 Okay. So good morning. It is Wednesday, April 28th. That's 834 a.m. This is a meeting of Senate natural resources and energy. We are in our final week of formal testimony. We may have some special meetings called after this Friday, but this week we're actually doing oversight and revisiting a number of issues all with an eye towards both keeping the committee informed and thinking about work we may do over the summer and fall to prepare for next session. Let's get started. Good morning, everyone. This is a joint meeting of a house, natural fish and wildlife and Senate natural resources and energy to spend a little time on Vermont's universal recycling law and how it's being implemented and more particularly within the universal recycling law, the handling of food residuals. So our committee yesterday spent a little time with Mr. O'Grady doing a primer, a reminder on Vermont's universal recycling law and for anyone who's interested if you look on our committee page under yesterday's resources, you'll find a really helpful four page summary that Mr. O'Grady put together. And so today we have a pretty packed agenda, but I think we'll work fine. We'll have to move ourselves along. I talked with Chair Sheldon in advance. So what we're going to do is to ask people to hold questions until after we get through the groups of presenters, we'll do them in basically in groups of three or so. And that if you have a clarifying, if there's something that's been said that just is confusing, it may well be confusing to others. So please do interrupt and we'll get a clarification and go out. But in terms of more big picture questions and discussion sharing points of view, we'll hold that off until the last section of the morning. We did set aside time for Q&A and committee discussion. Let me turn to Chair Sheldon. If you have any other remarks before we get rolling here? No, I don't think so. But it's great to be here with Senate natural resources. And we also did a walkthrough of the overview of the Universal Recycling Model with Councilor Grady yesterday. So hopefully we're up to speed enough to follow today's testimony. Okay, well, great. So the first group of folks that we'll have up include Tom Gilbert, Deb Nair and Jen Duggan. And for this group of witnesses and those that follow, I'm going to invite people to use it as a team time. So if you want to interrupt each other and offer comments to help each other out whatever, pass the baton back and forth as you like. But meanwhile, we'll first go to Mr. Gilbert. Good to see you again. Thanks for coming in. And I think one of the things you can really do is help us understand you and I have spoken in the last several weeks. And you've shared some concerns. So if you could bring us up the committee up to speed on how we got to where we are and what you think needs to be addressed, that would be helpful to all of us. Thanks. That's great. Hi. Good morning. Good morning and thank you to chairs Bray and Sheldon and to the respective committees for hosting us. We really appreciate the opportunity to take this issue up and the fact that we have so many committees that are here as part of this hearing. We feel reflects your appreciation for the seriousness of the issue. And so at the outset, I just wanted to extend my gratitude for that. While we only have the opportunity to have a short list of witnesses, hopefully folks have been able to see the letter that we submitted to the committees in February. But we are speaking on behalf of a group of over 25 individuals and organizations throughout Vermont that are very concerned or equally concerned about these issues as well. So with the limited amount of time, I'll just operate to it. Really, while this issue may seem very small to the un indoctrinated and those that are outside of the industry that we operate in, really what we're dealing with are our central issues that will define the path of Vermont's organic recycling system going forward. And simply said, we have we have two basic scenarios. We have a systems based approach, a food systems based approach. And we have an industrial laissez-faire approach. And while the two may be able to exist concurrently with one another, we do need to prioritize because we can only have one priority. And I think one of the things that you'll see as we go through this is that Court of the hearing this morning is about upholding the existing laws. I've been talking with some of you over the last several years, the most frequent immediate response to somebody is, well, what legislation do we need? And the truth is, is that those of you that were in the chamber in 2011 and 2012 when we passed this law did excellent work. And we have a law that is worthy and simply needs to be protected. So I think Vermont should be extremely proud of its law. For those of you that don't have a view of the national environment, this is considered to be one of the most progressive laws in the country. And at core to that is our source separation provisions and definitions and the hierarchy. So instead of back peddling and apologizing for our ambitions, I think this is a time to stand boldly in front by them and and protect them. These new interpretations around de packaging systems, which I'll get to in a little bit. They also are actively undermining decades of work that Vermonters have done to build the existing system that we have. And, and that should not be overlooked. Fundamentally, central to the URL is is protecting resources. So at some point, I suspect you'll hear that the URL itself was designed just simply to mitigate waste from the landfill. I don't think that was the sentiment of most people in the room, I believe that most people were setting out to develop resource management and resource conservation legislation. And the idea of simply developing infrastructure for waste mitigation is an extremely antiquated idea. Really, it's more of an 80s or 90s idea that has already been proven out to not succeed and create all sorts of externalities and unintended consequences. So key to that, that resource protection is the source separation provisions, which are really the watershed question for everything going forward. And that's that's the question that these committees are facing today is how important are these provisions and did the legislature enact them with good reason. Source separation is best practice. It's widely known. It's an accepted industry term. And we all know what it means. It means to separate materials, compostable materials from non compostable materials. It's as simple as that at the source. That's why we call it source separation. The issue of de packaging is really just a testing question. So it's secondary to the issue of source separation. So de packaging machines by nature, reliance, mechanical separation and not source separation. And they don't do a perfect job at that separation. And that's what we'll come back to as we talk about soil health. And many of you have been a part of very important legislation in this state around farm to plate and food systems here around working lands and emissions reduction. And I as you as we go forward, I would encourage you to think about those laws and the ambitions that they represent and ask yourself if we're unwilling to prioritize soil health and protect soils from micro plastics. How do we have the audacity to pursue farm to plate working lands or emissions reductions legislation? We can't take micro plastics back. And there's so much current research and evolving research right now in micro plastics and increasing awareness of how ubiquitous they are in the environment. That it's shocking that they have not been taken more seriously by our agency that is most discreetly charged with protecting the environment. Ultimately, the universal recycling law was also a law that that began to come out of a vision for Vermont's economy. And it was largely a food systems based approach. And unlike many of our surrounding states, Vermont chose to define things like source separation very, very clearly and define a hierarchy and use words like shell in our definition so that we could pursue that system. We learned from Act 78 that not directing markets and leaving decision making up to the markets never gets us where we want to get to. I think it's also important to realize that the decisions that these committees make on this issue is precedent setting, not just for Vermont, but also nationally. There are many, many states that have been watching Vermont for the last eight years as we've pursued this path and many now that are watching us as we start to backpedal on it, including I believe representatives from around the country may be on this call today, observing these hearings. A little personal background just before we get into de packaging specifically, I spent 13 years, I currently, I should say run own and operate black dirt farm here in standard Vermont. But I spent 13 years running Highfield Center for composting. And during that time, we developed statewide composting infrastructure around Vermont, as well as developing things that are still in use right now by the state like the state opera compost operator certification program. And I also participated in the drafting of the URL. At black dirt farm, we have an integrated operation. We go off of the farm, we collect discarded food from about 90 schools, institutions and businesses. It's about 30 tons a week, which we bring to our own farm as well as a couple of their composting facilities. Here at our farm, we blend that into a compost mix that we feed about 1000 laying hands on, from which we ship eggs around Vermont and into the Boston market. We also then make compost and worm castings from the material that they don't forage. And we grow crops on the back end. Our farm has been designed to follow the carbon cycle. And we're vertically integrated to both contain scale, but also remain economically viable. Our farm might be considered a good indicator of the effects of decision making at the agency level. And the fact that we are struggling financially, COVID aside, since the packaging came on the scene in 2018, is a good indication of the effects that these changes have on local economy. So getting to D pack to source separation just quickly. It's important to realize that this is a this is a key industry term and the sort of legal yoga that may be required to adopt the agency's new definition of source separation would not be considered to be consistent throughout the country. Source separation is how we protect our resources from plastics contamination. The hierarchy is a roadmap to how we direct resources to the outcomes that we as a society want for them. We learned from act 78 that without legislative direction, markets are not good decision makers, markets cannot account for externalities. And markets cannot account for things that are outside of the market. We can't expect food insecure families to compete economically with energy companies nor can we expect local and small farmers to compete with energy companies. The opportunity at hand for organics recycling is great. And this is one of the reasons why the universal recycling law was passed to begin with. Vermont throws away enough food that is estimated if composted to be able to fertilize nearly 20,000 acres of mixed vegetables organically that's somewhere between 50 and 100% of what it would take to supply vegetables to the state. If we have micro plastics in that material, it would be simply criminal to be putting it on our farmland and therefore either we choose to contaminate our soil or we don't put it on our farmland and we don't get the system's benefits. One of the great things about composting operations and the ability to respond to something like the URL is that they're highly decentralized or they can be highly decentralized. And therefore the benefits of them are distributed widely. They're not concentrated with one large operator. Those include building soil health throughout the region, bringing nutrients, crop nutrients to those soils and in the process sequestering carbon, protecting water, building local jobs and distributing dollars throughout the state. Additionally, we can mitigate greenhouse gas emissions from transportation and build insurance economies that put our communities and ecosystems first. So a little bit on how the de-packaging piece works. I'll just take one example. So we used to collect from the Hannaford store in Morrisville for years. We also did price choppers and other stores that we've lost as a result of this de-packaging issue. And if you think about the cookies that go on that are on special in the front of the bakery of the Hannafords, it used to be that for a decade the employees there would call those, they bring them to the back, they take that clamshell that shake the cookies into our container to be used locally and they put the plastic into the recycling container to be recycled. Now what happens is those cookies are never separated from the plastic that are thrown in one bin. And then that material is aggregated and trucked up to main where it's mechanically de-packaged. The result is that a certain percent, the organic material coming out of that machine is guaranteed to have a certain percentage of plastics. It may sound low, around one percent possibly, possibly higher. But if you think about the tundages we're talking about, that's a considerable amount. Those materials are now lost to the Vermont food system. Those dollars are lost to the Vermont food system. And that clamshell that itself was being recycled before is no longer recyclable and is headed to incineration, which I thought was illegal about 30 years ago. It turns out it wasn't 30 years. So ultimately what you can see is that as we take people out of these systems and try to mechanize everything, simply the result is centralization and the downgrading of resources. So we're not evolving right now. We're not developing transcendence policy that could be cross-cutting and interdisciplinary in its approach. We're reverting to 1980s style waste mitigation strategies that actually keep downgrading, downcycling, not upcycling the materials. In 2018, when de-packaging came on the scene in Vermont, having been circling Vermont for quite some time, there were immediate impacts. By way of example, in a very short period of time, in a matter of months, we lost about 30 percent of our business. Vermont Compost Company, one of the premier composting operations in the United States and a long time composting operation in Vermont, went from 2,000 tons of food scraps a year to zero in one week. They're only now two years later back up to 150 tons per week, only because they're actually now collecting, which they weren't previously. So fundamentally, we have to consider the implications of these things. We have to understand that if we're going to permit a facility to compost 1,000 tons of organic materials coming out of a de-packaging machine, that really means that we're composting 990 tons of food scraps and 10 tons of plastic. I'm not sure that if you submitted a permit that included 10 tons of permit requests with 10 tons of plastic on it for composting that it would be awarded. The EU has been ahead of us for decades on these issues and they have been using de-packaging machines for issues and they are having so much plastic showing up in their what they call bio-waste compost that there are now calls to revert back to incineration as a safer measure so that they don't contaminate food-growing soils. In a 2020 EU report, they cited a German study and said in the EU report, avoiding contamination with plastics at its source is the most effective and efficient approach as removing plastic contamination from bio-waste during treatments is both expensive and limited in its effect. Germany is now moving towards not a 1% tolerance of plastics but a 0.1% tolerance of plastics. So looking forward I hope that the committees can take the testimony that you hear this morning and think one first whether they fit into the universal recycling law and uphold the the integrity of that law but two if we decide that de-packaging has a place which it very well may then I think we should take caution from what we know about microplastics and the importance of stewarding these resources and apply a precautionary principle as we proceed and allow for adequate science and deliberation to help guide us in engaging a new technology. Greenlighting de-packaging without serious consideration of its impacts will be a choice that we can never take back we'll never remove these these microplastics from our soil. So I hope that we can I hope that we can set forward to do our best work and be as ambitious as we can and not follow in the footsteps of others simply to make their same mistakes. We shouldn't be following the same trajectory as Europe we should be looking at the trajectory from Europe. We should be seeing where where it's ended up in gathering lessons learned from their mistakes and leapfrogging those problems into into a new future into the 21st century. So first let's be clear about the law let's protect the law as it is and then let's utilize caution as we proceed so that we can protect the precious Vermont food system. Thank you for your time. Sorry Mr. Chair I I forgot that we were going to hold on questions. Okay no problem thank you. Thanks very much Mr. Gilbert. I'd like to turn now to Dr. Nair. Yeah hi I have asked Marcy Gallagher to share my screen with five slides that I have. I hope she has permission to do that. For the record my name is Deborah Nair and I'm a professor of plant and soil science at the University of Vermont and my scientific expertise is in soil ecology and today I'll be I just want to be clear I'll be speaking as an individual professional not on behalf of the institution. Science is is lagging policy. Current practices are driven by economics and antiquated solid waste policy without really considering environmental factors such as soil and water quality climate change and food safety and an investment in research is really necessary to ensure that our data driven policy our policies are data driven and that we can avoid unintended consequences. So scientists I seek to make data to make decisions like where are data to support statements that source separation won't work work for who. So with this slide I say as a systems thinker I think about connections among different perspectives and the consequences of if we discount source separation for example without source separation we diminish the quality and uses of the end product making them no longer suitable for application to our land that's producing our food they add risks and costs downstream and they also generate psychological distance between people and their role in production reduce and recycling next slide microplastics result result from the splintering and fragmenting of plastics into small bits that do not decompose these microscopic sized particles do not weigh very much and they accumulate in volume and surface area they get mistaken as food by organisms microplastics are consumed and they bioaccumulate in the food chain including our own food supply these effects are well documented in aquatic food chains and all evidence suggests that the same patterns are occurring in soil given my expertise in soil ecology I'll focus on the science related to soil as a resource to provide our own food supply next slide the empirical evidence is mounting of detrimental impacts of microplastics in soil food webs it only took me five minutes to find over 35 references about the aqua effects on soil quality and none of these tout any neutral or beneficial effects they all suggest we proceed with caution some examples of detrimental effects are on this slide when we see that plastics tend to decrease the nutritional quality of our fruits and vegetables these inert fragments are so small that they're in soil in water soil water and they're taken up by plants through natural processes and end up in the edible parts of fruits and vegetables carrots and apples for example been found to be the worst cases found to date and plastics can also act as a source and a carrier of agrochemicals to soil organisms such as earthworms they've been found to impair soil function the microfibers can be incorporated into soil aggregates but they introduce these fracturing points so the aggregates are no longer stable and able to reduce and they end up reducing the water holding capacity of soil and the consequences it diminishes the resiliency of plants to drought that we might expect with climate change they also bio accumulate in the food web been found to changing the behavior of organisms in soil including earthworms the hypothesized mechanism is that it's affecting basically the hormonal or the endocrine system equivalent of these soil invertebrates there's also climate change connections next slide please the plastics are polymers of carbon and carbon storage in soil is promoted to mitigate climate change however our most common method to determine organic matter cannot distinguish between plastic and organic matter and therefore we end up overestimating our soil carbon storage large economic investments tend to favor really highly centralized networks that require long distances of hauling that burn fossil fuels lifecycle analysis has not been performed to determine net environmental impacts of diversion versus greenhouse gas emissions lifecycle analysis could help define the optimal spatial distribution of hauling networks in organics handling facilities so in conclusion on my next slide there's good reasons good scientific reasons for policies associated with the hierarchy and source separation that relate to our health and environment and these effective solutions require a systems perspective let's use our current science to inform and advance our environmental agenda rather than rely on paradigms of the past thank you for your attention thank you very much and with uh any clarifying questions okay seeing none I'll move on to uh Jen Duggan Ms. Duggan good morning thank you for coming back to join us in the committee good morning uh Chair Spray and Chair Sheldon and members of the committee and thank you for the opportunity to provide testimony this morning the prior witnesses have provided some really important context and background around the passage of the universal recycling law in the intent and ambition of the organics management provisions and you've also heard about the serious economic public health and environmental impacts and the shift towards an industrial food recycling system that are the result of A&R's interpretation and implementation of the organic management provisions and so I want to use my limited time this morning to focus on the legal interpretation of two of the most important provisions the food residuals management hierarchy and source separation provisions and although we are not in court today I do think it's really helpful to take a step back and think about how a court would evaluate A&R's interpretation of the law you're hearing different interpretations from folks and I think it's really important to make sure that we're grounding that conversation with an illegal framework to start because A&R is not interpreting the provisions of the statute through a formal rulemaking process a court would afford the agency some level of deference but it would be limited and there's a really good reason for this in this situation the agency hasn't vetted these interpretations through a formal rulemaking process which means that the agency would be if they were to go through this process they would be required to put forth a robust rationale members of the public would have an opportunity to provide comment the agency would be required to respond to them and then the interpretation would be reviewed by ICAR and ELCAR that's not happened here and so the level of deference a court would give would be limited where an agency has gone through a formal rulemaking proceeding a court would apply a much more deferential standard but courts will only defer if the statute is silent or ambiguous and the agency's interpretation is reasonable and no matter what courts must reject interpretations that are contrary to the intent of the legislature and if the language of the statute is clear and it's unambiguous the court must give effect to the intent of the legislature and when interpreting a statute a court must follow the plain meaning of the statute and it has to read each provision by reference to the whole statute for example a court can't interpret a provision in a way that would render another provision meaningless or in a way that would be inconsistent with the policy of another provision in that statute and so it really is looking at these provisions in the context of the whole and in the intent of the legislature and so with that legal framework in mind I want to talk first about the food residuals management hierarchy to start the plain language of the statute is clear it's specific and it includes the term shall it says it's the policy of the state that food residuals collected under the requirements of this chapter shall be managed according to the following order of priority uses and it lists those five specific uses and although you may hear that this is just a non-binding policy statement the language in this provision is distinct from the kinds of vague and general statements of policy that courts have found to be non-binding in fact it's really similar to a provision in the groundwater protection statute that provides the state with the ability to take legal action for impacts to groundwater so 10 vsa 1390 provision five that's the groundwater protection statute it states it's the policy of the state that the groundwater resources of the state are held in trust for the public this is similar to the specific clear mandatory language that's found in act 148 a few other comments on this provision you know i just want to you know underscore that the goal of the organics management provisions of act 148 is not simply to keep food waste out of the landfill it also includes goals of resource protection and management otherwise the legislature would not have gone through the trouble to include express language that food residuals shall be managed according to this management hierarchy the management hierarchy is also not a menu of options to pick and choose from subsection a states that food residuals shall be managed according to the following order of priority uses the title of the section includes the term hierarchy and the term hierarchy means a system of things ranked one above another this term does not mean a list of things to choose from finally an agency can't advocate its obligation to promote and enforce the laws established by the legislature because the law may be difficult to enforce the agency can promulgate rules or issue guidance related to enforcement it could come back to the legislature to seek a change or additional guidance but as far as I'm aware the agency has not done any of these things and they can't simply see you know their obligation to enforce the laws that the legislature establishes I also want to talk about source separation because as Mr. Gilbert noted this is really how we protect resources it's critical to implementing the food recycling system that the legislature envisioned when it passed the law which is a system that supports a community-based food system and not industrial technology that contaminates our soils with micro plastics and is downgrading valuable organic resources so under these provisions generators are required to separate food residuals from other solid waste and source separation means the separation of compostable and recyclable materials from non-compostable non-recyclable materials at the point of generation and that's key and the definition of food residuals includes this term as well so if we use Mr. Gilbert's example the grocery store is required to remove those cookies from a plastic clamshell container and separate the cookies and the packaging at the grocery store this is important and it makes sense when these provisions are read together with the management hierarchy the inclusion of the hierarchy in combination with the source separation provisions is to make sure that our organic waste is diverted to the highest and best uses before it's used for things like energy recovery and in order to accomplish this you need an uncontaminated stream of material which is where source separation comes into play and you've heard from both witnesses that the de-packaging technology that's used when materials are not source separated at the point of generation leads to contamination of both our soils with micro plastics and also our recyclables with food residue so this interpretation is also consistent with common understanding in the compost industry as Mr. Gilbert pointed out which is something that courts look at when interpreting statutes if a term is used and widely understood to mean one thing that is given weight and in neighbor states considering similar issues industrial operations they're advocating for specific provisions that expressly remove the generator source separation requirement there would be no reason to seek out these exemptions under ANR's interpretation of source separation so just to you know pull it all together the interpretation that generators are required to separate food from packaging materials at the point of generation it's consistent with the plain language of the statute it's consistent with the statute as a whole it's consistent with legislative intent and it's consistent with industry understanding of the term the agency hasn't provided any explanation as to how the use of de-packaging technology is consistent with that requirement to separate at the source at the point of generation and instead we're hearing other interpretations like food can remain in packaging as long as the food in packaging is separated from the trash or there's no requirement to separate at the store if food remains in packaging that's recyclable but these interpretations are not consistent with the language of the statute the statute as a whole or legislative intent or how the industry uses these terms so I'll stop there because I know our time is limited but I want to underscore that not only are the interpretations of the agency inconsistent with the statute and legislative intent they have real world and adverse consequences for compost operators for our food system for public health and the environment and there is a lot at stake but the law to protect these important resources and build strong community-based food systems is already written you already passed it it's already on the books we just need to enforce it I really appreciate all of the time that the two committees are devoting to this issue and I look forward to your questions okay so for the moment any clarifying questions of Ms. Duggan all right Senator Campion yeah thanks Ms. Duggan so this is it you would frame this as an enforcement issue at this point I would note that there are two issues at play I think that we would point out that the interpretations by the agency are not consistent with the statute and so because those there you know we don't agree with the interpretation of the statute the actions of the agency in terms of implementation enforcement flow from that does that make sense Senator Campion thank you and I'll just ask one very quick follow on to that question then because you were general counsel at ANR so you've been on the other side of the street what is in terms of an option for how this might be addressed from the legislature's perspective how might we say we have a concern with that interpretation and how would you as how would the legislature then engage ANR based on your past experience would we for instance require a rulemaking so I think that you know the legislature plays a critical oversight role to ensure that the executive branch is implementing and enforcing the statutes that you pass the policies that you that you put in place so I think by holding this hearing is is critical communicating the concerns that you have to the agency um in a formal way um is also important if you believe that the agency is not interpreting the law or implementing the law consistent with the statute formalizing that um in a letter is important the agency already has rulemaking authority to um you know to promulgate rules to implement the statute and so um you know there's as as you know as as Mr. Gilbert noted and I noted the law is already on the books they just have to actually implement it and so I think expressing that formal concern about the interpretation of the law and directing them to address it would be important okay all right well thanks Mr. Chair may I ask one clarifying question also of you so is there I see that Secretary Moore is really where the buck stops on this if it's not the governor himself and I know we're not hearing from Secretary Moore today Isis is it accurate to say that Ms. Jamison is representing the administration's position on this well she's our next witness so we can ask her that but yeah we did we did ask uh Ms. Jamison in to speak on behalf of the division and the agency and so remember the administration I'm guessing this is an administration view but we can get that explicit so with that we'll continue the uh to move forward I'd like the next call on uh Ms. Jamison to talk I would say since we've uh spoken with you in the past at some length about various aspects of it not trying to put you in the hot seat in any way but because we have limited time if you could speak about the two issues that are really coming front and center on on how the program regards uh food waste and maybe if you have some comments around source separation and the notion of a hierarchy those seem to keep re-emerging as issues that people are interested in interpreting and getting clarity on Yes, thank you and for the record I'm Kathy Jamison Soloway's program manager at the agency in natural resources and with me today is Chuck Schwere as well We have discussed this issue with Commissioner Walk and Secretary Moore and what we're about to share is a position that they concur with so just I would like to touch on the issues that are being raised the hierarchy, source separation and contamination and all with respect to universal recycling law and remember that that was a law passed in 2012 and the goal was of that law because I was very much a part of the development, drafting and implementation of that law the main goal was to divert materials from disposal and we of course want to divert them in a very responsible manner with that as you all know we had the disposal ban take effect in July 1, 2020 which means we have a lot of food waste that needs to be managed throughout the state and as part of that food waste we have about 80,000 tons of food waste that's being disposed by Vermonters and through our waste composition study which is a statistically sound study we found that 30,000 of those 80,000 tons so that's 38% of the food we throw away is in packaging so we need to deal with food waste and packaging if we want to divert those materials and with respect to food waste one of the most important aspects if not only saving landfill capacity when we divert that is also reducing greenhouse gas emissions because when food waste goes to the landfill it can generate methane which is a more potent greenhouse gas than carbon dioxide as you all know and so jumping into the hierarchy and with respect to both the hierarchy and the source separation issues I would encourage folks that haven't seen or heard Mike O'Grady's discussion with the Senate Natural Resources Committee yesterday to view that because I think he has maybe a different view of that than maybe that that was just shared with Jen Duggan but with that the hierarchy that's in the law is a policy statement and we think of it as the three Rs so we also have in statute the three Rs which we've had for a long time reduce reuse recycling and in implementation of that we don't require the generators of waste to maximize reduction before they can reuse it or before it can even be recycled so we do promote all use of those options even though we understand there's a better benefit much better benefit from reduction than there would be recycling we don't say you can't recycle until you've maximized reduction and so likewise with the hierarchy for managing organics we don't say you have to it's not a mandate to maximize one of the preferences before you go on to another in fact there are organizations generators large retail grocery stores that are using more than one of those preferences in the hierarchy simultaneously and and think about it from the law's perspective the hierarchy is a mandate on the generator and actually everyone in Vermont's a generator of food waste but in particular think about it from the business so how would a business let's say a restaurant know that they need how would they know that they have maximize any option on one before they move on to the other that would be pretty hard for a restaurant to know have I maximized sending food waste to farms um how far would they have to go before they send it to the compost facility we've not implemented the hierarchy in this manner and I don't think it would be possible to implement it in that manner I don't I think it would be unattentable for the generator who is responsible for managing the material in accordance with the hierarchy I also don't think it would be enforceable for A&R to determine did that restaurant maximize one other preferences before they moved on to the other so so we do use and promote the options we understand the benefit of using one option more than the other but we allow the use of all of those preferences in the hierarchy and there's a diversity of options and I think it's healthy for Vermont to be using multiple different options and pardon the fine but you don't want all your eggs in one basket you know I think we need to have different options and and I think the marketplace you know it's evolving it's sorting that out and I think there's enough organics we got 80 000 tons of it I think there's enough organics to go around and and there's a need to process these food scraps throughout the state moving on to source separation because I understand we have a limited time I think it would be really good to hear from the generators and to visit facilities to see what is actually happening on the ground the law requires that the food residuals be separated out from the trash we are requiring that all the generators have to separate it out from the trash what we're hearing is that they want further separation from the packaging and again the use of deep packaging equipment is going to be an important tool to get at that 38 000 tons of food that's in packaging and it would be you know if to follow what the folks are advocating for is that every grocery store would have to have their own equipment on site to do that to follow what they're saying is at the point of separation that that would not be practical some of this equipment is very expensive and it makes sense to have it centralized so we are going to depend on the use of deep packaging there is plenty of food waste out there and there's going to be those waste generators that are wanting to do that source separating themselves because that will give them a less costly option if they do that work up front they can use a less costly option they're not going to want to pay the amount it would take to manage it through the more costly use of the equipment from deep packaging so the other hierarchy preferences are going to continue to be used DEC will continue to work with generators on promoting the various preferences in the hierarchy um and the contamination issue is is a real issue it is an issue and a challenge whether one is composting or separating it out to go to an anaerobic digestion and just to be clear even if food waste is perfectly source separated out for it to be managed through an anaerobic digestion which is a very valuable option to have because that helps provide us renewable energy it has to be processed that food waste has to be processed so it's pumpable and the equipment that can be used to do that is the packaging so the packaging can be used whether or not the food is in packaging or not in packaging to allow that food waste to go to anaerobic digestion um but we are concerned about the amount of material going to both composting facilities and anaerobic digestion that could eventually end up on the soils it is an issue that is evolving that we need to learn more about I think you're going to hear from others that are involved with anaerobic digestion and how they're screening that material to try to reduce any of those items getting into the waste stream up front and we're also looking at how other states are managing this are they coming up with standards you know California it has a standard not necessarily because of the microfossils but they don't want waste being inadvertently or purposely going through their organic stream in order to achieve their waste production goal and I we are looking at what other states are doing and I think it's important to continue to do that but in the meantime we need to continue to maximize our food waste reduction our diversion from the landfill and to maximize trying to reduce greenhouse gases while we work on these evolving technologies and reducing contamination so with that thank you very much okay seeing and hearing none thank you very much miss jameson thank you keep us marching right along next up is miss cross we mr chair just so you know mr a representative mccullough has his hand oh okay I miss that representative mccullough it was a late hand thank you um um kathy you mentioned the concerns around composting and and and anaerobic digestion did that include the incineration options also as a clarifying question okay so to be clear food waste is not being incinerated anaerobic digestion is not incineration um so that facility in Maine that's receiving food waste is an anaerobic digester just like we have in Vermont and I should have mentioned and I meant to that we we have investments being made in anaerobic digestion which I think is a real positive thing in Vermont for managing food scraps is a new one in in Salisbury and we have application for three more elsewhere in Vermont and that's going to help us achieve having capacity for managing food scraps um but it's not incineration thank you uh sarin McCormick clarifying question thank you mr chairman just touching this is fundamental I should have asked it at the beginning of the hearing are there people depositing food wastes in plastic containers in the uh compost facilities I mean I don't understand how plastic gets in there in the first place I think you would dump the compost out of the plastic container into the uh the receptacle so who I'm asking okay um so with respect to composting there's different facilities allow different types of materials to be processed at their facilities so there are some that will say absolutely no nothing other than food that could actually go in your mouth basically um is kind of how we think of that um there are others that will take the the compostable utensils that will take compostable bags they may even even take milk cartons that you know that not the plastic ones but the the ones that have the cardboard in them that can break down in the composting process and so there are different facilities in Vermont that allow different types of materials to be composted some will take um you know um paper type products because that's a carbon source uh while others will not and so we and and with that though I do want to say July 1 2020 we implemented the ban statewide which is a positive thing um I think we're getting more mistakes now of what can and cannot go into your compost bin or a bucket that goes to a facility and an A&R needs to continue to work with outreach on trying to help better educate people on what is appropriate and not appropriate but I think if you ask facilities they are seeing an uptick and things that should not be going to their composting facility um over the last year okay thank you that's all I know right um I did want to ask one very quick clarifying question so I know that you were saying the facility over in Maine that is de-packaging food the food isn't being incinerated but the packaging that's separated from the food is being incinerated is that is that the connection I think sometimes it's confusing people that yes yes um Maine does have an incinerator that would be used like disposal for us um that package food um think about it before much of that the majority of that had been being land-filled uh packaging and all uh with the use of de-packaging night and I think you'll hear from others regarding this they can capture some of that packaging um we had a staff person go up to the new de-packaging facility up in Williston and there were a lot of aluminum containers um that going through the system and there was a nice clean bale of aluminum that came out of the de-packaging you know the the material that was in there the food that the liquid actually was drink the beverage went to the digester and the aluminum went on the market to make aluminum cans okay well thank you so I guess we'll just flag it although the incineration is happening out of state if we're part of the system that feeds that incinerator then we should acknowledge our role in it um with that I'd like to turn to Ms. Crosby thanks very much thank you good morning Senator Brae could I just ask a clarifying question yes please thanks Ms. Jamison I'm sorry if I missed this but when Mr. Gilbert started his presentation he talked about the situation at a Hanifers where somebody goes in or where a staff in the evenings goes through and discards things that have passed etc in the state of Vermont right now is Hanifers uh legally able to toss cookies and things in their packaging into into some kind of compost process if you will right um we believe Hanifers is compliant with the law the law would tell them they they are not being it's against the law to do that right where would you draw the line um they are sorting out their trash they're sorting out their recyclables they're sorting out food that's edible for food rescue as the Vermont food bank they will confirm um that Hanifers as well as other large retailers are doing that and so I'm sorry I'm not being clear there there are a dozen cookies that have gone bad and they're in a plastic package do they have to remove the cookies from the package before they throw them away no we we part of the problem okay well I would say they're not throwing it away they're putting it in that then gets further processed off site to separate out the packaging from the cookies and then the cookies get processed in an anaerobic digester and the packaging comes out and gets managed differently okay you can return to this but I think I think what would be helpful is for folks to understand more of what happens at a deep packaging facility perhaps thank you all right well what is that my cue yes I think that could be a cue for you miss Crosby thanks so good morning for the record Kim Crosby um Environmental Compliance Manager with Cassella um so with the final phase of the organic span um coming into place we recognized that there was a large portion of the organic waste stream that isn't being sourced separated or isn't sourced separated at the point of generation um and prior to July 1st that material was going to the landfill for disposal and then after July 1st with the statewide organic span in full effect disposal was not going to be an option for for those um customers anymore so without an in-state deep packaging facility this material would have to be hauled to an out-of-state deep packaging facility to be separated um there are many food manufacturers that are our customers and we needed an option for managing their off specification products in little disposal so recognizing that need Cassella began permitting and constructing a deep packaging operation adjacent to our transfer station in Williston we received our final permit from the Department of Environmental Conservation in February of 21 so we're still in the real early trial and error phase of operating this facility we're trying to figure out the best way to process the various types of materials that we are accepting I think it's going to take a good year to figure out some of the best management practices especially as we go through some seasonal changes we're currently working with a UVM graduate student who is working on quantifying microplastic contamination for different food slurries that are being produced by the deep packaging unit the research that is being done will help us determine best practices for deep packaging and generate key information for digestion facilities that can receive de-packaged food waste slurries um I do have a brief PowerPoint presentation that includes some photos and pictures of the types of materials that we can process um to share my screen here if it works can you see my screen uh not quite yet hmm you notice there was an optimistic report not quite yet we know what's going to happen uh let's see if she has to be made and here we go okay good let's go from the beginning how about are we good yes okay so just an overview of our facility um we have a tip floor and bunkers for organic material storage as the material comes in and is tipped and offloaded we can store it in bunkers prior to it being loaded into the hopper that feeds the deep packaging unit the type of unit we chose was a top of the line scott turbo thor which can process 20 tons per hour so an eight hour shift 160 tons we have three really large 15 000 gallon tanks of organic slurry capacity and our our liquid slurry goes to currently three digesters for cogeneration we're taking it to one in south burlington the one in salisbury and a wastewater treatment plant digester in Essex and we can also process organic solids through the unit for additional composting or animal feed we installed a baler to recycle the cardboard from the material that we are getting in that was formerly being landfill so now we're capturing that material for recycling and as kathy did mention um we do get a lot of off specification alcohol products and side hard cider products um that need to be separated from the cans and once we do that we are bailing the cans and recycling them again prior to the installation of this unit that material is being landfilled and like i said we received our operating permit at the end of um february and 21 just a overview of the site plans kind of difficult to get your bearings if you've never been to the site which we we would like to have both committees come out and see the place hopefully once COVID-19 restrictions lift a little bit but there there's the tipping area in the lower right hand corner right above the two tipping areas you'll see a little rectangular object that's the hopper that's the infeed that's where the material gets loaded into and it feeds into the de-packaging unit which is connected to that hopper and this is what the actual unit looks like itself this is when it was being installed there's inside the the shaft of this unit there's several um paddles inside and that's what help that's what wax the the packaging out of the liquids or the solids from the packaging and helps it separate it out um below the paddles there's a series of screens so essentially the organic material falls through the screens and the packaging material stays on top of those screens and you can you can change the screens the sizes of the screens out depending on the type of material that you're processing so there's large screens and then there's a smaller screen depending upon what you're getting in so here's a a general view of the types of material that we're running through this piece of equipment um a lot of Ben and Jerry's um this was Ben and Jerry's was going to a waste incineration plant prior to coming to our facility um the right hand side is expired baby formula um so I can't I can't imagine some a generator spending the time to empty each one of these containers um out into a content out into another container to be composted um the lower left hand corner is an example of some curbside collection commercial curbside election collection organics material that we collected and you can see there's quite a bit of of plastic um in that material that needs to be separated and here's how we're getting some of the other material so a lot of off-spec product um there is some labor involved on our part we have to unwrap the plastic we have to take the material out of the cardboard boxes again when recycling what we can we're not sending any packaging that can be recycled to incineration and so I mentioned earlier the the organic material falls out onto the screen and it goes up a shoot and empties out into a designated roll-off container you can see the yellow powdery material that's the baby formula and then beyond that is the garbage that comes out from another shoot from below the screens and the one on the right is the organic material um from the curbside compost uh route that we process through the unit it's a picture of the slurry tanks and that's really all there is to it um again you know we were hoping to have a grand opening at some point it's kind of been delayed um with with COVID but we would like to have everybody come out and see it in person at some point hopefully this summer great well uh I think we're all hoping for it to be able to do a lot more things this summer and a field trip would be helpful um yes meanwhile thank you for bringing those pictures because it does make it a lot easier for us to see things rather than just have to imagine them yep I'm mindful of the clock I don't see any questions but I can't see everyone very well so if there's a question please holler out all right and with that then thank you miss Crosby we'll go to um Lisa Ransom it's with us good morning miss Ransom good morning good to see you again thanks for coming in thank you for having me um my name again is Lisa Ransom I own Grow Compost of Vermont with my husband Scott Boffman our business was formed about 12 years ago to capture and protect the valuable resources of organics to reduce methane and to help build soils um in Vermont we collect and haul food scraps and agricultural organics to make compost and soil last year our trucks hauled over seven million pounds of food scraps from Vermont businesses resorts schools prisons office buildings and residents diverting this material from the landfill to agricultural uses for chicken foraging compost for bedding and for clean energy uh Grow Compost runs a double stream of organic collection one stream that collects food scraps for the creation of compost for Vermont soils and a separate stream that is diverted to de-pack and anaerobic digesters Scott and I and our incredible Grow Compost team of truck drivers and soil builders feel as if we are making a difference as the united nation warns that the earth continues to somersault toward irreversible climate change consequences Vermont is making a difference currently as Kathy mentioned Vermont diverts over 80 000 tons of food scraps from the state's single landfill and puts these resources back into agricultural uses a new york times article published just this week reported that reducing emissions of methane will be critical to reaching goals for reducing climate change the article discusses that the reason reducing methane has gained prominence in this global conversation is because cutting methane concentrations is the quickest way to slow rising global temperatures and as you know methane emissions stem primarily from three sectors fossil fuels landfill and agriculture Vermont is a leader in the country for our progressive and successful diversion of organic material from landfill through our universal recycling law our position is that we need diversion on every level organic collection for chickens to forage hauling food scraps to make compost for our Vermont farmers collecting organic material to be used to create energy through anaerobic digestion as the economy reopens Vermont is poised to be stronger and more resilient the future of green business in Vermont is bright our compost law is encouraging resilience and local food production Vermonters are building gardens creating small compost collection startup businesses building new anaerobic digesters such as the one now located on the Goodrich farm in Salisbury and I see um that John Hanselman is here to speak as well so I look forward to that it will take all of this effort to reach our goals for diverting food scraps across the state I believe the resiliency of Vermont is directly related to the universal recycling law and Vermonters engagement with these resources in their own homes in their businesses at the grocery store where they buy their food at the office spaces and schools where they spend their days at the parks in which they recreate all of these businesses before you both large and small compost operators haulers anaerobic digesters they all play a critical part in meeting the needs of regional businesses food manufacturers breweries convenience stores prisons schools universities hospitals and individuals throughout the state these efforts are crucial to survival on this planet to the growth of our green economy and to the clean oil air soil and water in Vermont reducing greenhouse gases and building soil in Vermont requires that we continue using all of these resources and work collaboratively in order to offer Vermonters every opportunity to engage in this important work through something they all do every day eat I have so appreciate your attention to this issue and I'm happy to answer questions. Senator Campion. Thank you Mr. Chair I appreciate the testimony very much it's you know what I'm sitting here thinking we need to do more and more is quick pressure on those people those manufacturers that are sending the plastics to us in the first place and in other words you know how do we get them to say you know and we're not California we're not a huge state that has that kind of you know economic influence but we have to get to the point where we say you know we are just not going to accept things wrapped in plastics and we are going to we are going to accept things that have are more compostable easier you know works well more than just acceptable acceptable to be composted and then spread it has to be we need to rethink that and I'm not sure how to put that pressure there part of it is I do think we say to the grocery stores and everyone along the way you need to separate this so that the grocery stores that do have some economic force they can then go and force the manufacturers to put pressure on the manufacturers to behave the way that they need to behave in this so I'll just leave it at that but I appreciate uh Ms. Rampson's uh testimony and her commitment to to what is uh could again lead to unhealthy drinking water unhealthy foods it's this constant poisoning of ourselves and the future generations of of humanity so I could just say just respond with a couple quick things one is that we no one wants plastic nobody wants that in our it's expensive it's you know it's it's horrible for the environment we can't put it in our soil compositions and so nobody wants that and one the other dynamic that we're finding is that these larger grocery stores have brokers that are nationwide right and so like Hannah Ferts for instance isn't just your local Vermont Hannah Hannah Ferts stores anymore you can't even talk to the manager of that Hannah Ferts stores and it's not even someone located in Vermont right so it's a it's a you know regional um or even national broker so it is that is the pressure and because we run that dual stream we we charge almost double to carry you know to for that d-pack stream as we do for the clean stream so that's one little way that we feel we can we can make a difference sure nothing's going to happen unless we regulate I mean history shows unless we regulate unless we make these major changes we're just going to continue down this road thank you um so just as a reminder we were working we sort of got knocked off track by COVID and there's still work going on in the background on extended producer responsibility around packaging and so it's a good point and it you know I think that everyone in this both committees knows the best cure is going as far upstream on the problem as you can as opposed to mitigating downstream um but I do want to make sure we have time to turn to Mr. Hanselman who's uh we haven't I don't think you've been in our committees before or at least not the senate side um so welcome to uh today's hearing and love to hear about your take on this system we're talking about thank you chairman brand and committee members I really appreciate your opportunity to speak on this incredibly important topic and all the important strides that I think we're making in Vermont to move the the problem forward my name is John Hanselman I'm founder and chief executive officer of vanguard renewables uh vanguard renewables is the owner and operator of the Goodrich farm anaerobic digester uh in Salisbury Vermont and it's the newest addition to Vermont's historic leadership in agricultural renewable energy production um at vanguard renewables were committed to immediate actions that can make progress against the goal of reducing greenhouse gas emissions and slowing the rate of climate change as Lisa said a minute ago uh the un intergovernmental panel on climate change has noted that if food waste were a country it would be the third largest greenhouse gas emitter in the world behind China and the United States if there's any chance of reaching the the climate goals agreed to in in paris we must dramatically reduce the amount of short-lived climate pollutants the slcps that are so duly noted in all of the proceedings um methane which is produced from the breakdown of food waste is the most destructive slcp being 40 times more corrosive than co2 as as Lisa also noted um we are honored to be part of the Vermont renewables community and recycling community and we see act 148 in the url as one of the most important set of laws in the united states as it recognizes the role that organic waste plays in generating these slcps um Vermont has gone further than any other state in encouraging food waste recycling and the public private partnership that vanguard and others have built in state is due to these progressive public policies it's a strong and functioning example i think to the rest of the nation is how we can immediately attack these terrible stationary emitter uh sources and also to start to lead the charge on dealing with the other issues of microplastics and other issues that come up with the recycling of food waste um because of act 2048 and the the policies of vermont mega renewables felt comfortable building this digester in solsbury the digester was built to create a new model even for us and recycling organic materials in the us we built a closed loop system there to take both commercial and residential food waste and recycle it into carbon negative renewable natural gas for vermont residents and businesses and then to return those food nutrients back to the soil um but after they've been mechanically processed so that we can actually reduce the phosphorus and reduce the the carbon commitment and return that fertilizer back to our firm hosts we believe that this is probably the first in the nation where this much care has been taken on the downstream product and we think it is the model that we'd like to see across the us to be specific about solsbury we take a hundred percent of the manure from the farm that's over a thousand cows worth of manure and we source our food waste from local food manufacturers and generators like cabot agar mark ben and jerry's alchemist brewery and many many more local food manufacturers and institutions um we then heat that that slurry we cook it if you will like in a million gallon instapot um set the timer for 30 days and temperature for about 104 degrees maybe let the naturally occurring microorganisms from the cow's gut break down the organic material um emit the methane we then capture that methane clean it send it through the natural gas pipeline uh to middlebury college and then to the retail customers of vermont gas services to decarbonize their thermal footprint that one single digester is the equivalent of removing almost 5 000 homes from their current fossil fuel source once that methane has been removed from the organics we work mechanically we take that liquid the the post-process slurry um and we remove the phosphorus we move plastics we screen it and actually use a dissolved air flotation system um to remove both of those incredibly important pieces out of that we then return that that digested liquid um as low phosphorus low carbon fertilizer back to the farm um this close-up system has the direct impact of removing all of that atmospheric methane creating renewable energy to reduce our lines on fossil fuel and improving the sustainability of the farm in the otter creek watershed and the resulting lakeshine plane sustainability what all digesters want to do is encourage not just large sources of organics but also residential restaurants and institutions to recycle their food waste what every digester in vermont cannot do currently is recycle package your bags organics at the farm the consistent safe operation of our digesters and the farm requires that mechanical mechanical separation of the organic matter from its packaging prior off to the farm mechanical separation or de-packaging that we've been talking about um it's expensive and complicated but it's something that has been ongoing in europe and the uk for for decades now uh we at vanguard renewables actually operate our own de-packaging facility in massachusetts and it is radically increased the participation in food waste recycling in the commonwealth and i can't stress that enough we have almost doubled the amount of food waste that we're taking out of incineration and landfill by opening that that de-packaging facility um as you heard from from kim uh there's like one mechanical separation facility in vermont um that that chinna county castella facility um we commend castella for actually taking the risk in building that facility um because as ensured those tons do not leave the state and they end up uh or end up in less desirable insights um we believe that for the benefit of the other parts of the state and for the benefit of consumer pricing that more de-packaging capacity and more collection points or organic transfer stations if you will need to be built throughout the state food waste is really unique um in that the disposal pathway how it's treated actually defines whether it's a destructive greenhouse gas or a fuel for renewable energy and regenerative agriculture and we believe that vermont has created the best example in the united states of how to do this i urge the state to continue um encouraging the recycling of food waste and refrain from limiting the development of the necessary infrastructure that would ensure that food waste will remain in vermont will be recycled in a carbon and a cost-competitive fashion for the benefit of vermont residents and thank you for your time thank you very much any clarifying questions for mr hanselman i do have one you were talking about um post processing that allows uh the additional reduction of removal of phosphorus and plastics phosphorus of is of course of interest um can you just say something briefly about how much what you end up with uh i guess people are using a term contamination level right so uh what percentage plastic remains in the the ultimate product that leaves the facility to be used as fertilizer and if you might also quantify briefly the phosphorus reduction it's of interest to everyone here as well and the two are actually separate mechanical processes that we we run at the farm um so as as we stated we we don't take materials that are more than one percent contaminated with with plastics um we then after we've we've actually taken that lower process we run it through an additional screening system um to reduce so i i'm couldn't tell you what our percentage is of of plastics but we're we're actually taking a full secondary screening process to make sure that we're reducing as much as possible um on the phosphorus is something that we're we're extremely excited about especially as someone who grew up swimming in lakeshamp plain um the phosphorus as everyone knows is an issue in the watershed we actually built a i think it's first of its kind uh on the east because i think there's one in in the anah a dissolved air flotation system where we actually remove the phosphorus um from the digested so food waste has the enormous amount of phosphorus in it uh whether it's in compost or in anaerobic digestion we've chosen to actually build the post-process mechanical separation so that we can tune the phosphorus um before the the land application of the fertilizer um i saw uh uh representative smith and then representative uh dolin uh dolin oh thank you my question was just answered thanks great and i would really um echo kim crossby's invitation kind of as COVID um hopefully diminishes um we would very much like to host everyone at the farm to to see the the system in action it's it's quite exciting representative dolin thank you and i i do want to thank you for your testimony and i appreciate uh chair bray's last question it's just a follow-up clarification uh as you know uh vermont has been paying attention to plastic pollution with its initial ban of microbeads and now looking at my microplastics in soils in conjunction with a healthy soils movement and regenerative agriculture for all the benefits we talked about for water quality for food systems for carbon storage for uh methane reduction for our uh our our food in particular our local food systems and so the question with regards to plastics in digest states is of concern if we are then turning around and spreading that digest date on to ag soils as an amendment so are you testing for or is there a means to test or evaluate that digest date for the the presence of plastics to ensure that we are aren't causing or contributing to accumulation of plastics on our agricultural soils unfortunately i think i agree with senator campion and his statement earlier which is whether you look at compost or and i know we we do quite a lot of work with cswd in williston and the other composters in the state plastic is everywhere and whether it's it's in the digest state or in the compost it's a it's a challenge that we need to address at every stage so we we are obviously working hard to diminish it i think there is got to be massive change in packaging legislation and in the looking really at the source material because it's it's this is not a unique issue to anaerobic digestion in composting landfill wherever you see food waste there is significant amounts of plastic that is resonant in those streams and i think you know we're we're working diligently with all of the packaging and and that our own system to try and reduce it but it really is is kind of a vertically integrated problem where we're going back to the source is probably the most critical first step and i'm hoping some of the bright kids at uvm and mit and all the other institutions around the united states will actually come up with truly biodegradable packaging systems that allow us to remove those those source contaminants you're muted senator brian thank you ma'am so i want to thank everyone we have just two minutes left so i think we'd wrap up i think one of the things that it's a long-standing interest of in this case i think i can probably spend center center representative sheldon will chip in here but i think this is one where i think both committees think similarly and that um contamination is an ever-going problem and so we're trying to shift to a more precautionary approach things as opposed to so i you know entirely an agreement going upstream managing packaging is ideal but meanwhile i think one of the most worrisome aspects is that if we have a process that puts microplastics into organics and then broadly applies those organics to the landscape we risk soil as a living healthy ecosystem by literally poisoning it and and so i think that's a you know an open why don't i would say for myself we don't know the answer but we know there's a serious risk there and we've been trying to make progress on and making some on things like p-fast but we keep seeing it's a pattern over and over again dangerous chemicals get released into environment and then we are it's virtually impossible to remove them so i think we're we're trying to move ourselves to a more proactive more precautionary footing where we don't once again allow something and then wonder how we will clean it up after we've proceeded to fire down that path um so uh that's a little bit of editorializing but it does it is reflective of years of work in the committee including making soil health part of the rapes that didn't actually come out of the ag committees came out of natural resources committees um so uh without i'd love to turn to representative sheldon to um see us off for the morning if you have any concluding remarks no i think you summed up the challenge that's before us quite well and i i just really appreciate everyone taking the time to bring us this information and um we do need to follow up and figure out what our next steps will be but um i think that the issue of the soil contamination that's to the heart of it and and we gotta put our heads together and figure out how to prevent that um from happening okay well again so thank you uh to everyone who came in to help us learn some more today a fellow senator what's going on thank you to everyone on the two committees for getting together