 Good morning and welcome to the Vermont House Natural Resources Fish and Wildlife Committee. Good morning. We are going to be considering S148 and actually environmental justice in Vermont. I have with us Jennifer Byrne, Environmental Justice Fellow at the Vermont Law School. Welcome Ms. Byrne. Thank you so much. Good morning. Morning. Shall I begin? Yes. Good morning. I am very honored to be here today introducing an act relating to environmental justice in Vermont. My name is Jennifer Byrne. I am an environmental master's fellow in the Environmental Justice Clinic at Vermont Law School. And today I'm here representing the Rejoice Project. I will be starting things off today by providing you with some history of the groundwork that went into developing this bill. And we'll highlight a few key components of the bill's connection to the deep community engagement work being undertaken by many people throughout Vermont. This bill represents the input and expertise of many individuals across the state. And we worked hard in the Senate committee alongside advocates and agencies to reach these agreements and compromises. We fully support this policy and we're satisfied with the current bill as a first step to developing a framework on how to increase environmental justice throughout Vermont. Environmental justice is a term that until recently was seldom used here in Vermont. The demographics and rural setting of this state can hide environmental injustices in our communities. And yet issues of water quality, indoor air quality, energy affordability, transportation access, food and security and associated health risks still disproportionately affect low income and BIPOC individuals in the state. Community focused groups across Vermont have been organizing for five years to inform the creation of this bill. And I believe the environmental movement should be led by the communities who have the most at stake. We support and rely on community knowledge and expertise to co construct interventions policies and transformative approaches towards building sustainable, just and resilient futures for overburdened and underserved communities in Vermont. So by studying the history of the environmental justice movement in our country, that the act of ensuring meaningful involvement of all people means actually building processes to enhance public participation in decision making. We also know that in rural areas, environmental and health impacts may affect one small community far greater than a community just one valley over. We identify how environmental health, housing, transportation, energy and food policies overly burdened low income and BIPOC populations, and to eliminate structural barriers to entry in public decision making processes. In the last five years, we have heard directly from overburdened and underserved communities to identify shared experiences of unseen environmental injustices in Vermont, all pointing to the need for the fundamental procedural justice protections this bill is seeking to establish. I want to share a few slides, and I would now like to introduce you to the rejoice project rejoice is a collective of academics, activists, nonprofit leaders and community partners rejoice is an acronym, which stands for rural environmental justice opportunities by community expertise. Our fundamental fundamental purpose is to craft environmental justice policies for Vermont, based on the testimony of those who have been systematically excluded from the mainstream environmental movement. We strive to deepen the democratic process by creating a space for BIPOC working class and digitally underserved different monitors to speak out for statewide change that centers the most impacted communities. These partners included representatives from Center for whole communities, community action works, CBO is mobile home program, the environmental justice clinic at Vermont law school and University of Vermont's Rubenstein School for of environment and natural resources. We have expanded our network and partnerships to include other groups and individuals which I will touch on briefly. Over the past five years rejoice the rejoice project has been conducting surveys, interviews and focus groups around the state, forming connections in Vermont's most isolated and underserved communities in order to inform iterative community led policy in Vermont. This is an example of a word cloud that was generated from one of our first community meetings before the pandemic that we held in Newport. In the months before the pandemic rejoice began implementing deep relational methods for community engagement, working with and compensating community liaisons to co design and facilitate meetings, paying stipends and providing food and childcare to participants of community conversations, working with interpreters and hosting fully accessible meetings as appropriate, and inviting agency partners to attend as witnesses to the meeting. During the pandemic rejoice continue to engage communities extending these practices to an online context. In the summer of 2020 rejoice held 17 virtual conversations with 77 participants from digitally underserved communities across Vermont. We drew on established relationships to hold focus groups with members of the boot knees Nepali Somali bond to migrant farm worker senior rural deaf and hard of hearing disabled and mobile home communities. Our aim was to produce evidence based accounts of environmental justice in Vermont. The driving questions behind our work were, what are the key environmental and health issues of concern to frontline communities. How do ethnoculturally diverse and low income communities identify prioritize and integrate health and ecological concerns. What are the challenges to access inclusion and participation in state environmental and land use policy. How do these challenges contribute to existing environmental health issues, and what factors contribute to structural racism in Vermont and thus contribute to environmental justice issues. In our pandemic era focus groups we asked questions about access to information and resources relating to the pandemic and challenges to accessing healthy food, safe housing, transportation, health care, and environmental information and resources. Rejoice is commitment to valuing the time and expertise of affected community members is central to ensuring equity throughout this type of community engagement. I'm going to take you to our website environmental justice vt.org. So data from these conversations has been collected and analyzed by rejoice in order to understand community health and environmental concerns to understand how community members access information and participate in government systems and programs. And what barriers and gaps exist in current policies and procedures as experienced by Vermonters. I encourage you all to browse this database of community identified findings and recommendations relating to environment health food housing, transportation, economy, education and equal access. It's very important to note that members of communities who had strong ties to service and advocacy groups or case workers were less likely to express concern about lack of information because they had trusted sources of information and support. I'm just going to click through a few of these you can see here we have these detailed summaries by community. If you select one of these, there are a few charts at the top as an overview of what was most prevalent in our conversations. And then as you scroll down, you can see by topic, what folks talking about. And there are plenty of quotes. So this is really a great way I think everyone would be interested in this to as a way to hear from here directly from Vermonters about what their experiences were throughout the pandemic. For our next phase of work, Rejoice partners and members of the Vermont Renews Coalition are currently contracted to develop the Department of Environmental Conservation Community Engagement Plan, and recently received funding from the EPA to develop the environmental justice network, which will serve as a bridge between communities and their government, improving communication between historically marginalized Vermonters and state decision makers, while fairly compensating BIPOC and low income residents for their lived experiences and expertise. I would like to turn now to S148 and give some very brief highlights of the bill. So for context, the Environmental Justice Clinic at Vermont Law School is engaged in a multi year effort to document environmental justice laws and policies across all 50 US states and territories. This slide details the building blocks of EJ policy. We can say with confidence that this bill incorporates the basic fundamentals of effective EJ legislation, and is a starting point for ensuring substantive procedural and distributive justice in environmental decision making in Vermont. So what does S148 or the Environmental Justice Bill do? It sets an environmental justice policy that ensures that no segment of the population of the state should, because of its racial, cultural, or economic makeup, bear a disproportionate share of environmental benefits or burdens. It defines EJ populations based on low income, race, and limited English efficiency. It also provides definitions for environmental justice and meaningful participation. These definitions were developed through a participatory process led by the Vermont Renews BIPOC Council. It commits targeted spending in EJ populations. It sets a goal for the state to spend at least 55% of environmental, renewable energy, climate, transportation, and resilience funds in designated EJ populations. It establishes an EJ advisory council and an interagency council. The advisory council is comprised of community members from EJ populations. It commits the state to building an EJ mapping tool, and this tool would be useful to communities and agencies to aid in information sharing and decision making. It establishes a date for compliance with Title VI of the Civil Rights Act. So that all state agencies must develop community engagement plans. So I'd like to provide some legal context for the necessity of including the deadline for compliance with Title VI of the Civil Rights Act of 1964. Title VI provides that no person in the United States shall on the ground of race, color, national origin be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any program or activity administered by a recipient of federal funds, including state agencies that receive funds. Discrimination in the environmental justice context can mean that communities of color and people with limited English proficiency bear disproportionate environmental and climate burdens, or lack access to environmental benefits and climate solutions. It can also result in the exclusion from governmental decision making about these critical issues that impact our health and well-being. One of the driving missions of the environmental justice clinics work at Vermont Law School is to enforce Title VI in the environmental context. You will note that in the legislation we established a deadline for all state agencies to move toward compliance with Title VI by developing and adopting plans to ensure meaningful community engagement. These are also known as public participation funds. According to federal guidance, recipients of federal funds can demonstrate a commitment to Title VI compliance by establishing and implementing meaningful public participation and language access plans. To date, most Vermont agencies are grossly out of compliance with this law, resulting in public policy and decision making that is not informed by the communities most affected by these policies and decisions. By enforcing civil rights law in this way, we are dedicating our state to incorporating key principles of environmental justice, including the fundamental right to political, economic, cultural, and environmental self-determination of all people, and the right to participate as equal partners at every level of decision making, including needs assessment, planning, implementation, enforcement, and evaluation. Developing a clear public participation and community engagement strategy can be partially informed by census and geographic data as a starting point. However, in Vermont, as we have seen, the lingual geographical, transportational, and technological barriers to participation are so varied, data must be supplemented by the expertise of community members in order in order to understand community experience needs and desires. I would now like to point out a few critically important budgeting considerations that advocates for this bill agree must be incorporated by the House in order to have the intended effect of equitably and meaningfully engaging overburdened community members. As we saw from the climate council process without adequate funding or time for engagement with communities or for onboarding of council members, the most overburdened and underserved community voices will be silenced. And we as a state will fail to benefit from the expertise and vision of our most affected community members. We have provided this sample budget based on the work of rejoice to account for per diems training and and facilitation of the advisory council members, as well as community engagement in standing up the advisory council. So the fiscal note from JFO and the budget from senate appropriations did not include any funding for this critical advisory council work. The fiscal note does point out precedent for paying certain councils members higher than the typical $50 per diem rate. I would recommend an amendment to this bill to include language that provides e j advisory council members at least $200 per meeting to better account for the actual costs of preparing for and attending meetings, and the personal costs of representing their communities lived experiences of environmental and health issues of concern. This budget includes funding for engagement work in each county and each community represented on the e j advisory council. This funding is intended to support the necessary engagement to recruit council members and to host any meetings and to support and inform the council members as they perform their duties. The budget breakdown and column H is based on rejoices engagement model and includes stipends for participants, liaisons and any necessary interpreters. This relatively small funding request is the critical bedrock that will allow for a successful rollout of this bill that will not be extractive of the very community members we seek to serve. We did submit this budget to the senate committees and we hope that you will consider taking it up in the house. So, in summation. We believe the environmental movement should be led by those who are most affected by the impacts of climate change and pollution, both as a matter of principle, and also to ensure that any policies developed to address environmental and climate challenges will benefit from and incorporate the perspectives of people from all corners of the state. We believe in upholding community members as co designers of environmental and climate policies and defend communities rights to self determination and decision making community perspectives should be sought out, valued and incorporated into policies and programs that affect community health and the environment. By doing so we are confident that the results of this level of engagement will be stronger, more effective and more resilient policies programs and communities. We're very grateful to you all for taking up this bill for consideration and hope that you will consider us as willing partners in the effort to create an equitable future for all of our volunteers. Thank you very much for your time today. I look forward to engaging further and am available anytime for questions or further conversation. Thank you for your testimony. Do members have questions for miss burn. Thank you so much for your work and your testimony here today. Our bill passed over from the Senate asked for 55% of state dollars to be invested in in the communities on our community communities. Could you, could you tell us what your expectation of that is what it what it means. Sure. So to clarify, this would be 55% of environmental climate energy resources that we're asking to be invested into what's currently in the bill called EJ populations EJ population is defined by a population with 6% or more BIPOC 1% or more limited English proficiency or there's I believe it's 80% I'm going to pull up the bill, there's a low income standard as well. So any of those criteria would designate a census block group as an EJ population. And so, yes, so the expectation would be that when when we do that mapping. We actually see that within the currently defined EJ population that covers 52% of the state population. And so we believe that, you know, assigning 55% of the resources to these overburdened community members is reasonable. It's also mimicking the justice 40 initiative. And so this is our attempt at codifying that in in state law. I thank you I do understand. And I'm sure the committee does as well, the census block concept and the need for dollars there. One question is, is it your understanding that every water quality dollar, for instance, gets spent there every transportation dollar gets spent there every every actual expenditure initiative from the various agencies get spent that's literally 55% of it in those districts or or is it a different aspiration such as grant money. Um, you know, I think it's it's definitely something that we've been talking about with the agency that's a very important question. It a lot of it will align with and and depend upon some of this mapping work. And I and I do think that asking I know you're you'll be speaking with Miss Jenvin, or later I think that they would probably have a better for you on that but but yes we're not really defining this as a monetary resource but but resources broadly and services. So that that's does need to be worked out. And I and I think the agency folks are in a better position to answer that question. Thank you. Any other questions. Representative Dolan. Good morning, and thank you for coming today. A couple of things. One is that how we define overburdening be really helpful when you mentioned that meeting those three criteria would result in identifying overburdened community with the statement you just said. I think of overburdening and look at other examples around the country such as New Jersey, or Michigan, or California overburdening has is a term used to illustrate the environmental burdens that are disproportionately placed on a population, which relates to, you know, exposure to contamination or air water quality degradation that sort of thing and I'm struggling with predetermining what we mean by overburdening using these criteria. So I think we should be out here and trying to better understand that term. In this version of the bill, we actually don't use that phrase overburdened or underserved. The phrase that is used and defined right now in the bill is is EJ populate environmental justice populations. We end the something to know is that within the first year, the advisory council is tasked with looking at that definition and suggesting edits and additions to that population so we're starting with these three criteria, which are pretty standard and, you know, based on even, you know, our research within the state of Vermont, we understand that these populations are overburdened. And so this, you know, this is where a starting point for this definition and I think you're right we're, we're also not satisfied with this being the final definition, you know, forever, which is why in the bill, we're asking the advisory council with that's one of their first jobs is to look at the definition of J population and recommend if there are additional criteria that they want to see included. I hope I hope that answers your question in a way. Yeah, that is helpful and tie to that is the, while I think your presentation has helped to identify other inequities that may be present. And such as, as you mentioned in your presentation you described food security and housing and transportation and access to open space, which is something you haven't mentioned but it's in the bill or perceived to be in the bill. And I look at other states and working on environmental justice that has been focused on those hotspots of where we have cumulative viral burdens relating to, as I mentioned degraded air and water quality or, you know, occupational or safety issues related to indoor air quality or asthma related you know from some of these impacts so I'm struggling with the, the scope of the bill. If we're looking at environmental justice as as a topic that other states have have used in that context can you help me out and understanding the scope of this bill. Well, you know, because this is so new to Vermont this is really a starting point. And it, it's part of it is identified, you use the word cumulative. We do identify, you know, and set forth a rulemaking process in the bill to define cumulative environmental burdens. And this is really going to be reliant in a large part of the mapping tool, as well as the, you know, advice and expertise of the advisory council. And so, you know, we don't want to set out and define that before the mapping tool is created. So, that's why we, you know, are offering it in in the rulemaking process over the first year, or two. And so, yes, so you're right and in other states you know you mentioned, like hot spots in other states and that's really just not what we have here in Vermont in a lot of ways, where we don't really have, you know, a obvious polluter in some communities but because, you know, it's so widespread and it really comes down to access to information and resources that that is not equal, depending on where you where you live, what language you speak or the color of your skin. And so that's where this bill is really a procedural bill in large part. Other states have gone farther. But this is where, you know, we believe we need to have this this baseline procedural framework set up before we can really move into doing and potentially mimicking what what other states have done. That's, that's all I really can say to that. Thank you again for joining us with your testimony this morning. Thank you very much. With that, we will go to deputy secretary, gender. Hi, hi. Commissioner Walker is going to join me today but he had a family emergency this morning and so he was not able to make it so it's just me today. Good morning, for the record, my name is deputy. Well, my name is Maggie gender. I am the deputy secretary of the agency of natural resources. We're glad you've taken that on. You're going to actually hear a lot of the same terms used today. And I think something that is helpful on the space of environmental justice because it is really comprehensive and complex is something I wanted to do is just without diving into the bill set the tone for where we've been and where we're going when it comes to environmental justice and how it intersects with the agency of natural resources. And I, and I am familiar with the bill I did not come prepared to do a section by section but happy to answer any questions as I recognize them and anyone's I don't remember. I will make sure I get back to you. So I'm not going to read I did had a PowerPoint slide that I wasn't able to go through last time and not going to read word for word what's on the PowerPoint slides but I thought I would just talk to you what are the important components and why we're talking about it. So, enter. So members know the PowerPoint is on our webpage under Maggie gender. So one of the third there are two, there are two things they're two, there's three components of what I want to talk about today. First is talking about environmental justice. The second is talking about the Civil Rights Act of 1964 and what we refer to as title six of that fact. And then talking about ANR's commitment to the EPA to work towards an environmental justice policy for our agency. So those are really the three components I wanted to talk to. So environmental justice, you have seen the definition pretty regularly now. So I think the two main components of environmental justice that are really important is that to the same degree, the populations as described, have the same degree of protection from environmental and health habits hazards, and have equal access to decision making as a process. And that's really what a lot of people refer to as meaningful engagement. It's that shared decision making, which is a shift in how we do it now which is really a lot of what state agencies do is communicate to the public what we're going to do, and communicate so it's a more meaningful process in which you're pulling in the community, and they will help you shape your decisions versus you having made a decision and communicate it out to the community. So that, that alone is a pretty big shift in terms of how state government agencies operate now. And also, let me just make sure and so an important component of environmental justice work is that an executive order in the Clinton administration was passed in 1994. And it took every federal agency to make an achieving environmental justice part of their mission by addressing and identifying how people are disproportionately or adversely impacted by health or environmental impacts. And so that's important because then the federal government said to every federal agency, you must incorporate environmental justice. And every federal agency does takes on that engagement in a little bit different of a way, or, or supports agencies in a different way and so at the agency of natural resources, we have the environmental protection agency that works directly with the Department of Conservation as their federal funder grantee support system. And so that's why I'm saying that so when I get later and in the process of talking about specifically the EPA, why, why I'm doing that. So an important difference between title six and EJ is that title six is ensuring that recipients of federal funding are also ensuring that their programs and activities do not discriminate on the basis of race, color or national origin. And this includes limited English proficiency, and where EJ closes a gap is addresses low income as well. So they are the civil rights act of 1964 is really a cornerstone of environmental justice work, because a lot of the same components of meaningful engagement and limited English proficiency we'd like to say language access are incorporated also into environmental justice. So they're very much tied together and that's why you hear a lot of people refer to civil rights act and environmental justice kind of in the same breath but they're different, but they're important to each other. So, so that brings me to the EPA does regular reviews of state agencies, and they enforce what their expectations are of us as a recipient of federal funding. So two years ago, or three years ago we had a review, and then they submitted a speed back on where we needed to close certain gaps. And what you do regularly as you come to a performance partnership agreement, which we call PPA. And that's really it includes quite a few components, but it's a space where you're creating an agreement with the EPA to say, we're going to work towards doing better in these places that you've identified that we need to be better at. So for us, one of those spaces was that the agency of natural resources did not have a environmental justice policy in place, and we needed to close some gaps on compliance around Title six, which is our non discriminations that really deals with grievance procedures and mitigations of those grievance procedures. So we are on a four year journey, and we're two years into that journey of both adopting an agency wide environmental justice policy, and putting in place some mechanisms to do better with our non discrimination and title six compliance. I'm not there just for a second want me to keep going. I feel like I'm saying a lot. Okay, you're saying a lot it's helpful. I think that third, I mean we've. So, this is great. But I want you to actually just restate the last sense you just had about the, I think understanding this kind of interplay between title six and the environmental justice is, is important for me, I know. And so can you just restate that relationship, just, Sure, what you just said I think. So, title six of the Civil Rights Act of 1964 title six in particular requires that any recipient, even $1 of federal funding has to ensure that the programs and activities that you offer the public. Do not discriminate on the basis of race, color or national origin. And that includes language access. Where environmental justice closes a gap is environmental justice includes low income as part of that so income in general. And so the 19 the Civil Rights Act of 1964 and especially the title six component of it is, is a is a huge foundational building block of environmental justice, because you are taking into consideration, a bunch of demographic and social determinants that are focused on environmental and human health, and the burdens and benefits that you receive because of that. And so, and another piece of title six that is really important is creating language access and meaningful engagement for the public participation. And that is also a cornerstone of environmental justice. So they really, really are our work on the Civil Rights Act as a country laid the groundwork for a lot of other really good work. That's been happening for the last four years. And then I guess though what I was getting to was under this performance agreement. Part of that performance agreement is telling a and R to invite to adopted environmental justice. Correct. Yes. Representative Smith. Yeah, I'm having a hard time get my head around this whole whole subject is really is actually very comprehensive and complex so you're not alone. I was wondering if in in the statements that you have for not discriminate against individuals. Have you ever been brought up short on that I mean has there been any lawsuits or actions or against those person, you know, make a claim against you. And how do you handle that I mean how, because you mentioned low income people. And I understand low income people are struggling with a whole host of issues just to put food on the table and eat at home. However, do you treat them differently with your permit process or anything is it still the same I'm trying to understand how this piece comes together. So in terms of the actual title six and non discrimination clause. You have to create a grievance procedure investigative manual, etc. So have in place at your agency to do both external and internal review of complaints that might come in if somebody says I think I was discriminated against in this way, and can, and can submit a complaint. That's different than us participating with, for example, if we know a new program is going to be in place to offer funding to Vermonters where where environmental justice comes into play is if you happen to know that there's funding available to a low income community, you will change the way you engage with the community so that either your communication is clear or different based on the needs of that population, or that is let's say you're trying to decide what the mechanics are of a program and how you're going to fund it is folding communities of that are ej populations into that decision making process so that they are accidentally left out of participating in the benefits of that funding. So that's, that's the hard, that's a shift in how a lot of state agencies have typically done their work and so that's why environmental justice matters, and why it's hard work to do. So, in the example you just used is that result in reverse discrimination. I don't think I can answer that I don't know. Yeah. I am. When I was working for USDA. I remember there was a case of discrimination in the south. And it was discrimination against African American farmers. It was called the pigford case. And I think it was picked from versus click man who used to be sector agriculture time. And there was some huge settlements there. But I know one of the outcomes was because you know just in casual conversations with my counterparts in other states. And if an African American came in to borrow money or sign up for one of the programs, they just, they just signed them up without any qualification so you know while this case was being subtle so I'm just wondering to me that created some discrimination with the rest of the farmers. So I'm just wondering how this all fits together and how this program might have prevented something like that from happening in the first place. I don't think I can answer your question directly but I think what I can say about environmental justice is that the core components of environmental justice are to support. And I think we do have a lot of key factors in being a part of decision making before decisions are made by the government, so that you are taking into account things like minority populations, low income populations and it's, and we don't do it well now as a state so justice has, I think, gained a lot of support around the country, especially, you know, whether you have climate crises or you have flooding events or you have a pandemic, we're seeing more every time that we just are not doing a good job of taking care of certain parts of our populations. There is a undue burden and a undue benefit based on who you are. And so that's how environmental justice tries to make some changes there by incorporating the principles into your government activity. I know what the principle is. I'm trying to understand how it's actually applied and I know it's changed over the years. Yep, so I can, so we don't have an environmental justice policy yet at the agency, so therefore we haven't put together a directive for each department of how it would look, but I can, without getting ahead of myself, A, you need shared definitions, B, you need to put a policy in place, and then C, you need the right kinds of tools to be able to understand what your population looks like, whether it be a state or community. And then you need to be able to put some directives in place to say, for example, we have three departments at ANR and Fisher Mildlife is different than DEC, which is different than Forest Parks and Rec. And so what we would have to say is when you are considering, and I'm thinking of ARPA right now because it's such a relevant example. So if you have funding and probably new program, and you're going to issue that program through ANR, we would take into account our EJ policy as we build that program. And part of that EJ policy would be community engagement, so that you're making better decisions. And it's a lot of work, and it takes more time. It's the right way to put your energy into Vermonters. And I'm okay for trying to get my head wrapped around this whole subject. Well, the bill is more comprehensive than the scope in which I'm talking about that impacts ANR. So I think that's the challenge that we're all facing. So the agreements that we have to adopt an environmental justice policy and to continue our civil rights compliance. And so we've made some pretty big strides at ANR over the last even year that I've been here, which is we were able to hire an environmental justice and civil rights coordinator. And she has put into place some really important pieces of the puzzle that we're missing for us, which is an agency-wide investigation process and manual that's consistent with our ANR non-discrimination grievance procedure. We have a draft limited English proficiency and plan that we're going to be bringing into final stages this summer, hopefully completed by fall. We are issuing training that's going to be regular and consistent for our staff so that people can have a better understanding of how this work is incorporated into their day to day. And then we've established liaisons in each department in our agency so that we can start to build out what our recommendations are going to be for an EJ policy for the agency. And there was another document that was shared with you last week, which was titled our Environmental Justice Timeline. And this timeline is attached to the development of our EJ policy. And you heard Ms. Byrne talk to DEC engaged with Rejoice in a community engagement contract. And that community engagement contract, the results of that will be finalized by this summer or next spring. And we're going to incorporate what we find from that into our environmental justice policy, which we want to have finalized by spring of 2024. And so what we learn from this community engagement contract that we're working on with for Rejoice is going to be really instrumental in understanding how we incorporate a community engagement plan within our environmental justice policy. So how does your ongoing work kind of interface with this proposed legislation? I think I don't know yet. That's the part that I'm trying to wrap my head around to is that we're going to do this work anyway. We have to. It's really important to our teams that we do it. But in terms of this legislation, this legislation, I believe that the goal of the legislation is to make environmental justice policy more consistent across state government. With that said, like I said, we're on a four-year journey and we're two years in. And I'm trying to think through where are some places that we can take the work that's already been done and share it. I think it's really important we match the funding available with the scope of the work. And it is really important that we do have better lines of communication across state government and who would be stakeholders on the advisory council. How we do that is a challenge. So you'll hear, you know, without I'm trying to be respectful of your time too, but you know, you'll hear some pieces talked to like the mapping tool and community engagement and definitions. And I struggle with the resources available to do the work because it is intensive. I struggle with how we create these definitions together, which is important while also creating a community engagement plan while also developing a mapping tool. Those three items alone are equally and independently as important and are going to take time, especially because state agencies are coming at environmental justice with a different lens. So we come at it from a pollution lens, whether it be air, water, hazardous waste. If you're VTRANS, you might be coming at it with a lens of if you're building a new highway, how are the emissions of the cars going to impact the neighborhoods? And are those neighborhoods low-income populations, minority populations, or Indigenous peoples? And that is where their lens comes from in terms of justice. And then same with the Department of Health, thinking of algae blooms. How are you communicating to the public properly if there's an algae bloom outbreak and you need to let people know they shouldn't be swimming? They're going to come at their community engagement around that with a different lens. So I think that's the there's some in a lot of ways there's some foundational steps that need to happen before we get to the end results. And a lot of those foundational steps are they include starting the conversation. And so that's why I'm glad we're having this conversation in the legislature. I'm just not I'm not sure how we again, like I said, match what's available for resources from the state to getting some of this work done. Well, I guess that kind of gets to the request for 10 staff right out of the gate to do this work. Seems a little mismatched to what the tasks outlined are. So that was the work that we so that was in terms of how we created that analysis is taking the scope of the bill, which doesn't just include what I would explain as a kind of like natural resources lens, but it's lots of different lenses. And most of the work was following following following on the plate of the agency of natural resources. And so our perspective there is you both need just learning from the Global Warming Solutions Act you need technical analysis. It's data heavy. You're building a mapping tool. People who are an analyzing data don't have the same skill set as staff who are developing community engagement plans and working with stakeholders on how to do that. So there's there's just it's a human resource intensive body of work. And my experience over the past year at the agency is that if you don't focus your energy, it's so overwhelming that you it's you're almost paralyzed by making progress. And so both what is was great about the EPA review is it made us really hone in on what we need where we needed to close our gaps. And then over the last two years, what we were able to do is even further focus what steps you need to take first, second, third, and how do we get there over a period of time. And so how does the the EPA review and then the work you're you're doing related to that? Did that bring in other agencies at all or was it only ANR focused? So it's just ANR focused. We do work in for we were quite a bit with Department of Health and VTRANS, but not necessarily an environmental justice, but we a lot of like the health related initiatives. We do talk to each other, but it's not formalized. I think other members had questions. I'm thinking about the mapping tool. And the inputs that will be what has work begun on that as one question. We have only done research on how other states have developed their mapping tools. And the mapping tool will be a really important. Again, when you talk about inclusive decision making, the advisory council outlined in the bill would be responsible for creating expertise and advice on building the mapping tool as well. And so and just be driven by agents, by government. So you're you're you're then saying that that's a prerequisite for developing the mapping tool or well, it's a prerequisite. You can't build a mapping tool on a silo because especially this bill looking at food access, transportation access, health access, with the decisions that need to be made in the mapping tool, which other states have said, really, they struggled with is how do you layer your decisions? Like it's not just you're not just looking at low income minority populations or Indigenous peoples. You're starting to look at where are the bus stops? Where are the grocery stores? Where are the flood plain? Where are the brownfield sites? And then you kind of have to decide when to stop. Um, and that's where that's where that conversation I think sometimes can take a lot of time because you have to get to a common ground. So I buy and I understand you can't build a silo that makes total that makes sense. Are engaged now with rejoice, right? We're working on a community engagement contract with them that's going to inform our environmental justice policy. Representative, thank you. Thank you for your testimony. You know, it seems to me so much of the environmental injustice has been driven by economics. I mean, no one wants to live on Backstreet. No one wants to live next to a railroad yard. One wants to live close to a factory. And I'm having a hard time figuring out how this policy or guideline would prevent would do anything to mitigate that or change it if basically people move where they have the money to live. And I don't know how this policy will either increase their earning or or or they're standing. Well, I would I would encourage you to think of it this way. What environmental justice does for example, let's say you live, let's say you're a low income family and you live in a flood plain. When the state of Vermont starts looking at are we going to allow people to build in flood plains? Part of an environmental justice principle based in that is, hey, wait a second, a lot of low income families live in flood plains. How do we support those families to find other places to live while simultaneously disallowing homes to be built in flood plains? So it's the the work of environmental justice is to correct past injustices. And that's kind of the utopia and also prevent those from happening in the future. And so a lot of environmental justice work, you don't necessarily see immediate impacts right away. It's that shift over time where you start to bring you shine light on decisions that are made by government agencies that that may or may not be inclusive or comprehensive of actual thoughtful community engagement. Just one other follow up. So environmental justice is basically looks to rectify or kind of overcome situations which have been environmentally caused. And by that, I mean by by living in a flood plain or by, you know, living in places that are environmentally sound. And yet what if you take that concept and think of it as in terms of the environment as a larger context, you know, not so much nature or natural resources driven by just the environment itself. And I'm just kind of hard, you know, in terms of I don't understand how situations that have been created by either, you know, by such a forces capitalism, it's going to help these people. They're living there because they just don't have the money to move elsewhere. So I and when you come down to it, most people would say no one wants to live there. And that kind of a context where there's really, they're kept up. They can't sleep very well at night because of the noise, because of traffic. I mean, there are all these variables, it seems to me that, you know, I don't you know, and they're not natural resources driven. They're driven by how the how the environment has been shaped over the years. Yes. And your this is a lifetime body of work. So you're not wrong there. But what I would say is that environmental justice populations which have been identified in the past as low income minority populations or indigenous peoples disproportionately feel the burdens of pollution in a natural resources way. And so what this, the goal of environmental justice is, is to correct that by also making sure that all communities are enjoying the benefits of decisions made by government, especially when it comes to programs or funding. And that's not a goal you reach overnight. That's not a goal you reach in two years. That's not a goal you can attach a timeline to where you can start is by developing a policy that provides everybody a shared language. We need to wrap up. This is the beginning of a conversation. And I think actually we're going to have great clothes for this session. Thank you for coming in today. Thank you. Helpful. We have a lot of people at ANR that work programmatically with environmental justice and with our legal team around compliance. So I just offer that because they they have more thorough expertise than I do. But I look forward to it. Thank you. Thank you. Thanks for listening to me stumble. I'm trying to trying to articulate it the best I can, but thank you. Thank you. Thank you.