 All right, so as we get ready to get started, I wanted to pass, we have the two things for us to do between now and March 15th, right? That's how we spill, we have a lot of life-bills, we're originating, we're also going to see 267, the RDS bill that's in finance, it's kind of like a bullet out comes back to us. So we're going to have to be somewhat nimble. There's a Senate housing bill that includes provisions in our first couple of sections that are going to be planned. And so whether we're going to be 50 or having a municipal planning team, we need to be able to vote. Doesn't matter which title, we'll need to be able to respond to that in a timely way, but that doesn't cross over. And food residuals are under discussion at the Act Committee in terms of being a feedstock for compost and chicken feed for the way to make this work. So we're going to need to be able to respond to that. So there's a lot to cover, a lot of ground to cover. This week, we're going to have to be coming to March 13th, he said, before March 13th, I guess. So we have the balance of this week, and we have the full week we're going to get back from down here. Okay, okay. So meanwhile, yes, ready on the solid waste bill, there's a short article here on extended use of responsibility, which we'll talk about a little bit. The people's copies, if you read this ahead of time, the conversations that we're going to have on EPR, so you can see the responsibility will be more meaningful. Thank you. Okay, there's also, it's just so people know, an overview of the procedure that ended on the constitution. We have Prop 9, all in power, right to clean air and water. Our constitution, we're not going to keep that up until really a death, until after a crossover, because it does, and we'll check this with the senate secretary, but constitutional amendments aren't subject to a crossover. So, but I don't want to wait much longer than a crossover deadline, because should we take it up, move it and pass it in the house enough time to dig in and look. So, honestly, but from what I've been reading, it will be an interesting conversation to figure out. What do we gain from ourselves by having tuition like that in the constitution? Well, Senator Berg, did this, Scott Cassel, asked, did he testify for this meeting? He, so I think we've, he came this fall, just because he didn't even try to speak. Okay, he wasn't, I thought, yeah. One of his associates spoke, he said. Oh, okay, that's right. Reference, Scott, thank you. So, Senator Berg, before we move on on the whole constitutional thing, I guess my interest in it is I signed down because I believe in the premise of it, but how do we protect individuals and property rights? It's going to be a danger concern for me as we move forward. So, yeah, Article 1, Chapter 1, and Article 1, like the likes of what we should have in this and property. So, from what I've started out, we're going to be, like, funding a sector and how we balance that off. I mean, I'm going to say, I think it's going to be pretty interesting to be able to figure out how we can have a tribal property rights swap, also affirming explicitly for ourselves that we'll even have to be in this environment. Especially given what's been going on at the federal level, where we're reversing things that have been in effect for most of our life, which I think this would seem, but it's happening. It's going to see the oldest administration will continue for another couple of years. Don't worry, any man that is already got a couple more generations, are you ready? There could be further updates that we might want to put ourselves in a better position to respond to. So, that's it for air traffic control. And we really have two or three other roads that we can see. And we have, like, a full steam ahead from here to March 13th. Okay. With that, I'd like to invite Melissa Bailey, Ms. Bailey, to join us, to the table. Are you going to fire us? Should we move the tissues? Hopefully, I won't be brought to tears. That depends on your response. You might see issues with this thing. There are now discussions as to whether or not it needs to come back here. Right, it was an agreement that we're now asking. In rules, it's happening. Right, it's not happening. But, yeah, it's happening. Thank you. Oh, there's nothing. Shared. Was there a witness? My mother was there, I think. So, I'm going to be ready. So, with that, good morning. Good morning. I'm Melissa Bailey with Vermont Public Power Supply Authority. Thank you to the committee for having me in. That is a beautiful photograph, by the way. Yeah, I'm just kidding. It's really stunning. I believe that that one is Morrisville, Katie's Falls Hydro. Okay. Pretty dramatic. Yeah, pretty dramatic. Thank you. Got the end of the question. So, we want to talk about the importance of community hydro to the VEPSA members. And that will come out in my testimony as the committee is aware. I'm here representing 11 municipal electric utilities in Vermont that represent roughly 6% of Vermont's aggregate load. VEPSA offers a variety of services to these municipals. I think the committee is aware those are listed on the third slide. Specifically, power supply rates and planning and financial services, as well as the legislative and regulatory support for these member utilities. And jumping into our overarching position on Vermont's energy and climate policy, as this committee has heard, VEPSA is supportive of meeting state energy and climate goals in the most cost-effective manner. The term cost-effective does not mean unwilling to incur costs. And sometimes I think it gets misconstrued that way, but really VEPSA's core position is that we should be efficient with scarce resources, rate payer resources, and taxpayer resources, and target those where we'll get the most bang for our buck in terms of making progress on energy and climate issues. And we strongly believe that a comprehensive strategy across all energy sectors is needed. There has been a lot of focus, as we've talked about, on the electric sector. And we think that a broader policy cover in all sectors is really going to best serve the state. As community-owned nonprofit entities beholden to our member customers, cost-effectiveness and equity are both paramount to VEPSA members and with any kind of policy change we're cognizant of who's benefiting and bearing the costs of those policy decisions. We have a desire to minimize cost shifting and really do any shifting of costs among rate payers in a mindful way, in a deliberate way, and not have that be a byproduct of, an unwanted byproduct of policies. And since this bill specifically, I think as drafted, would promote more solar development. I think we do have some concerns around whether unregulated private entities will maximize the public benefit and achieve the most for climate and energy goals. So, and the final point I want to highlight in my testimonies, VEPSA members have experienced some, to some extent, a disconnect in state energy policies and that would be the policies around when we get into talking about the hydro units, maintaining water quality and protecting biotic life and our other, and our goals to increase renewable energy and specifically in-state renewable generation. And so, to the extent practical, we'd like to see policies that are more in cohesion as we move towards potentially 100% renewable future. So, moving specifically on to the bill, VEPSA's supportive of increasing renewability in the electric sector. We're supportive of 100% renewable energy standard requirement, the so-called tier one requirement. We clearly see value there as conversations around increasing reliance on the electric sector as a larger portion of our overall energy use. It's important that that be drawing from clean energy. So, we're supportive of that. I just want to make sure we've been in the thick of this. Not everybody has. So, I don't know if it's worth saying just a few words of what's happening. Yes. So, as we don't have a bill in front of us, I'm sorry to do that. No, that's so right. You don't have the bill. Oh. Right. I'll speak at 60,000 feet on it. And I'm sure if you see all of it, I think we're going to be tempted. But so, the 267 says for tier one, where we currently have a roll of moving from 55 to 75, by 2032, that will pick up the pace that may all understand the grid of renewable by 2030. So, tier one, basically, short of the back to the house. It goes from 75 to 25. It's 20%. It really goes hand in glove with our stuff like beneficial electrification. It's really only beneficial if the power that's here, the fossil fuel you're displacing, is displaced by clean electricity. So, quite a power plant driving the power to their EV. The second major piece in that bill is to pay tier two, which says it's a carve-out in that 100% or 75%. So, you need to do local renewable generation to inspire that monster. That's how it should be. It has to be cited in Vermont. And it says 10% of the current law, 10% of the 75% must be about nature. The proposal is that going forward, if it's 100%, it will also be 20%, that's 100%. And the question is, if you're doubling the amount of the state generation, what of the engineering and financial impacts that kind of shift in made it very versus the power supply? Well, I would question the value of in-state. I mean, why is in-state more valuable than out-of-state if somebody else has a renewable resource that's easy to pipe here? And I think one is as valuable as the other. I don't want to speak. I mean, I think that, apart from what's come up in finance pieces and child crime, that's where the economic development piece is a component of this. I think people believe if, I'm just answering, I can the question and some of the concerns. The other thing I just want to mention, if you want to say a few words about how this would connect us or disconnect us with hydro-kebac over a bit, because in part that's one of the goals of this. Right, so there's another provision in the bill which says that as we go forward, that we, well I think it's actually, any expansion of renewable energy in the future will not rely on a large scale. And I don't remember the precise ways for it, you've been in the middle of it, but it ends up removing hydro-kebac as one of the sources I think for fulfilling the growth 200 percent. Part of that, I guess, again, I was in a conversation locally yesterday. It was having to do with if hydro-kebac continues to expand, but what is that impact, I think a combination of not only a negative impact on the environment, but also I believe there's concern about indigenous peoples up there as it relates to the expansion. So those are just some of the themes that have come up in finance. Right, but also hydro-kebac is invested in large-scale wind development in places where there's not many people. And so there's the question is, is it better? See, that has not come up. Is it better to, if they can get the power here cheaper, in my mind, it's better that they're putting it in a big flat place for no people than blowing off the top of another mountain. And so my concern with this in-state stuff is the environmental impact we have in this state. And there's a whole bunch of people that don't think blowing the top off a mountain and putting industrial wind on it has a negative environmental impact, but I believe it does. And I can, of course, see us putting another hydro-kebac in the state of Illinois. No, and that's it. Even our small hydros to me make perfect sense to be generating power. It's not economically feasible to put small hydro in because by the time you've been through all your permitting and engineering and regulation, you've spent more money than they can ever pay you back. So I'm just saying I don't necessarily agree with the economic argument about jobs because, like, lol, all the money the profit that's created goes gas metro is the parent company. So, I mean, yes, they pay a lot of employees here in the state, but still, the overall profits go back to a multinational company. Do you happen to know if the wind on the gas big peninsula, is that hydro-kebac? Does it even know that? I'm not sure which one is theirs, but I know they started a big one up there somewhere. So, I mean, it's just a pretty example of that it's a very interconnected system. So, we're adjusting it in one place. There's not a condition and unintended consequences that will, and we'll, so, thank you everyone, for surfacing these things. We'll have to dig into it before we would fill out. But, yes, did it add one more complexity to it. So, to me, I don't know if it's accurate or not, we'll have to get tested on it. That part of HQ's strategy is to sell clean, renewable energies in the states. There's a rack value associated with it. And, but they're backfilling their own demand with fossil fuel powered generation because they're exporting enough hydro that they need power in their own region to fill it on me. So, that would be, we wouldn't, I don't think we wouldn't want to have the whole pull of our eyes on that word in case. We just need to know. Yeah, thanks. Right. So, thank you for offering this very simple leave. And thanks actually for flagging the desk. So, that's what's operating at that point. Thank you. Thank you, yeah. So, these comments will be on the bill as drafted, which I think has been characterized. I see three components. One moving us towards a 100% renewable energy in the electric sector requirement by, I believe, 2030, increasing the distributed generation in state requirement to 20%, and then this limit on hydro-cubec, on the amount of hydro-cubec power that any utility could hold in its portfolio. So, again, that's the supportive of the 100% RES. I think the testimony in the building has been fairly consistent on that. I have not heard a lot of opposition to that provision. I mean, how that's not, or I mean, why that's cost, you know, affordable. Which, I'm sorry that you- 100%. The one, getting there sooner, which seems like great news. Mm-hmm. I'm just wondering how it is today that you're much comfortable picking up the pace that you have. Sure. And I think it does get to your point about there's a lot of interconnection in the electric sector around the region, and there is potentially some benefit to getting there first. I guess what I would say is existing resources, you know, all renewable generation essentially comes with the renewable energy credit that is available to be bought and sold separate from the generation, and there is an adequate supply around the region of renewable generation enough to keep those prices fairly low. I can't be specific on prices, but in the single digits of dollars for a existing, you know, rec. So because of the hydro that exists in Maine and other parts of the region, you can purchase those at a fairly low cost. There absolutely will be a cost to going from 75% to 100%, but it's not when you're looking at the trade-offs, it doesn't seem to be an unpalatable cost from our perspective. And it is, again, if every state in New England, I mean, I've tried to run through these scenarios in my brain, if every state in New England went to 100% renewable standard, then those recs would be in shortage and that would drive up costs. There is something to be said if Vermont is the first one to implement, I believe other states are either committed or contemplating this commitment to 100% renewable, but being a little bit ahead, essentially gets you some benefit there. And we do have a lot of existing renewable resources and I think that that sometimes gets lost in the conversation about how much new resources to promote. There is a lot already in the ground, specifically around hydro. So doubling tier two, I think you've heard testimony from several other parties there. There is a good deal of angst around the cost impacts of simply doubling tier two as currently structured. There will be costs, those are expensive resources to build. There's some concern that they're more expensive than the value they deliver to ratepayers, so kind of an above-market added cost. There are siting and grid concerns as well, which I think have been highlighted in testimony, but Velco, the statewide transmission entity, has, I think, put those costs of enabling the transmission grid to absorb or accommodate this level of distributed generation in the hundreds of millions of dollars. And I believe the department put just the power supply costs of procuring in-state renewable resources in the tens of millions of dollars. Tens of millions. I think it was 15 to 55 million. They had quite a range, depending on where the selection of where to locate. It would be exactly the location matters, and there is, I think, some concern that this, we're talking about a thousand to 1200 megawatts of solar would be needed to meet this, and there is some concern that we might simply run out of sites and actually not be able to build projects, in which case folks will remember that under the Renewable Energy Standard, the fallback is if you can't procure the resource, you pay the ACP, which is over $60 a megawatt hour and growing. And so I think there were some assumptions about, in that wide range of cost estimates, about utilities needing to essentially pay the penalty rather than being able to build due to the grid constraints and the locational siting constraints. So in terms of testimony, ongoing conversations have been going on. I think you've heard from a lot of utilities that they're asking for some sort of flexibility if this tier two requirement does get increased. To Senator Ryder's point, some utilities are asking for acknowledgement of regional resources. The flexibility that VEPSA thinks would be most valuable is placing added value on existing hydro resources that are in the state, our community-owned hydros. And valuing those as tier two resources would help keep them economically viable and keep in-state generation running. So as we're looking to increase the amount of generation that we actually have located in Vermont, our position is that we should do everything we can to maintain what's already been built, the investments that customers have already made in renewable energy as well as, so not instead of promoting new resources but as a compliment to promoting new resources. Isn't there a, just thinking outside the box here for a second, if we continue to move just towards solar, we've got a little bit of wind, there has to be some base load. And so without Hydro in Quebec, I know we've got a lot of small generators, but I just, I guess I don't understand right now, unless there's huge leaps in storage technology, then how do we provide base load with solar and wind? It's a, it's a really good question. And I think we need to, it's the complexities of the rec market essentially. So we, and I will show our power supply chart, but we're able to purchase base load power and that may or may not be renewable. I mean, we do have some renewable resources in Rygate and HQ does act as a base load resource. But the way that renewable energy standards or RPSs in the rest of the states are structured, you can purchase your power and then you can purchase your renewability elsewhere. So if you sprinkle a little pixie dust on a gas generator, it becomes renewable. Exactly, whether it's ideal or not, that is the regional structure that we have. So when getting rid of HQ or not qualifying it as renewable anymore, wouldn't that create a major hurdle because of the amount of energy that we gap wouldn't utilities have to spend a bunch more on recs? Yes, yes, absolutely. If HQ were not qualified as renewable, there would be a big cost pressure for the tier one. They would be possible to rate payers. Absolutely, and I think that that was a deliberate decision that the legislature made in setting the 75% current RES target was, we're going to set a more aggressive renewable target than any other state in the region and we're going to allow large hydro to qualify, which none of the other states, they all set their targets lower 20 or 30% and didn't allow HQ to qualify. So, and my understanding in this bill is that it wouldn't change, it wouldn't exclude HQ from tier one compliance or eligibility, it would limit that to 35%. We could use 35% of our tier one compliance could come from hydro Quebec. But yes, to the extent we can't rely on hydro Quebec, there will be cost pressures from other resources that would need to fill that need. So, I remember the price scheme for the tier one is roughly a dollar per megawatt hour and tier two, that we associate with something else. So, I can't remember, 30, 40, 60. I think in the most recent energy report that the department put forward, it was in the 35 to $40 range and currently, and again, that's capped at the ACP of 60. And the concern is that if we're not able to build, that that's going to increase, that that's the current, those are the current essentially values of tier two. So, again, we're moving on to some considerations that we looked at when we were in the context of this bill. Again, these have been touched on the support, the goals of the bill, one, getting to 100% renewable energy clearly does have some carbon reduction benefit, but the doubling of tier two seems mainly targeted at supporting local in-state jobs rather than carbon reduction. And I say that because as we've discussed, the electric sector is currently 2% of our carbon emissions. So, there's 98% of our carbon emissions are coming from elsewhere. So, if the primary goal were emissions reductions, we would probably, that would implicate a different strategy. That's a really good point. So, 2% of all purchases are, or 2% base load. So, from A&R data, 2% of our carbon emissions across, holistically, across the transportation sector, manufacturing, electric sector. The electric sector is only 2% of those. Yeah, the electric sector. So, a very interesting chart and way back in the first week where it showed the assessment by fuel type. One, to stay at the highest, and then if you look at emissions per fuel type, they also have the lowest emissions associated with it. So, what do you see from the other fuel types? Exactly, it's highly taxed, if you call it a tax, the surcharges we put on electricity while also being fairly clean. And so, our concern there, of course, is that household energy costs, the electric bill is a significant component of those. And, of course, we're keeping in mind that increasing costs in the electric sector make it harder for customers, for homeowners to electrify either their vehicle or their heating source. So, it's running in cross purposes to other state policies and goals. And so, I think this bill opens the conversation about what is the value of in-state generation? What is the appropriate amount of generation to have in-state versus import from other regions or other states, or potentially our neighbors to the North? Is 10% the right amount? Is 20% the right amount? And I would point out also, I think we received testimony from the Department of Public Service that there's much more in-state generation than what counts under tier two. I just wanna make that really clear that tier two is a very small subset of our in-state generation. We're talking about excluding the wind projects. We're talking about excluding any project that's over five megawatts and also the new date in statute that is July 1st, 2015. So, even our standard offer projects that were procured to increase renewable generation in the state don't technically count as new and they don't count towards tier two compliance. So, we do have a lot more in the ground than we're counting. And all of them are net metering by the fall of those in-state sectors? New net metering, so post 2017. If the customer elects to transfer the wreck to the utility, which they're compensated, so I won't say give the wreck, but if they transfer the wreck, they're compensated for that and the utility must retire the wreck. If the customer elects to retain the wreck, they can sell it, they can do whatever they want with it. So, not all net new net metering, but the net metering that the utilities receive, which is the vast majority of new net metering, that automatically goes towards tier two. How many people are paying out? I don't know, businesses might say they want to be building the plane. Exactly. So, they became the wreck as a cost, except people cost to them. Have you seen much of that? Are most people just letting it float through the utility? I would say 90 plus percent transfer to the utility because of the differential in compensation. They get more revenue for their kilowatts. Ms. Biller, would you just mention, so the cost pressure in electric sector under my state climate goals, do we know for sure that this is going to increase electric costs and over what kind of period would it increase electric costs? Because I remember in mine, as we talked a little bit about, you know, we're talking, there's some unpredictability there. Tier two will absolutely increase. I mean, you're talking about, I'm sorry about that. Oh, that's the emissions. Yeah. I mean, there have been different rate increase numbers that you've seen, you know, in the five to 10 percent rate increase. There are a lot of variables, but it will absolutely increase costs in the electric sector because buying in-state generation costs currently $30 or $40 more, a megawatt hour. Right. So, we know how much it'll cost. I mean, what we're looking at. For overall state costs? Well, the only one that's cost pressure in the electric sector will undermine state climate goals. I'm not quite there in agreeing with you. I really don't know if that will happen. I think in part it depends on what those electric costs actually look like and whether or not it'll make that kind of an impact. Such a negative impact. And I have not, I think it's additive, right, I think that our concern is that we have a lot of cost pressures in the electric sector. We've kind of had this conversation in the energy efficiency utility realm as well. Whether a two percent rate increase or a five percent rate increase, I mean, to your question, where is that tipping point where it makes it uneconomic to go to an electric vehicle or a heat pump? I think for electric vehicles, the operating costs, it's a fairly compelling difference between an electric vehicle, operations versus a gas-powered vehicle. So I think there's potentially more room for increasing rates. I did recently see the testimony of the department comparing heat pump deployments in WEX territory and GMPs territory, and that's maybe a five to eight percent rate difference, and it actually makes it uneconomic to put in a heat pump. And I know WEX is very cognizant of having high electric rates and being concerned. That will, yeah. But in terms of an exact rate impact, I don't think we have that. The generation around who's got higher and lower rate increase is it related back to the utility scale, like the smaller, that's a number that we need higher costs for a while and not necessarily. Not necessarily, I don't think. We actually have some of the lowest residential rates in aggregate, but even within our members, our members' rates range probably from eight cents to about 22 cents among just, among our 11 numbers. So it's a variety of factors. One of those factors is whether you have a hydro resource that's in your community. And just to make sure I understand what you were saying. So is your concern around meeting energy goals that the more expensive electricity gets, the less attractive it is for people who have electrified existing fossil fuel boats? Yeah, exactly. Oh, is that right? So you keep focusing on net metering, and if we depend largely on net metering to meet these goals, isn't that some of our most expensive energy and doesn't that affect rates pretty dramatically as well, if that's where we're developing? Yes, I would agree with that. Much of our tier two deployment so far has been net metering. This bill doesn't explicitly expand. It's silent on net metering, but we do have a concern that raising tier two to 20% would encourage more net metering and it is the most expensive way to meet tier two. That's what I was thinking. Thank you, Tom. Can you interrupt me upon an error, please? We were looking at some amendments in finance that would take into account any new, well actually it's being drafted now, any new renewables to take into account places that are already restricted, and to say that they should not be taking big chunks of new renewables until the other areas where there's room, there's a location to be filled, and that the larger net metering activities might also be curtailed with testimony that the smaller net metering were added to a degree of nimbleness and flexibility that was one could accommodate, but the bigger ones weren't. Challenging to areas particularly where there was constrained electricity. So there'll be some changes in the finance before it comes here and those for it. I'm looking at drafting some amendments that we'll be discussing this afternoon or tomorrow in an effort to address that. We haven't heard from WEC recently in our testimony that got calls into Richard's. You were, the chair was asking about what utilities, which, what makes it difficult for utilities and that two numbers always seem to come back to me is how many customers do you have per mile that separates utilities into their efficiencies and what percentage of your customers are homeowners and versus commercial industrial because you can coerce commercial and industrial to use electricity at different times a day that it doesn't, that uses space power that might otherwise be lost. And I did, and you represent a wide swath of municipalities, each of which has probably pretty separate houses per mile and customers, industrial versus homeowners. So I think that's what finance is looking at right now. So that came in here. Tell me more about it. And I think you've nailed kind of the two issues. There are kind of two cost drivers, I think as we look at tier two and increasing tier two and one is the grid related costs, the infrastructure of what does it take to accommodate this electricity. I mean, I think to Velko's testimony, we would literally be exporting solar electricity during a lot of hours of the year. So the grid constraint and the grid costs are one bucket of costs and then the power supply costs are kind of the separate ones. How much more expensive is it to buy solar or wind or something else than something else? I'm just going to leave you to it. Your people have to pay for the rather high price, Frankie. I don't think you should almost call them your people. And you're so full of it, you're crying. Usually, the go ably represent here is taken today. I mean, it's immutable. Frankie is expected to expire in two years, I think on the current law. And that would reduce the amount of money that utilities are paying for the rather high cost of what currently in the right age was $50,000, $5 million a year, $50 million over 10 years. Unless Massachusetts wind comes on and then there will be $54 million over 10 years. Those are generally real numbers. I mean, I think the rate we're paying for ride gate right now is about 10 cents a kilowatt hour and that would include the renewability of that plant. So is it above market, 5 million new referenced? Absolutely, it's more expensive than market power. It is a renewable in-state resource. So we're neutral on the ride gate bill, the extension of the contract. It is paying it slightly more for an in-state resource. And if the state's policy is that we want to have some of our own generation supplied within state resources, we're not in opposition to that, provided that the rate is reasonable, which I think the current rate is reasonable. So I'd be happy to testify on the ride gate bill, but. My question is, ride gate would terminate and then new renewables would come on, would they be less than that? No, new renewables would be more expensive to develop than the ride gate, yes. Yes, new biomass is probably not viable. So this is kind of similar to our hydro question that Bepps is proposing here. How much do you invest in keeping what you have operating versus closing down a 20 megawatt plant and then trying to replace that with a new resource that will be more expensive to build and site and permit? I'm sorry, I know I'm... That was good, that was helpful. And some are in this bill, and some are not in this bill. The tree-blower part sector is just... Yeah, yeah, this part is all right. Well, and I do think it's important to bring these kind of competing discussions or complementary discussions together. So my next three slides are pictures, so hopefully we can go through those fairly quickly. This is just to try and illustrate the interplay between the power supply that you purchase. This is where we get our electricity for our 11 municipal members. These are the different sources of purchase. And so you'll see a great deal of diversity there. System Mix is what we're buying from ISO New England. There are either contracts. Hydro would include Hydro-Quebec as well as internal Hydro. And then the next chart shows our renewability in compliance, yes. The purchase of those purchases, you buy as a block, you know, and then as opposed to part of the electric thing going out and doing something. Yeah, Vepsa does the power supply in aggregate. It is a little bit more complicated than that, but yes, we are able to at least, to the extent that we have economies of scale from our 11 members, we're able to do that. And then each member decides individually on each contract whether they wanna participate or not. So for renewability, that's demonstrated, as you'll see here, almost exclusively through Hydro-Power. That wood, I didn't check that maybe Rygate, that would be constituting wood. Solar would be mostly net metering and some standard offer. And that's looking to comply with tier two in this picture here. And tier one, obviously, the overall renewability. So this just shows that there is a great deal of diversity in our power supply. And when it comes to demonstrating renewability, we are selling high value wrecks and purchasing the lower cost wrecks in the interest of keeping rates down for our members' customers. So you're 37% non-renewable. Where does that come from? The non-renewable. So that's, if you go back one more slide, sorry, the nuclear, the Seabrook, is a fairly large component of that. That's a five-year contract. So that's not a long-term contract. And we're looking at what options will fill that gap when that expires. But a big chunk of that is nuclear, which is carbon-free and non-renewable. What is that contract? I think 2022. Yeah, pretty soon. Yeah, they're actively looking at most likely wind and hydro to replace that chunk that would come from out of the state. Thank you. And then obviously some of this fossil fuel, what we purchase on the market. This just shows net metering deployment. This is just showing that we are seeing aggressive solar deployment in Vermont. The net metering program has been largely successful in getting solar developed here. And there's breakdown with all of our individual utility members. And that's largely a result of the attractive compensation that's been paid under that program. In addition, we've touched on there are more cost-effective ways to deploy solar than net metering. These are projects that VEPSA is pursuing with the PPA, with the developer. Those are staff from Encore Renewable Energy there, cutting the ribbon up in Morrisville. And these solar projects are, well, that's one that came online. But these are all scheduled to come online this year. And this is a direct result of the Renewable Energy Standard tier two. This is, we're building projects to satisfy our tier two need. Senator, the demo. Is, when you look at your, the people, the units that you represent, is what they have in common? Generally, they're about micro-bite, hydro, and the rest of other places. What distinguishes them? Group from the rest of the local power purchases. I can't say what distinguishes us. About half of our members, and I'm gonna get into hydro right now, about half of our members own their own hydro resources, but we have members that don't own hydroelectric. Let's go ahead and do this. Okay. Sure. So overall, an aggregate, you know, VEPSA's members own enough hydro power to generate electricity for over a thousand homes. It's just a graphic there. And the list of the members that do own hydro facilities appears here. The benefits are this is locally-cited, it's renewable, it's fairly low-cost, and it's complimentary to solar generation. That's a point I had meant to make earlier on. That as we have this tier two conversation, we think resource diversity is really important. Having all of our local resources be there doesn't make sense from a power supply portfolio. Hydro and solar have different load shapes. They provide electricity at different times of the year and times of the day. And that's a good thing from a power supply planning perspective in terms of minimizing risk. And the challenges we've seen in recent years around our hydro is, as I alluded to earlier in testimony, going through re-licensing efforts has typically reduced output 30 to 40%, and that's an adherence to the new updated water quality standards. So plants need to get re-licensed, I believe, very 40 years. So there has been a lot of change in how the state implements water quality over that time. And so when a plant goes in to be re-licensed, they are seeing a pretty big, they are taking a pretty big hit on their output. And we've had the Morrisville units and Lindenville have gone through re-licensing, and the remaining four, with the exception of Barton, are coming right up on their re-licensing and expecting to see reductions in their output. And the concern there is that they have an existing resource that's located in state, it's sending value directly to the community. No new environmental impacts. There's no impact, exactly. There's no grid impact, because those have been absorbed, and it's making it harder to meet our renewable energy goals to have this reduction in output. And is that the ANR implements on behalf of the federal government, or do you figure what it's called? 401C? 401C, yeah, yeah, that's exactly right. ANR implements, there's a portion of the Clean Water Act that the states are responsible for interpreting and implementing, and there's, I think there's differences in how different states implement that federal provision. But ANR's interpretation is that they cannot look at economics or renewability of the generation in issuing those water quality certificates. They are able to look at recreation and aquatic life, but not overall climate or energy considerations. So is it less impounding or bypass, what is it that they're requiring? Yep, I think, and I'm not a hydro expert, but with that caveat, they want the plant stopper as close to run of river as possible. So less impounding, only one of these, the HK Sanders in Morrisville is the only one that is a reservoir, and they want more bypass constantly around the clock in all hours. Oh, more water flowing over the dam in all hours. Okay, select, it's more difficult to select, peak use hours too. Yes, it's more difficult, yes. So HK Sanders in particular has had a very hard time, and I don't know how familiar folks are with the Morrisville relicensing, but they're finding it's not even economic to operate that dam under the reduced flow. And Darian, a little bit of a conundrum about whether to pull out the dam, which would drain the reservoir. Which seems absurd when we have dams producing low-cost, base-load energy, and it's happening all over the state in an event. We are picking, we are choosing one environmental benefit over another. And I remember talking about this with Senator Westman when he was going through the Morrisville bank, and he was saying they're gonna make it, so we can't even run this great resource that's been there. Any idea, it's been a long, that thing's been producing power for a long, long time. Early 1900s, most of these are out. The way I understand that. And so if we shut this thing down, what do we do? Do we blow the top off another mountain and put up a bunch of windmills? Do we fill some more farm fields with solar panels? And so what are we lending off? What exactly? The reason for shutting it down again was, they're not letting them use enough water to make it economically feasible. Morrisville. No, those are separate hydro units. And HK Sanders, all three went through re-licensing. HK Sanders is the one at Green River Reservoir that's having the most difficulty. It's very small, and most of the value of that plant did come from the fact that it was a reservoir and they could essentially release the water to do peak reduction. So that value has basically been erased, so just generating the energy is providing minimal value. If you have what these utilities charge from the electricity they sell, would they be in concert with a percent of their own generation? Would they look down on this somewhere alive? No, and I think that just gets to, there are so many variables that impact utility rates. One of them you've alluded to, which is customers per mile, and your mix of customers, two of them. Swanton has probably the lowest rate. Swanton of our members, Barton, has the highest rates. So there are other, I think, factors that go into Barton's the second. That's the second largest percent of its power supply coming from higher. Is there a shortcoming of customers per mile? There's shortcomings in poor management for a lot of years, I think. The customers per mile impacts at Barton, that whole municipality has had some questionable management that just cost them a lot of money over the years, and that's part of the problem. I think a big part. And I'm speculating, I think Barton does not have a lot of commercial and industrial customers as well to offset costs. So just, it's a little bit more complicated than to say those with hydros have lower rates, although it certainly helps keep rates low in some cases. If one of these companies just said, we quit taking it over by remount power, or directly to be taken over by the local large utility, what the customers just exceed increases or decreases? Some would see, I don't want to speculate too much. Some would see increases and some would see decreases. I mean, again, some of our members have much lower rates than the other utilities in the state that are not public power utilities, and some have slightly higher, Barton happens to have slightly higher rates, but Barton's rates are in line with Vermont Electric Co-op's rates being kind of the neighboring utilities in that area. So they wouldn't see it. Yeah, I would try to be quick in wrapping up. I'd like to put one more quick thing. This whole conversation here is very interesting to me, because we're talking about trying to go to more renewable. We know that we need some kind of storage for some kind of base load. Yeah, at the same time, our own ANR is making these small hydros less efficient and less able to store power. Some of these things can act as a battery, and we're saying, no, you can't act as a battery anymore. Instead, we're going to buy lots of Tesla batteries and hang them up on people's walls, which the expense and the energy to create a battery. And then what do we do at the end of life with batteries? It just seems counter to what we're trying to do as a state. Well, remind me again, ANR is doing this in interest of habitat, something. Yeah, that's right. Okay, thank you. Run a river. Right. Right, and the gridder's in the river. Yeah. But what this brings to the table is that it represents many different places. The rest of the witnesses can represent one place. So this is, I guess my questions are, we've got a lot of different control groups, and this one's the hang. Try to see what kind of, compared to one another, where is the rest of the folks that come in and tend to have one point of view of any additional work. To aggressively, that fits very totally. Moving on to our proposal around hydro, and I did put out an amendment, or circulate an amendment, and to be explicitly clear, we're not looking to change ANR's approach to relicensing hydros. What Beps' intent is, is to find what we consider a win-win, a hybrid solution that allows the dams to keep operating and be economic and deliver value to the communities, even given reduced output. And so that's, you know, our overall request is to make these locally-owned hydro units tier two eligible as a way to bring value and to avoid having those ratepayers then have to procure more renewable electricity from new, expensive resources. So this is our recommendation. Again, this is to the extent that the state wants to place a value on in-state renewable, which Beps' does feel is important, and there is benefit to that. It should acknowledge existing in-state generation as well. For these units in particular, the RECs would be kept in-state. These would be used towards tier two compliance in-state. So as we know, even though we have renewable energy generation in the state, a lot of those benefits are flowing outside of Vermont. And again, some of these hydro units were, you know, they're centerpieces to the community. They are the reason that a lot of these utilities emerged. They were the, you know, Unisburg Falls, the dam is right in town, and it was the basis for the actual. The basis for the development of the whole community in some cases. Yeah, so there's a great deal of, you know, pride and value that the communities place on these assets. So tier two, which is a true kind of check, I remember as you recall the tier two RECs, that they only went to new generation. Is that generally true? I think we're in parallel with that one. Yep, the tier two right now, the requirements are under five megawatts and came online after July 1st, 2015. And I think since the REZ statute was implemented, our experience has shown we weren't aware that these reductions in output were going to be coming. So I think that's one thing that we didn't understand. I think when the REZ was initially proposed, it was assumed that all in-state generators would continue to generate at their historic levels. They're resending to a changing, regulatory environment. Makes sense. It's a creative idea. Yeah. And we want to pull out that work our way through it. Sure, so we just see this as kind of bringing those conflicting or competing state policies into better alignment. Not saying that habitat is not important and that A&R isn't furthering an important goal, but this would, our energy goals are also in complement are also important. And adding this value, bringing this additional value, one avoids the need to purchase other replacement sources and also would give the hydro owners more certainty around making investments in their plants to improve the productivity. So they'd have some capital freed up to potentially operate more efficiently, get better output even with the reduced flow. One other point about the whole run a river reduced flow argument. Whatever wildlife is in that river has been in some cases dealing with that increased flow for their entire existence for the last 100 years. So the environment, whatever it is, I'm sure has made the evolutionary changes necessary. We've already selected, we've already selected a rapid Darwin. So that's, I think that's pretty much my testimony. I mean, we did have some recommendations on the HQ limit. Again, the 267 as drafted has a cap on the amount of HQ that can be used for tier one compliance. We're not advocating for a cap, but to the extent the legislature decides one is appropriate, we would just ask that it be the same across all utilities. And setting broad policy essentially, as I mentioned, the utilities are asking for a degree of flexibility if we contemplate increasing our renewable requirements. And that flexibility has come in different flavors from different utilities, but for VEPSA in particular, we're looking at flexibility to use what we already have. So I've introduced that as an amendment to the bill, and we think that's a valuable change now because we are embarking on relicensing, kind of in the short term. So I have a quick question on cost related to site. So when we did Act 177 for a year, we did some sort of regional local control, financial reference, et cetera. And then working on the viewing 2.0, Carter was to try to adjust the siting and the price to get generation to bring right to the table from Leggeco, and engineering now is the five projects to be well-cited, not just aesthetic, but in terms of load, is the current regulatory environment delivering projects that are well-cited in terms of generation next to load, and then took a subversion to that question and next to sufficient transmission infrastructure to efficiently distribute that power. Yeah, I would say not. I think that the Act 174 provisions that you alluded to gave the communities a bigger role in where which sites were desirable for development, which is separate and distinct from whether the grid can handle the added generation there and is separate and distinct further from whether generation is adjacent to load. So I do know that there are provisions within net metering that I think make, that do give a little bit more compensation if you have 50% of the off takers are adjacent to the project. But in terms of my understanding is that there's not an incorporation of grid conditions in either net metering or standard offer or kind of the regulatory scheme more broadly and that those determinations are still being made on a case-by-case basis. We've seen the PUC deny CPGs for projects in the Shiai, but that's in my mind a reactive approach rather than proactive. Well, so that feels to me like we talked about that, the one trying to aim for that kind of engineering assessment in front of some research have projects proposed that would make sense and would work really well. How about interconnect costs? Do they end up being, is that really sort of the chief mechanism for filtering? Like the interconnect costs go high enough if it's not a good location, then that flushes. So those projects don't even come to the PUC or is that not enough of a deterrent to having to have poorly-cited products in the low perspective proposed? Sure, I think the fear is, trying to think of the clearest way to say this, yes, the interconnect costs can be a gatekeeper and a barrier to developing a project. If a developer wants to connect and we say it's gonna cost, the price tag will be big, they may look for another site. The implications of doubling tier two, that policy, if the utility is on the hook to procure more in-state resources, even with a big price tag, the utilities may be forced to say, yes, I will buy your output at this high, high rate, because obviously interconnect costs just get embedded into the rate, right? People say the developers pay, but ultimately that does get passed on to the consumer. Great, well thank you, I just wanted to check because before talking about any kind of expansion on the operation, I think we better have sort of output in-state engineering, sort of the feedback part of how we plan and we'll try to go with that. Well, we're not really planning right now and we really haven't, we've let the developers cut up. Why is the promotion, so tier two doubles and there's going to be more generation data that's passed on that, then we're getting pressure for more projects or whatever we want to call it, but. But we still don't have an efficient way to, other than the PUC say no, to stop projects that are, where projects are necessarily being invested. Right, and so that's why I wanted to check, so right now I'm here. Well, if it's reactive, it's not quite as good enough. Yeah, my understanding is that conversations come up a little bit in the finance committee and they're using the terminology location versus citing, citing being the aesthetic community concerns and location being, where does the grid handle it? In order to spread media. Yeah. To me, that's the important part of our downfall is that we haven't given the department or anybody else the charge to say, build a map, show us where we need it and that's where we are going to let developers do us. I think we did one of them before in 2017. So it's now we're being in a good state to see what's working or not working. We're going to try to further change. So thanks so much. Thank you. I appreciate it. But Mr. Crowley, the start of the run got very long, but there are a lot of different questions on this. Can you, would you like to reschedule or is 15 minutes of time for your presentation? Well, 15 minutes would be enough time for me and not sure if it'd be enough time for you guys. You've noticed that would work. Which would I, you know, I would. So let's. Press reschedule. I could do this now or I could reschedule. So we can have a thoughtful time. It feels like a little bit of a speech to it. She's, I told her to be time for this little reschedule. Okay, so she's waiting in the lanes, okay? So, I'm fine with the frame now. We have, let's go, yes, let's go ahead. We'll take the long reschedule and then we'll probably do it. Okay, so I have some copies here, but I'm probably not going to go directly off of this. Okay, so I'm Steve Crowley. I'm the energy chair for the Vermont chapter of the CR club. We're a group that operates in the state as a chapter. We're also a nationwide organization with something like, you know, several million members around the country. We have about, I think it's about 3,500 members in state. And we've been working on energy matters for several decades and other issues as well. Nationally, we had more of a focus on, say, wildlife and forests and wilderness until about 15 years ago when we made energy and climate issues our top national priority. And I had the opportunity to work with the national CR club to make that change happen. And then I chaired their campaign for several years and had a chance to work with states all over the country on different policy matters. And so it's been interesting to watch Vermont sort of sometimes be a leader and sometimes not so much be a leader. But I think we're, it wouldn't be fair to say in too many areas that we're leading on any of this right now. And it would be great to see Vermont pick that up again. So what I'd like to focus on here with regard to S.267 is primarily the question about the tier one concept. And I wanna raise some questions about whether that's generally met by renewable resources at all or not. But let me start with addressing. You know, we can just let you know. So we're taking the top nine off the table. We have a whole lot of power, so. Oh, okay. Oh, okay. We've seen a profit in time. Okay, thank you. Okay, well, that's helpful. So with regard to tier two, we strongly support expanding tier two to 20%. We would suggest going further than that. We would be, it's our view that it might be narrowly defined right now and could be expanded in terms of what we consider tier two, the higher quality renewable energy, probably in several different ways, expanding to include more local smaller hydro is one interesting thing to think about, community, solar is a handful of different things that could happen around Vermont with smaller scale distributed generation that make a lot of sense. Let me ask a quick question. So we've heard that in finance and here that this is not going to necessarily reduce our greenhouse gas impact. So can you tell me how you sort of square that with your thinking around some of your priorities? Well, we think that tier two does and should. When we talk, I mean, let's have to be a little careful here because renewability and carbon neutrality are not the same thing. Right, right. So that's important to keep in mind. And I think it's an important question to ask, you know, what's our priority? Often they line up really well, but they don't always line up really well. So I think that's part of the question. But I think it's the whole question of whether it's more or less renewable and carbon neutral or central to our thinking about this. So, you know, we certainly think that the tier two resources are a huge economic development engine and we have seen that sector of the economy grow rapidly in Vermont and then decline as our local generation met various standards or caps. Can I check in on that? So when you say decline, today's not what day it is. I'm thinking primarily of jobs in the clean energy sector, which were a few years ago were up to what, 17,000? I don't have the numbers on top of my head, but they have declined by a couple of thousand in that time. We just got data from the Department of Public Service that doesn't have any impact on the board. I have heard it from Renewable Energy, Vermont. Okay, well, we should probably share that. This shows that there was, in general, they have, they do absolute head counts and then they also do a percentage of, whether you're part-time or full-time, they sort of weigh it in that count. Okay. We're back in job building, total lenders, and a higher percentage of them, those people are working a higher percentage of their total job in the end of the year. But they changed the metric of how they stay in, and so it could be someone's parsing that. But also, we have to acknowledge the point that we can't continue to pay three times as much for power as worth and cost shift that on to people who are not met metering. And the point is those jobs were growing exponentially when we were giving an excessive incentive. I think there's truth to that, yeah. But I think your point is, it adds to my point that the kinds of incentives we offer translate directly into development of that sector. Right, but we should be developing where we have the most impact, and net metering has had a big impact, but it's the most costly way for its power. So there are better ways to produce it, but the net metering does provide many jobs, and there's the balance, if we focus on the very high-cost energy that produces more jobs because it's less efficient to build those systems, are we really making progress? And I say we're not because that cost is going to be passed on to a lot of people who can't afford their power bills today. Well, I think those are important points. What I would suggest is setting targets for how much carbon-free power we need to generate in-state or nearby. And if our policies are supporting that development path, then our policies are right on target. If we're falling off of that development path, then our policies need to be more generous. If we're exceeding that, let's pull back, but let's set the targets to where they need to be based on science, based on what we know about. Primarily, my thinking is in terms of climate change and the need to get to carbon-neutrality, by 2050. I think that the science is really clear about that. The only place where it's fuzzy is that might be way too slow, but that's what our state goal is right now. And so if we're on track with that and our renewable energy development puts us on track with that, then we're offering the right kinds of incentives. If we're falling off of that path, then we need to increase incentives. That's my opinion. I've heard it from other folks, because if we move to 100% renewable by 2030, every utility that's provided instantly has supported, then once someone might say, okay, if we've created that obligation for them, why not have them solve that puzzle as economically as possible? Why? Why in-state versus out-of-state? Well, let me address that by, I have a few comments about tier one generally that I think will address that. I'm not a big stickler for state boundaries, even international boundaries, but there are real-world considerations that come in related to those things. It's particularly control and verifiability and we know what we're getting and do these projects meet standards that allow them to be cited. If they were, if there was a location in Vermont, could we tolerate this here in our state? So those things all are important factors. But let me address tier one generally. I have great concerns about this because I think the concept is fine, but where we turn out to get our power, which is primarily Hydro-Coback, something like 50% of our overall power is either direct purchases from Hydro-Coback, which is, I think, now I'm going back a few years because that's the latest data that I have, but it was about 23% direct purchases and about 24% the RECs, the unbundled renewable energy attributes. So I think it's worth looking at what we're getting and in this case, I think there are real questions from that source, whether that's renewable power in the first place and secondly, whether it's carbon neutral or positive. And so to address the question of renewability, well, in our statues a decade ago, the size cap was lifted. Used to be 200 megawatts, before that it was 30 megawatts, other states say 30 megawatt cap on Hydro. Now we don't have any cap on the size of Hydro. And that's a little arbitrary. I think there's probably some big projects that are okay, but by and large, the larger projects involve two things, well, several things that relate to the question of renewability. If you look just at the flowing water, it's fine, it's renewable, it keeps on coming as long as it keeps raining. But if you look at other aspects of the resource, and our law is not narrow in terms of saying just water, it says if you're using a resource faster than its regeneration rate, then it's not renewable. And so, well, what has to be regenerated in the case of some of the large hydro projects, if you're going in there and cutting hundreds of square miles of forest, well, if you're doing that for the purpose of producing paper or producing wood products of any kind, that's not gonna be considered renewable. But we do that for hydro. We wipe out hundreds, Hydro-Quebec alone has something like 12,000 square miles of reservoir that used to be forest and peatland. Vermont's share by percent of terawatt hours is about 100 square miles of Quebec that has been clear of forest. So we close our eyes to that. We don't consider the issue of the fish resource in the rivers, which has been poisoned with methylmercury and is no longer suitable to consume and has caused health problems by people who depend on that resource for food. So there's another strike as far as what's actually a renewable resource. The source of the methylmercury? The source is the naturally occurring mercury that's in the soils and in the biomass that's part of the soils. And once it becomes in the reservoirs, once it becomes flooded on a regular basis, then that develops a whole food chain of bacteria that do that conversion from an inorganic, pretty inert form of mercury to this methylmercury that then becomes absorbed in the fats and works its way up the food chain so that by the time it gets to the salmon and top of the food chain, fish that the folks there eat, it's at such high concentrations that it'll make you sick. So when you're talking about the environmental impacts, do you, does your group look the same way at the mountaintop wind projects? Because they clear cut, they completely change an isolated environment just to something different. Yeah, there's no question about the fact that it changes a ridge top. But I would say this, I would say that if you're looking at something like the impacts of a wind project, if you think about acres per megawatt, a wind turbine, a big three megawatt wind turbine might take three to five acres per tower, right? So that's about an acre of megawatt. If you look at solar, that's a field of solar panels we see all over the place. That is more like 20 acres per megawatt. If you look at hydro. It's less impact. The solar's definitely less impact. It's certainly different. It's different. It's different, it's both different and, I guess in my humble opinion, less than the other two we're talking about. Yeah, but if you, you know, so one acre, 20 acres, about a half a square mile for a megawatt of hydro. So there's a, so it's 320 acres for a megawatt of hydro. Not if it's from the river, not if it's one of the smaller facilities that doesn't have a huge reservoir and it depends what the reservoir used to be before it was a reservoir. But in terms of, you know, this, so my point would be that there's a real question about whether this particular source, I'm not saying all tier one source, this particular source that happens to be half of our portfolio is, it's really questionable whether that's a renewable resource at all. Even though it's, you know, we allow over 200 megawatts, that's arbitrary, that's in law, but the rest of it is, it's a real question to me. So the other aspect of it is carbon neutrality. And when we think about this forest that's up there, that's soaking up carbon dioxide and that's where, you know, it's putting it into the soils. And because of the cooler temperatures up there, it does, it just builds up in the soils and has been for 10,000 years. And so there's an enormous carbon sink up there. It's shifting because of the changing climate, but there's an enormous carbon sink and part of it is the forest and part of it is peatlands, which are like wetlands here, they're really important carbon sinks and they have been doing that for a long time. When you clear that and flood that, you lose that carbon sink, you lose that whole potential for carbon sequestration. At the same time, once you flood it, that carbon that was built up in the soils and the biomass starts to decompose at a faster rate than it used to. So now you have emissions, greenhouse gas emissions from the reservoirs, both CO2 and methane. Methane is, as you know, I'm sure you know, is a much more powerful greenhouse gas. 86 times as powerful as carbon dioxide, especially over, you know, if you stretch it out over a long, long time, it decreases, but over this critical next few decades, a huge footprint for every methane emission. So when you add those two factors up and you work it out on a grams of carbon dioxide per kilowatt hour, it actually is better than just burning natural gas, but not a lot better. Is that all this in your test mind? It is. I guess a couple of points. Number one, your carbon neutrality discussion, I like, and I wonder if you've seen my deal, I think it's S201 that would require all of our monitors to be responsible for their own carbon. I haven't seen that, I've asked for that. I have read that, yes. It's a concept worth exploring how it's not simple, but what bothers me in this building are the folks who pretend to be worried about climate change, and then when the session's over, they jump on a jet and fly around the world. I think there's a lot of people who say we gotta do something about climate change, but they take far too many commercial, a lot of lives. Well, I won't address that, that's a separate discussion, but in regard to your forest question, I think it's an important one. I think that people are working hard to figure out how to make that a real and valuable effort statewide. I think one of the things that's super important to consider is that the status quo that we have today is creating an enormous problem for the planet. You know, I guess that Australia's the best recent example of that. The IPCC, the International Panel on Intergovernmental Panel on Climate Change has pointed out that this is one of the differences between the super aggressive reductions, the 1.5 maximum temperature increase pathway and the two degree pathway. The one and a half degree pathway predicts significant major heat and drought and fire conditions in the Southern Hemisphere. The two degree pathway says that those conditions show up in the middle latitude and the northern hemisphere. So what we saw in Australia is coming here. So that's what the status quo is bringing us. So with regard to forests, it's really important to think not just about the status quo and forests have been doing this for that million forever, right? But we have to think about what we can do that's additional. What can we do extra? So if we commit to taking forests out of rotation permanently, then you can start then at that scale you can think about the extra growth in the forest that is doing extra sequestration. But to do the normal status quo kind of sequestration that happens all the time is actually not helping. I mean it's a lot better than going back to 1880s and having Vermont be clear cut completely. But it's when we think about what we do with our forests, we think about additionality and permanence as far as what we need to accomplish for the carbon cycle. The permanence you're saying, no cutting trees. Well, it's complicated, it's way more complicated and there are other people that know more about this than I do and I recommend having the men here when the time comes. But there are different management, it's complicated about management. Yes. Since that man trap that was being set for you right there and you just walked around and filled that. When you're looking at your analysis, do you do assessments on embedded energy and creating infrastructure? Yeah, I thought it was, for instance cement has a very high energy and hydrophysicology, I believe. Well, you're gonna even create power lines, all of that kind of, well the creation of energy from a solar panel to a windmill to a hydro dam, they all have. It's a complicated question. The hood is starting looking at the embedded energy of the technology that we're in. Yes. Well, typically, hydro from green house gas from large hydro is an interesting example of that. Typically, you'll see if you look up the numbers on grams per kilowatt hour, it's something on the order of, you get like 30 to 40 grams per kilowatt hour is what's listed for large hydro. But that's entirely embedded in the concrete and the construction. And it's generally considered carbon neutral as far as landscape impacts and emission impacts from the reservoirs. Where I come up with numbers from like 100 to 200 when you add in the others, just burning, efficient, really efficient burning of natural gas, methane is something like 200 in the ideal. Not counting fugitive methane. But, correct, correct, but just burner tip. Yeah, depending on how efficient the plant is. So, let me make sure I'm not missing important things that I wanted to cover here. So we have to go off, we're here. Okay, let's see. So one other thing I would like to address, well let's see, I guess is the cost question. That's not in my testimony, but I've been doing some checking on this with the department. It's hard to figure out how much we are spending. And just thinking about, well actually I should back up because I'd like to address the question of the unbundled renewable energy credits, unbundled REX which cover about half of that renewable energy that we count from Hydro-Quebec. And we buy just the REX, the cap on that is like a penny a kilowatt hour, but I don't think we ever pay that much, our utilities don't pay that much. My sense, talking to the department, is that it's something like a tenth of a penny per kilowatt hour to a half a cent per kilowatt hour. So if you, now it turns out that we are purchasing at about a quarter of our power, a six terawatt hour total power supply for the state. A quarter of that is covered by these unbundled REX. So it turns out if you take a sort of a low estimate of cost for that, say a quarter of a penny per kilowatt hour, 25 bucks per megawatt, then it turns out to be something like $3 million a year that we are spending on these unbundled REX which to me don't really do much of anything. Hydro-Quebec has a C of something like 179 terawatt hours worth of power that they produce from their dams, of which we purchased about one and a half as renewable energy credits alone. So when we do that, we aren't, it's not really renewable. It's not doing anything for our carbon budget and it doesn't affect carbon, hydro-Quebec's additional growth of renewables in any way. So to me it seems like we are purchasing these REX that are not doing a single thing. They aren't helping, they aren't hurting, they're just this, it's paperwork. So we are spending about $3 million a year for this paperwork that really just, it works for our accounting and it works for, within our legal system right now of accounting for renewability, but it's really not helping in any way, shape, or form. So there's $3 million now. If we, as, as, Okay. All seconds in a way. Okay. Well, I would love to come back and finish this because I think it's an important aspect of what I'd like to say and, but I'll just finish by saying that we support the 33% cap as we expand to 100% renewables. We'd like to see it drop, we'd like to, we'd prefer to cap it at the current purchases of Hydro-Kobek power, which is about 220 megawatts. So rather than have the amount that we purchase from Hydro-Kobek increase as we electrify everything, we'd rather stick to the amount that we purchase now. Thank you very much.