 Educational Television Access. Yes, thank you, that's awesome. Morning, everybody. So my name is Jess Wilson, and I'm the executive director of the Regional Educational Television Network. I'm also today representing the Vermont Access Network. The acronym known as VAN, if you hear me say that later, you'll know what that is. So RITN is an Educational Access Cable Television Channel, and we serve the communities of Chittenden Addison Counties, a part of Addison County. And as I said, we're also a member of the Vermont Access Network, and that's the trade organization that represents Vermont's community media organizations around the state. And thank you for the opportunity to just to provide you a brief on what's going on in our industry here in Vermont. There are multiple threats right now to Vermont's Cable Regulatory Authority and as well public educational and government access media organizations like mine. And I just wanted to talk a little bit today about the value of those community media centers and specifically related to the educational opportunities for learners in our state, because I feel that's something your committee might care very much about. Someone just gave you the very briefest background in history because Cable Regulation is a little complicated, so I'll try to boil it down. Vermont's authority to require public educational and government, also known as PEG Access franchise fees, and those are the fees that basically support the work that we do. That authority rests on its ability to manage its public rights of way, and that's enshrined in the Federal Communications Act of 1934 and the Cable Communications Policy Act of 1984. So the Cable Act is a national mandate that requires both regulators and cable operators to encourage the growth of cable systems, respond to community needs, interests, and assure the widest possible diversity of information sources through the regulation of television, cable television franchises. So the state of Vermont first established PEG Access channels as a funding and public policy objective in April 1984, and it's the Public Utility Commission in our state that provides regulation of that. A little bit about where we are currently, because of Vermont's really firm commitment to PEG Access and those values, Vermonters are benefiting from a thriving local community media ecosystem that connects our communities together around the state where there are 25 community media centers. Over 80 full-time channels, we produce 18,000 hours of live public meetings, events, community-based education, free speech forums each year. That basically amounts to $74 million worth of equivalent community services in 2017. And we're doing that with $8.7 million in cable subscriber funding. So that's an $8.7 million investment that returns about $74 million. And we employ across the state almost 200 people. And specifically, what I wanted to share with you today is what happens at an educational access channel like RITN. And so we provide professional video production coverage to local communities in the form of school board meetings, school events, community concerts, other arts programming, all at little or no cost. And these programs are carried on cable and online and provide a lifeline for residents to connect to local news decision makers and events in the community. But perhaps what would be more interesting to you is that organizations like ours actually provide learning opportunities for Vermont students and professional development for Vermont educators. This work includes hosting video camps, supporting student internships, both high school and college internships. We provide trainers for teachers to use video in their classroom, which is a great engagement tool for student learning. We provide free or low-cost classes to community members and students at our centers. And we support equipment for video integration into student personalized learning plans. That's been one of the big things we've seen lately is that students using video as part of their PIPs and PLPs and media literacy training and much more. And I can't underscore how important media literacy training is in this day and age, for certain. And then a specific example of this work in action in 2018, RETN completed with Charlotte Central School students, NASA, and the International Space Station, a great project. The students were given a once-in-a-lifetime opportunity to speak directly with astronauts aboard the ISS as part of an interdisciplinary unit on space experiments. School officials called us because they did not have the equipment or expertise to figure out how to connect these students live with the ISS. But we were able to do that. And as a result, the students talked directly to the astronauts on the ISS. And that television show was broadcast live on RETN and on NASA TV for a national or international audience. And we also worked directly with the students to create short videos about their research and experience talking with those astronauts. And there were 22 student videos that came out of that project, and also a short documentary that we produced about it that we were able to share with the community. And I did include a link in my testimony. If you care to see any of those student videos, they're fantastic. So I know time is short, so I'll get to the meat of this. There are a lot of threats facing us right now in our industry. One is cable cord cutting, which I don't need to say probably too much about, but that folks are cutting the cord, and that directly affects revenue because the federal government prohibits the state from taxing any internet services. So people are moving away from cable and over to internet that has a direct impact. There was a cable revenue reclassification that Comcast took advantage of last year that basically resulted in a $500,000 loss statewide in cable funding revenue. Many of you might be aware that Comcast is also challenging the authority of the Public Utility Commission and Federal Court right now. There is an ongoing lawsuit about the most recent CPG. And then we also have an FCC rulemaking that's in progress right now that basically would enable cable companies to charge back to local communities to the franchise fee, anything that they donate so they could consider our channels in the cable system as something that they could charge back. They get to assign whatever value they want, the rulemaking has, this has nothing about the value of these channels. They just get to decide and then charge it back against those franchise fees. And so the big questions that we're really trying to answer right now are how do we preserve the state of remonsibility to manage its public rights of way in contracts with the cable providers? And how do we continue to support the public policy objectives of peg access through our administrative, legislative and regulatory authority? And we have a couple of things that we're proposing. One is a workshop with the Public Utility Commission to really look at these issues. That actually has just been scheduled. So progress there in late March, there will be a workshop between those of us in the band community, the department, the PUC and the cable operators. And then we also are working with members of the House and Energy Technology Committee to put forward legislation for a summer study committee. And so my big hope for you today is that if we are successful in meeting the crossover deadline, that you would consider supporting this summer study committee to really take a deeper look at these issues because we do think that it will have a huge impact on our ability to work in the state and provide these services. And I'll wrap up there and take questions if you have them, but I really appreciate your time and consideration this morning. Questions? I'm actually curious to know more about cord cutting. Why do people have to cut the cord? Why do people have to cut the cord? They have to pay if they don't cut. Well, cord cutting is really about basically getting rid of cable television and just having internet service because you can watch all of the TV you want now. Oh, you don't mean to actually. Correct, right. Yeah, it's just a... Because I've seen so many cut cable cords, I thought that that was... No, it's a term of art to basically describe. Internet is now really one of the primary ways video is being served. In Vermont, though, we have seen that cord cutting has been a little bit slower because we have an older population. We also don't have, I'm sure you're all very well aware, great broadband in a lot of places, so you would need cable to be able to watch TV. But it's certainly an issue that, you know, within 10 years from now, be a lot less folks actually watching TV on cable and it'll just be over internet. And this is the distinction between cable and satellite and internet. Very good question, yes. So the distinction being, while there are no franchise fees charged for satellite, there are no franchise fees that cannot be charged for internet services. The federal government has said that. So franchise fees that support community media channels can only be collected on the cable side of the revenue. So if you have a cable provider that does like triple play, which could be phone, internet, and cable, revenue to support community media channels in local communities is only collected on that cable side of the bill. And that side is going down. Representative, too. Yeah, I guess that goes on with my question because Northwest Access TV in St. Albans, they've done a great job with their, they have new rebuild and. It's a beautiful building. Yeah, it's beautiful. And, but they do a lot of stuff through Facebook and YouTube. Yes. There's probably not a lot of revenue generating in that bill, is there? Or is there a way to grab that? We're thinking about many ways to find new sources of revenue. Yeah. You know, from fee for service work we all of us are putting content online. At RITN, we've had tremendous success with engagement with our communities around Facebook Live. Yeah. So every school board meeting that we film and special community school event we put on Facebook Live. And remarkably, we've seen wonderful engagement. Yes. It's people who really care, who are commenting and watching. And a brilliant school board meetings, we'll see upwards of a thousand viewers on Facebook Live. And you can see them live who we actually know. Yes. Yeah, which is great. Because we don't know that on our cable channels. Absolutely. So, yeah, we're all working very hard to develop new services and new ways to reach our community. And that's really why the study committee is important because it's gonna help all of us think together about what this looks like in the future. Do you have any update on that FCC rulemaking? I know I submitted a letter in support of, I'm a GNAT viewer. John and Manchester. Yeah. So the latest, there, thank you for supporting the letter. And in fact, you can still send letters to the FCC and we're encouraging that. Where it is at right now, the government shut down, slowed down that process a little bit. But the latest guesses, and these are just guesses, is that the rule will still come out probably in September or October. And then there's a 90 day period before it goes into effect. We believe that on day 91, cable operators will probably take advantage of that rule. And there will be lawsuits. But the likelihood, and again, this is all guesses, is that there will not be a stay while it's fought out in court. So there could be up to an 18 month period where funding for these community media channels could be cut estimates as much as 30 to 50%. And so our centers need to find a way to survive. During that time period, while this is fought out at the federal level and in court. What would be the composition of the committee, the summer study committee? Thank you. The idea for that, and I'm gonna take a look at some notes because I have not been directly involved with all of that, is we're proposing possibly a series of six meetings that would include a member, a legislator from Senate Finance, House and Energy Technology, the Commerce Committees, and then representatives from the Department of Public Service, the PUC, cable operators, internet operators, representatives from our organization, Van Vermont Leeds and City in Towns, the Vermont School Boards Association, and a group that represents the public interest. So trying to, but I think it would be about two to three legislators potentially is the idea. Thank you. Well, it's really been great to talk to you. Thank you very much. I really appreciate your time. It was an interesting time. Thank you so much. Thank you. Good luck. Thank you. Okay. We are switching gears over to a discussion about what to do when public youth, our independence goals appear to be gearing up to close. And we had this introduced last week, correct? Introduced last week? Did we have it? Yeah, Jim came in and introduced it last week. And we have first, Susan Stitely from the Association of Vermont in the Department of Colleges. Thank you for coming and welcome back. Thank you for having me. I'm still just a little discombobulated at being Nick Rodwell, which was super hot to come back to super cold. Would you like the draft request up behind you? Sure. I have a copy, so. Okay. Do you all want the documents? Yeah. For the record, I'm Susan Stitely, the President of the Association of Vermont Independent Colleges or AFIC. Just by way of background on this legislation and why this issue came about, when Burlington College closed suddenly, they left behind their academic records and the agency of education had to go in and physically take the files and the records and then respond to students' requests for their transcripts. You know, Burlington College was really an outlier. They closed so suddenly in a disorganized fashion. But the agency came in and requested an appropriation to take to manage the records and also requested that private colleges maintain a bond in case of closure. That would have really caused a hardship for the small institutions that we have. Bonds are based on financial stability and it could have really caused a financial hardship. So we came up with a compromise in that AFIC members would maintain a memorandum of understanding. What did AFIC students want? AFIC is the Association of Vermont Independent Colleges. Just too much of a mouthful. So AFIC members signed an MOU agreeing that they would take care of a member institution's records or ensure that they were taken care of by their party. That legislation was up only when we proposed that. We also had proposed a piece if an institution wasn't a member of AFIC. But when the legislation passed, that part got dropped. So the problem with the current legislation is that if a private college is not a member of AFIC, they're not part of that agreement. We have no control over what they do with their records. And so this, what we're posing now is an effort to fix that problem and really making the responsibility of the institution whether they're a member of AFIC or not, that should they be placed on probation by their accrediting agency that in five business days, they would notify the agency of education. And then within 90 days, submit a student and academic record plan that would need to be approved by the State Board of Education or the agency. That way it doesn't matter if someone's a member or not. And we have been working hard and brought people together at the presidential level and the registrars together to talk about how we all might work together to support each other should an institution close. So as a result, the presidents voted on an academic record retention policy in November that everyone has adopted. And the purpose of the policy is to ensure that all students enrolled in AFIC member institutions have access to their academic records should an institution close. Our preferred course of action is that another AFIC member institution takes on the academic records. But if that's not possible, we acknowledge that a third-party vendor experienced an academic record management may need to perform that function. And there are third-party vendors that manage student records and academic records when an institution closes. And actually their fee is very nominal if depending on the state of the transcripts and whether they're electronic or digital. So that is definitely an option should another institution not take on the records. And we also talked about what should happen if your records that are maybe 100 years old, that the records that need to be preserved are the ones that the students are gonna be needing so that things are destroyed in accordance to best practices. And we've developed a naming convention so that we're trying to get everybody on the same level playing field for student academic records so that if an institution closes, they're easily transferable so that everything's electronic, that there's naming conventions for how and other institutions so that everything lines up on the records. So I feel we've worked really hard to get a good record retention policy in place. Again, that does only apply to AFIC members. So if an institution's not an AFIC member, we have no control over what they do. So that is why this legislation is important in that it puts the burden on the institution whether they're a member or not to work with the agency of education and the state board of education. That's good. Representative Hoover. Susan, how many AFIC members are there? There are 14. And how many students in total went to Burlington College at one time or another? In total, I don't have those numbers. I mean, it was a small institution but over the course of their life. How many at one time? I think about 300 to 400 maximum during the same day. So 14 or eight of the members, how many colleges are non-faceted? Necky is not a member, New England Institute, the Culinary Institute and Green Mountain College, which is closing as none of them ever were. Those are the only two? Those are the only two, yeah. There were a couple of cartoon studies? Oh, yeah, they're not accredited, but yes, they're not a member of that. And there was some really small religious one down. Well, yeah, there is a very small missionary college, it's not a member. And then, I mean, it depends on, but like a Bryan School of Cosmology is not a member. So those types of institutions are non-members. Mostly accredited agency. It's Necky. Necky, is there acronym as New England Association of Higher Education? Accreditation probably. It used to be Necky, no, not Necky. Nea? Yes, yeah, Nea. What's Nea? It was Nea, so now they go with the acronym of Necky. That's the same group. Same group, yes, yeah. Why do they do that to you? I don't know. We have enough things to do every day. So I can only remember the acronym, Necky is catchy. So. I'm just trying to remember, in the last biennium when we took testimony, I only recall the schools that weren't part of AVIC as being like the, you know, sort of a VEDA Institute or whatever they would be considered. The Cartooning Institute and maybe it was like Southern Vermont College, it was one of them. There were only several though. I thought Green Mountain College was in AVIC. Green Mountain was in AVIC, but as their financial situation got more unstable, they dropped their membership. So that's one of the issues that, you know, people may or may not be a member, depending on the circumstances. Representative James? Just did Green Mountain drop out because they literally couldn't afford the membership fee or their larger reasons that you guys have policies and procedures and guidelines that they were no longer able to meet. So was it just a matter of the fee or was it a larger? I think it was just a matter of the fee. What is the fee? It's based on the amount of students that they have and so it's sort of a complicated formula, but it's based on the students. So that the larger institutions pay more than the smaller ones pay less. And they, you know, they had a new president who wasn't in higher ed before. So he was making difficult choices when he first came in and he didn't really understand AVIC's role. So there were all, there's a lot of factors at play. But the range of the fee is like? The range is several thousand dollars up to probably 12,000. Any questions? Could you describe a little bit more these third party vendors and what they specialize in and how much confidence one can have in them? So there's a group called Parchment which is based in Chicago and that's a group that we have talked with most just to explore the possibility of if necessary that the records would go to them. So they have managed records of other institutions in other states that have closed. So they take the transcripts. They, if the records are all electronic they don't even charge a fee. They just take the transcripts and then they charge students when they ask for the transcripts a minimal fee, I think of $15. That's the only one that I'm really familiar with and that's probably the one that most likely our institutions would use if necessary. But they also will handle paper records about 50 years ago or no. They would charge more for that. They would have to scan them and get them into their system. So that's one of the things we've been working with the registrars is let's get everything scanned in and everything electronic to make it easy as possible to shift the records over. Why would another institution be able to take these records? I think because some of the students may go to that institution and just because of the partnership amongst the private colleges of wanting to help each other out. But it's more like with the Green Mountain College they made an agreement with Prescott in Arizona to take their student records and their students. Some of the students are gonna go to Vermont institutions as well and they will take those records. And the agency, thank you. Oh, I just do what I say. That the language that we worked on had worked with the previous administration at the agency and their previous council. So we had agreed upon that, but I haven't had a chance to really touch base with Emily on this. Hey Shannon, I'm gonna go to my testimony on this but I think I can handle it, okay. Hi, Emily Simmons, Agency of Education General Counsel. I'm gonna go back to where we started. I wrote some quick testimony for you through it together yesterday. Which would make sense, Mrs. I haven't touched base. I looked at this yesterday. So here we go. So thanks for taking this language up. I think first of all, this is an important issue as Susan alluded to the agency and the state board did work with Green Mountain College last month to have the state board review and approve an agreement with Prescott College in Arizona to be the permanent repository for Green Mountain College's student records going all the way back as far as they have those student records. It's an important note I thought this morning you might not realize universally whether it's federal law or state potential policies. I've seen that the requirements to maintain student academic records at the post-secondary and the K-12 level is indefinitely. There's a need to keep those records available to students should they need them just normal life activities like getting a new job or another degree. You all probably have had to access your student academic records from college. So you understand those records. So the state has an interest in essentially its consumer protection interest in protecting Vermont students ability to get their money's work is the way I would say it from the degrees that they've received in the coursework So I just wanted to say thank you for taking this up. I appreciate the intent like we said to protect students' consumer rights and also I sense that the agency has an interest in or the committee has an interest in protecting the agency of education from becoming what I would call the custodian of last resort in the case that that system just totally falls through and we see which we would not like to see another Burlington College incident that was unfortunate on all fronts and those records are currently housed at the agency of education. We can get into that a little more. So I think that this approach is a good one. Very quick turnaround on notice and then some very clear duties on the closing institution to act really proactively to come up with the plan that the state board would then approve. We appreciate moving away from the AVIC language because as the Green Mountain College sort of scenario demonstrated it doesn't do the state and the students that acted much good if the membership association that has the duty to protect one another's records no longer for whatever reason has the closing institution as one of their members that defeats the purpose. I do think seeking a different policy solution is appropriate. So in order to improve the language that you've got drafted and that you've been looking at I just have four really recommendations to make the language stronger which you would consider that. So the first is that the language as you have it drafted now refers only to financial probation from the accrediting institution. We think that it would be more appropriate to have the trigger be any kind of probation from the accrediting institution. We have seen unfortunately that academic probation is sometimes the first indicator that an institution is going to be facing some difficulties and that just like financial probation can lead to that unfortunate cycle of very quickly declining enrollment and the institution having a hard decision about closure. So we feel that just probation period would be an appropriate trigger five days from that notice of probation the institution would notify the state board the way you have it currently drafted. The next sort of trigger in the language is that it provides 90 days for the institution that has been placed on probation to get a plan together and submit that plan to the state board for approval. The agency feels that a shorter time period would be more appropriate. 90 days is just shy of a semester and that's for instance, just looking at Green Mountain College that the notice that their board worked with in advance of closure so they have announced they'll be closing in July of this year and they announced that like the second of January. So we don't know if that's difficult but if it is 60 days would have been a more appropriate time limit and we think still give the institution enough time to seek out a partner, follow their records written in Jim policy as Susan mentioned and work with the state board to make sure that that is enacted according to section A and section 175. And then third, we feel that the general assembly should designate some appropriate state government custodian to act as the custodian of last resort. Hopefully we will never need a place for the records to go and hopefully the process where the closing institution is proactive and seeks their own agreement with their own chosen partner to take those academic records. Hopefully that works every time and we never need this but if we were to see just totally abrupt and unforeseen closure as Burlington College unfortunately was there was no time for this process. That closure happened within a couple of hours. So the five days notice even wouldn't have addressed that really unfortunate circumstance. And it is true that agency of education sent staff to Burlington College to physically gather up those records and those records still reside at the agency of education in essentially a, it's not a closet. It's nice within a closet but it's not really a filing room. And we feel that the agency is really an inappropriate place for student academic records. As I'm alluding to we do not have a secure record storage facility if we were to see any sort of environmental impacts, flood, water of any kind, fire, smoke. Those records would be totally susceptible and that's not common practice with long-term records retention. Usually you have some sort of climate controlled facility. Second, the agency doesn't have any staff who have it as part of their job description to work with these student academic records and retrieve them with Burlington College records. We do see periodic requests from students. I mean, the students are seeking other degrees. They're applying for jobs. That wasn't that long ago. And that is agency staff time that's taken away to go in the file room and find whatever the student is seeking. These are not folks who worked in a registrar's office, who are familiar with the way that transcripts appear, the information transcripts. We're doing the best that we can. And the agency staff who frequently get these calls told me they feel a great sense of urgency to go, they prioritize these requests really about anything else because they know that it's a student who's applying for a job or some other positive life experience. They don't want them to wait on agency staff to do that. So take it really seriously. It's just not, it's not a good fit. And then finally, the agency doesn't have authority and statute to charge fees for access to transcripts as is really common. If you ever have to get your college transcript from your institution, it's, I think I paid $12 before to get my transcript. You sort of expect that, that the agency would not be able to charge that fee. We could follow the Normal Public Records Act, the processing process, but that's nominal and we wouldn't do that to those students anyways. It's not the intent of that section of law. So the agency is suggesting that the, the state actually has an appropriate entity for student academic records. It's the Vermont State Archives Records Administration they call it the SARA. It has a state of the art climate control records facility that is, that was built specifically to house records that goes along with staff who are trained in records administration and I assume it was full-time job to work with those records. The SARA has existing authority to charge a fee. I looked into it. I'll just show you it. I think it's $9.50, if this will load. Yeah, they currently charge $9.50 for students to access records for these schools that are currently housed at the SARA. And those are all the Secretary of State's office. That is a dividend of the Secretary of State's office, yes, and I have to give you a disclaimer like Susan gave you of not having a chance to speak to anyone from the Secretary of State's office about this. Understanding is that the State Archives of Records Administration stopped accepting student records at some time in the past, but no one in the agency was familiar with the exact background that you have to ask then if that's accurate. So has the agency approached them about the ground then? They've, I'm a little hesitant to answer that. I know the agency did not think that we were in an appropriate place for the Burlington College Records. We saw other avenues to get the Burlington College Records in a more appropriate place and they're still in the agency of education. What happens if Prescott College closes? This statute gives the State Board Authority and the Attorney General, in the worst cases, some authority over post-secondary institutions operating in Vermont. I don't believe Prescott College fits the definition of operating in Vermont under their Teach Out agreement with Greenville College. So I think that it would be Arizona's jurisdiction and I'm not familiar with their statute. Questions? So I've taken the absolute liberty right here of some language that we think accomplishes the goals that I lay out. I hope that you consider it the last sentence there that's totally new. We hope would cover the Burlington College Records. I just want to be totally upfront about that. If the General Assembly passes a new process that does establish some other state agency as the custodian of last resort, if everything else just goes wrong, we think it would be entirely appropriate for the Burlington College to go along to that institution. No questions? James? So we don't know yet whether Visara feels like they have the capacity in the staff. I have not asked that. Okay. I have two questions. One is, would it not make sense to have colleges kind of, or for you to have a form for these colleges that if they get to a certain point in their finances that it flags way before 90 days, you know. I have to assume of an institution that size, you probably know a year ahead that things are not looking good. I just wonder if there's a way, just easy, simple, just that they let the agency know that, yeah, it's just something very simple. Like if they go below a certain level or meet certain criteria, it's a flag that they need to let you know that in case, just to give you a heads up that they're headed. So that's one question. The other question is, can these records be digitalized? I mean, would it make sense to have all colleges have records, you know, stored digitally instead of paper copies? So that's an easier question to answer up front. I believe that it's the absolute norm at this point for our colleges in Vermont to have digital transcripts. My sense is that Burlington College's records were in a state, sort of, they were in the middle of working with some records at the time that everything happened. So I think maybe even some of the Burlington College records under their policies were digitized. What we had is paper records at the agency. So, yes, I think in the future, there's a, I was gonna show you right here in the language, it's actually where these stars are. There's a provision that the, oh, here it is, into prepare their academic record is in duty of the closing institution. So essentially to get the records in their normal order and to be prepared to go wherever they're going is an affirmative duty in section 175. So we would hope so. The agency hasn't digitized the paper of Burlington College records that we have for any number of reasons. We're like we said, we're not experts in record maintenance and working with transcripts and my understanding is that sometimes students don't need the whole packet. So we've not made any sort of decisions about Burlington College, we're housing them and we are responding to student requests and trying to not change the form of those records. We don't really feel like we have authority to do that. But can you insist that they're digitized from this point on that all records are digital? So the, in this sort of answer is your first question. The agency of education's relationship in the State Board of Education's relationship to post-secondary institutions isn't that close. We don't have really robust oversight, we're not seeking really robust oversight to give them directions such as digitize your records. So, and I'm not a post-secondary person so I don't know what they would even think about that. That's another reason why, to your first question, the agency might not be told by these institutions at the first sign of trouble. We might informally and they might give us the professional courtesy certainly of calling us earlier. I think that the language here about five days after probation from the accrediting agency is appropriate and is a pretty quick turnaround. You could play with the number of days but that does seem prompt. And the agency of education doesn't have financial oversight in a way that would just let us know on our own that there's trouble. The system is really set up to strongly utilize these accrediting bodies that are third-party bodies. Thank you. I'll say the two. So the five days, I'm just worried about the five days I feel like it's really quick. Because if they had notified you it doesn't become public, is that public? We could call us. Okay. We would not... That's a harder question to ask if it would be public. And then I see the concern it's really sensitive because they do sort of trigger that spiral of just coming in from that. I'm working at this college, this college, and they're under this probation. I'm not gonna let you know if I'm saying it. I wish I had the full stat. I wish I had my green book in front of me. I don't know how much Chinese I might be doing. I mean it's really tough because I'm trying to think if it's on the radar or... Yeah, your answer is a nice one. When an institution goes on probation it does become public. Okay. It's a netchi and it makes it public. So it does become public. So the five days would matter. Yeah. So the five days is just to make sure the agency knows insufficient time. And normally an institution is placed on probation for two years. So that's the notice, the advance notice and that they have time to work out the situation. So more of the oversight has to come in from the board. Is that what you're also saying? So the state board has the authority to give certificates to institutions. It depends if you're chartered in Vermont or not, it's a little complex. But the sort of approval for any institution that's beginning business in Vermont is actually the state board's authority. That's just one of those things where the agency is doing the right work to inform the state board of those instances. I'm gonna wanna move you back when we do work on this. I'm cognizant of the fact that we've got a two hour meeting coming up and I'd like to give us a little 10 minute break and be in the chamber at one minute of... To meet with the agency on our oversight of the agency and capacity. We will be meeting with, thank you very much, L.A. to be clear, clearly not finished. Great if you and A.V. could meet, you know, just wherever. The premise area, sort out those differences.