 Great, thank you, Rowan. Good morning, everybody. I'm Tim Briglin, the Chair of the House Energy and Technology Committee. It is Thursday, March 17th. This is our nine o'clock hearing. And this morning, we are going to touch on the world of cellular telephone tower sighting. And the reason we're having this discussion this morning, I don't wanna say at an introductory level because this committee has dealt with some of these issues before, but we're gonna return to them for a couple of reasons. One, there's a proposal from the governor and appropriations proposal to invest in publicly funded cell tower sites in Vermont. And that is something that this committee supported in terms of a $21.5 million appropriation, some of it for planning, some of it for actual capital construction. And that is in the Appropriations Committee right now. We'll see where that goes through the budget process. But there are questions that have come to this committee through email and otherwise in recent weeks about how we cite cell towers in the state, especially ones that are publicly funded. There's a member of our committee, Representative Pat, that has a cell tower proposal and one of the tabs that he represents that's garnered a lot of attention publicly and maybe an opportunity to learn from some of the issues that are being discussed there as we consider as a legislature appropriating money to support this kind of work. And it's not entirely clear to me how much policy ground in terms of changing statute we're gonna break in terms of dealing with 248A issues in Title 30, we may. But just as I said, kind of an introduction to those conversations that might occur between now and the legislative, at the end of the legislative session, I wanted to at least dip our toe into this water if that's possible without going up to our hips in this area. So this morning, we have our legislative council, Ellen Czekowski, and this is her area of expertise in statute. We also have the leadership team in the telecom area at the Department of Public Service, Clay Purvis, Jim Porter, and Commissioner Tierney is with us as well. I wanted to first give us some background on this issue and then we'll turn to the team from the Department of Public Service. So, Ellen, thanks for being with us. It's only been maybe two weeks since we've had you here for six hours a day. So welcome back. Thanks, good morning. Ellen Czekowski, opposite legislative council. So a big picture, the Telecommunications Act of 1996 was federal legislation that regulates telecommunications within the United States. That legislation dictated that the federal government regulates telecommunications, except that state and local authority still has the ability to regulate telecommunications facilities in regards to the siting of them, so their physical location. That is why this falls under my expertise because in the state the primary regulation is in regards to their land use permitting, essentially. So there are two, I think it's fair to say there are two different permitting pathways that happen for a telecommunications facility in the state. So if someone wants to construct a cell phone tower or add a small cell facility, they're sort of an optional pathways. Currently the construction of a cell tower could trigger Act 250. However, they have the option to either go down the Act 250 permitting route or go through section 248A of Title 30. If an applicant is looking to construct something and they decide to go through the Act 250 process, they may also need to get local permitting from a municipality if they have zoning regulations in place that would require a permit. So if an applicant is looking to go down the Act 250 path, it's Act 250 and municipal zoning. However, since section 248A was added to statute, I think most applicants choose to go through the Title 30 process under section 248A. If they go that route, they are exempt from going through Act 250 and the municipal process. So those are the two sort of big frameworks we're looking at here. The federal government states that the state and municipalities have the ability to regulate based on the siting of the tower. The federal government has the authority over the rates and other aspects of telecommunications, but the state is still allowed to regulate based on the siting and location of a facility. So 248A has three categories of projects. So in an applicant files, there are sort of three buckets of projects, three categories that a project could fall into. The smallest projects are under the de minimis modifications. De minimis modifications are two existing structures and this is a pretty streamlined process. If an applicant is looking to do one of these projects, they file an application with the PUC. The PUC is the regulating entity here in this section 248A process. They then provide notice to the statutory parties. It is the town in which the project is located, the landowner where the project is located, and the Department of Public Service. And that is why they are here today. I think they'll be able to answer a lot of the detailed questions about some of the specific aspects of how these applications play out. And then there's a 21 day public comment period that's open during which time people can provide comments and raise issues, but with de minimis projects, the comments I think are largely focused on whether or not the project is actually going to be a de minimis project. Then after the 21 day comment period, the PUC makes a determination after reviewing the comments and the application. They determine if it is going to be a de minimis modification, and if the applicant has provided enough detail in their application to meet the statutory requirements and then they issue the decision. The decision here, by the way, that the permit they are seeking is a certificate of public good. So that should sound familiar. It does have, this process does have some similarities to the section 248 process, which is also a certificate of public good. So communications facilities that are going through the 248A process are seeking a certificate of public good. So then for larger projects, the other two types of process, the sort of buckets are projects of limited size or scope, and then large projects. So limited size and scope projects, there's a defined category of size. And so if a project is going to be, fall under the limited size and scope category, it shall not exceed 140 feet in height, modify an existing facility or support structures that would result in total height of less than 200 feet would not increase the width of the support structures by more than 20 feet or would not disturb more than 10,000 square feet of earth. So if it would fall into those parameters, it would be a project of limited size and scope. If it's going to be larger or exceed any of those thresholds, it would fall under the third category, which is for larger projects and the largest projects. And so then it has a similar process but with more steps. So for these two types of larger projects, both of them require a 60 day advance notice period. So that's before the application is actually filed. That is when notice is filed with the statutory parties so that they are aware of the application. So this includes the parties I've already mentioned. So DPS, the town, the landowner and adjacent landowners, then the application is filed. And there's a 21 day public comment period during which there's also requests to intervene or requests for hearing on the projects. And if during the public comment period, there are significant issues that are raised, if there are no significant issues that are raised, the PUC will review the comments and the application and determine if the project meets the qualification to earn a certificate of public good. However, if there are significant issues raised during the public comment period, then there is the ability for the PUC to hold hearings on the application. So then there would be a scheduling conference, there may be discovery from the parties where they'll file information. There may be testimony and exhibits from experts. There may be an evidentiary hearing, stipulations or memorandums of understanding, and the parties may have the option to file briefs on the issues in the case. And then after all of that, then the PUC would review the evidence in the case and determine if the project should receive a certificate of public good. One of the other differences in the process between a project of limited size and scope and for larger projects are the amount of criteria. A number of environmental criteria that are applied to a project. So projects of limited size and scope have a shorter list of criteria that they have to meet. And I'd maybe wanna defer to hearing from the experts on the specifics of that. They're not the same criteria that are used in Act 250, although there are some of the same criteria, but they're the typical environmental criteria that I think you may be familiar with. I did wanna know one thing that I think might be of interest. So as I did mention, towns receive notice of these applications when a project is going to be located in a town, the town receives notice of the application. In addition, they have the statutory right to appear and participate in all applications that are located in the town. In addition, the commission is required to consider the comments and recommendations submitted by the town on these applications and the PUC has to respond to the recommendations in the town, in their decision. So that is the really high level overview of the 248A process. So Helen, we've got a couple of questions in the room and I would also welcome the folks from the department if they also wanna chime in on some of these, but go ahead, our presenters to be there. Thanks, good morning, Ellen. I actually have a question about regulation and your earlier statements about federal preemption. And maybe this may actually be a question for you, Mr. Chair, I'm not sure. So we have Vermont move forward with our net neutrality laws. We had both an executive order and a law that we had passed and we were sued by the entire telecommunications industry. I think that that situation has reached a point that we should hear more about perhaps related to our ability to regulate in a state. And we also had received, and this is my question for you, Ellen, have you spoken with Maria Royal about the Mozilla case and the judgment there related to our ability to regulate here? No, I'm not familiar with that case. Okay, so Mr. Chair, I would just like to suggest that this might be something we wanted to hear about. Those are both issues related to consumer protection, which we have not, we've been prevented by preemption from really considering our consumers and have been fighting for a long time. And those two pieces, both the Mozilla judgment and what's happening with the net neutrality case, I think are extremely relevant here. So I would just like to ask us to consider additionally hearing from them from us. Great, did you have more for her? That's it. Okay, the question that I have, and this might be getting a little bit too quickly into the weeds, but it's something that has come up in this committee when we were discussing the governor's proposal last month. And it's also been a kind of question at a high level that's come up with regard to wireless cell tower deployment. And that is in title 30, 248A, there's a reference to the facilities promoting the general good of the state consistent with subsection 202CB of this title. And looking at 202CB, there's a reference to the deployment of cell towers not negatively impacting the future improvements in the deployment of broadband technology and encouraging the use of existing facilities in preference to new taller structures. But a question about how some of the work that we may be proposing here and funding through this budget this year might affect the deployment of broadband technology and whether it's the department or ultimately the PUC having to take that into consideration in issuing a certificate of public good, how that plays into what we might be looking to do in the coming years, I'll say. But how much will that come into play in this discussion? Because I've heard some concerns actually from people in this room, but also kind of in the COD world of if we're gonna build whatever it is, another 50, another 100 cell towers, how is that going to overlap with or impede the work that we're doing in an adjacent technology area? I'm happy to pass that question. I do not know. Jim or Clay, I don't know if that's something you guys can comment on. Mr. Chair, I'm happy that this is Clay Purvis with the Department of Public Service. This is certainly a question that's come up in the past. I think the concern is if we build cell towers that ultimately provide LTE service, that people might prefer to purchase the LTE service over the fixed broadband that's coming, so the fiber product. And I think that concern rests on I think a misunderstanding of kind of how LTE service is used versus fixed broadband. I don't see the two competing against each other. And in fact, I think most people would prefer to have the wire line broadband service at their home for a variety of reasons. One, it's going to be a more stable connection for home use, you've got your television and your smart appliances and your computer all running. You know, that's really not how LTE service is presently designed to handle that amount of data and on that with the kind of consistency that consumers come to expect. So I think that you're gonna find that people are going to prefer to purchase the wire line product for their home rather than rely on an LTE service. They'll also buy a cell phone and a lot of people do that. I'm one person who buys both. I think probably most people in the room are purchasing both if they have it available to them. So, you know, I don't see them as mutually exclusive. Where I do think you're going to see people prefer LTE service or where they currently do are folks who are priced out of the wire line option. So if they can't afford the wire line broadband product or service that's available at their home, they're gonna tend to purchase the phone first. So we're talking about low income people that probably wouldn't be participating in the wire line market to begin with. And, you know, that requires a different solution other than simply expanding broadband. That gets into questions of broadband affordability. But when we're talking about our proposal here, I mean, we're really focused on, we're not really focused on home broadband service. We're really focused on highways, places where there's already some population density. So there's probably already wire line broadband there. But, you know, voice on the highways is really where we're going with this. We wanna be able to, you know, use our cell phones for emergency calling for the mobile aspect of mobile service. So the commercial uses like tourism, precision agriculture is becoming a bigger thing. And, you know, wire line broadband can't help the farmer in the field like LTE service can. So there are applications where wireless is really going to be the only method of providing connectivity. And that's what we're really focused on. And so just at a very high level, what I'm hearing is from a market perspective, your sense is that the bar's pretty high in order to make the case that the deployment of a telecommunications product that's using a cell tower facility, the bar's pretty high that that's impeding the deployment of a wire line broadband service. Yes, I think that's correct. I think where you might see some competition is really in the denser areas where carriers are focused on densification of their networks. And that's gonna be Boston and New York and maybe Burlington someday. That's where 5G comes into play. But, you know, 5G is really not a rural solution. And I don't think it's ever going to be. When we're building these macro towers, we're really still talking about 4G. They're calling it 4G advanced to now. But, you know, I just don't think it's going to ever become a replacement for wire line service. I think people want the consistency and the reliability that wire line broadband provides as well as the other services that wire line carriers also can provide like home telephone, though that's becoming less important. But, you know, the video packages, the home security, the, you know, all these other things that wire line carriers provide. And in fact, in many or in some cases, we're seeing the wire line carrier now offering cell phones as an add-on. So it's really kind of working the other way. You know, you sign it for Comcast, for instance, and you get a cell phone. And that may be something that the CUDs do someday, I don't know, but it seems to be almost the other way around. Not mobile carriers eating the lunch, the wire line broadband provider. So before we generally turn to our guest from the department, Representative Rogers, also has a question. Yeah, I think this is going back to Ellen's part, but I guess just, I just wanted to clarify that I'm understanding correctly. So the choice of going through Act 250 or 248A lies entirely with the, what is the word? Provider. Applicant, which, and I guess that's a good clarification. The applicant would usually be like a provider, like AT&T, Verizon. Is that who the applicant usually would be? Usually it's who's ever seeking to construct a facility. So it could be someone else, but I think usually it's a provider. The department may have other examples, but it can be anyone seeking to construct. So it could be a developer or it could be a private person seeking to put up an antenna somewhere. Okay, and then the reason why most applicants would choose 248A is it because it's considered a faster process, a less expensive process? I mean, I don't know if any of the witnesses have an answer to that. Yeah, it is hard to generalize, but yes, that is one thing I failed to mention. There are deadlines by which the PUC needs to respond to applications. That is true also for Act 250. I do think there may be a perception that the 248 process moves more quickly than the Act 250 process. I can't fully speculate. I think there are a lot of people who dislike the Act 250 process for a variety of reasons. So this option was created, I think it was created a number of years ago. One other small legal thing I wanted to mention is that there's a sunset on Section 248A that the legislature built in. And so it does come up for regular review by the legislature. And so currently it is set to sunset next summer, but it was an, yeah, so yes. I think people have a variety of reasons why they would choose to go before the PUC as opposed to go through the Act 250 process. Okay, thank you. And I do have to go to another committee. And so I'm happy to come back, but I do think you have the experts in the room who participate in all of the applications. So they may have more detail to provide than my high overview. Thank you, Ellen, for being with us. And I'm gonna just for kind of clarification purposes, kind of piggyback off of Representative Rogers' question and the question of some of the timelines that are laid out in 248A. Are those more, I don't know if there are any federal constraints or designations as to what very specifically some of those timelines are that have to be met in order to approve a citing proposal or not that are incorporated into 248A and maybe are not in 250, which is a more general kind of land use development law. So are the timelines in 248A something that more fall in line with federal guidelines? Do you want to handle that, Jim, or do you want to? So I think the answer to that is there is a federal law that says that any petition for citing I think has to be completed. Is it 180 days? Quite. I actually can't remember the timeline, but I believe it's shorter than the section 248A. And there have been some changes over the years to the federal timelines, but my understanding is currently right now they don't align. And I'm not sure they do align. And is one thing Ellen said, you know, with telecom regulation at the state level, you know, the state essentially gets to regulate what the federal law says it can. And that's not always that clear. And the statute that I'm talking about that's federal, the providers or it's referred to is the shot clock statute. And on occasion, if a cell tower proposal language is too long, you know, ever so often you'll have a petitioner rattle and say, we're going to invoke the shot clock. It's never happened. And I think generally from speaking with all of the providers, our 248A, I think provides what everybody considers to be a pretty workable and fair framework for cell permitting. Representative Sebelia. Yeah, thanks. Good morning, Jim. So related to the shot clock legislation, do you have a sense of, or have you assessed or done any work to see if that is in conflict with Mozilla or these decisions around net neutrality that are seem to be giving statement seem to be giving states more ability to regulate and look at consumer protection? So the question is, are those in conflict? Have you, has the department done any assessment about that? I don't believe we have. I don't believe it's becoming an issue for any cases that we've had thus far. Okay, thank you. Representative Sebelia, I would just add, I think the shot clocks are in the Telecommunications Act and the Spectrum Act of 2012. So, they're kind of expressed, they're in statute. It's a little more cut and dry than other preemption issues. Well, actually, why don't you explain that to me? Why that is more cut and dry than other preemption issues? Oh, I apologize. Yeah, that's probably not the right way to explain that. I would just, I think that the ability of the FCC's jurisdiction is expressed in the statute. Whereas with net neutrality, there is a debate as to the state's jurisdiction over that issue. So, my question, and please pull me back if I'm too deep down there. I will, I won't let you go over the question. Okay, so my question is around the shot clock issue and in Vermont, and whether or not that legislation in Vermont, which prevents us or seeks to prevent us or threatens to prevent us from citing regulation, from different citing things that we might want to do. I mean, that legislation is in place to expedite citing. And so my question is that legislation in Vermont which seeks to prevent us from consumer protection in citing, in light of the Mozilla decision and what has been happening with net neutrality has the department looked at whether or not or assessed whether or not that ability to prevent us from consumer protection is still on really steady ground. I just deferred to Jim on that one. As he said, I don't think we've looked at that. Yeah, I have not. And when you cite consumer protection, automatically think about the Attorney General's office which that tends to be in that realm, I think more of their purview. Okay, thank you. Yep, so Clay and Jim, I actually want to pull back a little bit. I know some of our questions have focused on some of the detail in 248A, but really the high level reason I wanna make sure we are hearing from you this morning is to think about citing issues and some of the opportunities and challenges in Vermont around citing and the governor's proposal here. I think some of the questions of this committee a few weeks ago as we were talking about our recommendations to the appropriations committee is a hundred cell phone tower sites is a lot of sites to put in place in Vermont in a whatever a four or five year period. And we look at some of the work that has been done in the net 18T tower, I'm getting the name of the program. The first net program. And some of the challenges of citing a few dozen towers. And this is a much more ambitious program that's being proposed by the department and the governor. So I just wanna hear more whether it's the other citing issues that you have to deal with and how this kind of fits into the world that we're living in right now in terms of resistance in some communities from people want cell phone service they don't want cell phone towers. And how that plays into the work that you're looking to to unroll here. So Mr. Chair, I'm gonna defer to Clay completely on his ideas for the cellular proposal. Would it be at all helpful to have a very quick synopsis of how the current process works and what I have in mind frankly is the proposed tower that's in represented past district. Yeah, if you'd like to speak to that and again kind of dovetail off of some of Alan's kind of overview that would be really helpful I think. And that can take us into Clay providing some more detail about the the capital proposal I'll call it for cell tower construction. So the first thing, 248A has been very dynamic and I think it has been amended several times over the years to try to fit the needs of when communities have felt that they don't have a voice kind of balancing the interest. And one of the things that was more recently added was one of the problems was you would have a company file a petition and once the petition was filed then you have a legal process and it's a little more complicated to deal with that in an informal way. So in many of our things under section 248 and 248A required the 60 day notice filing but what was amended in 248A is that the municipalities when they received that notice they are the petitioners are required to within that notice say here are the things you can do essentially if you're concerned about this project during the notice period. One of the things is, you know the department has the ability to retain experts in various fields for various proceedings that are then built back to the petitioner. So frequently when after 248A was amended because typically that was only available to us when a petition was filed. So for instance, and so what this requires is during the notice period before anything's filed where a process is started the town has given the ability to have a public meeting that the department attends where we can go ahead and retain experts and the company has to come in and do a presentation. And then when that happens, there's the ability to have interaction with the town. You know, the town may say, you know we would like to have this service but it would be better if it were located on this hilltop over here. And frequently that process has been successful. The one thing I'll tell you of the in Clay's got the numbers we see a huge number of petitions every year. Most of them are the de minimis classification which really is practicality. It's when people swap out antennas on existing structures but of the full tower proposals that we get there have been maybe five that I can come to mind that have been controversial over the years. And typically I think because of the way 248A is structured the process works. Some of the companies bend over backwards when there is protest from the town and in many instances relocate the tower to facilitate the town. And so the one thing I wanna say is 248A is a process that I think probably works as well as any that we deal with. And my guess is that the process in the instance of the one that's in representative Pat's district my guess is that one is gonna work out as well at the end of the day. Could you say that again? Last part of what you said. My guess is that case will work out at the end of the day. There's still a lot more meetings and visits that will occur. And we certainly hope that in that instance the petitioner will listen to what the people in the town is saying about the proposed location of that site. Does this be the time for me? Yeah, go ahead. Okay. Okay. All right. It's team, yeah. I, when this happened in Worcester where it's not just one of the towns in the district I live in Worcester. And I looked at 248A, you know, first of all, and I mentioned this to committee members informally. I told them that I met with you about this. And actually I think it was a day or two later was when the commissioners spoke about your proposal at the press conference and outlined the community engagement and public engagement process that you would do under your proposal. And my response to people in Worcester was that exactly is exactly what was missing in with this company. And I understand from you and others that some companies that put in the proposal do more of that and some don't. I don't think this company did not do any. And so I am seriously looking, I mean, the process is underway and there will be what it will be and that this little town had to learn how to get be prepared and hire a lawyer with expertise in these matters and things like that in a hurry. But I would like to see something in the statute that there is, and I don't know how to phrase it and what would be legal and all of that but that there is an expectation that there will be communication before the notice is filed. And the kind of discussion that the department said you would be engaged in any of the sightings that you would be doing under your budget proposal. So that's what was missing. This was kind of dropped out of the blue. No one knew what was coming. I also do think that for a project of this magnitude there should be some additional guidance or limitations on large projects in terms of proximity to people's homes. Not an outright ban, but that you need to have some kind of agreement with somebody before you put a tower of that size 300 feet from somebody's house. And who did not know that they were planning to do that until the notice was filed. So I would like to see the statute changed a bit to avoid this kind of thing. And I do know, and I said this from my utility experience with 248A when Washington LectorCoff was proposing a 248 project. We went to everybody well ahead of time and if the neighbors said could you do something or move it over here a little bit more, you know. Yes, and that it was in our interest and it's in the interest of a cell tower proposers interest I would think to do that upfront to put out a proposal that will get no opposition or less opposition. And it didn't happen here. And I'm looking at how to correct that in the future. Thank you. So I'll just generally ask is there in the department's view and maybe you don't have one yet but is there an appropriate change to address some of the issues that representative Pat has here. And again, acknowledging that it sounds like the department is going down as a practice going down this path. Is this something that should be more directly focused on the market at large in 248A? Thanks and Clay can probably answer that. I think what I was trying to say and I'll be a little more explicit this time earlier. I don't remember a cell project that was approved that met the kind of opposition that we got in the Worcester phase. I don't remember that happening. Yes, the process can be a little messy. This company, this is the first time I remember seeing a petition by this company. Clay may correct me if you tell me that's been around for five years. But I think to some extent, this petition is a bit of an anomaly but I'll let Clay fill in. Yeah, I think one of the issues that this particular case raises is the physical distance between the tower and residential buildings. And this one I think is closed, it's 300 feet, which I don't remember seeing that before. We've seen that kind of proximity, of course, to commercial buildings, which is typical and expected, but I can't remember one being cited in a residential neighborhood that close to other houses before. So this is one that I think, at least a contested case that will be a new issue for us to think about. I don't know if I have a recommendation for a hard and fast number of distance. I mean, I think one of the challenges of cell siding is that it's really case specific. It really has to do with geography of the site and the expectations of the community. And one piece where I think towns succeed, or one area where towns succeed is having a robust town plan that really identifies areas where they'd like to see cell coverage and where they don't. And I know quite a few towns have over the years updated their town plans to be more precise. And so some town plans will say something short about wireless, like the town has spotty cell service. We could use more cell service or something like that, but then it doesn't address the land use questions. Other towns have very robust, citing recommendations placed in their town plan that call out conservation areas, aesthetic areas to be protected and that kind of thing. And that's where I think we, I think that's where I think that maybe some of the focus could be put to help clarify for the petitioners, you know, when they're crossing the line, what's okay, what's not okay in a given community. Good to follow. Yeah, go ahead. Yeah, go ahead. Okay, I don't want to dominate this about Worcestershire. I just wanted to mention one other thing that I have also mentioned to the committee or at least to some people. And you may be aware of this in your communication with people in Worcester, but there's been a very robust discussion in town in a variety of forms, including front porch form about this issue. And there have been some people who basically said, well, you know, cell service or your cell phones, that's a convenience. And when they said that, they heard from a whole lot of other people who disagreed very strongly with that. So I think the great majority of people, including people who oppose this particular proposal at this particular location, recognize that Worcester is very underserved in terms of cell coverage and what that means. And I have pointed out to a number of people because they wouldn't know this, that I think the number 78% of 911 calls come in over cell phones now that these are critical uses that it's not just people who are calling from their landline phone at home. It's people in town and people traveling through town who was using cell service, businesses and all of that. So I just wanted to make that clear that this is actually as emotional as it is for a lot of people. This has been, I guess, a very robust discussion in this little town. Yes. And we hear that all the time across many towns and I'm sure you've heard about the tower in Chelsea and that's certainly a point that's been brought up by some of the members of that community and the public safety community about that tower. You know, I think one thing about the Worcester tower that, again, makes it an outlier is that it actually is not a cell tower. And that, I think, really changes the dynamic there. As far as we know at this point, there's actually no cell service that's going to be provided through that tower. So it's a private radio tower. So you go back to 202C and what's in the public good. You know, the 202C identifies mobile wireless coverage along state corridors and that's a very important thing to have. And not every communication facility provides cell service but that's kind of where the state is focused and it's telecommunications policy. So at the end of the day, it's a waiting of the pros and cons of a given facility and what we're willing to tolerate. I think everyone agrees cell towers are ugly. I've never been moved by one myself and I don't think anyone else has but they're necessary for the communication that they provide. And so it's always a trade-off. So Clay, I want to kind of give the last word to you and whether it's five minutes or what time you need to take us through this but again, just kind of thinking at a high level how some of these siting issues to the extent you see them out there affect what the department, what the governor is proposing with this appropriation to support tell, excuse me, cell tower construction. Sure, I think Jim pointed this out but I'll start by just reiterating that the vast majority of facilities go through with little or no objection. In fact, many communities welcome cell facilities and I was looking at the numbers last night and according to epoch there have been 79 limited size and scope and full petitions approved in the last three years since 2019 to 2021. And the vast majority of those, there was not a significant issue raised with regard to the facility. So I think we hear a lot in the news about the towers that aren't going so well but we rarely hear about the ones that are going just fine. And so I don't know that I think of siting as a big impediment to our project. That said, I will admit that a hundred towers in four years, we haven't told 2026 to expend this money is aggressive for sure. But this is our one chance to do something big on cell service and it is certainly something that we at the department here from Vermonters all over from all corners of the state. That's a big problem for them. We hear from businesses, it's a big problem for them and it's one that we think merits some focus given that it's our money and it's our project, we've really put the siting questions to the forefront of the proposal. The proposal calls for 1.5 million in planning funds. And I thank you all for your consideration of the proposal in your vote on it two weeks ago, both the nine to zero for the planning and the eight to one vote for the funding as I think heartening to see. But it's the planning aspect I think is probably the most important piece of this in that we're not going to be ramming these things down the throats of communities. It involves identifying first the tarry corridor. So we're doing the drive test where identifying the areas that lack service. We want to take those corridors to the communities say the town of Stratford for instance and say here are your areas that lack cell service. First, which areas are important to you if any? And if a community is very adamant that they don't want cell towers in their community, we don't see the need to build one there. If the town select board is in opposition to a state funded cell facility in that area, it doesn't seem appropriate to put our focus there. I think there are many areas where we can do good in the state. And so that would be the first step. And then when we're identifying the search rings, again, we're coming back to the town and saying, okay, in order to serve this tarry corridor that we've all agreed is important, here's where we need to site a facility. And again, receiving the feedback from the town, from the regional planning commissions, from A&R who would like to participate in this as well. And also working very closely with local and the state public safety organizations to make sure that we are providing coverage that is necessary for them. So that's where we want to take this and the planning stage, really weed out any controversies we might find early on before we get to the permitting stage. And that we believe will make the permitting go quicker because if we can identify the significant issues at the forefront, we won't have to litigate them or the carrier won't have to litigate them at the PUC after it's followed its application. Clay, just as a follow up, and I should know this, but can you remind me the $1.5 million appropriation that this committee supported that's to do kind of the drive tests and more of the upfront planning work. What was envisioned in terms of the time of actually expending and that money and doing that work? Is that a one year process? Is that what is like? Yes, that would be, we'd like to be at the permitting stage by the summer of 2023. So that process would include identifying the target corridors, meeting with the towns, publishing that data, meeting with the towns to figure out what the target corridors are. And then doing the search ring analysis. So, before the summer of 2023, we're ready to put these sites out to bid. Got it. I'm looking around the table to see if there are other questions. I will say this was just helpful for me in terms of kind of ramping up my recollection of some of these issues, which I feel like personally I turn to once a year and every time I come back to them, I know a little bit more, but there's plenty that I've forgotten as well. So I appreciate you folks from the department and Ellen who's had to go to another hearing, giving this committee a refresher on this stuff because I know we're gonna continue to hear from constituents and folks around the state about this issue. And obviously it's really topical because of the recommendation of the department and the governor that's being incorporated into the budget process this year. So I appreciate your time with us this morning. Great, thank you very much. Yeah, thank you.