 Good afternoon. We are going to convene our meeting this afternoon and talk about S5 and the timeline with our legislative council, Ellen Tchaikovsky. Ellen Tchaikovsky, Office of Legislative Council. So I'm here to talk about the timeline. I sent you a while ago a timeline. It's dated March 22nd. I'm not sure if it's posted for today, is it? Okay. So this is the timeline on what passed from the Senate. And I think we can just walk through it. I think that what I tried to do in this, so first of all I deal with words. I'm not really like a graphic visual person. So it isn't even in a line. It's more of a chart. But I thought you should have a representation of all of the steps that are going to need to be taken before the program even starts. And so in addition to that, I've also included things on here that have tangible dates, known dates in the bill. So things that don't have specific dates, I've captured a few of them on here. And they're the ones where the date box is blank. So I just want to point that out quickly. For example, box number one, two, three, four, five, number five, the PUC may hire a third party consultant for public engagement. There's no date on that one. And that's because there isn't a date certain in the bill. And so I put it on the chart there to roughly give a sense that that is going to be something that needs to happen sooner rather than later. So it might not happen on August. It's not to say that it's going to be part of the August 31st bucket, but it's going to have to happen sooner rather than later. So Josh, just a designation that that one, the date box is blank because there isn't an affirmative date, but it's going to have to roughly happen earlier in the process rather than later. But so to start from the top, the first line is on January 1, 2023. This is when the early action credits become available to be registered. Now technically, this bill hasn't passed yet. And so January versus already passed. So no actions are necessarily going to be taken. But if this bill were to pass and that date were to be part of the bill that passes actions that have taken that have been taken that have been taken this year by people doing clean heat installations will be eligible to apply for credit. And so what that would mean is we're going to talk about the ultimate date of when this program will actually maybe start. But between now and the start date potentially 2026 for the next two and a half years, people who do clean heat work can be eligible to earn credits that can then be sold. So this will establish a pool of credits to be available before the program starts and when it starts, so that there's a pool available that can be sold so that there isn't it allows the system to ramp up. So there isn't an immediate sort of shock to the system with people meeting credits and they're not being any credits. So this is a date that you have the authority to set. If you want to push it out another year because it's weird that it's January 1 and that already passed or you want to adjust that date, you can. But this was a concept that was in last year's bill and last year it was 2022. Do you also provide us this? No, I think that's for the next witness. Okay, thanks. The next line is sometime between May and July 2023. If this S5 were enacted, it currently is set to take place and take effect on a passage. And so what that means is that all the statutory language would be enforceable and so that the PUC could take actions under it or any of the other agencies implicated could take actions under it. Additionally, the funding will be awarded and the positions will be created so the PUC and DPS can start the hiring process on that. So the next date, July 1, 2023, the PUC buy that date needs to open a proceeding to establish the default delivery agent costs and the hiring of the DDA itself. Additionally, this isn't specified here because it doesn't have a date certain, but the potential study will need to start sometime around there as well. Time around July 1. Yeah, so I don't think DPS would start it before then, although it isn't clear. But the potential study is listed as part of the DDA process. So it's listed as part of the proceeding that starts on July 1. So I don't know exactly how they normally handle that if they started on the day of the opening of the proceeding or if they start it within a couple of days after the proceeding has been opened. I don't know what the initial steps of it are. So that's one of the reasons it isn't mentioned there because I'm not sure the exact timing. So next is August 31, 2023, the PUC needs to commence the proceeding on the cleaning standard by that date. I think potentially they may start it earlier. They may start it in July. But that is when officially they have to start the proceeding by. And so then as I mentioned before, there isn't a date certain, but the next I think the next item is that they're going to need to hire their facilitator for public engagement, particularly because the next box is they need to hold at least six public hearings or workshops. And presumably you want the public engagement facilitator to facilitate those meetings. So the proceeding is going to start and you want to you want to get public feedback on the clean heat standard rules. You probably want the facilitator to be hired sooner rather than later so that they can assist with the public meetings. And there isn't a date certain by which the public meetings need to be held, but they probably need to be held sooner rather than later because the information gained there will be from the members of the public, but also the stakeholders, including the other state agencies and the potentially obligated parties. So you'll want the feedback to be given to the PUC sooner rather than later. So then the next date certain in the bill is January 15, 2024. And this was actually in your most recent draft proposed to be changed to February, I believe, yes to February. So but January 15, 2024, the PUC needs to report back to the legislature on its proposal for funding sources for the clean heat standard. So as we talked about the other day, currently this bill does not have any taxes or fees directly in it because and so there is an appropriation in it to start the program. But currently the Public Utility Commission and their existing work is not funded by general fund dollars or appropriations. They're funded almost exclusively by the gross receipt stacks, which comes from the utilities that they regulate. So to fund the ongoing work of the clean heat standard and its administration over the next how many years, there will probably need to be a dedicated funding source established. The PUC in the past has provided their initial thoughts on what the funding source should be. However, this bill doesn't actually have a funding source in it and so it's asking the PUC to come back next year with their recommendations. Additionally, there is a date on January 15 also the PUC must hire the consultants to help establish the clean heat credit registry. There are three facilitators, facilitators slash consultants required. I bolded the first two and then I forgot to bold the third one, but you will forgive my hectic schedule lately. But there are these three consultants that the PUC is going to need to hire and so I bolded them because those are going to be RFP processes. Yeah, the third one is down in the 8128, 8129 box. The developing the admission schedule for the clean heat credit. And we got a question. Yes, Representative Snuff. Thank you. On the last page, well page 40, we're talking about the hiring of people here. There's three employees are going to be hired and the sum of $825,000 is created. And a little further down there are two permanent positions for $900,000. Could you explain why that is so much money for so few people? Sure, because it is a pot of money that so we're talking about multiple pots of money, but they're just from single appropriations. So the first one is $825,000 to the PUC and it's for the three staff members and the three consultants and the marketing public outreach and advertising and then any other costs they need for the rule development. And so one of the costs that came up on the Senate side was the translation services. So I think approximately $300,000 is for the three staff members and then the rest of that is for the three consultants and then all the marketing and outreach as part of the rule development. And then additionally with the public service department, $900,000. So three permanent staff members, they're also going to hire a consultant and then they asked for $500,000 for the potential study. These money is coming from the general fund. Yes. Thank you. So on January 31st, 2024, the entities are going to have to start registering with the PUC if they sell heating fuel in the state. And then on February 15th, the Public Utility Commission is going to have to do their first sort of status report to the General Assembly. And so this is an update on the development of the Queen Heat Standard Rules so far. And so I just want to list some of the things that that report has to include. What page are you on? So I'm on page 37 of the bill as passed by the Senate and so that would be 39 and that's recent track. Yeah, 39. The check back reports. There's one next winter and then the winter after. So this in the check back report, they're going to need to have estimates on the impact of customers, including customer rates, fuel bills for participating in non participating customers, net impacts on total spending on energy for thermal sector end uses, also fuel reductions, emission reductions, and if possible, impact on economic activity and employment with high, medium and low estimated impacts. Additionally, they should report on any need for enforcement or any other aspects they need legislative approval for. So in addition, by next February, they will have hopefully started drafting the rules after they've had all these public hearings. They're also going to have to write this report that has quite a bit of economic modeling and then submit that to the General Assembly. They're also going to have to report back on the funding they're going to need. So the next box that I already sort of mentioned is 8128 and 8129 and so the Public Utility Commission needs to hire a consultant to develop the emissions schedule for the clean heat credits. And so that's all the work that's part of 8128 and 29, which relates to what are the emissions calculations? What's the modeling that's going to be used? First of all, they're going to need to look at the the Greek model or whatever analytical model they choose to go with, then do the analysis to look at the different fuel types that are used and what their emission schedule is. And then also look at the different clean heat measures and what types of how much emissions reductions each of those measures lead to. Additionally, they're going to need to appoint the members of the technical advisory group and then your last draft got rid of the equity advisory group. But if you went with that, those members would also need to be appointed fairly quickly, particularly because the equity advisory group is supposed to be involved in the public outreach during the public meetings. So that one little box is doing a lot of work. There's a lot of other details there, but these these are details that are not necessarily given specific deadlines in the bill because they really are part of the overall development of the whole clean heat standard program. So there's a lot of math involved in this box specifically, but there is also the appointment processes. People are going to need to apply to be on the tag for the equity advisory group and then the PUC is going to need to review those applications and appoint those people. Representative Stebbins. So in this box, the way our most recent bill does not have a point, the equity advisory group would actually give us back to the box just after August 31, 2023. It doesn't have a date where it's talking about a consultant slash facilitator for public engagement, right? Yeah. And so that would probably be a shall instead of depending on where you guys land on this, May versus shall and the public engagement. So yeah, this this timeline that I'm working from is from as it came over from the Senate. Sorry, I just missed what you said. Well, so based off of the Office of Racial Equity, the most recent draft does not have the equity advisory group. Right. And so they said we're through a consultant, which really means that this step is really like box five from the top. Oh, yeah, yeah, representable. Yeah, the timeline, well, first of all, it's strange because the public engagement process was supposed to take place in consultation with the equity advisory group. So it's odd to me that that would have been on the timeline in February 2024 in the first place. Also, the facilitator that may or shall be hired this summer is only a facilitator for the public engagement process and has no further role in consulting with the PUC on any equity related impacts of the clean heat standard. So I feel like that's important to point out that we're just missing an entire process of oversight related to equity on the clean heat standard. Like the equity advisory group was to come back, you know, if they noticed that there were inequitable consequences of the clean heat standard, they were allowed to require the PUC to change, you know, a number of clean heat credits issued or the rates at which clodomodern income hopes were served or whatever. And now that rolls that kind of structure is absent from the bill. Anyhow, but it is strange that the equity advisory group was appointed in February and the consultant is supposed to start doing engagement in August with the oversight of equity advisory group in the original bill. I just find this all strange. So I mean, I'll apologize, because like, you know, I only have so many hours in the day to update my timelines. And I will say that the equity advisory group participating in the public engagement process was one of the last changes that the Senate made. It actually might have, I think it was actually it was actually changed in the Senate appropriations amendment. So originally they weren't. And so that's sorry. So this is a holdover from an earlier version of the bill. Thank you. So you're saying perhaps after the floor amendments that appointment of the equity advisory group would have happened earlier? Yeah. Okay. Thanks. That's fine. Yeah. Yeah. And again, though, there isn't a date certain in the bill. So like working backwards to figure out, you know, when exactly the PUC is going to have to figure out all this themselves. This is really this is really a rough estimate I've done. Information is in the bill. So I think a lot of these things they'll want to try to do sooner rather than later, because this is actually a pretty compressed timeline, because they have to report back to the legislature with the final proposed document in January of 2025, which essentially is like 16 months to give them giving them a total to do all of this work. So the next box also doesn't have a date. And it is not going to happen in February of 2024. So just want to assert that the issues draft rules for public comment. I think February 2020, it's not going to happen in February 2024. That seems, but this is just to indicate that sometime before January 1 2025, we have to issue a draft proposed rules. And there needs to be at least a 30 day comment window on that. So counting backwards, it probably is going to happen in the fall of 2024. But maybe they'll have draft rules earlier than that. I'm not sure. And then also the next So is there any we were to make dates or I say November 1 or any kind of you know, we want to have the PC have as much flexibility as possible, but also want to make sure that things Is that a question? Yeah, is there any so I'm wondering if there's any reason not to make that a date certain? I mean, I'd say yes. I think they're going to have to do a lot of work to get words on the page. They're gonna have to hold all these meetings. They're gonna do a lot of math on the emission schedule. We're gonna have to hire all these people. And then they're going to write the detailed policy rules on the process. So you already do have a very date certain in January of 2025. So you I think my rough estimate is that November probably is when they're going to do it. But I don't know how they how long they think the drafting of the rules is going to take. They didn't included in here in the section six of the bill is language that they requested that they will have at least three opportunities for public comment, which is their rough estimate of how many times they'll have drafts available for the public to review. So I think they're intending to have multiple drafts. But again, I think it's hard to predict right at this moment how many and when they will be released. But these are policy decisions. And so if you do want to have a date certain, I think you could put one in there. But as with most of these things, the more the less flexibility there is more risk that they'll get behind in the process. So you may want to consider that too. Where is the potential study in here? It's not on here. Where would it fit in? Well, actually, did I include it in? Up in July. Sorry, July. Yeah, sorry. So July one. Oh, you talk, you added it verbally just now, I guess, because I did write it down. They would begin the potential study July one, 2023. And they said, pick up to a year. Yes. And I'm still here. And then they would need like a few months to cross like adjust the results. Right. July 2024 is when that. Come back for certain. Okay. Go ahead, Representative Congar. They also talked about having to do the RFP process for somebody to run that to the central study. So if the central study actually takes a year, I don't see why it's back. 24 September one. So I think they said it's gonna take six months to go through the whole process of finding somebody to do the potential study. I heard that right this morning. Great. So and I had no information on the potential study when I drafted this, so I didn't have any way to guess. Yeah, no, no, no, I know, but I didn't have anywhere to guess on this. So yeah, that was the DDA. Okay. But I think it might be a similar point. Yeah. If it takes six to eight weeks to put out an RFP and collect RFPs, and I retired when I was to review them, make a selection contract, negotiation, with state governments like nearly three months. So that was July 15th, September 15th, American's lips in October 2024 for potential study could be done. Another date just to be aware of, this isn't an action item, but January 1, 2025, the carbon intensity scale kicks in. And so the PEC also needs to establish the decrease rate for the acceptable carbon intensity value in January 2025, for the years 2025 to 2030. And then, so then there's the big date, which is January 15, 2025. Oh, and this is, so the PEC has to submit the final proposed rules to the legislature, and the rules cannot take effect until the legislature enacts a bill giving them authority. Additionally, they will also be submitting the another checkback report in here, which I feel like was on the prior draft and it's not here, but they also will be with the rules will be submitting the checkback report, which has, again, the updated financial and economic modeling that's in section six. That's my best work on this one. So where would that one go? Also in January 15, 2025. And say one more time, it's the checkback for, yeah, so it's the report I registered the details on earlier, which is in section six, I, so again, it's the economic and price modeling. So it's all that customer rate impacts, fuel price impacts, emission reduction potential, economic activity employment, so it's all that information as well. And does that include the potential study? Does the potential study inform that? Those, that was a separate issue. There's a lot of overlap. And so maybe potentially it would inform that report, but this, that checkback, the checkback report language was part of last year's age 715, so it predates it in that way. Just remind us again when the potential study was added to this bill. Late in the Senate, like two months ago. So the next box, okay, so let's talk about June 15th again for a minute. So the final rules are going to be submitted to the legislature. And the way that the checkback language reads now is that the PRC can't do anything until there's legislative approval enacted by the General Assembly. So that does mean a constitutionally acceptable enactment, which requires a bill moving through both chambers of the body and being sent to the governor. The governor would then have the option to sign or veto or let become law without his signature and come back to the legislature for veto override. So it will need to be a full legislative bill process. Additionally, you will have the opportunity to review the rules and make changes either directly in the statute, which would then impact the rules or changes can be made by the PUC to the rules before they are approved and sent for final approval to Elkar. So it won't be an up or down vote necessarily on the full rule package. You'll have the ability to impact what the final rule will look like. So that process will probably take the length of a legislative session or close to it. Representative Smith. Thank you. January 15, 2025, there could be a half a dozen different people sitting at this table. That looks to me like it's going to allow maybe two weeks for new people in environment energy to figure out what S5 is. No, no, no. So that's when the PUC has to submit them to the legislature. The legislature doesn't need to do anything. It has its own timeline. So there's no bearing on the legislature and what time they have to act on those rules that they have to be submitted. Okay. I see. Okay. Yeah. And so actually there's a typo in the next one. So I left the June 1, 2025 date, which should actually be struck. So because of the checkback provision, June 1 is no longer accurate. The PUC will not submit the final rules to the Secretary of State and Elkar until the legislature enacts its approval. So I will be submitting a new updated timeline correcting all of my mistakes. Apologies. But June 1 is not when this version of the bill currently says. The bill that came out of Senate natural resources had June 1 as the deadline. But the Senate appropriations amendment changed that. So the rules will come to the General Assembly and they will stay here unless and until you approve them. So if you don't act on them in the 2025 session, they will not go into effect. And have we done that before? No. So they'll stay there until we act on them. So, but you're saying that have to act on them in that biennium? No. No. So it could wait if that legislature doesn't act the next one, but because it's still set. Okay. Yeah. So, but to be clear, these will be rules that we put into statute or would we approve the rules that come to us in a big way and then the rules could then still be changed by rules. Yes. In 2025, there will be multiple options for what happens. There could be a range of different actions that you could take as a General Assembly. The simplest one would potentially just be passing a statement, either a session law provision or something like that. That would say we authorize the PUC to go forward with the rules they've presented. Or you could pass a piece of legislation that says the PUC shall not adopt the rules until they have clarified in the rules that there is a blank on blank. Like if they, if you want to make an assertion about something they need to change, you could do it in the bill. You also could make an amendment to the statute that would directly impact the rules that would require them to make a change. Because any, this proposal still requires them to send the rules to Elkar for a final review after the legislation, after the legislature gives its approval. So there will be another look back by the legislature before the rules are final. Additionally, you could direct the PUC to make changes to the rule to meet legislative intent and then they could, after you pass the approval, then they could file them. Or you could potentially go with codifying them in the green books if that's something you wanted to pursue. And the only example of that is the Fish and Wildlife Rules. So that is a unique structure and that would give the legislature the ability to specifically rewrite or change the rules themselves. If you wanted to do, if in 2025 the legislature wanted to do it themselves, or you could just pass statues that would directly impact the rules. So there are actually a number of options that the legislature could have depending on how many changes you want to make to the rules that the PUC have drafted. I mean, just because it's come up now twice, the Fish and Wildlife Example is, I mean, they still pass additional rules. So when you say that, you mean it's an underlying rule in there that created the board or something and then the board is now enabled to promulgate rules? Yes. So that is a really unique structure that doesn't happen in other places in the state of Vermont. And so, yes, currently the Fish and Wildlife Board has authority to change the rules and the legislature can change the rules themselves. And so if you wanted to do something like that, you could where both the legislature and the PUC would have authority to change the rules. It does get a little complicated. So, you know, when 2025 comes around, we can have that discussion. But I do think it's important to know that there are a couple of different mechanisms that could have, there's a few different routes to get to final proposed rules that are adopted. Yeah, thank you. So if in 2025, the General Assembly allows the rules to be adopted, after the rules are adopted in August 2025, the first, the next report will come out from the PUC describing the rules that have been adopted and steps taken since they have been adopted. And then there will be annual reports thereafter the rules have been adopted. On the next page, the cleaning standard will not go effect until when the legislature's approval dictates. So this is a big one we need to talk about. So I'm going to come back to it in a second. August 31 of every year is when the annual report will come out from the PUC. And then in January 1, 2030, the PUC again has to look at the carbon intensity value and update the decrease on that. But the big one of when the PUC's rules on the need standard go into effect are a big question here. This bill is technically silent on that, although there's a strong suggestion that it would be January of 2026. It doesn't actually say that in this version. In prior versions, it has said that, but it does not say currently when the program will start. And I do think that's at least partially because of the uncertainty associated with the legislative approval. So if things went according to the schedule set here, final rules came out in January 2025. The legislative general assembly took a full session to deliberate and consider the rules and make changes they thought were prudent. They would pass probably in May. There may be some tweaks made to the actual rules and then they would go to Elkar. So the earliest they could probably take effect would be July or August. Maybe June if you moved really fast. But potentially they wouldn't take effect until after that and then the program would start. So it is setting up enough time for it to be tab 2026 be the first year that the program is running fully. But it doesn't say that explicitly. It could be later. It could be a little bit earlier. It could be fall of 2025. But I don't think it could be much earlier than that. So I think there are some big questions in here. My typos aside, my mistakes aside. I have pointed out the dates certain in this bill. I do think there will be a lot of additional work. The PUC is going to have to be keeping track of hiring processes, appointments of members to the tag and getting all the consultants to set up not only the default delivery agent. They're going to need to establish the credit market and the registry and be working on setting the amount of credit reductions or emission reductions needed every year. How many credits that translate to and the price of credits. So there's a pretty significant body of work that needs to take place between this summer and January of 2025. I just have a question. Representative Morris. Thank you Madam Chair. Thank you Ellen for this. This is phenomenal. Don't say that. It was a good try. Okay. Still phenomenal. My question is going to be around and that's going to cover a couple of the costs for the price for the credits, the price for staffing within the subsequent years, etc. But on January 1st, 23 credits can start to be earned. So they're already earning potential. The carbon emission value and pricing for the credits won't be established until January 1st, 2025 when the report comes back. We have the check back date. We'll have the information start the process to approve it on. Back up a half step or one year. The PUC is going to establish potential funding sources by January 15th, by January 15th, 2024. So we're going to have credits earned. We're going by 25. We'll know the price of the credits. We'll know perhaps the potential funding sources. And then if this is implemented and arguably it could be mid 25 or January 1st, 2026. The default delivery agency is going to want to start installing. We haven't got any money. So concerned about how that would be set up. They're going to expect to install these or to be compensated. So that's a little, I struggle with that a little bit. And then we've established the funding sources for three employees for the PUC and what was it? The Department of Public Service for the second one. That's for one year, which is 23 to 24. And then if the plan doesn't roll out until 26, we're going to need additional salaries for 24, 25 and 26. Okay. Yeah. So the potential, sorry, potential is a bad word. Confusing word here because I don't, it's not bad, but the funding source that the PUC is going to identify is going to be a recommendation to the legislature just to enact. And you do think that would primarily cover their individual agency costs, which would be the, those three employees. And then the PUC is going to work to establish the budget for the DDA, which will then lead to figuring out how much credits are going to cost so that they can cover their costs. So there's slightly separate funding issues at play there. Yeah. I think that there are some obvious potential funding sources for the agency. I think there potentially are a couple different ones they could combined, but that will probably be a decision for the legislature. I think the PUC has thoughts on that, but the legislature is probably going to need to or make the affirmative decision that it be general funding, general fund funding. Thank you. Representative Tori. Oh, there's just two representative Morris is concerned about they're not being enough money for any measures to happen. Is that, that you're using? We're setting this program up and there hasn't been any funding identified. Correct. There's all the federal funding, state funding that's already being used. I wonder if maybe you, Helen, would be willing to just walk us through the market just a little bit about what, where the money comes into play in the market. Like it's it's not necessarily clean heat measures that are being done by the obligated parties. It's one payment. Could you clarify a little bit about how the money works in the market? Sure. So this is going to be a new market. So some of it is still a little vague. But anyone who takes an eligible action under this bill, which would be primarily the installation or weatherization work to a building that meets the definition of clean heat measures, could be eligible for a credit. Additionally, there will also be credits specifically for work done on homes occupied by customers with low income and moderate income. So there will be a few different types of credits that will be generated based on the income of the building type based on the resident of the building. The obligated parties have a need to retire credits so they have an interest that's creating a demand for these things. And so they will be seeking to purchase those credits from people who generated them, which could include contractors or other people who are already doing this work generally in their everyday business life, which is why you have early action credits. So in these first couple of years before the program actually goes live, people who are already doing this work, whether it's funded by a homeowner or subsidized by Efficiency Vermont or one of the federal, regardless of who's funding it, if the work is done in Vermont, it can generate credits. And so these will go on to the market, which will have this pool so that obligated parties will have options of credits to purchase in order to comply. At the moment, the economics of this haven't been borne out by some of the details yet, but it's still an open question about what the price per credit will be. It will relate to the amount of carbon dioxide equivalent emissions reductions the action leads to. Every obligated party will need to have a certain amount of these credits, so they will be worth something to those obligated parties. It's unclear at the moment how much they will be paying for those credits. So it is unclear at the moment exactly how much each credit is going to cost. How did I do? I was in circles there a little bit, but... I think we also heard it from the Korean, she was talking about organs market and the fact that it's these transactions between those market actors. It's not like a fund that's collecting a lot of money. I think there will be some of that when the DDA gets into the picture with those that choose to just write a check for the DDA, but there's all this other activity between those market actors, buyers and sellers, that's not going to end up in some pot. I thought I'd just clarify that because I was having a little trouble kind of thinking through market itself. There is a graphic that Energy Action Network has that shows it's a graphical presentation of the market. Any more questions for Ellen? Thank you. This was really helpful. I look forward to your changes, but it is really a good timeline, so thank you. I just feel like two weeks ago, on March 22nd, I may have been sleep deprived. Well, and the bill was in motion significantly. Yes. Yeah, we understand. I'm actually doing it a little real time. Probably helps us catch up to good sign. Great numbers. Let's take a 10 minute break and come back at five. Great. So we're reconvening our meeting and continuing our discussion of S5, and we have with us Allison Despathy from Dando. Thank you so much. My name is Allison Despathy, and thank you, Chair Sheldon, for allowing me the opportunity to be here today. First, I just wanted to start. There were two pieces. One, I want to thank you all so much. I watched most of the testimony, most all of it from last year and also in the Senate, and I just wanted to say to you all that you really have a loud, robust, honest, effective conversation in my opinion that I wanted to share compared to what I saw in the Senate, and I just appreciate that that's happening here. It's very important to the process, so I wanted to point that out. And the other thing, before I sort of dive in, I guess it's also part of it here, I came into my concerns around this because as you, I'm sure, all you're here because you care for people and you care for the environment, you're tasked with a really difficult job right now. You're trying to find a solution that serves both, and that is, and I appreciate that, and I thank you for doing the work on it. So the reason I came into this legislation and was really sort of concerned about it was because of I'm a nutritionist, so I've been sort of fighting GMOs for a long time and I had issues around the biofuel piece that wasn't dealt with at all last year. There are some steps in it, or in it now that obviously make it a little bit better with sort of phasing out, but I still have a lot of concerns around that. The other piece is the carbon credit system. So the clean heat standard, which is really what the bill is, and the clean heat standard equates to the carbon, a carbon equivalent, which was defined and established in the Kyoto Protocol out of the United Nations. And so all of my research in the past decades, and I won't go through all of it, but so basically Bill Draper in the 1970s came up with through the EPA. He worked for McKinsey before. He came up with emissions trading. We're going to do emissions trading. And then essentially for decades, really through the 90s a lot, they were like, what is carbon? Is carbon a commodity? It's a currency? What is it? So they were really starting to try to establish carbon on the market. And so the question is, is working with a clean heat standard carbon equivalent going to serve Vermont? And so the people and the environment, is that our best performance standard? Is that the way we can do it for the environment and for the people? Is it possible? And every single way I've tried to work my head around this is I cannot see how this would actually happen. Is this the way to fund the system on the plan? And I just want to also sort of preface that there's two big issues. There's massive fraud in carbon markets and carbon trading. There's tons of greenwashing that goes on. The nature conservancy is responsible for it. They are basically middlemen right now. They have been called out by Bloomberg 2020. There's been big conversations about they are essentially saying, here's this protected land. It's already protected. We're going to buy the carbon offset. So we're going to sell them to Disney, BlackRock, JP Morgan. They're doing it here in Vermont as well right now. So I think we also have to be careful of the history with the carbon market and how that's going to play into Vermont doing that. So that's what sort of brought me into this. I have three concerns. I'm just going to read so I can get it straight. And if I go too fast, just ask me to slow down. I tend to talk fast. I'm sorry. So there was a recent public records request that was made to the PUC and the DPS regarding documents related to the Clean Heat Standard Design Group, also known as the Clean Heat Working Group. The PUC provided the request documents, requested documents just this week. It's clearly evident for anyone who's been watching the Climate Council and Subcommittee meetings that the Clean Heat Standard Design Group had conversations about the development and use of the Clean Heat Standard, the carbon credit equivalent prior to the initial Climate Council meetings. This is concerning for many who've been watching closely and wondering why and how we ended up with the Clean Heat Standard as the answer with no formal transparent analysis, conversation, or debate regarding this option within the Climate Council itself. I have enclosed the public records in my testimony, which I will submit so you can all take a look at this. I encourage and hope that you can go through them. They're insightful. They might offer guidance for best action and potential amendments. Based on the documents and timeline provided, conversation around determining an option and discussions about whether they should go with an allowance or standard happened in this separate group outside the Climate Council. The standard was decided within this group and then presented to the Climate Council as the path. It was unofficially adopted and there's no record regarding any robust analysis and conversation within the Council on the Clean Heat Standard. It does not appear that the private meetings were shared with the Climate Council either. There was a white paper submitted to the legislator from these meetings. However, it does not appear that this was discussed with the Climate Council either. Yesterday, Charity Clark sat here and she discussed her support of the implementation of the Clean Heat Standard as part of the Climate Action Plan. She described that it was a well considered policy by the Climate Council. However, acknowledging that the Clean Heat Standard did not develop within the Climate Council and originated outside of the Council is relevant and deserves scrutiny, in my opinion. In this Clean Heat Standard group that met outside the Council, Tom Nour of the PUC, Don Rendell, Neil Lunderville, Tom Murray of EGS, Richard Cowart, Jared DeVall and others were involved in these meetings of the Clean Heat Working Group. This legislation presents the PUC as an independent body, tasked with creating rules and establishing this program, but it's clear that Tom Nour of the PUC was on this Clean Heat Working Group. I fully understand the need for those knowledgeable in these areas to gather brainstorm, but the different options were not then presented to the Climate Council of, hey, here's what we come up with. Here's some ideas. Let's go through this and decide what's going to work best for Vermont. None of this deliberation and decision-making seems to have been shared with the Climate Council in meetings. This is relevant. Like I said, I attached to what the Climate Council have supported the Clean Heat Standard choice if given the options. At this point, we do not know. Due to the situation and the questions and concerns of surfaces, what many want to see is that the history of the development of the Clean Heat Standard become part of the discussion at the legislature this session. What many Vermonters want more than put to any particular outcomes is an honest and transparent process which, based on these public records, appears to be compromised. There's several meaningful quotes that came from the meeting minutes. From December 15, 2020, Don Rendell of VGS, VGS has not yet seen reduction in fuel sales and service territory due to heat pump installations. Specifically, fuel use was not significantly reduced in VGS territory among those customers that received efficiency Vermont rebates for heat pumps. March 9, 2021, Tom Murray of VGS, quote, people who got heat pumps a few years ago have had no decrease in gas use, using mostly for air conditioning. They put a single-head system in a house that would need multiple heads. We would like to help to get heat pumps out there, end quote. In my opinion, these warrant that legislator or PUC request to see the data from VGS regarding the clean heat pumps and their ability to reduce fossil fuel use. In other words, are these worthy as eligible measures in reducing carbon emissions and how they are currently working? Also, obviously, this is going to vary on can you get the right system put in the house? Who's the installer? Are they trustworthy? Do they know what they're doing? What's going on right now? It's going to cause a flood of installers. Are they going to do a correct job who's monitoring, regulating, overseeing that process? My second key piece is Dennis Percy of Fred's Energy. He was just here the other week. You guys heard him. He was also in the Senate. Him and other fuel dealers have specifically requested in both the Senate and the House that a high efficiency heating system that reduces fossil fuel consumption by 50% should be counted as an eligible measure. This is the direct, clear, easy, measurable reduction in carbon emissions. This absolutely should be considered. The reason also, the reason many people have said this shouldn't be considered is because it locks someone into fossil fuel for 20 years. However, I want to point out it's so important to recognize at this time the existing language in the bill regarding renewable gas enables Vermont gas systems to continue to flow frack gas, fossil fuel gas, fossil gas into Vermont until 2050. I understand that VHS has tremendous amount of money invested in the pipeline. And if they will be continuing to move this fossil gas through the pipeline until 2050, that it only makes sense and is equitable about fuel dealers. It's also being able to have the installation of high efficiency heating systems offering immediate and local reductions count as an eligible measure. This can be revisited and removed at any point. I heard Ellen talk about this yesterday. Any eligible measure can be taken off, put on, et cetera, et cetera. So VGS is going to be able to continue to move fossil gas, frack gas through their systems until 2050. Shouldn't an installer be able to put a high efficiency system in that has massive reductions in fossil fuel and will help the people as well as help the fuel dealers to sort of get in on this. Because right now the fuel dealers are limited to using biofuels, but not getting any credit for the known easily measurable reductions with replacing old systems with high efficiency new systems. And I know yesterday you had asked, are we taking any sort of considerations or amendments from the fossil fuel dealers as we had were taken from efficiency, Vermont and equity office, et cetera. And so I think this would be one to consider. So by allowing high efficient fossil fuel systems, the fuel dealers are offered the opportunity to significantly help reduce carbon emissions, even by 50% or more in some instances. So this obviously as technology evolves, this can be taken out. But right now heat pumps unless you have a tremendous amount of money are supplemental systems. And so there are many people I live in the Northeast Kingdom. There's so much poverty. There's a lot of people that absolutely they're they're living day to day, they're not going to be able to take on a supplemental system. And I know there's you know, the wood systems that can be considered that that's not going to be an answer for everybody. And if these are cutting, I mean, you heard the fossil fuel dealers, I don't want to be repetitive. They are significantly cutting carbon emissions, which plays into the GW essay, the goals of the global warming solutions. So with this in mind, my request, one of my requests is please consider striking from the bill on page seven, section h123, under definitions number three, clean heat measures, quote, it says clean heat measures shall not include switching from one fossil fuel use to another fossil fuel use. I think this could be really clarified where you could have this potentially be an eligible measure if it reduced carbon emissions by a certain percentage. And I'm sure all of those metrics are known by the fossil fuel dealers, and otherwise that you could look at independently, obviously. Further support of this consideration to allow high efficiency fossil fuel systems is the fact that biomass and biofuels are considered acceptable, both of which are more carbon intensive and create more emissions based on full life cycle analysis metrics compared to fossil fuel. So with out this amendment, this legislation greatly favors Vermont gas systems and is highly inequitable to the fuel dealers who have the capacity to make immediate and significant reductions in carbon emissions with this as an eligible measure with these efficient systems as an eligible measure. So I had those pieces that I wanted to convey, and I will send all of the paperwork in the public records. I'm sorry. Are there any questions? I had one last piece, but it looked like there was maybe a question. Sorry. Okay. Sorry. So say thank you. Oh, okay. Okay. Sorry. Oh, yes. Do I have one or two more minutes? You're right at the time, but go ahead. Okay. Okay. I'm sorry. Thank you. My very last thing that I wanted to, and this is just dear to my heart because it's about the ethics, and it's just something that I know may not be relevant to you at this moment, but just moving forward with the electrification of Vermont is thinking about the copper mining that goes on and the mineral mining. And if you've ever, I will send it to you all if you have a moment, but in South America right now, it's hideous what's happening in Chile with Codelco, the largest copper mining plant in the world, and they are totally poisoning the water and the air of these people, and they have the highest rates of cancer, excuse me. And it is something that I think Vermont, because we are good people and we do care and need to keep in mind as we move forward with electrification, because as you all know, copper is what is going to enable this to happen, and we're not doing it right in any place in the world right now. So, sorry. So any other questions or any questions? Thank you. All right. Thank you so much. Thanks. Next up, we have Driscoll in the room. What's coming into the room? Thanks for the opportunity to talk to you folks today. I'm William Driscoll with Associated Industries of Vermont. We'd like to recommend you with regard to S5. I think you should have them. I think they're on the website, so hopefully you have them electronically. They're up under your name. And so I had originally drafted these to the Senate passed version of the bill, so I changed them to work with the draft from yesterday. Hopefully I didn't miss anything in trying to make the adjustments, but that was what we did. And these amendments were worked on. We worked with, in addition to Associated Industries of Vermont, we were focused on manufacturing. We worked with the State Chamber, the Lake Shant Plain Chamber, Associate General Contractors. So this is sort of our brainstorming of some suggestions to make. We also checked in and consulted with Global and with the fuel dealers. We've run these by Vermont Gas as well. So that's sort of the context of them coming here before you. And basically, there are two main concerns for us and the other business organizations that are weighing in. And they're both closely related, but they both basically deal with the fact that process fuel for machinery and equipment is going to be included basically in the fuel that the credits are going to be required for, and therefore there's going to be the potential for cost increases in those areas. And we have concerns that unlike actual space heating, not only just residential, but even commercial and industrial space heating, where I think it's hard to say, there's quite a few opportunities to either invest in efficiency or fuel switching or other sort of things to achieve sort of the emission reductions that this program is trying to pursue, we're concerned that there's less opportunity to do that with processing applications. Not that there are no possibilities, but I think it's tougher to be able to identify and implement the kind of measures that can help mitigate the cost impacts that could flow. So we want to ensure by sort of going through the bill and inserting some of these amendments that we have for you that whatever help can be done or whatever projects can be done on the processing side, get the attention and support that they would need. We would have concern that with the low hanging fruit of other projects, other actual heating projects, the processing side might get neglected or left behind, and we just want to try to avoid that. So we're not paying that cost, but not getting the benefit of these programs. So that's what the lead started. And then the other major issues is again, that question of what is this going to do to the cost of fuel? Obviously that's a very contentious topic. We may not really have a firm idea what that cost increase might be, but it could be significant. It could be meaningful to businesses, particularly ones that are dependent on fuel for processing. So we also want to make sure that there were elements in this bill that definitely take a very proactive focus on monitoring what those costs might be and thinking and acting on measures that might help mitigate them if possible. So those are the two main issues set at the background for these proposals, and I'd be happy just to walk through them and see if folks have any questions. So the first one, and this might be maybe the most substantive change in terms of policy, but on page 5, line 1, basically our concern is with the provision that prohibits a qualifying project from switching from one fossil fuel to another fossil fuel. Now there are very particular reasons why that's a concern for commercial industrial customers, but I think arguably it raises some questions for all customers broadly, which is why we have sort of two options. One that would just simply preserve the opportunity to switch from one fossil fuel to another for commercial industrial customers, and then one that would allow that for everybody. And what's important here is a number of manufacturers over the years recently have worked hard to switch from oil to propane natural gas that certainly has financial benefits, but it also it is a reduction in emissions. It may not be as extreme as electrification, but it is a positive step forward. And given that we are concerned about how many viable options there may be to pursue credit worthy projects in the processing sphere, we would want to hold on to this as an option. We would want to be able to have the ability to have companies move from oil to gas, which is probably going to be much more viable across many more scenarios than trying to electrify. So we would argue for that. It's also I think some practical questions and maybe this is something that you folks have already discussed and there's an answer, so I apologize if that's the case. But the bill here allows for efficiency measures as allowable clean heat projects. And I think that this language raises the question, please in my mind. Let's say you're going to do an efficiency project right so you're going to see you want to switch out a boiler and you could switch out a less efficient boiler for a more efficient boiler. If the new boiler, if the first boiler is oil and the new boiler is oil, fine. But if your new more efficient boiler is propane, does this language actually prohibit that as an efficiency measure? So I was trying to think through what the consequences are of this language here. I know you want me to not take too long, so I'll just leave that and be happy to talk that through more if folks want. So the next change, page 19, line 16. And this is again getting back to we want to make sure that that processing projects don't fall through the cracks. They could be much more challenging, it could take a lot more sort of thinking and strategizing about how to make that sector work. So we just wanted to include commercial industrial process fuel use and customers among those specific programs that the default delivery agent would have to have to work have to work on for sure. And please stop me if you want. These are fairly simple or straightforward things. Similarly, along this theme, looking through the list of specified or called out, just that would qualify on page 23, starting on line eight. I think several of these I think could be applied to the kind of projects that we're interested in. But where I think some more specificity was required is process fuel efficiency improvements, just to avoid confusion with the thermal efficiency movements that are listed up higher list. And now I think we're getting more into the cost concerns. So in looking through the bill, I was trying to, we were trying to make recommendations to kind of fit in and parallel to or similar to other provisions. And originally looking at the review of consequences on page, I have page 24. I don't know if that's still correct or not. It's H. And the existing bill as it's drafted has a review of consequences. And when you look through that list, they're essentially environmental consequences. And just sort of monitoring those and then taking steps might be required if there are harms to deal with. I originally, we were originally trying to put customer costs and economic impacts into that section, which I think is fair to say wasn't really a great fit. So what we did is simply created another section that's very similarly designed. And it's just simply dedicated to addressing customer costs and other economic. And because we were calling it out as an economic consequences section, I added environmental to the original section just to make clear that those are the two areas that those sections will be looking at. And then the last major thing or lengthy section is, as you know, there's language. There was originally a advisory group, but now there's language in the public outreach section about looking at equity issues. We would like to see a similar focus on sort of the economic and process fuel issues that we have concerns about. So basically, we're just suggesting adding in on page 35 by night 18, those list of things to try to work and help and help in the development of the program on. I condensed two of them, but basically as three points, they're very similar to one is they're in there already about equity and just have that encompass the economic and the processing issues that we have concerns about. And then finally, maybe the least significant one is because of our interest in having these topics on a higher profile and being doubled directly. We've felt that the check back reports ought to also go to commerce and ways and means. And I neglected to include economic development in the Senate. That would probably also make sense about this. So that's what we have for recommendations. I will say that we do support the idea of having some sort of authority for the commission to look at price caps. I don't have language on that. I think another party may be coming to you with language that would address that. So I'll just leave that for that possibility. One thing I will flag in talking to Vermont gas, they raised a concern about the term process fuel in here because that can encompass my understanding of their concern is that can encompass a number of non number of things beyond simply oil and gas. I don't know if that really would complicate or make a problem in this bill, but I would just simply say that if that to the extent that that might be a concern that folks want to address, I would estimate that that's very easy to do. So in the definition section, just make sure we're talking about, you know, basically talking about oil and gas for processing fuels for the purposes of this bill in these sections. Thank you for your testimony. Members have questions. Is that a civilian? Just one. Well, thank you for these. Thank you for coordinating with other groups. I just want to make sure that your groups are clear that there's no ban on fossil to fossil in the bill. So fossil to fossil would not be an eligible. Right, but it's still so there just wouldn't be a credit for it, but it's still possible to go to a cheaper or more efficient. Yes. Yes. And what our concern about is that it wouldn't qualify for the credits, therefore it wouldn't be able to go toward mitigating costs. But more efficient would use less fuel. Yes, but we also wanted to address the impact of the credit system. Thank you. Thank you. Thanks. Others questions? All right. Thank you. Sure. Thank you. Yeah, we have been at really well. Welcome. Thank you. Thank you for having me today for the record. My name is Ben. I'm Julie Walsh. I run the climate and energy program with deeper. It's my first time in this new V constituted committee, though I know some of my colleagues have spent a lot of time here and you've done a lot of great work on other issues that deeper works on. So thank you for that. Recognizing our time is short. I wanted to just talk at a high level today about the benefits of a need for an affordable heat act, get into a few key principles that deeper has had through a last session in this legislative session. As we've considered the bill and provisions in it and finally cover some key improvements from a 715 from last year and why we see them as so important. So passing and implementing an affordable heat act from our perspective is a critical step as we strive to move the state away from polluting price volatile fossil fuels. I want to be very clear that we are not on track today to hit our legal requirements under the global warming solutions act. We are not on track today to get the substantial portion of Vermonters off of this price roller coaster that they're on right now with most fossil fuels and that's a real problem from a climate standpoint from an equity standpoint. So the elements I want to say of this bill, some of them can I think accurately be described as complex at its core. This is a very simple idea and it's not a new idea. This is actually something that Vermont is already doing in other areas essentially saying as we do in the electric sector for instance this set of companies, so energy companies are responsible for helping their customers reduce their energy use, reduce their fuel bills and reduce the climate pollution coming from the energy that they use. That's something that we have in the electric sector under tier three and this bill essentially extends that concept to fossil fuel importers in the heating sector. So this is not something that is brand new in Vermont it is something that we would be applying to a new sector and a new set of companies and you know frankly a set of companies that have been selling these fossil fuels for many decades with no responsibility to help their customers reduce their fuel use, their carbon pollution or their fuel bills. So from our perspective you know this is a step that we should have perhaps taken a while ago but if we take it now we still have a real you know we can still hit our 2030 requirements or 2050 requirements and you know really importantly have some enormous equity benefits for Vermonters. In terms of the principles that I wanted to touch on you know any policy like this from our perspective would need to ensure that we get to our legal requirements under the Solutions Act this policy does that. It would need to do so on a life cycle basis and taking into account not just the pollution created when you combust or use a fuel or a measure in Vermont but the full pollution carbon pollution created from the you know initial creation of that fuel all the way through its transportation to Vermont and its combustion in Vermont and that is required under this bill so every fuel biofuels biomass hydrogen uh the fossil fuels everything in the thermal sector would need to be assessed on that life cycle basis and we would need to hit our requirements on the basis of the greenhouse gas inventory we have in Vermont and on a life cycle basis that is true across the board under that bit this bill and that's a really key principle for us. It also needs to be something that drives affordability and equity it needs to be something that is implementable on the ground given the reality of a burial building stock and hundreds of thousands of pieces of fossil fuel equipment we already have in people's basements and utility closets and it needs to be one that while from our perspective it is important to have some what I would consider less bad options it needs to have clear guardrails and limits in place for those options so that we do not become overly reliant on them as we are trying to transition to a you know truly different more affordable heating sector. So I wanted to spend just a couple minutes talking about a few key improvements from age 715 of last year that we're very supportive of that really speak to those principles and then I want to make sure I leave a couple minutes at the end if you have any questions for me. Number one the declining carbon intensity threshold that is a very important piece of this bill for us that really speaks to those guardrails that would from day one not allow the sort of dirtiest options in some of the sector you know some of the fuels that are eligible under here like biofuels into the program and would require those fuels over time to become cleaner and cleaner to be eligible to be used at all under the program that from our perspective is important it would leave options on the table but it would make sure that they are they are the better versions of those options. Number two the lifecycle assessment is much clearer and more transparent and I would argue stronger than last year's version there are things like like fugitive methane emissions that were not called out in the text of last year's bill that are very clearly in the text of this bill and any life cycle assessment should take those things loss of carbon sequestration fugitive methane into account this bill in black and white in the bill does not leave any ambiguity as to whether those things will be covered the PUC is required to account for them under this bill and that again from our perspective it was a big improvement from an equity and affordability standpoint the addition of the requirement for eligible measures that half of the substantial amount of clean heat measures being delivered to low and moderate income for monitors need to be installed measures that reduce their energy costs over time that is again a new feature of the bill this year and that is a very important element from an equity standpoint for us that's going to get more weatherization more heat pumps more measures that are reducing the energy burden for low and moderate income for monitors out in the world the last point that I want to make is we have a moment right now because of the inflation reduction act that passed last year at the federal level and the very substantial tax credits that are available to Vermont businesses in Vermont families under that bill we have an incredible opportunity if we pass something like this now and get it stood up quickly we can take advantage of literally hundreds of millions of dollars of federal money through those tax credits those tax credits only will exist for about 10 years so if we wait around and do something like this five years from now six years from now we are going to have very little opportunity to take advantage of those federal dollars but another way if this is done soon the federal government is going to foot the bill for a really big portion of this transition if we wait a while the federal government is not going to be there with that assistance absent additional credit congressional action and we are not banking on additional congressional action as much as we would like to see it so that is my testimony for today again we are strong supporters of this construct think that it has improved substantially since it was initially conceived of at least legislatively in energy and technology the beginning of last legislative session and believe that we need to do so now both based on our state requirements and the opportunity that the federal inflation reduction act provides us to really move from on a better direction and provide Vermont families you know insulation from the fuel prices that they've seen of late representative thank you for your testimony representative Sadkowitz now can you talk more about the relationship between the federal money and this and this program and how this program in particular will allow us to draw down more than what it was absolutely so there are you know broadly speaking sort of two or three buckets of federal money through the inflation reduction act that are relevant to this bill there are two pots of about 30 million dollars that are coming regardless they're just this is formula grants that all of the states are getting a portion of so Vermont's going to get about 60 million dollars in money for direct rebates that'll be administered by the state that's probably going to start going out the door in 2024 that is not affected by this bill that much money is going to go to low and moderate to Vermont families regardless the piece that is affected by whether or not this bill passes are the substantial tax credits that are available for individual households there are tax credits of 30% it's a little complicated there are some you know caps on specific types you know up to 2000 for a heat pump up to you know different dollar figures for different technologies but essentially for just about everything eligible under this bill there would be a 30% tax credit that a Vermont family could take advantage of there are also tax credits for businesses they're structured a little bit differently but they're also very generous if you meet the prevailing wage requirements and again are eligible you know for essentially everything that's part of this bill I do want to note that unfortunately the way the inflation reduction act was structured those are all tax credits they're not refundable tax credits so low and moderate income for monitors don't have access to those same tax credits that's unfortunate it's something that I think the state is not a lot to ameliorate with state funding over the last couple of years to the tune of about 150 million dollars for low and moderate income incentives in this space but you know we would love to see you know federal money that's more available to low and moderate income for monitors absent that something like this that has a very strong requirement to provide benefits to low and moderate income for monitors is really important from our perspective I guess I still understand how that money which you're saying would really only be available to folks who have enough income to have taxes that could be offset how this bill allows them to make better use of so this bill at its core is going to require the creation of new incentives in Vermont through the clean heat standard from the obligated parties the fossil fuel importers because there will be additional incentives in Vermont that are adequate to you know get enough of this activity done in Vermont in order to actually hit our requirements with more Vermonters installing heat pumps whether rising their homes and doing all the other things envisioned in this construct more Vermonters will be able to take advantage of those tax credits essentially more Vermonters doing those things means more of that money is going to flow into the state if you look at you know what's been modeled as business as usual like what happens if we don't do this versus the requirements in this bill through the global warming solutions act and you add up all of the activity the heat pumps and everything else that would need to happen because of that you're looking at a couple hundred million dollars more in tax credits that would float of Vermont businesses and families because of that activity so essentially it gets more in the door because it requires more activity and there will be more incentives in Vermont so I'm just trying to look out from the perspective of like a particular family you know without a particular income that would qualify them to get tax credits but I see tell me if I'm wrong or I'm sort of seeing I'm thinking you're implying is that at least some of those taxpayers would not take advantage of the tax credits that are available to them except for the additional incentives that are in this bill that's going to push substantial large numbers but I think I'm hearing the push large numbers of people from doing from basically letting the those tax credits pass them by to saying oh if I can do get this tax credit and I can get this other piece of incentive then I would be willing to make this investment that's that's exactly right that's very well put yeah essentially there will be families that look at the federal tax credits and other incentives currently available in Vermont and go we can't quite make that work but then with this additional incentive the additional incentives created under this program to look at it again and say oh actually we can make that work now and then they will be able to avail themselves of the federal tax credit in addition to the incentives provided through the clean heat standard so yes you articulated it very well all right representative Clifford thank you man chair thank you for your attention so say if someone uh someone wanted to take advantage of the tax credit system what's the avenue for that how what organization would go through I need to yeah so essentially when you're installing anything like this the installer is going to be familiar with that they're going to let you know hey there's a federal tax credit for this the tax credits are structured generally I can't speak to every single one of them but I know the residential ones are ones where you would have to you know purchase the equipment get it installed and then next year a tax time you would say hey I installed this thing here's so much of cost and you'd get 30 back up to the cap for the particular technology it's just like you know for instance if you buy an ev there's a 7500 dollar tax credit you file on your taxes next year you said hey I bought this ev here's what it is and then you get 7500 dollars taken off of your taxes it's the same thing but just for different measures installers obligated to give this information to the customer there I don't believe there's any federal requirement to inform people of the tax credits but I would be very surprised if installers are not because it is makes it that much more likely that people okay thank you somebody didn't tell you about the tax credit or no they they did because it was in their interest oh yes because then I I said okay I'll buy what you'll buy your boiler all right representative Smith thank you uh these incentives people aren't going to know how much of an incentive they're going to get if well say for example I've got a 30 year old oil burning furnace right now if I was to replace that it would be the least expensive route for me to take I could replace it for probably 1200 dollars I do the work myself I won't get any incentive for replacing an oil furnace with an oil burner will I that's right okay that's unfair but that's okay I'm wondering you get a family so living in a hundred year old house like my own if they decide that they want to go with a heat pump and the heat pump that someone comes and looks at Fred's energy will go and look at their house and tell them well with everything that you need to do with the wiring exchange everything it's going to run you probably $10 or $12,000 to do it correctly do they know how much of an incentive they're going to get they once this is implemented yes they would you know by the the installer or the default delivery agent whoever they're working with would have to provide them that information and they would be in their interest to provide them that information because they would be have a legal obligation to achieve a certain amount of activity okay so they would create it sorry go ahead if this is a low-income family say a family of four with making 42 or $43,000 a year do you have an idea is this incentive of a $12,000 heat pump system going to be 10,000 or is it going to be 1500 or 2500 as if it's $2,500 this four families not going to be able to afford to kick in 10 grand of their own money or eight grand agreed my answer to that would be the incentives will have to be adequate to generate the amount of activity that the bill requires and so it would actually require very substantial incentives for low the lowest income for monitors and more substantial but not you know quite as high for moderate income for monitors I'd also you know I'll leave it there okay one last one why wouldn't why wouldn't V per look at incentives for someone my oil burning furnace right now I clean it every year it's fairly efficient I think if I put a new oil burner in it's probably going to be twice as efficient as this old old dinosaur I've got my basement right now so why wouldn't why wouldn't that be supported by if I'm looking at trying to conserve energy by putting a better burner in so I guess I'd have two answers to that the reason that we don't support incentives for that kind of activity is you know if you're looking to lifespan of that furnace is probably going to be an operation past 2050 and as we have these requirements in 2050 both from the standpoint of climate science and the pollution reductions we need to achieve and legal requirements as a state from our perspective it does not make sense for the state to actively encourage people to install equipment that we know will need to be phased out in order to meet those requirements now that does not include anyone from doing that as you say um and I you know I do want to know one other thing the sort of second answer for that is if you have a furnace that is 20 or 30 years old i.e old enough for it to need a replacement any new furnace is going to be dramatically more efficient than that and the marginal efficiency over the sort of the energy standard versus the energy star level is relatively small so if you get a new furnace you're going to be cutting your energy use but we would like to see is more incentives for you to have say a heat pump to supplement that so you can use that furnace less thank you thank you thank you thanks again for your testimony my pleasure thank you very much for the opportunity next we have anthony arepino conservation foundation good afternoon and for the record yes anthony arepino from the montpellier advocacy center of the monta conservation law foundation it's nice to follow ben because he has basically covered a lot of the same ground as i covered and i just want to call your attention to the fact that i have fully written comments that have been submitted to the record so i'm going to be cutting back on a lot and i would hope that you can look at the written comments for the full extent of clf's position on the record um so on behalf of um its members clf has advocated across new england for adoption and ongoing implementation of enforceable greenhouse gas reductions and um that includes the global warming solutions act i'm here today to urge that vermont lawmakers take another important and meaningful step on the path toward lowering our greenhouse gas emissions and complying with our obligations under the global warming solutions act um the pollution reduction deadlines in the global warming solution act are not arbitrary um some have said that and i couldn't uh disagree more there are a rational and arguably long overdue response to the catastrophic signals that our climate is sending us as extreme weather in vermont and the world increases water pollution disease property damage and economic disruption the latest report of the world's leading climate scientists affirms that we must make dramatic greenhouse gas pollution cuts by the mid 2030s to stabilize the climate on on which our safety our health and our happiness ultimately depend and i've cited to that latest report my testimony you know i was in the predecessor of this committee um 17 years ago that's the first time i came here to talk about climate change and it was in the context of lake champlain and how our then existing cleanup plan failed to account for the fact the climate change was going to make pollution to the lake worse and we needed to update that plan now because if we waited it would cost us more money in the long run unfortunately back then it took uh a long time for the legislature to get to that conclusion um and more pollution flowed into lake and it ultimately cost more um to address that pollution so really thinking to myself sitting here today how much easier and less expensive would this all have been if we started down the path that you're on today 17 years ago and i really say that as a response to those people who say you need to wait you can kick the can down the road even further it's a mistake that we've made in our past and i hope it's one that we won't repeat we just don't have time to use the affordable heat act is responsive to and has undergone substantial public process you well i don't need to tell you all that you've been sitting here for a couple of weeks i've been mostly listening on youtube and appreciating your thoughtful questions and the wide variety of people that you've heard from i know this is the second go around for the legislature with this bill now while the need for climate action becomes more and more urgent each day another response to those who say we need more public process is to recognize that the affordable heat act as you're now considering it reflects a measured and thoughtful approach to accelerating and codifying the ongoing transition toward cleaner more price stable heating measures for our homes and businesses you've got a significant phase in period of this bill it won't take effect until 2026 at the earliest following a subsequent legislative review and approval process immediate passage of the affordable heat act will send an important signal to the marketplace encouraging more vermonters to join the climate friendly workforce of the future and allowing time to train those workers to hit the ground running 2016 now some of you may know that clf's position on a clean heat standard for vermont has evolved since last year and that's in large part because the legislative process has been genuinely responsive to some of the significant concerns we had with last year's bill i'll just highlight those been covered a lot of those but chief among them is limiting and phasing down the use of biofuels that would not truly reduce greenhouse gas emissions and other environmental and public health farms um expressly promoting effective pollution reducing strategies weatherization electrification and ensuring that a meaningful percentage of those measures are installed in homes for low and moderate income vermont households and then strengthening greenhouse gas accounting to make sure that we're accurately tracking progress toward the pollution reduction requirements of the world warming solutions act um can't stress enough that the new bill's declining cap on carbon intensity of biofuels eligible for clean heat credits is a central reason why clf is now able to support the affordable heat act uh there's been a lot of work on life cycle in uh greenhouse gas accounting i know you've heard from other experts on that topic um and i can tell you that the language that has been inserted into this bill compared to last session's clean heat standard uh are really strong guardrails um and if they are faithfully implemented as you've written them in the law by the puc i think we are going to see um over time that only the cleanest uh of alternative fuels that truly get us pollution reductions will be eligible for clean heat credits over the long term um i know you heard this morning from folks who work in um the uh with low income vermonters and in the housing sector some of those folks i also work for in other facets of my practice um and i just echo what ben said about the importance of the equity measures that you've adopted this year this is a much stronger bill in terms of addressing the needs of low and moderate income vermonters um you know the reality is it's not just vermonters with more financial needs means who want to be able to keep their houses warm without contributing to the warming of the planet that uh threatens their families so um i know you heard extensive testimony on that i know uh you're also asking questions about um the federal funding i do have a link in my written testimony to uh an explainer about some of the federal funding programs and i do also want to point out because i echo everything ben just said but even the money that's already coming to vermont should be something you think about in relation to this bill and your concerns for its effects on low and moderate income vermonters because in addition to the tax credits which leave some vermonters behind there are powerful rebates that you can claim and that money is going to hit streets and that means that even if there are increases in the cost of fossil fuels as a result of passing the affordable heat act that federal money is going to in the meantime help a lot of vermonters get off the price roller coaster and be less exposed to any price increases that come as a result of passing the affordable heat act but as currently drafted s5 also includes an important relief valve that allows the public service for good cause which includes unduly adverse impacts to low income vermonters and to small businesses but it includes the authority for the pc and i understand you're you're thinking of extending the amount of time that the pc can exercise this authority but to basically say we're going to back off on some of our um uh our credit requirements temporarily as long as we can keep on track for the long term goals to soften some of those transition um uh price issues if they should in fact occur so been very sensitive and very thoughtful on that we know that the federal funding is finite we know it's going to taper off um and that some of the the activities supported by that funding um will taper off as the funding runs out and so this funding cliff it sends a very troubling signal into the marketplace particularly for workforce development and passing the affordable heat act that says we're not going to take our foot well i shouldn't say foot off the gas that's a bad bad pun in a climate change discussion but we're not going to back off on our commitment to things like weatherization and electrification and geothermal when the federal money runs out we're going to follow through on this commitment so if you're a vermont or contemplating a career choice in the the workforce of the future rest assured that there will be plenty of work for you to do in the future that's an important interplay in in those funding sources so you know the path to a more stable climate is a long and steep one passage of the vermont affordable heat act is going to keep us moving and onward and upward um on behalf of the conservation law foundation i respectfully ask that you please pass a strong affordable heat act so we can increase for monitors options for access to cleaner and more affordable options without further delay and thank you so much for the opportunity to come in i know you've heard from a lot of people and i do want to stress there's a lot more i had to say but i'm trying to be respectful of your time i put it all in writing and it's all in the record happy to take any questions thanks for your testimony uh representative thank you man here thank you for your testimony thank you sir just a question what would the clf position say we didn't meet the the standards say we couldn't meet the global warming solutions act standard what what would the position be on the clf well i don't like to deal in hypotheticals because i hope that you will pass the affordable heat act and that will reflect best efforts towards meeting those targets and it's possible that even if you pass the affordable heat act but you don't take enough action in the other sectors that clf would um on behalf of its members invoke the global warming solutions act and you know ask for action from the judicial process we keep all options on the table to promote public health protect the environment and preserve our our communities certainly the global warming solutions act is a powerful legal tool um but we're here today we've not just shown up here today we worked in the senate we've been working for the last year with the ean working group and with other stakeholders so our first preference is always to be a partner to be a collaborator in your efforts as the policy leaders of vermont to achieve those reductions and and so that's what we're why we're invested in your process why we're encouraging you to move forward with it thank you thank you for the question thanks for your testimony appreciate your time next up we have Johanna Miller from vnrc good afternoon i i hope you're not waning i'm a long day and you guys are doing a lot um but i'm very glad to be here with you today i'm Johanna Miller i lead the energy and climate program with the vermont natural resources council we're i'm sure you've met many of my colleagues in the past i have not had the privilege of being in your new and newly reconstant committee so it's great to be here um so my work um on the energy and climate program is informed by the work that i get to do at the local level helping to coordinate the statewide network of town energy committees and the important work that they're doing in partnership with their communities i am also the appointed environmental representative to the vermont climate council um and i've been at vnrc for about as long as vermont has had pollution reduction goals and statutes so it's a really long time um that's why you brought us this yes and i'm going to reconstitute my testimony just a little bit because unsurprisingly i um share and support the testimony of the folks who just heard from um folks that i get to work with a lot uh ben edgerley walsh of v perg um anthony and his full conservation law foundation we collaborate broadly as a council on a lot of different issues and to be honest with you i wanted to start first by saying and just recognizing all the important work that you've been doing in this committee um you guys have been doing a lot and your work with the bottle bill and h126 and the household hazardous waste i just want to say while those are not necessarily issues that i'm leading on these are really critical issues in the state of vermont and i just very much appreciate all the work that you've been doing and what you're lifting here in this conversation and um so you know i'm really here to support and ask you to support the affordable heat act um as you just heard um the work that has been done over the last year and the work that led up to it which yes i did share for you all um sort of a synopsis of some of the very things that have led us to this moment just to underscore that this is not a strategy that is coming out of the blue in vermont has been doing a tremendous amount of work um to figure out how are we going to make our you know how are we going to do our part on climate change again goals and statutes since 2005 um that catalyzed a series of explorations which i don't need to go through in terms of the list that you're seeing here but we have had three climate councils we now have a vermont you know climate action office and a climate council that is operationalized in state government i very much appreciate the work that this body has done to make that possible because we are in a predicament when it comes to climate change and that has costly consequences not just for people's pocketbooks um especially in a state that imports every liquid drop of the stuff that is driving the crisis um but i actually just want to underscore the importance of taking action because of the fact that it's not going to get harder it's not going to get excuse me easier it's not going to get less costly and it's really young people in future generations who are going to bear the burden of insufficient and ongoing inaction and so what you're talking about and looking at before you when it comes to s5 is the again result of almost two decades worth of work and all of the work that you see here in terms of the different task force commissions analyses it it generally all points in the very same direction which says without some sort of regulatory or policy framework or ongoing um you know consistent funding source we're never going to be able to meet our legally binding inclusion reduction requirements um with any certainty and so we are supportive of s5 and we very much appreciate again as you heard from folks previously all the work that this body has done the others have done we have participated in processes to try and really balance a lot of very important considerations when you're talking about a new program that is designed to make certain pollution reduction process progress gradually over time in a cost-effective equitable manner and that is what s5 is designed to do it's designed to set a gradual ramp and a transition for Vermonters and Vermont field providers to begin to move off of the fossil fuels that we import and that we have absolutely no control of their over their price um and their availability and i think that fundamentally is one thing that i just want to underscore i mean you heard from anthony you're i'm sure well aware i mean you're probably going to hear more you've read the ip the intergovernmental panel on climate changes latest report i'm sure or you've seen the headlines they're terrifying their latest headline or is act now with urgency or it will be too late vermont's not going to solve the climate crisis alone but we certainly have an obligation to do our part or monters want us to do our part this nation has um you know we have much more of a responsibility because we've caused more of the problem than other you know persons in countries around the world so we have an obligation to fundamentally do our part on the climate crisis and it is also an economic opportunity because 75 percent of the dollars that we spend to stay warm from fossil fuels goes out of our state um i know you've been hearing a lot about the costs and the consequences of implementing this policy lots of different numbers out there um you know and those are unverified um but what we do know um is that the cost of number two fuel oil for many vermoners went up by about two dollars again and about the span of a year or so um we have absolutely no control over that what we know and what you have heard we all were surprised to learn that you know Saudi Arabia and Iraq are now ratcheting down on their oil production i mean that's going to has already and will drive up energy prices the goal is to move vermonters off of this roller coaster because we have technologies at our fingertips today that are more cost effective um and that are cleaner and that is exactly what s5 is to design to deliver to create a market to deliver and fundamentally um and i don't need to belabor the point because i'm sure you are all waning but one thing i i would say is that at this point i fundamentally look at this bill as a market driver and critically most importantly besides the climate crisis which keeps me awake at night is very fundamentally essential to bringing everyone along in the transition people who can afford to get off fossil fuels have or will and if they don't then that is their choice but people who who can afford it will and we have to bring everyone along this transition this will require the fossil fuel heating provider sector for the first time to participate in the energy transition like we have required our electric provider sector to participate in the energy transition and oh by the way it's done good things for the state of ron it's saved vermonters money um and it's cleaner in our portfolio so we have more work to do in the electric sector but we have made progress by design because we have required the electric sector to participate in the transition you are asking the liquid fossil fuel heating sector to do the same i think we have to be very thoughtful about supporting them in the transition you're focused on that a little bit here there's more to do when it comes to supporting a climate workforce but i just want to underscore that i mean you heard a little bit today about the inflation reduction act there are other federal dollars coming in you also heard that the inflation reduction act falls short um in some ways because it relies on tax credits which lower income vermonters can't avail themselves of i view this policy as helping to fill that gap in some very critical ways and fundamental to actually doing our part on climate and moving people off of a roller coaster of high prices that we have no control over and it's really hard it's obviously very controversial you're getting a lot of pressure um this body has done hard things before i don't necessarily envy you but i i agree that you've been incredibly thoughtful about the process hearing a variety of perspectives i very much looking are looking forward to you know staying tuned into your work supporting you doing more things i see some improvements related to the equity provisions particular in the latest version of the bill i think that's very important we have to make sure as we make this transition which will happen i mean this transition is happening it will happen you've heard that from fuel providers we can either do it by thoughtful design with intention like this this policy and this bill is designed to deliver or we can do it by default and i fear that we will be leaving people behind and so i just want to underscore the high cost of the status quo whether you know the climate crisis keeps you up at night like it does me um moves you i the status quo is deeply costly deeply inequitable and it is my hope that you support an advanced spell thanks for your testimony thank you members have questions and i'm happy to provide links to this i will follow up share this with kate provide thanks to it and to the general um sort of high level takeaways that were fundamentally undergirding all of these processes thank you so much representative sabilia yeah i just want to thank you for uh this uh hopeful reminder well you know these members have not just popped out of the sky randomly well thank you and having been involved in some of some of them before i had gray hair my my request to you is it is my hope that we finally move from taking our goals meeting our requirements and actually doing the hard thing and acting upon the commitment we have long rhetorically made but have failed to deliver on in terms of policy regulatory design and this is a good well balanced bill that i think we can work together to make better to help everyone in the transition thank you thanks all right next up lauren hurl i'm vermont conservation voters uh oh i will try to be brief i know it's late um but thank you so much for the opportunity to testify today in strong support of s5 the affordable heat act uh for the record my name is lauren hurl and i'm the executive director of vermont conservation voters and it's a pleasure to be back with the committee and just echo the gratitude for all of the bills you've been working on in past really meaningful and important and great work and um the affordable heat act um like some of the other issues is was one that was identified by the environmental community the 19 partner organizations that we worked with to develop the key priorities that we were expecting hoping to see action on this year that are critically important to vermont's environment and health and the affordable heat act was the number one thing listed on our agenda this year as the most meaningful action and you know as you heard repeatedly it's because this is the most significant climate action that the state is contemplating right now it's among the most impactful ever considered by the legislature in terms of really moving us to um a cleaner future and we worked hard to support and um the enactment and implementation of the global warming solutions act and of course this was the cornerstone recommendation uh in the thermal sector and i really want to applaud the legislature for the meaningful progress um of evolving the bill from last year's version i think um you know you've been hearing this afternoon so i don't need to belabor the points but again the provisions around um making sure that we are focused on helping those most harmed by the current system and making the transition um including low and moderate income vermonters including renters and so on um that's really important work that's been done to improve the bill and it was really important to have the mechanisms in the bill to ensure that we're not transitioning from one bad fuel option to another bad fuel option and i think that there's really good provisions in here to do that i know you've been hearing from some folks we should go further we should ban certain technologies this and that i think the current language reflects a feasible responsible and scientifically based approach to do that over time um and i think that we in the environmental community will need to continue watchdogging this program to make sure that it really is leading to the technologies that we want to see and that we're not creating you know problems down the road and i you know i'm sure we will all be watching this closely and ensuring that you know we're really getting people to cleaner solutions that are really driving down climate pollution and not creating other environmental problems so um i'm sure you'll be seeing that um and with the provision added in the senate to require the legislative approval i think we'll have a chance before the program's implemented as you heard repeatedly to make sure that in its initial design that it really is achieving these dual goals of helping everyone come along in the transition and also making sure that we're transitioning to truly clean uh solutions that are going to do our part on climate and help for monitors um and i know we're all concerned about heating costs and i believe the point of this bill is to make sure you know as you've been hearing that every vermoner can in fact benefit from transitioning to cleaner and more affordable alternatives and you know not acting is costly and harmful and you know you've been hearing about the the headlines we're seeing about um you know the world in store if we don't act and you know my 11 and 8 year old are always front of mind you know what is the world going to be like in 20 30 50 years and you know i know i want to be able to say we did everything we could we did our part you know we stepped up and part of the ipcc coverage was focused on you know there's a limited time to act and what's holding us back is political will it's not that we don't have the technologies we know how to do it we just need to step up and act and i coming in today was just like i'm feeling deeply grateful that you all are taking something that's really hard and doing that work and acting and really stepping up and so you know vermont being here leading putting in place a an innovative and important policy um i'm just i'm really grateful and um you know and i think doing doing the opposite and failing to act would be really irresponsible when we look at oil prices right now you know all that does is leave vermoners vulnerable to price spikes um you know that we have no control over um it's expensive and leaving people in this reality and failing to act and not taking steps to get people to a better um future is exactly the wrong path so i think that the affordable heat gives us a tool to really make the transition thoughtfully with equity and accountability and being able to shape it to work for vermont um i'll just skip a little bit i know it's getting late um just one thing i was thinking about was the recent um experience i had to oh our oil boiler was ready to be replaced and we had you know our field dealer come over and we're talking through options and you know very nice guy and you know we were clear that we wanted to find the cheapest and cleanest way to heat our home and stay warm and you know the guy was running through a bunch of scenarios and basically talked us out of heat pumps even though that was what we first thought and kind of convinced us that our house was not a good setup for it i am not sure if that was right or true um we eventually put in a woodpella boiler um which i had mixed feelings about um you know that they were very clear about the incentives that were available from the federal government for those it was like a 30 percent federal incentive for that um but you know we were basically wrestling with a guy a little who you know was very nice been doing his job but his job was to make as much money for his company as possible because that's you know what his role is and we were trying to find the thing that would be cleanest and cheapest and i think that what this bill fundamentally does is you know instead we can imagine where the fuel dealer is coming to your house and you're working together because we both have the shared goal of finding the cleanest and cheapest alternative and so you're getting the advice you're getting better incentives and you're able to transition to you know something that's going to keep you warm which is what we want and save you money over time um you know in my work I talk with Vermonters all over the state um I do a lot of work with voters um you know climate change was a top issue in this past election as it has been for a number of years um there was a lot of people running on climate action platforms those people overwhelmingly won their races the people who were literally running on a platform of climate change is too expensive we can't we can't afford to act on climate those people overwhelmingly lost their races it was not something that Vermonters were compelled by you know I think there's very much as we all are feeling and working on is how do you bring everyone along how do you not leave people behind as we make the transition and I think that's what this program is really trying to do um but just not doing our part and stepping aside you know voters consistently are calling for climate action they want to see people step up and again I'm just really grateful for your time and attention your leadership on this bill on addressing the climate crisis the biodiversity crisis and all the work that you all are doing and I would be happy to answer any questions thank you for your testimony Representative Logan thanks um so um carbon intensity scores um just want to make sure that we hear from some of the folks who have been working so hard on this bill for years where carbon intensity scoring is concerned and the life cycle emissions analysis of and the schedule for for fuels is concerned do you believe that the way that this bill is currently drafted in those sections is sufficiently protective to ensure that we don't develop um an overly large market for biofuels that are sourced from places that we might consider um environmentally or even um you know justice death detrimental locations yeah I think that the way it's structured with the ratcheting down carbon intensity over time in part you're sending that market signal so if you're a Vermont company then making big capital investments and something that you know in a few years you're not going to be able to use anymore makes no sense so a lot of the conversations that I've had with um you know colleagues allies who are really concerned about what does this transition look like and making sure we don't somehow lock in or um you know unfortunately incentivize fuels that have really damaging effects on the environment um just like fossil fuels do and you know I think that the structure does does the job of giving time for the transition but making clear that we do not want to be moving to damaging alternatives um you know and some of these terrible biofuels that are devastating parts of the world and so I think it's sending the right market signal by being clear that that's not the future of what Vermont is feeding and putting in technology is not a good investment because it can become a stranded asset um so I think it accomplishes it you know again I think we'll be watching closely and making sure and how is this really playing out and how how's everything incentivized and you know there's always you know you can always like look at it and make sure it's really doing what we think but I think that the structure um does the job of sending that signal like paired with all the considerations of the PUC needs to look at with you know the um the other environmental impacts I think having both of those together give me comfort that we're going to transition to the right kinds of technologies that are really cleaner over the long. Thank you. Your questions. All right thank you for your testimony. Thank you so long day. Um all right. So Avram we're still in in committee and um thanks for your testimony. We are on tomorrow after the floor it's listed as 15 minutes after the floor with Ellen on this and then we're going to have a kind of a hearing on the trapping rule that the Wildlife Board is considering I believe they considered it this week and we'll get an update on that in the afternoon so we'll see you all after the floor tomorrow.