 Right. We are opening the bylaw regulation review subcommittee on April 15th at 9 0 8. And we are waiting for the Roy Gaynor to join 12. Right. Well, I sent him, you know, I'm wondering if he might have an update. I know Dave had trouble with that one day. He couldn't get in and it was because he needed to do like a zoom update. And he usually tells you that right. You need the update. They do but sometimes older computers and stuff like they get like they block those popups and stuff. I know because my computer, my home computer is like so old. Like a dinosaur and it moves so slow it doesn't always give you the updates. I don't know. Unable to join as a panelist. Do you want to, did you like click the invite as attendee? Yeah. Join as a panelist. Why every time does this happen? Yeah, and it won't like let me edit it because the meeting's underway. We need to restart. Is it worth asking him. That's what we did last time and it worked right. Maybe we, oh, hold on. Wait, wait, wait. Yay. Hey. So what worked. In the end, I just kept trying as a public member. And it went through. You had to try multiple times and it worked. Yeah. And then never ended up working as a panelist off the top. And you know how you're not allowed to be a panelist. So then give you the open option son and to any meeting, give your name, give me the screen. I just kept reopening zoom as like a fresh sheet. And copy pasting the meeting date of it. And then eventually work time free. That just makes no sense to me. So what do you guys say you want to get rolling here? Yeah, let's hop up to it. Okay. So I was thinking we sort of take a quick, just a quick stock of where we are really quickly. And this is what I have based on. Let me let me do like a share screen. So as far as I know, I just, I just want to make sure that you guys remember the same process I do. So we, we went through the general provisions and we marked this up and made some edits. I responded to Michelle's comments. I think we reviewed these changes. We made a couple changes to a little bit of verbiage here. And that was kind of section one. So I, I just have to make that a clean version except the changes and then remove the comments and that section is good to go. Section two. So, definitions. There have been a little bit of edits here because I went through this with town council. We had done a little bit of editing. We added in a little detail on the clear cutting section. The competent source section. We added in a little detail on the surface definition. Isolated wetland and vernal pool are still. Kind of we're still working on those, but we'll come back to that when we get to the actual resource area sections. Self-imposed hardship. These. I got two definitions from town council and I. I got two definitions from town council. So those are incorporated in here. And if you want, what I'll do is send you guys all of these, we send you guys all of these so that you can look at the definitions if you want. I just kind of wanted to just take stock of where we were, but we already went through definitions. And I did edit the structure definition. Structure within the context of the built environment means that it's not going to be in the spring or summer. I think the previous definitions said like interlocking pieces or something. It was kind of weird. I did make some edits to the vernal pool because I didn't like the at least in there, at least in most years, like at least it doesn't need to be there in most years. It holds water for two contiguous months. The months could be in the fall. So I took out spring or summer because it's not always in the spring. And then just the specification about. Certified or potential. And that's that. Then section three. I always screw up the Roman numerals. I have a question about in most years. I don't have a better way to say it yet, but if. If it's like every three years, the pool fills. Just because of rainfall or something. In most years, is that like 50% I mean. Well, this isn't, this isn't the. This isn't the final definition. We can word Smith out a little bit more. And Michelle, if you want, I can send this to you. And if you want to make any other edits, we can. I'm hoping that we can do another sort of. Full or like a last flush over these at the next, at the next last meeting that we hold. So there's still a little chance for a little editing. Okay. I just want to sort of put that out there. Yep. And I think that makes sense. Okay. So section three. Procedures, I believe we finished. I'll open it up again, but now that I'm thinking about it, this was, this was. We reviewed this and I believe we had it clean and it was good to go. This was the determination of applicability, the notice of intense section. The enforcement section, I believe is in here, public hearings, coordination. I think we got that section all set. But again, I'll send you all the clean versions. If you guys have any final edits or comments on any of those, we can definitely get those in. So then there's. Standards for inland wetlands, which will go over that's not done yet. That's still work in progress. That's the one I sent you yesterday. And then. There was filing fees. Plan requirements and work conditions. This one is almost there. I think that the only thing we were. We were discussing not having an emergency certification. Yeah. Did you. Does that with anybody else? No, I didn't. Didn't discuss that with anyone else. But I think that that's in this section. That's the only outstanding as I recall. But I think we incorporated all other changes on that section. And the only other section is. This amendment section, which is very short. These regulations are amended time to time. So I think we've, we have reviewed all sections at this point. We're, we're still obviously editing and whatnot, but I think we've reviewed all. So I just kind of wanted to just give a quick overview if that's okay. And then we can start talking about standards, unless there's any other comments on those. Okay. It seems like a little, little kind of adjustments here and there for some of the remaining ones, but. Okay. So. The bank preamble. I'm hoping that Jen fair is going to help with that one, but it may end up coming back to me. We reviewed this. No change from existing regs under bank definition, but I think we're going to go back to that. Okay. Okay. Okay. So we're going to go back to that one there. Made general performance standards consistent with WPA. I added in the little asterisk, Michelle, for bylaw only, but our bylaw specific. I'm a little on the fence about that because there's so many sections where I mean, you'll see as we get further down where it's like, it's, it's basically what stated in the wetlands protection act, it's like, you know, it's like, you know, it's like in the case of wetland replication, the one changes that we double the requirement for the replication area as opposed to, you know, just requiring them to replicate whatever they alter. Okay. Well, I mean, if it. Is more tedious or doesn't really serve. It's true purpose. Like I'm not. I'm married to the idea of it. I just. I'm. You know, streamlining the process and the permitting process that. Yeah. Have been relevant to you, but feel free to just mix that idea. I like the idea to be honest, just because it's like, it calls out where this. It's bylaw specific, but what's tricky about it is. It's hard to say where the bylaw changes start and end in each section, you know, like we could put an asterisk on that section or on an asterisk near a specific statement, but it's hard to say like this little section right here is bylaw only and the rest is all wetland protection act. The same, you know, it's consistent with the wetland protection act. So that's my only concern. Well, it probably makes sense to remove it because if it's not like a. Yes or no straightforward. Then it's more probably more confusing. I was almost going to say it's. We could keep it because there's no case in which it's going to be less than the state law. Right. So, of course. Yeah. I can't really. Every time we denote that it's for town. It'll be specific and people will know that. Even like in your case where it would be mid sentence that we're just doubling the size. But otherwise the same as the statement that change is the only thing they're reading and it is a time. So it works. Yeah. I just don't want you to have to do double work of now going back and removing all this. Right, right. Well, we can, we can, that's another thing we can come back to at the next meeting. I'm hoping. We'll be, it'll be tight enough at that point that we can talk about some of these little final finishing details. Again, we've already reviewed most of this. This is like where I pulled in. The wetland protection act sections and then just our by law specific things. I made notations of where nothing had changed or where things had changed here in this section. So I'm just going to keep scrolling because I, what I really want to get to is this section. Okay. So this was kind of the meat of our discussion. And this is where the meat of my revisions are because this is like the trickiest section, I think. Thus far of these regs. So we had talked about isolated vegetated wetlands verse vernal pools and how vernal pools aren't always vegetated. And I talked with Emily Stockman. She's our peer reviewer. She's a very knowledgeable. Consultant that we hire regularly for peer reviews. She knows her stuff in the field from a delineation standpoint. And she knows the regulations better than almost anyone I've met outside of DEP. So she's very good. She recommended that we keep IVW as IVW and add vernal pools because. So that they should be combined in the same section, and they do serve some very similar values like in the preamble, a lot of their functions are the same, but the definition of what they are is a little different. Their performance standards are the same. So do, does that make sense to you guys? So the definition of what they are is different. But if any, but their values, their functions and values are the same in terms of wildlife and groundwater, surface water protection and those things. And also if anybody wants to work in the more near them, the performance standards are the same. So they're required to meet the same standard for both. So the preamble, I think is pretty solid. The definition for isolated, just ignore that for right now, because I have to spend a little time on that. She suggested that the definition for isolated vegetated wetlands is almost exactly the same methodology as for bordering. And the reason for that is because she said basically a lot of what I said earlier, it makes it almost impossible to go out in the field or delineate and to delineate something like may or may not, like how does a delineator know how to interpret that in the field? And so what you'll see here is there's two separate definitions. There's a definition for isolated vegetated wetlands and a definition for vernal pools. I spent the bulk of my time working on the definition for vernal pools because I felt like that was the section that needed the most work and the most kind of wordsmithing. So what I have to do with this section is have a look at what the BVW delineation recommendations are and then just make sure that they're consistent here and that the wording is isolated and not bordering. But the idea being an isolated vegetated wetland would have hydric soils. It would have hydrophytic plant communities. It would not be bordering on something. It would have all of the same delineation criteria. It's just not bordering on a river bordering on a pond or bordering on a stream or whatever. So that was her recommendation. There was a bunch of other questions. Okay, so she doesn't like may or may not. She said take may or may not out. Well, if we're separately just defining vernal pools that solves the problem because we were just trying to combine it. That seems like a great. Resolution to our wishy-washy. Trying to incorporate every too much into one thing. Yeah. Yeah, I agree. I agree. Again, she said use the same methodology for delineation or bordering just change the language so it's isolated. Also, she made sure that we look at a specific section. So that's what we're looking at. So that's what we're looking at. In terms of if there had been historic alteration that disrupted the plant and soil community that. That we still have a criteria to evaluate that similar to like what happened out at that site on monarchy road. That we're looking for specific indicators. If the site is altered. So those all incorporate. Then she suggested defined vernal pools separate standalone. So that's what we're looking for. So that's what we're looking for. Sometimes like to answer some of our questions about it, like we had asked, well, what is the criteria for delineating? And she said, sometimes only a portion of the pool will key out. So like you could take a bunch of soil samples throughout the entire pool, but only one corner of the pool would have hydric soils. So she said. That's why it's difficult to have these. With duplicate definitions or duplicate delineation criteria. So we're looking for a lot of people about the buffer zone issue, like if we can extend the buffer zone. And she, Emily did say a lot of towns do use a 200 foot or 250 foot buffer around for. I talked with our town attorney and he said. We looked over the bylaw and he said, I don't think you can do that because it's not in the bylaw. It's not in the bylaw. It's not in the bylaw. It's not in the bylaw. It's not in the bylaw. It's not in the bylaw. It's not in the bylaw. Which would be like going through town council to do that. But what he said, we can do. Because it is allowed under the wetland protection act as well. Is make it very clear in our bylaw. That if there are. Going to be alterations to a resource area or alterations or impacts to wildlife habitat. Adverse impacts to. We can do that in cases that are not just enforcement. So we don't have to be specific, which is nice. We can just say. If we're reviewing a project and, and we, we. Our interpretation based on the evidence before us is that there is going to be an alteration to a resource area. We can do that in cases that are not just enforcement. So we don't have to be specific, which is nice. We can just say. If we're reviewing a project and, and we, if we're reviewing a project and we're reviewing a project, we can just say. The only other interpretation based on the evidence before us is that there is going to be an alteration to say wildlife habitat as a result of what's proposed. The commission can say works. We believe that this is critical habitat for the wetland. And the species that use it. And we're going to take jurisdiction over this now. We should be on very solid ground with evidence and documentation. If we do that. But. because we can still take jurisdiction, but we don't have to specify it's 200 feet or 250 feet, we can take jurisdiction over what we think is appropriate. Right, so like if there's gonna be a development surrounding the 100 foot buffer, that's different than a single family home, like, right, so we'd have some ability to make case by case calls. So I like that. Right. Compromise, I mean, it's still, not as clear as it might seem to be. Right, and the other thing is, and she and I talked a lot about the whole concept of like, this is loud, I was realizing my voice is really loud, talk to me with this mic. We also talked about the whole concept of like the complex of vernal pools versus like an individual vernal pool and whether having a complex would impact the jurisdiction versus a single. And she said she's seen single vernal pools that are in the middle of the woods with nothing around it that are some of the most productive vernal pools she's ever seen, and clusters where it's less crime habitat. So she said she doesn't necessarily think that we should base it off that too. She said it should be based on the habitat values of the resources on the site and not specify, well, we can only take jurisdiction over more if there's a complex, we can take jurisdiction over more if the resource, if it's appropriate based on our evaluation of the resource. So I think that's good too, because it's like, it doesn't matter if there's a complex around it or not, if it's valuable and it's gonna have adverse impacts to the wildlife, then we can do what we need to do there. I asked her, okay, so I asked her about including specific species. Now, I've done a little bit of research on this since our last call and the species that are listed here are the obligate and facultative species that are listed under the NHSP certification criteria. So that's why those specific ones are listed here, but let's not get hung up on that because I wanna show you what I did as far as the definitions here. She suggested that the strongest protections we can provide to a vernal pool are not just based on the physical characteristics, but the biological characteristics as well. And she had suggested that I or we look at the Natural Heritage Endangered Species Program, the criteria for certifying a vernal pool, which is exactly what I did here. So here's how I did this. The vernal pool must meet the following physical and any one of the biological criteria. So a pool or pond, which is in a confined basin or depression, no minimum threshold size in most years holds water for a minimum of two continuous months. Any one of the following indicators listed below is an acceptable indicator. So this is 50% vegetative community, obligate, facultative wetland species, observed pooling, presence of waterstain leaves. Is this to make sense, the broadest extent of pooling observed or recorded in said area? Yeah, that's actually witnessing that it's full, that the pool is full of water. Oh, I see. So if the pool is empty, some of the other criteria could be used, like the extent of waterstain leaves. What if it's half full? Well, so the way that it's worded here is that any one of these can be used. So if there's waterstain leaves that expand, so let's say somebody's out there doing the delineation and the pool is three quarters of the way dried out, but there's waterstain leaves that extend out way beyond then the extent of waterstain leaves would be the one that we use and actually maybe... So these are not indicators of whether or not it qualifies as a vernal pool, but actually like the delineation of the boundaries of the pool. I guess I was just thinking about the former, like is it or is it not? It's both, it's both. It's to determine it's a vernal pool and delineate it. So that's the guidance that we're giving people right now. I guess, yeah, the wording is just confusing. So acceptable indicator of, I don't know how, like it's how big it is. I'm not whatever we can move on, but yeah. I spilled that wrong. I think... Okay, yeah. For this extent of the following. Well, we can wordsmith that a little bit more, but I think... Maybe just that one word did it, but yeah, okay. Okay. Number four, when I was talking to my herpetologist friend, he also mentioned like crustacean, like shrimp, fairy shrimp or something. Yeah, fairy shrimp. Come up, okay. Yeah, fairy shrimp are obligate. Like they're exoskeletons, yeah. Yeah, yep. Yeah, but as far as like facultative and obligate in your beginning, you said these are the animals that are dependent, but if some are facultative, they're not like actually dependent. Yeah, well, so there's, this is the biological criteria section down below here. And so this is taken directly. I'm going to go too far. I just had a question on number five there. Okay. It's an area inundated by a hundred year storms. It reads fine to me, except it makes me wonder how do we clarify that it's inundated for a period of time and not just for a hundred year storm and washed out in the next day, you know? Can you say that again, Leroy? How would we... How we make clear the fact that it would be inundated and standing water as opposed to just inundated from the flood and gone within, let's say 24 hours? Well, so I would think that that particular method would only be used if none of the other criteria were present and that that would probably be based on an elevation. So they would have to survey it and determine where the survey boundary of the hundred year storm event would be in the pool. I think it's just another tool in the toolbox, so to speak. It wouldn't be... It would be like if there was no veg, no pooling, no water stain leaves, no evidence of any species in there, and no hydric soils, then we've got to use some criteria to determine the boundary. And I think that's why that's there, but I agree, I was kind of like... Is that original or is that from the state? That's from our original delineation criteria for isolated vegetated wetlands, which included vernal pools, although it wasn't entirely clear in the previous section of the regs that it did, but now it is. Yeah, it is a little... I don't claim to quite understand that one. So that would be... So, like I said, there's no other criteria available, but we see a visual basin in the location and we need a way to delineate it. And so how that would be modeled, it's actually... So they have a lot of... Computer software that can do modeling and usually what they do is they'll take the catchment area for the vernal pool or for whatever the drainage area is. And it's very similar to delineating a watershed of like a stream. It's looking at sort of the high points around the vernal pool and saying, if this entire area surrounding the vernal pool captured water, what would that precipitation volume look like if it's settled into the pool? I mean, I don't really know what more to say about it, to be honest. I think it just gives us another tool to... If somebody comes back and says, yeah, there's a basin there, but there's no other indicators. So it's not a vernal pool. We could say to them, well, you need to calculate the 100-year storm. Does that have like soils and stuff? Like what Laura was saying about drainage. I don't know why there would be a basin. It could be like weird glacial activity or something, but yeah, like is it combined with some evidence that it does pool? Is it just assumed that if there's a basin, it will pond if there's water? Well, so like, let's say you've got a field and then you've got a bowl in the middle of the field. I think that there is some assumption there that why is that bowl there? What is the reasoning for it? Like it could be a kettle hole, right? It could be like a glacial kettle hole and it's just dry upland, but that we have to assume that it's serving some sort of purpose in terms of storage of stormwater. It gives us, I think, a little more ability to protect it is all. Okay. Good to just further understand that, I guess. Yeah, it definitely doesn't hurt us. Right. Okay. No permanently flowing outlet. No fish, no fish populations and then supports obligator facultative species of amphibians or non trans transient microorganisms. Okay. So this was taken from then be here was taken from the natural heritage delineation criteria. So they, what I was saying is it could have any one of these as a biological criteria to determine that it's a vernal pool. So identification of an obligate species with adult wood salamanders, for example, frog and full chorus mated pairs, adult salamanders, spermatophores, marbled salamanders, egg masses, etc. Or one or more of the following from at least one obligate species documented by photos, videos or audio, coursing. And then it lists those same obligate species. So one or more of any of the following from at least two facultative species. And then, you know, the audio coursing, etc. And then the, there's also the, I think I've got to break that section up into two like I did with the top one should be two separate. So the states is five egg masses. For some reason I thought it was four, but you just grabbed this from the state. I did. Yeah. Don't forget to put your species names in italics. You're talking about the scientific names, Michelle. Yeah, yes. Yeah. Yeah, that will be like a final edit that we do just to, yeah. But I just need to get the content in here. Yeah, that's sorry. Just before I can get to this. Yeah. Of course. Yeah. No, that's, I can tell you, you're familiar with editing stuff. That's good. So that was my attempt to address our last round of comments on here. And then let me go down here. So the presumptions are. I believe the same. I don't think that that has changed very much. But yeah, we reviewed all of those and then the performance standards. I did change a little bit. I broke up a little bit. Any proposed work within 100 feet of an isolated vegetative wetland shall not result in the following. And then impairment of the capacity of the IBW or the vernal pool impairment of the area within 100 feet of the IBW or vernal pool. Impairment adverse impact to wildlife habitat within or surrounding IBW or vernal pool. Flood damage due to. So. Three. I personally would have a hard time saying that that's not going to happen with any kind of. Like. Well, I get, I mean any kind of significant work outside the buffer. I mean, how would that not impair wildlife habitat within and surrounding it? I mean, is it just. Well, that's exactly why that's there, Michelle. Okay. Well. Yeah, I mean, I can see where some things would be minimally damaged, but I mean. The animals that depend on these pools are living in the forest surrounding the pools except for two weeks out of the 52 weeks. I mean, I'm trying to give you guys as much. Regulatory authority. To. All right. Well, I'm not going to fight you for that. Like, I like it. I'm, it's good. It gives us basis. I'm just, you know, as long as it's not an overreach or something. Well, we'll send these to town council. Town attorney and let them make that determination. I don't like it. My goal is to protect. Yeah. I appreciate it. I just wanted to. I appreciate it. Sorry. Continue. All right. So flood damage due to filling that causes lateral displacement of water that would otherwise be contained adverse effect of public and private water supply or groundwater supply to prevent pollution of groundwater adverse effect on a rare species or rare vertebrate or invertebrate species. So the thing to remember here too is we have a hundred foot, no disturb. So no one should be in there anyway. No one should be within a hundred feet with any work anyways. These are here as a. A double, double secret, no, double public protection in my opinion to make sure that we have some leverage to protect if we need. That's great. I just have a question based on our last meeting about the endangered plant. And we don't mention, I mean, I don't know if that plant was related to vernal pools or even wetlands. Was it? We don't. The one that we were discussing at the. Last plant. Yeah, that one. So I'm just not, I'm seeing rare wildlife or rare vertebrate invertebrate species that I don't see plants. So. Should we add that? I don't know. Yeah, we can add it in there. I'll add that in there. I think it's, I don't think it's far fetched to include it. Let's put it that way. Land under water bodies and waterways. Thank you, Leroy, for spending some time on that. I appreciate it. I have, I'll be totally honest. I have not had a time, not had a chance to read through these yet, but I did plug them in just so that they were kind of a placeholder there that we could have a look at. And I don't want folks to feel. So rushed right now with this, like that we need to, because it, I literally sent this out yesterday. It's been insanely busy. And I am just trying to get through, you know, what I can when I can. So, I appreciate it. Did you add this content, Leroy? Is this your stuff? Oh, thanks so much for doing that. Most of the stuff is directly from Stay Rex. Perfect. Yeah, it's very, very helpful to have some assistance with that. Let me just, I don't know if I edited anything else. Let me just go through this really quickly and see. I may have done a little bit more. This is one of the sections that took you. Oh yeah. This section land underwater. This was really bizarre. It had like three performance standards taken from the state and the remainder were like axed out of it. And I was like, why was that? That was very odd. Didn't make any sense to me at all. So all of the state regs are added. All the state performance standards are added back in. On that section. As you can see, I haven't gotten to. The land subject to flooding yet, but I am working on it. So WPA, except we're highlighted or underlined. Oh, so. Under the, so this is just, I just highlighted those sections because I wanted to look more specifically at rental pools and how they're referred to here. I'm going to probably do some wordsmithing in this section. Because it does refer to vernal pools. And the reason for that is because. And this is the learning experience for all of us. And I wish I had known about this before, but it's new to me. You know, I'm still teasing apart the ranks myself and understanding them and learning them better. But the state doesn't take jurisdiction over vernal pools at all. It's only jurisdictional under our local bylaw and also the army corps of engineers has jurisdiction over them. Except. The only time the only exception to that is if the vernal pool falls within. Bordering or isolated land subject to flooding. And. The thing is if it is by default bordering land subject to flooding, if it floods, which rental pools do. So. I mean, I almost feel like there should be something in here that states. Vernal pools are assumed to be bordering land subject to flooding. Because. Do you see what I'm saying with that? Well, so that they can have jurisdiction over it. Well, but, but they do or don't based on their rigs. You're saying is what I'm saying is we, we take jurisdiction over them anyway under our local bylaw, but I would like it to state in here somewhere that vernal pools are presumed. To be isolated land subject to flooding because. They flood, you know, I mean, that is a function that they serve is that they're flooded in and dated areas that hold floodwaters. The boarding or isolated. I just presumed to be land subject to flooding. Because yeah, it makes perfect sense. And if I'm hearing you correctly, that means. That is a very, very little pool that we see in Amherst anyway, it forces the state to then cover under their ranks because it's land subject. The assumption would be whether we like so and for example, like in an or add, we'd have to call that out. But if we stayed it in our regulations, then the assumption is it is anyways. So yeah, you're exactly right on the money. So the state. Doesn't do vernal pools, but if we say it's land subject to flooding, they will, they won't just come and say this is actually a vernal pool and we don't do vernal pools. I mean, this seems a little bit. Like semantics and so not semantics, but it's definitely a definitions issue. We're talking about, I mean, I have no problem with that. I'm just trying to understand. So you're trying to trigger the state to take jurisdiction. Over vernal pools. No, it doesn't trigger the state to do anything. But what it says is that, that we are assuming. That the conservation commission is operates under the presumption. That a vernal pool. Is an isolated land subject to flooding. And so. We treat it as such and it is, it is fully jurisdictional as far as the commission is concerned under state and local law. So, so for example, if it went to appeal. DEP would be like, no, we're not considering that, but if it doesn't go to appeal, then that's just the presumption. We can ask a question about the boundary this there. So there's some more language about delineation because we just did review or what we put in for the bylaws. I know. Is this saying that mass DFW. Is the ultimate delineator of it. And then there can be discrepancies. And then it says an engineer must do it. So a second comment I have is we've been using. Expert, what have we been using? Competent source. Yeah. Is that in conflict with our. Can you specify where you are, Michelle? Are you on number six? I'm on six. Yep. And it's in conflict of opinion with the boundary delineated by mass fish and wildlife. The applicant can submit a certified. An opinion from a registered professional engineer. So I'm just, I guess, is that. Different. Is it in addition to, is it conflict with what we've been using as our acceptable sources? Like your. The third part, the peer reviewer that we often use is she. Is she qualified to do a wetland in the Avernal pool delineation? Or do you actually need a, is she a professional engineer then? So I think you're asking a couple of questions here. So people who are not engineers who are wetland specialists are absolutely qualified to delineate a wetland. I think. You, you raise an interesting point, Michelle, about the registered professional engineer and what I. If like, so just to throw a scenario out there. So let's say. Natural heritage says that the rental pool is like 3000 square feet, but the applicant is saying we think that the rental pool is smaller and we're going to hire an engineer to dispute that fact. And we're going to say that it's 300 feet instead of 3000 feet. 3000 square feet. Right. So that engineer would then somehow their credentials would give them some sort of. Authority over whatever the wetland delineator or the state did in the field to determine the boundary. They can submit that. And that would include hydrologic calculations similar to what we discussed up above. So I think that the reason for that is basically to give the commission additional information from which to render a decision. I don't think it is. Meant to supersede anything, so to speak, I think it's more or less just, you know, we can run hydrologic calcs to see what the engineer says. The commission can also at that point say, okay, we've got the state saying this, we've got. The applicant's engineer saying this, you guys can also hire a peer reviewer to do a third party analysis of it just to make sure it's accurate. Well, that's why I was wondering as if we went, you know, if it came to that, then the peer reviewer, could the peer reviewer be a wetland specialist like you said, or do that need to be another engineer, like, I guess it would need to be an engineer. Yeah, an engineer would need to stamp it. And we could hire another engineer to QA to see what was done by it. So, you know, similarly, like you could hire a wetland professional to look at a site and they could say, there's no wetlands here, we're all good. And then you send out somebody who's really good and they go out there and they're like, yeah, there's wetlands everywhere. And that happens all the time. Same thing with an engineer. They might say one thing and then another engineer says another. It's mostly just like having. Having something from somebody who's a registered professional to assert something I would, I would be very surprised and I haven't actually seen an engineer do anything kind of. Deceptive, so to speak. I just want to be sure it's not like it's consistent with how we've been defining our. Expert. The other thing is Michelle, just to be clear here, this is, this is border bordering an isolated land subject to flooding. So. Vernal pool is a delineated separately. This is a different resource. So if they were saying. We think within this vernal pool that there's a smaller area of isolated land subject to flooding within the vernal pool. That's what they'd be disputing. It wouldn't be disputing the vernal pool boundary. Because that's under a separate section. Okay, I'm sorry. No, it's confusing. It's very confusing language was popping out. Yeah, because they overlap one another. So, as you can see, I'm still trying to figure, get through some of these sections. Isolated land subject to flooding and riverfront still need some work, obviously. Buffer zone stuff. Okay. So I have a recommendation here on this from our. From Emily as well. And so I added in this language and I know we were sort of hemming and hawing about this. This is the language that I added in. So have a look at that. Did she recommend that as being acceptable? I mean, not that language specifically. But she, her language was you have to have an exception in there for a previously altered site. So like if the entire site is already, the entire buffer zone is already paved, for example. Okay. So your time I was zoning, et cetera. Okay. Exactly. Exactly. So that would be a redevelopment project or if it's in an urban area or like yesterday, you know where Michael's billiards is down off of root nine. I was like out behind Michael's billiards and it's where the fairing brook comes out after it's been culverted for like a thousand feet or whatever it is. And that stream is so scary when it comes to the other side. And it's just like beer bottles and just disgusting back there. And it's like, almost anything that you could do would be an improvement over existing conditions in a site like that, you know. So that's why I use the language that I did there. But it's mostly to say, like, if you're talking about an undeveloped untouched site, then yes, we should limit if we can the buffer zone alteration. But if it's a previously degraded site that's in really bad shape, then you guys can use your discretion. And I think that saves us from opening the can of worms of looking at a zoning map because you guys can just use your judgment. Yeah. Yeah, I guess. Yeah, so I don't know. Like. It says resource area degraded because that kind of takes us to a lot of places. You said, put this on your map away. The one was that you drive south. They just built a significant improvement over that resource, but I'm not entirely sure that was so end urban and all that was pretty much more than right. So, right. Good capture there. Yeah. So, and then I know we're at at one o'clock but I know we were still talking about setbacks and things so just that this is coming on to the end of this section so. Not as much progress as I would have liked, but I am making forward momentum. Hopefully, I'm thinking that the meeting on the 29th we should try to make a two hour session so that we can cover all of the additional revisions and there may still be a little bit here and there but we've got three hearings before the concom to make some final touch ups so. Okay, so we're still working on setbacks and limited projects. I mean, I made my changes. Okay, great. I don't know if you guys are on board with those or you know adjust them a little bit and that's fine if you do. No, I have to look at limited projects. Yeah, we haven't looked at that one yet. Okay, I love projects is pretty standard but we can yeah we can have a look at it I mean generally limited projects are. Projects like utilities, water sewer electrical. And projects that can't comply with the performance standards because there's a utility line and it's got a right of way and so there's no way to avoid wetland impact it's that's where the polls are that's where the line is and so. You kind of have to give them some sort of leeway as far as not being able to comply with the regs so that's what that section is about but we can have a closer look at that next time. I was going to tell you and I don't know if it's because of you or you should be made aware, but I saw Amherst highway division on Sealy Street, right where the, is it for broke crosses under. And they were patching holes with asphalt, bigger stuff crumbling all over the place. And it looked like they went out of their way to put in erosion controls while they were working. And when they were done they took them with them I was very impressed I've never seen a time to do that and such a. Not just a small stream crossing but you know it looks like it's 30 feet away because it's so deep down there so most people wouldn't even thought I thought it was pretty impressive. Yeah. Incorporate into general practices. Yeah, it really is. I just wanted to do that when they had the fill by the former ever just a couple of weeks ago but that made more sense the river's paying it's right there everyone can see it I was really impressed that they take their time with every little bit. So, either thank you or thank you to them through you. Okay. No, I hear that. All right guys, I know you're busy, and I appreciate your time so much, and we'll keep plugging away on this and you guys are both good for a two hour session on the 29th. I just wanted to just touch base of Roy like do you have potentially like a zoom update that needs to be made or just to like. That's a good point. I have not ever updated my zone. Okay, Aaron was saying that that that's what was keeping Dave so make out of a couple meetings so that might be one thing to check. And then if you can think of anything like it maybe like you joined before me, or I have no idea, but you try and start a few minutes before like that was. Wow. Okay, so you just keep pressing join join join and then it just works doesn't. Okay, but there maybe there's like a firewall. Yeah, and also, yeah, I don't know, Leroy, if you're having any problems with like spam and your spam inbox like maybe that's why you're not getting the actual link that was originally sent to you. The other thing is that the reason that you might be able to come in after a couple tries as a panelist is because we've actually we started the meeting and usually panelists can't or I'm sorry attendees can't come in until the meeting is started. I, as of joining as a attendee, doesn't work sometimes but does work others but I have no idea why like I literally sent you like four invites through zoom I'm like why is this not working. Did you get the interesting if you send me more than one because you, well, I sent you something and it bounced and I don't know if I had typed it in or not. It didn't bounce but are you getting that this meeting starts in an hour messages. I'm not getting those and I'm, I didn't get anything from you so I'll check it right now again. So, maybe his emails wrong on the invitation or something. That's a good point let's double check that right now let me just hold on one second. I do have one for you from 1209. So, that's weird yeah maybe check your spam or something. Because I, I took that. Did I know I didn't. Maybe yeah maybe check his email on the. Oh, you know what, there is one hold on, you're right there's an L missing from Gmail. That's why. Great catch Michelle. I am constantly dealing with these problems. There's an L missing on Gmail. That's exactly what it is. Hopefully that will save us issues next time. What a pain in the neck. I'm so sorry. I'm sorry. Hopefully it's working. Okay. Yes, with that we're closing this meeting at 107. Thank you everybody. Thank you guys have a great weekend. Bye.