to take to actually develop the standard itself. And I don't think the existing information out there allows us to just take existing data and develop a standard. I mean, frankly, that's what we'll be looking at over the next roughly speaking year to see how long it's going to take for us what the extent of the existing data is. Shouldn't that what you do with a lot of things that aren't federally mandated? Think to look at the existing data? Right. I mean, I guess my, again, like I guess my reaction is, is if I think we can look at the existing data and say there's insufficient data to develop a standard. The 2024 data is that adopt a standard, which means actually going out and doing the work with New England, the other New England states to gather the data to adopt a standard. And if what you do is you set a deadline by 2021 or two for us to do it. I suppose you can set the deadline. The agency will not have gotten the information together. I just will tell you that right now. It will be another legislative deadline the agency fails to meet. Well, is there another choice? Like the agency said, in order to meet this deadline, we would need to find resources. That frankly is what the plan is intended to do by next year is to tell us what the state of the existing data is and what the needs are in order to get us there. And we think that it's going to go faster if we're working collaboratively and with other New England states than trying to do it in isolation by ourselves. I think this committee's habit is not for the deadlines that we heard that someone can't meet, but we're trying to be practical on the other hand, five years out for is such a long time. I'd rather personally, so I'll speak personally, I'd rather stick with a closer date and then ask A&R to come back with if they feel like, hey, we see 2022, two years off, we're not going to make that. We need additional resources to make it. Then that to me seems like an appropriate pushback to say the legislature either needs to put the money into the program or we should be moving the date. I'd like Sears to see this and he's no kid. I mean, five years, six years, who knows, right? I'm already going to be running my committee till like 24. This contract says 2030, no more negotiations. Well, what's the committee sentence? I'd rather sort of, I agree, let's push it up. So 2022 is the right or beyond being in PA work. It also means there's three years for work to be done and have that dialogue with agency. When we can overwrite. Is there a parent? I'm fine moving it up. Okay. So we'll go to 2022. We need to ante up. So thank you for that walkthrough and all that back and forth. I don't know, but we've done point by point. Mr. Chavin, do you want to join us at the table and talk about this construct as amended more broadly? We may have missed stuff that you want to comment on. Love to. Okay. Thank you. I just got a text from Sears's GP 2022 is fine. Good morning again. Good morning again, Bo. So for the record, Matt Chavin, General Counseling Agency natural resources. I'm just going to go through sort of comment by comment starting with section one. I think that our proposal or suggestion would be that on line six after PFAS may enter the environment, I would say from numerous industrial or commercial sources, including from emissions during a manufacturing process from disposal of goods. I just think it's important for everyone to have an appreciation of the scope of the problem that's there. And this appears to be more limiting than it is in fact. My next comments. So would you say that? Sure. So PFAS may enter the environment from a number of industrial and commercial sources, including when emitted, I mean, you can use this as making it fit into the. Mr. Rothery, are you catching this? Yep. Thank you. We would strongly recommend the leading subdivision four. I don't believe it to be factually accurate. More research is needed. Well, it's not accurate with respect to exposure to PFASs. I mean, there are a number of PFASs that we do have sufficient information to determine the health benefits of humans for exposure to low levels of the environment. Sorry, are you citing line 12? I am, I'm 12 to 18. And can we say again, I'm not sure what you find inaccurate. The agency has sufficient information to determine the health effects to humans from exposure of low levels of the environmental exposure to PFOA, PFOS, PFF, HXA, PF, there are a number of them. So this is, this is not, it's speaking to the class of PFAS broadly and making it an accurate finding in the agency's opinion. They already know that it causes. We know that it causes, exactly. We don't need to say more research is needed. Right, and I think that that may be people who would like to say that the science is uncertain to use this as affirmation that the science is uncertain when in fact it's not. We know that there are adverse health effects that come from PFOA and PFOS and other contaminants. And it's unhelpful to have a legislative finding that says this. I'm okay with yanking that. Okay, but how about the assertion part of this? The assertion part is that there are health effects created from low levels of exposure to PFAS, including that sort of thing. Well, and I think again this goes back to, you know, the statement I made yesterday and is that not all PFOS are created in equality and the level of information that we have varies depending on what we're talking about. So I don't think you can make this statement as it relates to PFOS. And the agency believes for the five contaminants that we've set standards for, we have sufficient information to determine that they have adverse health impacts. Personally, this isn't where I want to bow, you know, this is, I'm comfortable with removing that personally. I don't know if it was intended to create any groundwork for the investigation language that comes later on. I appreciate it. I just think that it's not accurate and that it's not helpful to the state generally. Thank you. Does it make sense to have Ms. Duggan weigh in a little bit as we go along or no, just to have this conversation or no? No, I was also, sorry. Thank you for keeping an eye on the clock. So yes, if you don't be shy. I would just say. You can come back to this. So what are you basically saying? I will be sort of quick. I mean, I think that I agree with the recommendation to make sure that we're accurately characterizing the scope of the problem. So broadening it as Mr. Chapman suggested and finding two. And then for finding four, I agree that, you know, we're fine striking it because we certainly don't want to suggest that we don't have sufficient information where we do. Yeah. So the next comment that I have is in section on the page three, section two, subsection C on line 13. And the recommendation is at the beginning of online 13 to basically state that after the secretary confirms that monitoring results under B of this section exceed the Vermont Health Advisory of 20 parts per trillion individually or in combination and then strike to the agency shall direct. So again, I think that we need to make sure that we're, it's not just any time there's a monitoring zone, but there's confirmation from monitoring that we have a problem. And then we should just move to directing the system to put treatment on at that point. And I'm happy to share. My next sort of comment with respect to subsection D is I think that it should probably be clarified. The way I read the testimony around this seemed to imply that during the period of time between the confirmatory sample and treat the installation of treatment that some alternate source of water would need to be provided to users, that that's the intent. My initial reading of this was that during treatment that you were required to provide an alternate source of water, which is my reading was potentially post-installation. So I think it's more of a clarifying as opposed to. And I can send my, I wrote my comments. I think we're short on time a little bit, but if you can send language and then I'll sit down and we'll do an actual review. I'm sorry, I've done this one, thank you. The next comment is with respect to the, no, now I'm in section five on page six. And in subsection A subdivision, specifically subdivision two where it says that the minimum, at a minimum the proposal shall have standards for PFAS class of compounds or suckers. It's just not clear to me what this means in the context of the minimum standard. I mean, I feel fairly confident that we'll be able to come up with criteria for the five PFAS compounds. It's not clear to me whether this is directing us to examine like technology-based affluent limitations for purposes of discharges or whether this is looking at the sort of class and whether if we are looking at classes that require minimum or is it just an analysis? So I would look to greater specificity for greater specificity and clarity on that one. I'm not saying, but I'm happy to work with council to try and just figure out and the committee to figure out what the intent is there. So they're ended, right? They're ended and there are minimum requirements. And if it were not at a minimum, I think that if what you're asking us to do is to look at a class, then I think I understand that and we're willing to do it. But I think the at a minimum makes me think that I'm required to develop a class and I'm not sure that we'll be able how we would approach that in this context. We need more time in 2022. Yeah, I mean, I think that what we would want to see from the agency is a plan for both the five, but then also a proposal for how they would deal with the class or subclass for surface water standards as well. So I think that's what we would wanna see from the agency to make sure that the agencies continue to evaluate how we are moving towards a class or subclass approach. So if one were to do that and mirror it off what takes place for drinking water, where we basically initiate a process to look at a class of contaminants as opposed to, again, my reading of this is that it's a mandate to do a standard at a minimum to cover the class of contaminants. So I just raised that, because I'm not... So if either of you have more specific tweak to that one, which you can send along so they can be evaluated in the loop and then I'll be sitting down with Mr. Lee before we are next draft. So the next comment I have is with respect to section six on page seven, lines one through three. The agency continues to have significant concerns with testing for total oxidizable PFAS. We don't think it is reliable, replicable, or is going to give us any actionable information and we're concerned that based on what people have reviewed there we're going to get... We're gonna show detections where there's not any detection in there. Sorry about that. It's on page seven. It's basically the requirement for all... It's lines one through three on the total oxidized. Yes, okay. So for now I would say let's leave it and I'd like to circulate information that was done earlier today I think I first saw it. And can you just say something to characterize what that was? Yeah, I mean I think that the State of Michigan Science Advisory Council did evaluate a number of different analytical methods for trying to close the mass balance for PFAS and looking at PFAS as a class. And the top assay was one of the test methods that they ultimately recommended using as part of the state suite of investigation tools. So we'll get that information to you. We've actually seen it and again, you know, the document states that it's... Michigan's found that it's useful when designing and evaluating remedial systems which we don't disagree with. This is not for a remedial system. This is for site characterization. We don't think that this is an appropriate tool to use in the context of site characterization. This is effectively what you're asking is us to use it in the characterization process which we don't think is appropriate. So let's hold on to this question for now and sort it out. But I think the importance of my mind leaving it for the time being is that it is our broadest tool and that we're at it. So we'll debate how appropriate a tool is as we keep going. Thank you. I think that's the extended agency's comments. Okay, great. So we're at noon but I'd ask people to stay for another minute, you've been weighing in as we went, do you have any other comments that didn't get caught up already? The only other very small comment that we haven't talked about is in the finding section. Page two, oh no wait, sorry. Page two, line eight, this is sort of similar to the comment that we actually already have documented risk from certain PFAS. We would just recommend striking the precautionary approach because we don't want to, you know, I don't think that we want to suggest that moving forward with the investigation and regulation is based on a lack of knowledge. Like there is documented risk and so we would recommend striking that first clause and then just saying to prevent further contamination of state waters from PFAS and to reduce the potential harmful effects. I can no objection to that strike. So thank you, Rhino, for staying a little late and working through.