 Today this is Senate Finance. This is September 2nd and I'm going to call the meeting to order. First item on the agenda is we're going to continue our discussion on broadband. And Peter Blum and Fred Goldstein are with us. I don't see that Steve Whitaker has joined us yet. But I think today we're going to hear a little bit more about fixed wireless. There was a little discussion about that yesterday. And so I'm going to send a Pearson and send us a rockin who was just I'd appreciate some context from you, we're all very interested in broadband we need we do have an oversight role with the department. And a lot of us. Well, I think maybe all of us are interested in some of the planning but I'm curious if to your knowledge is there an assignment. You know this little session here for September that I'd like to help. Tell me if I had in mind some of the goal of, or if this is just more of an update. This is really part of our update. I know some of the contracts that have been awarded were for fixed wireless. I know. Yesterday there was some discussion about the CUD is doing some fixed wireless to start out. And eventually, if I think we'll go through this second but if all the contracts are not. If all the money isn't put out in contract we're going to have to decide and make some legislative adjustments as to where it might go. So, this is mostly on for information at this point. Mr. Rockett and did you have a question. You're muted. No matter what I'm chair take a point of personal privilege and have the Senate finance committee congratulate senator Pearson on his election. Not election is primary recount, which is very intense. And relations, putting up my thumbs up. Okay, thumbs up from everyone. That's okay. That's gotta be a. Congratulations landslide. What was the final count? 28 votes. It was a 45 on election night reduced to 28. We found that out yesterday. During our hearing and just, just an hour ago, the judge issued the final order or whatever. So it's done. It's official. Thank you. Congratulations. Learning all this stuff is not for not. Okay. So we're going to go. Okay. Steve Whitaker has joined us by phone. I have Peter Blum. On first Peter. I don't know if. You've talked to anyone or there's any. Particular order. I think this, I think this works for us, Madam chair. I'll go first and then I, I'm not sure whether Stephen or Fred, want to go second, but they've worked that out. Okay. So thank you for the invitation to speak here today. Just to refresh your memory. I lived in Vermont for 35 years, but I'm now a resident of Massachusetts. And I'm speaking to you from there. I have done some work recently. I've been working in Vermont with Fred and with Stephen for the, we thought about maybe applying for the departments. To be the department's consultant for the planning project and decided not to do that. And we've done some work together for the central Vermont fiber district. So I know these guys and sort of, we know what each of us has been thinking recently, at least on some of these issues. But I'm sure that I try to address as best I can. Senator Brock's list, which I received this morning. Senator Brock is, is the committee familiar with that list already or should I try to review some of the items in it? If you don't want me to provide it to all members of the committee, I'm not sure how many people have had a chance. Okay. Well, what I, what I would like to do, I had some prepared remarks and I think that fits loosely into your framework. So if you feel like you'd like to stop me, I'm not going to do that. I'm not going to do it at any time. The, the questions, some of the questions involved how the state is going about trying to achieve universal broadband service. And you've had, of course, this emergency grant of funding, which you've allocated through our recent legislation. And the way a lot of this money has gone out. I'm not prepared to tell you what percentage it is, but a lot of it has gone out as grants to. And then, to the next stage, there have been a lot of proprietary existing providers who billed, want to extend their proprietary networks. And that includes the major cable provider and the major telecom in provider in Vermont. And this may have been a reasonable emergency measure. To take in the short term. But there are still a lot of problems. to nearly everyone in the state. This strategy was easy to start with 15 years ago when you decided that you would start helping the existing utilities expand their networks. But it has become increasingly costly over time and I predict that this will continue. Years ago the low hanging fruit on broadband was people living in the towns in the cities close together with short cable runs, short fiber runs, and the existing utilities built out to many customers using private capital. And they built out just as far as it seemed profitable to do so at the time. But now you've got a new problem. You're stuck with trying to pick the fruit that's higher up on this broadband tree and you're finding that you have to use public funds. In the recent rounds of awards, it's my understanding that some of the awards amounted to about $4,000 per address served. This seems like an extraordinary benefit to relatively few individuals. I'm sure there are other things that probably exceed this, but you're spending in some cases a lot of money to get broadband out to relatively few people. That in itself may be a problem, but it's not clear that the strategy will ever succeed. The interim steps ultimately could make it harder for the communication union districts to make a profit on new fiber runs, something that the law now requires making a profit that is. They have to be able to be cash flow positive in order to float their bonds. In a few years when they're looking at a new fiber run to the end of a rural road, the most profitable portions of that road will already be served. This leaves the CUDs with very high costs and will likely lead to state with either a need for continuing subsidies or facing yet another failure to reach every household. So I recommend that as a planning measure, you encourage whoever it is you give the planning job to to focus on the end game. If you still expect 100 megabits up and down for every customer in Vermont, that's going to be very expensive and likely is going to require some continuing subsidies. One possibility I suppose is that at some point you'll just decide that that fruit, some of that fruit is just too high up on the tree and you can't really afford to reach it. I'm not suggesting that any other states with rural areas have really figured this out completely, but many are doing better than Vermont is doing. Having a good state plan to get consensus around the end game would be extremely helpful. Interim steps such as these grants should not make the end game more difficult, but you can't know that until you know what your end game is. You asked Senator Brock, you asked about CUDs. I think CUDs may be a reasonable approach to an end game strategy, but they are not on the verge of solving the problem soon. Some perhaps many are relying on volunteers, although it's helpful that they recently received grants that let them get started at least having some professional staff. They need more experience. They need a prototype on how to adopt best practices, which means help from the state, and they need training on how to live with the public records and public meeting rules, something that at least in central Vermont has been very controversial. So giving the CUDs technical and advisory help getting on their feet seems to me a very good idea. Now you also asked about fixed wireless. As I mentioned before, some of the senators got on. Fred Goldstein is our best resource on this, and I'm sure you'll have a lot of questions when Fred speaks about fixed wireless. All I want to say is that fixed wireless instead of fiber may be a near best solution in many areas. Fixed wireless has other advantages in that money spent on this technology can also expand cell coverage and help with emergency communications. But again, there are a lot of complexities. One major complexity is getting access to a broad enough band of spectrum. You may probably know that spectrum has been auctioned by the FCC. And the best and most useful spectrum in Vermont is owned by private telephone companies, notably VTEL. When we were working for central Vermont fiber, we initiated a very positive interaction with Michelle Gattay, who I know has some difficulties historically in Vermont. But I want to tell you that he has a lot of spectrum that can be very useful for fixed wireless, and I found him quite helpful in considering what Vermont's needs might be in central Vermont. I also want to comment on the secrecy question, Senator Brock. The state has, in my opinion, allowed too much to remain secret about the network. Even the location of fiber runs in the public right away today are kept as confidential trade secrets. I think this is poor policy, and I think it should be overruled. First of all, for something to be a trade secret, it has to be capable of being a secret at all. There is nothing hidden or secret about the location of fiber runs on roadside utility poles. It's also been suggested that you could support the compilation and publishing of a GIS database on poles and fiber locations. I see several potential benefits for this. It could be easier and more competitive to obtain interconnection at fiber mute points. Now, I take this second hand, but Fred knows a lot about obtaining fiber interconnection, and you may want to ask him some questions about that. My sense of it is that if there was an existing fiber map in central Vermont, a lot of work could have been avoided when they were setting up the proposals for that network. It could be easier and more competitive to get interconnection, and there would be a market price that likely would be lower than the prevailing price right now. Secret interconnection agreements are poor policy, especially if we are pretending that telecommunications is provided in competitive markets. If our whole structure is based upon the benefits of competition, then there should be a market, and you can't have a market if you don't have pricing information. Markets require pricing signals. This is a lesson that we have learned and unlearned at least twice. We learned in the 1920s when we required telephone companies to interconnect, and there probably some of those early statutes are still in Title 30 in Vermont statutes. Then we unlearned it when we let them go to proprietary networks. In the 1990s, we tried again with the 96 Act to create something called competitive local exchange providers, and there was a great deal of regulation that came out of the FCC and the states about how CLEX, so-called, would interconnect with the incumbent LEX. It was understood when the 96 Act passed that if that interconnection couldn't be accomplished effectively and at reasonable prices, the whole concept of the Act would fail. Secondly, this database could make it easier to anticipate transmission failures like the isolation of telephone switches. Many years ago when Governor Snelling was in office, there was a train derailment. There are all sorts of ice storms and events that break cables and fibers, and having a map of this network could be very helpful for emergency services. Finally, I would mention that in my opinion, it's more than I want to go into today, but your tax policy about tax and telecommunications seems to me quite obsolete, and having this database about where the poles are and where the connections are could be very useful in terms of opening up opportunities for tax reform. That's all I have to say, and I'd like to yield now, or I'd like to answer questions first and then yield to Fred or Steven, but I'll take questions. Okay, Senator Pearson has a question. Thank you, Peter. I'm just principally interested in the mapping and the understanding I think the public, as you say, has that it's in the public right away. We should understand what's going on, but I want to better understand something you said that if we had this understanding of where there is fiber around the state, there could have been some cost savings, I think, to central Vermont. Is that what you were saying? I'm not so sure about the cost savings. I think it would have simplified their design when they were looking for ways to tie in the last mile facilities that they were building, how to tie those into the backbone of the internet. How come, so Square, with me, if we have to accept the for-profit, private, motivations that go with it for telecom, why then any efficiency that could have been gained would be dependent on somebody leasing access or something? So why didn't the market just take care of that? I want to understand it better because I am interested in opening this up to the public view, but it would help me to understand that better. I think it's widely accepted that in the industry that if you can keep the locations and interconnection details secret, you can get a better deal from the next guy who comes through the door, that you can be a price setter as the seller rather than a market have to attach yourself to a market price. This is a constant problem in regulation. Ten years ago or so, when I worked at the National Regulatory Research Institute, I did a study on something called Special Access, which was a telephone company lingo for point-to-point access. The telephone companies, AT&T and Verizon, were going to extraordinary lengths to keep secret and to require their customers to keep secret, the terms of their interconnection agreements. The reason to do so was purely economic because they never admitted this to me, but it seemed perfectly obvious to me that they believed that by keeping the prices secret, that they could do better on overall revenue, that it was a good business strategy. Fred may have more to say about this because he's worked more in industry than I have. Does that answer your question, Senator Pearson? I think so. It begins to. Thank you. Senator Brock, I see your hand. Am I should I call on you? Well, I heard from the chair quietly just a question regarding the issue of the secrecy versus openness of what's on the polls in the public right away. How do other states deal with this? I think generally most states do it the same way we do. I think what that is, as I understand it, is that when the Department of Public Service or the Public Utilities Commission asks for information that a utility or a communications provider that's not a utility feels should be treated as a trade secret, the granting of that trade secret status is stated as being provisional, subject to challenge. But there's nobody really in the whole system that has an incentive to challenge it. So by and large, it just stays secret. And so there is a process by which someone could challenge it, but nobody seems to do that. And so you wind up with the whole state being worried with fiber that nobody in the public sector really knows where it is. Now, some of the fiber is not like that. I mean, I think Velco has been, as I understand it, has been pretty straightforward in sharing where its fiber is. But I don't think that the telephone company or the cable companies have done so. And it's not that the Department probably thinks that it ought to be secret. It's just too much work to challenge every single filing. And Chair, we have one person online here today who makes a habit of trying to find that out and is consistently. We're going to get to him. I think I saw Senator Pearson and then Senator Sirotkin. Sorry to ask another question, but don't utilities have to file something with the public service actually with the PUC in order to string? Isn't there isn't there isn't that a publicly controlled process? There are there's a process for setting towers that requires a permit. There's a process that's really a regulated private process for attaching to poles. Yeah, but that's what I'm saying. But that doesn't happen in the department or the board? No, a pole attachment is negotiated between the Attacher and the pole owner pursuant to rules that are either set by the FCC or by the state. And disputes can be taken to the PUC, but I'm not aware that any have. Usually they're just worked out. I'm not really up to date on the latest developments that the board I think the board took a undertook a docket on this and I don't think there was any any change, but I can't really speak from knowledge about what that docket did or didn't do. Does that answer it Senator Pearson? Senator Sirotkin. Peter, you piqued my interest at the very end. We started talking about how poles and revenue might intersect. And I didn't quite understand what you were getting at. You mentioned the word might affect revenue policies and. Yeah, I'm reaching out quite a ways here. I can see why it was a little obscure. Vermont's, I'm reluctant to tell the finance committee how Vermont's tax structure works, but my understanding of it is that there is a telephone personal property tax that is quite old and that is based upon the assumption that the best way to appraise that property is through depreciated original cost, which was the numbers that were sitting around easily available in the old days when telephone companies were regulated and they kept their books according to the uniform system of accounts. Today it's not at all. There are all sorts of reasons why that might not be a fair basis for taxation. It might be that the books don't reflect all of the investment. It might be that the depreciation has long ago come and gone. It might be, I don't know, there are a lot of reasons why that looks really obsolete to me. We have a universal service fund that is levied on revenues, telecommunications revenues. Vermont is way better than most of the states and most states it's only the state fund, if they have it, is based only on intrastate telecommunications revenues, which is a totally archaic distinction and you managed to avoid that at least, but still it's based upon telecommunications revenues and now a lot of the money is being used for broadband which doesn't contribute. So the thing is out of balance in a lot of ways and one of the things that people have talked about in my hearing is that perhaps one way to look at this anew is to look at the facilities that the telecommunications providers are using such as coal attachments in the public right away and that might open up some new bases for taxation for you. Does that answer Senator Sorokin? It answers and opens a lot of questions too. Yeah. What have any other states to your knowledge successfully gotten beyond intrastate taxation? Well, Senator, I'm a bit of a crank on this actually. We have a committee full sometimes. I have long held the view that the distinction between intrastate and interstate is an artificial creation for regulatory purposes and ratesetting purposes only and whether it was ever constitutionally required is something that's debated often among lawyers, but at the very least it's irrelevant in my view to taxation. Many of my peers disagree with me. Brad Ramsey who is still I think the general counsel at Nayarook in 1996 was very adamant that the 96 act should only allow states to surcharge intrastate revenues for universal service. I disagreed with that. There was a recent then Supreme Court decision involving the Illinois sales tax statute, Goldberg versus Sweep I think was the name of the case if I can remember it right and in that case the Supreme US Supreme Court examined the Illinois sales tax statute which was levied on intrastate and interstate revenues both and the Supreme Court reviewed the taxation policy in the Constitution and concluded that the Illinois sales tax statute was valid and enforceable. So for the purposes of designing Vermont taxes my belief is that the distinction between intrastate and interstate is largely or entirely irrelevant. That was a long answer to respond to your use of that one word. I don't know if I just sort of went over the top on you or not but I think that there are there's a great deal of uncertainty in federal tax law about what's preempted and what's not and there are different views and different circuits. If you go to the Fifth Circuit down in Texas they have a very I think crabbed view of what's allowed for the states. They they struck down a Texas statute that I thought should have been upheld some years ago but I think I don't know how interested the committee members are in restructuring telecom taxes but I think if if you are I think you should be constrained almost not at all by the traditional distinctions between intrastate and interstate and I think maybe you should be looking to see if telephone property could be taxed more like other kinds of property. Okay I think we might be but I think that sounds like an entire session worth of work if not more and it's not going to get done in the three or four weeks we have left. I'm not suggesting that I just thought I just thought that if you had if you had the data it might make you consider the options and that's my yesterday the CUDs came in and they were they're looking for I think it's three million dollars somewhere between three and four and they called it pole harvesting. I assume that is what you're talking about they said that there was a vehicle they could rent and drive around and then you had to walk in my backyard where all the poles are you had to walk there and but that's the information you're talking about right we know at least the major utilities can tell you basically and there's maps of where their poles are some more or less accurate but we don't know what's on those poles at least until you go to get a permit an attachment so I assume at that point you may know what's on the pole because you may have to pay to move it um right would the CUD request be a good investment for the state is that what I'm hearing from you? No I'm not I'm not prepared to express an opinion on that particular proposal I think that having a long-term or even a relatively short-term goal of trying to get that information about who's attached where has a lot of benefits including the possibility of being useful for taxation purposes but whether that technology is valid or invalid something I know the least the least thing about I don't either okay but it would be a good thing for the state to know this for a variety of reasons one of which it might make it easier for CUDs to plan which is what they're saying they need and that perhaps this information should remain it should be the states that you know if if the CUDs do it do they then own it and or should part of that be that it stays in some public utility commission or the public service department some state entity is where the the information should rest. My uh one of the high points in my career was uh working for Governor Cune in many years ago when I was reminded this morning that Act 200 was famous and infamous at that time and included a lot of planning information encouraging regional planning and it began a GIS system and that's that's the spirit in which I'm making this suggestion that I think if there were a free hopefully state GIS that not only includes where the roads are but where the fiber is there could be a lot of benefits and it's hard to anticipate all the benefits but as I mentioned I think it could be helpful to CUDs looking for places to interconnect it could provide price discipline for the market for those interconnections and it could be useful for emergency planning and response. This would be fiber we don't care where the telephone lines are well if you're doing that well the telephone lines yeah I mean you do actually you do care you want you probably want all the connections on any pole. I know Steve Whitaker's on and then there's E911 and I think things that we've had issues with. If I could I saw Fred nodding and I think Fred is really your best resource on how this information could be used. I'm a little bit over my depth here or out of my depth here. Well you're way above most of us so this is very helpful. Any other questions for Peter? How would you rate Vermont as to what we are doing regarding broadband and broadband expansion on a scale of A through F? I guess about C. The data that I have Senator are there's a website I can't think of it offhand maybe Fred or Stephen knows it that evaluates state by state how much broadband costs how good it is and how far out it is into the into the boondocks and in that survey which may or may not may or may not be definitive Vermont came out 47th of the 50 states so some people think Vermont is way behind. I don't think it's quite that bad. I live in western Massachusetts in Berkshire County and there are towns in Berkshire County that are just as bad off as the towns in the northeast kingdom as far as broadband and actually Fred has a project in northern Berkshire County on the Vermont line that's going to fix they're buying fixed wireless and so he can talk to you about that but I think so the states that have done this better I think have it may be worth considering whether you need some guiding hand here at the state level that can do I see it sort of like like zoning was when it first came in I don't know if any of you remember Bernie Johnson and Bill Mitchell but they were guys who were helping the towns adopt zoning after it was first authorized in the 60s and what they did is they went around and they explained how it was supposed to work and they helped them draft bylaws and they helped them make decisions and I just feel like the CUDs are a little bit at sea here and they need some help and I'm not really sure that with all due respect to the department and the commissioner who I've known for many years I'm not really sure that having the utility regulator be leader or the promoter is the best choice it seems to me that your motives are not primarily regulatory here your motives are primarily to enhance quality of life and economic development in the state and so maybe maybe having a different center for this might be useful is there any jurisdiction any state that to which you would point us as a model from which we could learn you might want to talk to the Massachusetts broadband council in my part of the state they have worked with they've given grants they they work with towns it's not CUDs in Massachusetts it's towns that some of them get together and form districts but the towns basically have voted in you know we want we want fiber and we're willing to pay for it and the state has been given grants given grants for that and it's it hasn't Fred knows more about this again it hasn't worked everywhere but it has worked in a lot of places and it looks like it's going to produce some good results in a year or so thank you all right second campion sorry that was a while ago I apologize I think my I think my only question was at the end of this madam chair where we're where are we heading I think you touched on it in the beginning I'm just taking notes this is all very helpful but is this background information for January some of it some of it may be we've given very specific instructions about fiber and how we want the present grants to go out we're gonna have to decide if there's still money left over what we're gonna do with it so this is obviously very complex and also somewhat new the technologies change quickly and so this is just basic information for us so that we can make the best decisions possible and yeah I'm assuming that I'm already thinking of and how would I phrase a bill like that because we're gonna need a vehicle for next year we're not we're not going to solve this whole thing this year I think the one thing we have is the request for the money to do the pole harvesting and that's something we're going to have to decide if we're going to push for and you know get before appropriations or maybe redirect some of the CRF money but or if we're going to tell somebody else maybe we want to reinstate the telecommunications authority that was put to sleep at some point not when I was on this committee but we may want to resurrect it if that's seen as the best thing so this is information harvesting okay um so I got right next I have I think Steve Whitaker on my agenda let me my iPad went to sleep I do um but Fred I Peter said you and Steve had been talking have you gotten a program you want to do together or do I just follow the agenda I have my own statements so I'm prepared to make whenever you're ready okay so we'll go on Steve are you there you're on mute I see a phone but no Steve at I see a phone but no Steve at this point oh no he's off mute can you hear me now okay I'm going to start with a couple of uh I'm going to start with a couple of comments responsive to the questions that the senator supposed the committee members and just then I will restrain my uh responses in the context of senator Brock's question okay uh just start with I think you should consider immediate action to get VIT restored possibly using CRF monies because that's a valuable tool to built on current fiber and existing technology new technology to have the necessary planning meetings and collaboration zoom is woefully inadequate for the level and the intensity of work we've got to do so VIT is an option in cooperation with the AMO's that you should consider uh launching using CRF money because it could be done before the end of the year yes from my interactive television ah especially because it was sunset it was sunset as part of the state college's effort to do it go it alone and now with the change of chancellor uh in the economics of the college's it's worth revisiting that okay that's a different conversation uh in regards to Peter Blum's conversation about the uh tax structure VTA had an obligation in statute to charge all broadband providers for their use of the right-of-way when VTA was mothballed most of its piece parts went to the public service department but the right-of-way fee obligation went to VTRANS so VTRANS is in violation of statute for years running now for not charging broadband providers now I'm not suggesting that we should be doing that in fact Fred will probably make a comment that we should not charge broadband providers but the point is that a GIS database of all the existing fiber makes it possible to study the telephone personal property tax the universal service fund and the right-of-way broadband revenue as one project broadband can also be taxed to support 911 through research that Peter found in the uh footnotes of the internet tax freedom act so there that's something that should get underway but it and be completed that study should be completed in time for January so we can pick that up another time but I wanted to answer respond to the question most important takeaway from today's testimony I would say do not allow the $500,000 planning uh COVID response and recovery planning funds to get spent in the next three months and not make it clear with with expanded oversight and coordination to lay a foundation for the 10-year telecom plan next year but also for immediate actions by the CUDs it will not work to let the existing oversight of the department we will end up wasting that money in resulting in a plan not much better than we've had so far so I would recommend that VTRANS public safety commerce vcgi and the department all be involved in guiding that contractor so that's going to take immediate action possibly without legislation just through committee pressure to make sure that the scope will work for that contract uh expands the oversight also put a one of the CUD reps on that body on that oversight so all harvesting uh that's a problem I reviewed the presentation yesterday the the proposal is claimed to be a trade secret no one has vetted or consulted the references for anyone who's made that process work uh it's absolutely unrealistic to spend that kind of money with that little oversight and track record in secret in this time frame it's impossible to do that many polls in 60 days uh I would suggest that we to put either put out an RFP and start with one region and do that uh to prove the technology but I caution wholeheartedly uh and I've appealed the decision to anyway I'll leave it at that question one if you all have the questions in front of you that senator brock sent out to guide our testimony uh I don't think so no okay I'll try to just have to have two or three screens to do that no I will I will briefly paraphrase the questions because Vermont have a broadband strategy does it make sense no the state has only a fragmented aspirational document not a plan we have a muddied patchwork of federal subsidies for incumbents and state subsidies in the form of loose plans and no regulation for example open access fiber and double pole removal are given a wink and a not and not enforced creating ineffective subsidy for the incumbents there's too much ability for the incumbent telecoms and the for-profit utilities like green mountain power and even velco to rake off the desirable locations which will further inhibit the ability of cud's to be successful du d municipal and cooperative management salaries are generally half of what private industry is making this information is all protected by confidentiality it's harder to peak under the tent the legislature should demand that cd's take responsibility and be held accountable same with velco which is half owned by v-light our statutory policy it or telecom policy involves begins with the purpose of this chapter is to strengthen the state's role in telecom planning it's about time second question how important is the plan how many years should it be for what are the essential elements the plan is very important more so now with the statutory changes you affected last year in the broadband bill this will be the first time that we have an infrastructure-based plan with specific strategies to reach every goal it it's fine for it to look out 10 years as long as it's updated every three years with uh review and assessment i will provide a more thorough vision in the interest of time uh a more thorough version in writing for you uh i'll reiterate here the oversight body to manage that 500 thousand dollar COVID response and recovery plan should be comprised of public safety b-trans commerce public service gis a cud rep and possibly a velco rep velco has opted not to step up and be the coordinating role yet that's rate payer funded infrastructure 51 owned by the people of the ratepayers of vermont and we should insist that it be more transparent and more serve as the backbone to enable these cuds uh the short-term broadband plan i've uh exposed earlier in writing i won't jump into that here it's useless it it should be set aside and we should focus on priority planning to be ready for federal stimulus money coming our way that does not do it um comment on the communications union districts obstacles for success we're missing right now we're missing the integration of mobile wireless tv fiber may have squandered money working on a plan for statewide i mean for a region wide mobile wireless fixed wireless strategy which they then rejected because of the issues of operating with detail spectrum cuds currently feel no obligation to integrate their plans with public safety radio with first net with public safety lmr radio backhaul or mobile wireless if we could designate that a cud owns and is responsible for a defined regulated territory that might be the answer short of that put everything in place as possible to make that happen hold the cuds accountable just as the regulators hold the electric utilities responsible the good news is that cuds are required to be transparent but even this will require legislative clarification to remedy current practices as peter alluded to this doesn't happen with velco and gmp if we don't demand accountability from the cuds we might as well not have them while the cud lack technical competence now they will build it the state should define the statewide strategy and architecture with a focus on resilience disaster planning and coordination with best use of existing infrastructure including velco fiber local solutions and plans will be different but they will fit together in different parts of the state provide state-level engineering support to build that local capacity don't ask the cuds to each go out and find a different professional with a different agenda to design non-compatible architectures the p public service department has not hired a telecommunications engineer since the late charlie larkin was retired in about 2006 the cd should not have probably not have veto power but should inform and propose conditions to be attached to public funding of commercial network projects then how come how can short-term installations affixed wireless best integrate with fiber and other long-term solutions they can serve to locate the fiber in the back call solutions the fiber connected buildings they can build vertical assets even if they're only temporary poles to support fixed wireless wi-fi public safety radio and lte small cells supporting mobile wireless as long as the cuds own the installation it becomes part of their asset base regulatory environment i'm not going to dive into that uh if you wanted to be broadband to every how would you go about it fixed in this order fixed wireless small cells serving both fixed and mobile resilient rings managed or assembled from all carriers and velco shared fiber aggregation to support otherwise non-economic builds fiber builds and then the cuds have only a short distance to go to reach these rings cuds will build the laterals evolving eventually into a mesh architecture cell phone i've already said we cannot afford to miss the opportunity to integrate mobile wireless with our current investments of public funds how should the electric utilities be involved in broadband expansion the electric utilities can and should build engineered fiber in the electric space and then lease that to the cuds that's the most cost effective method of financing and maintaining the fiber they have the trucks they have the contractors they have the space they don't pay their own pole attachments they will maintain and restore as necessary they must participate in an integrated planning process for rapid restoral because it's not sufficient to leave communications down as long as some areas uh have suffered electric outages um that's the gist of it unless you have questions that's a lot uh steve uh can you submit that in writing if you haven't already yes i just been typing it as peter was speaking so yes i can uh okay that would be great because i think you gave us a lot to think about i've been taking some notes but um it will be helpful to have the whole thing senator brough you have well one of the things that steve that you mentioned is this notion of integrating the various components of people who are involved from the cuds to the proprietary operations uh and legacy providers and so on uh in terms of how to get to universal broadband how do you make people who are independent companies who have their own commercial interests how do you make them part of something how do you force them to do that particularly when the state does not have um regulatory authority over most internet providers uh actually i only mentioned velco as the uh participant in that uh plan oversight process i did not mention consolidated or comcast the levers we have the most important lever we have on comcat on comcast is state funding if we're going to give them public funds to build a line extension we should require that open access fiber be pulled along with it and that be made available to cuds to put up mobile wireless or fixed wireless secondly consolidated uh incentive regulation plan expires next july and the new plan that they have yet to propose has to be found by the public utilities commission to be consistent with our 10-year plan so i believe we will need to delay the adoption push back the adoption of that incentive reg plan until our 10-year plan is complete and our leverage over consolidated is if they want their incentive reg plan they need to make all their fiber available to cuds or the unused fiber and if they don't what's the impact on them they don't get their incentive reg plan and their incentive reg plan is a long leash that that they basically get to do what they want wherever they want and it's it's not an entitlement well i'm what i'm trying to ask really is what's the fight what what do you see and i realize this is is from a long view the effect on them if they say no does this uh in effect damage destroy hinder or cripple their ability to operate in vermont or do they operate without that i think pit solidary overtime will become more and more of a middle mile fiber they will make more and more of their revenue off leasing middle mile fiber and less and less off their consumers the department has started speaking about converting shifting the obligation for carrier of last resort to the cuds and that is a very fraught because the resilience of fiber networks during power outages is not the same as battery powered uh central office consolidated infrastructure so if we're going to be consolidated from the obligations of last carrier last resort and shift that burden to the cuds uh we need to do that very thoughtfully and carefully because the resilience and the potential to block 911 calls is enormous i'll pick this up with you another time senator brock thank you another question senator mcdonald so um steve steve was telling us about our planning and um our expenditures are need to be consistent with our 10-year plan is that is that correct is that what you were saying steve what what i'm saying is that the currently the way the grants are being given out the with the emergency broadband action plan and all of the connectivity grants in fact much of 202 uh e which is the connectivity initiative uh it affect bypasses the uh statutory goals of 202 c uh so the we currently the telecommunications and connectivity advisory board should be required under statute to review every one of these proposals for consistency with the 10-year the 10-year plan and if in its absence the goals of 202 c and 202 e because the department is not doing thank you mike that sort of answers my question but doesn't the 10-year plan wasn't it's to expire in december of this year the new one was supposed to be prepared in december but they've pushed that the legislature uh as part of the bill you just passed moved that date out until next june which is what creates a problem that that won't be done in time to affect the consolidated incentive reg plan well then in this interim time when we pushed it out until june um will will the uh the department be able to make arrangements or deals or proposals based on the plan that should have expired in december or have our legislation or have we in our legislation said the department will not make such decisions until next june when the new plan is is uh up and rolling which of which the situation there senator the the 10-year plan doesn't expire the last time we had a duly adopted 10-year plan with 2004 the 2018 plan which senator brock's questions asked for a comment on was somewhat of a farce of asking for calling the first draft the final draft and all it is is a background document it does not have strategies to achieve the goals so we have not had a duly adopted 10-year plan since 2004 so when we extended the due date for the new plan to next june are we currently permitting or directing the department to grant various proposals and fund things that are yet unplanned not in a plan no they're just not right now it's not explicitly required that they adhere to the goals for consistency of the goals of 202c and 202e that's what you should put in any legislation you move or any more funding you provide to the connectivity initiative is to make sure that the the core principles of competitive choice open access uh not soon outmoded technology be adhered to in these grants because that that will level the playing field between the cuds and the incumbents and it will make sure that we're not wasting this public money so currently the department has the authority to authorize things that are not competitive that are outdated or or things that deny open access is that correct the department has the commissioner has full discretion to overlook all of those statutory requirements and and hand out this money and that's what we're that's what's going on right now that they can overlook those things in some cases yes it is uh the the open access provision the ability of fiber being built to be leased by a competitor or by a cud uh is is not explicit in the agreements and the grants that we're giving out wow thank you thank you other questions for steve okay thank you steve and if you can get that to us i'm hoping that somebody from the public service department is listening because i kind of feel we need to give them a chance to state their case and we will schedule that at some point but fred why don't you we're on to you so the floor is yours thank you i'm going to address uh some general issues and then some of senator brock specific questions uh noting that mr bloom and mr wittaker have already made some very good answers on some of these questions one of the issues we have to look at is coordinating the different activities around the state and coordination in general is important in many regards without coordination the market doesn't really meet the public needs all the time especially when it's not profitable we can look at what happened at the federal level with the pandemic response when ppes were left to the states and the major problems that resulted from the lack of national coordination well we look at telecom and it's really been the same way since the 1990s when as a federal policy telecom evolved from being a quote utility to quote a market that hasn't always worked it has brought competition and very good benefits from competition in most places but vermont was largely left behind because it hasn't been as profitable and responding to the telecom and information needs of the pandemic also is suffering from the lack of coordination and again this is not specific to vermont this is how it works in most places and vermont may actually be doing better than some others but it still is a general problem because the national structure of telecom has been left the market decide with some subsidy money given out on multi-year terms by the federal government and some smaller subsidies within some states the market approach fails when there aren't competitors now there's a way to look at this where is competition going to happen and where is there literally a natural monopoly fiber the physical facility is the natural monopoly in most places services provided across fiber like telephone internet video those are naturally competitive and they could pay rent to a fiber if there were a fiber utility vertical integration having the fiber and the services owned by the same was not the idea behind the telecom act of 1996 that actually had a concept of unbundling the FCC later adopted vertical integration because it allowed the natural monopoly to reduce the competition for services for the large incumbent companies that frankly had the ear of the FCC in other words the federal business model is wrong another approach that would have probably worked better and hasn't happened in the U.S. it has happened in some other countries is to instead have what sometimes is called the loop code a company that owns just the physical fiber copper and the buildings where they meet and that rents those to the service providers there was one instance sort of like that in the U.S. where windstream which is an incumbent telephone company in some areas spun off its physical assets to a company called CSL now called unity fiber and they didn't do this in order to open it up in fact there were some restrictions they placed on it contractually but the idea was that the fiber could be owned by a real estate investment trust with more favorable treatment than the telephone company so for tax advantages they literally created a loop code but a loop code created with an open access it totally independent would be one long term view i'm just putting on the table that it's like an elephant in the room that keeps getting missed in the U.S. discussion now i want to adjust some of senator brock's very good questions and point out with regard to the plan as steve pointed out the plan requires flexibility and review the farther out you look the more likely it is that during the time the underlying assumptions will become obsolete so a 10-year plan looking out 10 years is very speculative looking out only the three to five years you're much more able to do action and so you can have the long-term guidance but really you have to think about action in a somewhat shorter time frame because both improvements in technology and because the federal policies and federal subsidies come and go we don't know now what's going to happen over 10 years just as 10 years ago we didn't know where the technology was going to go in some other areas so it's a soft focus but yes an action plan can be based on a three to five-year view as far as the question for the question about the obstacles to the success of the cudes well one thing of course they need is access to funding they also need the unbiased expert help they need the court could work at a statewide level in which they receive help in and direction not from a technology vendor not someone who is trying to sell them a product but from just neutral views of how how to stay out of trouble how to get going how to build how to stay out of trouble um now a cud can't have veto power over competition that would violate federal law but uh it does make sense to limit the amount of subsidized competition if you have a cud you don't want to subsidize someone to come in and compete with them in in a wasteful way so you have to look at where funding and who makes the decision about who gets the funding whether it's the cud or another agency it's a different question but one does want to avoid too much overlapping uh of subsidization but the less competition than the more the monopolist even if subsidized monopoly needs to be open you know you can say well you know the big carriers who are not subsidized aren't open and the FCC frankly is gone well too far and taken away the traditional common carrier obligations that used to apply to the incumbent telephone companies like Consolidated Consolidated is no longer under obligation to make its fiber available they make more money now leasing fiber for back wall to sell sites than on telephone service but they don't have to make it available that's a legal distinction um if it's subsidized it should be open access it should be on a fair and reasonable basis to everyone so another question about cud's really is another big one is the cud's job to be a business and make a profit maximize their own profitability or is their business to facilitate the availability of adequate service at reasonable price to everyone in their district because if there are services available competing with an existing service might not be a good thing for them to be doing at least in the short to medium term they should focus on reaching the unserved that's a question because the highest profit if I look at central Vermont or I've already done some work we could have taken a more profitable view going in an overbuilding Comcast and Barry and Montpelier and the low cost to serve areas but the plan that we came up with my team came up with was leave those areas alone if they already serve 25 three or greater we're not going to go there initially we're going to go to the places that don't have service now because the real role as we looked at it and as the cud people agreed with us the real role was to make sure everyone was served so take what money our initial money and capital and find the places that are that sweet spot there high enough density to be worth serving with fiber and low enough density that they're not yet served by anyone else and that we are a lot of those places so it's it's those sorts of issues need to be resolved as a general policy question as to where to build now wireless has two very different long-term roles here one role is to reach the people who are not affordably accessible to fiber the most remote areas and that has the intermediate and short-term need those before fiber reaches them and there may be some who fiber just isn't going to reach you may say the 10-year plan is to reach 100% but in practice you run into situations where there are no power poles there are a lot of properties on the list of v911 sites that are camps that are off the grid they don't have electricity they're just on dirt roads in remote places and they're occupied maybe two months of the year bringing fiber to them would be very expensive and do people really need fiber to the camp it's an honest question you know that's not their primary residence they're going there to get away from the world so they are be unlikely to subscribe so from a business point of view and then you have a handful of year-round residents in remote locations where they're mostly camps and again the economics there may make it very hard to get fiber to them but easier to reach larger areas with wireless so better they should have 25 megabits of wireless than nothing even if they can't get 100 or more on fiber so that's one purpose of fixed wireless another is the vertical assets that are built poles that are erected can be used for other purposes at the same time they can support mobile fill-in mobile small cell into the hollows because when you go through a lot of places in Vermont there's no mobile service because of the terrain but a small cell on a pole 50 to 70 foot not just at the ground level but it may go higher a small cell could fill in mobile coverage and be you be shared by the carriers that was sort of the plan of again a VTA but we don't have a VTA I can see why it would serve a role of filling in the gaps using not the technology necessarily that the last VTA used but to find a way to work with what's now available to fill in the gaps so that's the same thing likewise the two-way services the public safety those sorts of services need fill-in repeaters and fill in well fill in receivers and so they can use the backhaul network as well as the poles to you know in the long term that are initially put in for fixed wireless to reach people who are not yet served on fiber now as far as the relationship of cell phones it's a very tricky very tricky business as to how cell and mobile relates to fixed wireless and to broadband cell phones are not broadband you have kind of a bimodal place where cell phone infrastructure and broadband infrastructure can overlap if you're tealing in a very remote location then this if you put up a macro cell site it'll have capacity both for all the mobile traffic that it's going to see and to provide fixed service to the small number of homes it'll see and that's sort of the retail strategy where it has fixed and mobile and it's new just recently last week funded cells the with the massive will have enough capacity to serve a larger number of homes than before as well as still provide mobile service so you do have the places where the low density means there aren't too many homes for the mobile network to use it's literally its spare capacity to serve fixed and mobile that doesn't scale up very far at the other extreme you have something we don't like to talk about out loud the term is 5g and this is frankly I'm not a fan either 5g is this notion of densifying urban cell sites building small cells higher frequencies to fill in urban areas to give higher capacity so such that maybe even in the city they won't need fiber this is an excuse by a couple of very large companies that are both wire line at and t in Verizon or wire line and mobile to invest more in their mobile side and less in their wire line side and say well people don't need fiber anymore we're not going to maintain our wire line plant we're just going to use 5g fixed well that's not proven I have serious doubts that that's a good idea in urban areas urban areas should be fivered up but again we're looking at these two different models in the middle which is most of Vermont frankly they're two different technologies and the fixed is a less expensive than the mobile they can't overlap and what we had originally talked about at CV fiber my team had come up with an idea working with VTEL was that we could in fact build capacity that would be primarily used for fixed but would also by using VTEL's mobile spectrum and connecting to their network using their license it would also provide mobility it was primary fixed secondary and to do that it had to use mobile capable equipment at a somewhat higher price but we would have done that for various reasons that they have not decided to do that at this point but that concept is is possible but in general the you know the fixed world can fill in gaps and serve neighborhoods of you know 10 homes which you can't do using mobile technology so you know even fewer than 10 homes you can you know reach much farther much more cheaply if you are just doing fixed so there are niche markets where each technology needs to be looked at so that's really where there's a key difference between the two other other questions to answer here is that the role of electric utilities is critical the pole attachment information is important I have serious doubts about the harvesting technology that was proposed I'd like to you know learn more about it before you know making up any my own mind up on it but certainly you know I do have locations of GMP WEC and I think that have you know made their pole locations public but who's on the pole is proprietary and that does impact the cost of adding another provider to the pole and also if there's an existing fiber provider and they're willing to make their fiber available at a reasonable price well you don't have to build the whole thing yourself maybe you could you know lease rather than overbuild that's again something people are the American model was let's discourage competition by saying if you want to be an internet provider you got to pull your own fiber that's crazy you know one fiber has huge virtually infinite capacity why do we need to pull more fiber rather than share the fiber that's on the pole and and that's really been the problem in the US that the model has been pull your own fiber and sharing fiber lets it go a lot farther for the same amount of money building it because you're sharing it among more users who can then share its cost okay that's that's basically what how I how I look at the situation why we need to keep those in mind any questions sounds like if we're going to make this work we have to buck the entire American history of independent profitability but it makes sense and that's part of what the CUDs then are asking if they're they can do a neighborhood or a mountain but they need to know where the nearest fiber hub is that they can plug into because they're not re wiring all the way to I'm not sure where so that's part of what they need to know well that's the one of the questions they need to answer because the CUD has to decide are you know do they have enough subsidies to reach a hundred percent on fiber which frankly require subsidies do they have enough or can they without subsidies just with reasonable access to inexpensive capital reach 80% on fiber and 20% on wireless and also there's a question quite honestly of the incumbent telephone company do they want to cooperate and work with the CUD or are they a competitor in all the time does consolidated or otelco or tds you know do they want to cooperate uh so you know vtel's already built fiber to the home but there's a lot of old copper and it's it's some of not much of it's getting replaced by the telephone companies unless they have subsidy money replacing copper with copper well no replacing copper with fiber but you don't you don't replace copper copper with anything without subsidy money in a lot of these places in and out of the remote places or any places well really in vermont there are not many places where unsubsidized maintenance is happening you know the um other than urban core areas you know fiber isn't profitable without some degree of subsidization you know there you've got the how did how did ec fiber do it very gradually very slowly and they had some low-cost loans from residents of the area that's how they started but how are they doing now well now they're able to borrow money at a reasonable at a rather you know favorable rate i mad chair i would suggest that ec fiber did it because they started in a place where there was the least competition where it was it was so devoid that they could get sign-up rates that were reasonable right but many other places are not operating with such an advantage which is which goes back to we shouldn't be subsidizing for profits to build out and make it more difficult for that you know now that we've got the cud's up and looks like they may be in a position to start stringing if we can get them the poll information um we can do more of that a year ago there was ec fiber and central vermont in a couple smaller ones that are thinking about it and i think we learned yesterday they're a lot farther along than they were and they're working cooperatively so okay i don't know about anybody else but i feel like i've just been given a two-year graduate course in two hours and it's going to take a while to process all of that anything written i like bullets and outlines but i think anything written um because we're dealing on two levels one is we've got kids that are going to be doing remote learning next week and they don't have access to fiber and a lot of them don't have access to childcare and their parents need to work probably more than their parents did last spring because the parents had been sent home either for a load of working remotely um so we're trying to make sure that on an emergency basis we get as many kids hooked up as possible without doing harm to future plans and i think that's one reason we looked at the fixed wireless because it's easier and i believe some of the testimony yesterday was that the fixed wireless you you have to every five years just so you have to upgrade the the the facilities the in general it's it's it's more because more electronics yeah the technology changes and you can okay generally it's a good interim perhaps on the other hand maybe they don't come down as easily as cable does in a blizzard or an ice storm or so there's and we've talked about redundancy with the e911 ability all of which makes me feel like we need to hire a consultant but um okay so next steps i start to feel like i need a list of exactly how many committees and advisory groups are involved in all of this because one of you threw out one i'd never heard of um but we have an oversight committee that's going to be working with the public service department and we've got a list of folks that should be on that including CUDs velco i've also heard a lot of interest in that we do some further work with velco and the electric companies for access to their wire and i last time we had them in which was the last time we met in person a whole six eight months ago um the the utilities and um i think it was the co-ops especially i know washington electric co-op was very interested in working so it's probably time we get them in for an update on their progress and get velco in again um and we need to figure out how we get the poll information not necessarily where they are but what's on them and who determines what is proprietary information do we do the companies can we just say it's not that would probably get us in court right okay we don't like court and i think this is a question that i asked uh peter a little bit earlier uh fred from your experience are there any other states that have tackled this and if so how well or poorly have they succeeded i don't think any really have tackled this frankly it's you know it's it's difficult and um a lot had not many are as rural as remonton have as much of the of the problem um you have different approaches in different states and uh no one has they've started there was a point about 20 years ago in pennsylvania was going to apparently create a loopco but then verizon pushed back very hard and lobbied and stopped it so the the incumbents you know wheeled power and that's really you know stopped a lot of things from happening around the country you have local solutions and you know municipal network here state subsidized network there um but you you don't have any states that have really uh taken the lead to fix the system so ma'am ma'am chair yes in the in this interim period where where we don't have a 10-year plan and we've extended it um and our current plan that we've extended doesn't provide clear guidance we our committee has received from the commissioner um assurances to work hard to extend um i mean to connect where we have world-class service i'm not talking 25 3 um to extend world-class service where it's possible and um and to help cud's organize with the future goal of achieving world-class service and the report we had the other day that commissioner has been has done has followed the commitment that she shared with us a month or two ago and there's a long time between now and next year when the new 10 when the new 10-year plan is perhaps available is there any assistance that we can provide the commissioner and in in her authority to meet that commitment that she's pledged to us and to give her some back up so when when the comcast comes in and says we want money we want money the commissioner can say no without appearing to be arbitrary i think we can produce some guidelines and put some conditions on any money that goes out i know once we talked about they could string it but they had to earn it over to the cud's that didn't go over very well uh but i think yes that's that's something that we can do and we are started to balance basically is our life there's a challenge yeah that is our challenge you might make simply add that this i'm not speaking for against um uh the the polled wireless which may be very effective in some places and not so effective and others spending on topography but those that the big picture there how do we protect and help the commissioner to meet the commitment that she's made between now and and the next plan okay and i think that's something we can all think about i'm going to try and give you a break because we have little things like the act 250 bill just a little this was supposed to be the light part of the afternoon um so i'm going to try and give you a break so you can get a cup of coffee and wake up and um kind of clear the brain for a couple minutes um so so anything that any of our witnesses can give us in writing because we've got several problems one we've got covid money in play and there may be more uh there may not but there's a good chance there will be some left over since the system has to be up and running by December 30th so um we're running out of time to let grants and have any reasonable expectation that something's going to be running and so what do we do with the leftover money is there someplace we could invest it before it get sent back to business grants or loans and how do we proceed we've got some money for covid resiliency planning uh which is going on we've got covid money there but we also have the 10-year plan and i believe there was 300 000 in play that's why it got moved to hire a consultant and i believe that that is still either went through in the original budgeters should be in this one um but the problem of course is the 300 000 is inadequate to do the plan yeah you're right and if we had 300 million we could fix this problem but i think one of the things we need to put just reading the last plan is a the department is been planning to the dollars and the only dollars they've had is the connectivity fund and so they've been planning on well you know we got 10 000 a year or 20 um what what do we do with it and rather than say this is what our goal should be and these are reasonable steps and hand it to us and then let us worry about funding it um i mean the last one was but if you only got a couple thousand a year you're not going to get much vision and i think maybe maybe by a year from now we'll have 300 million dollars from the federal government and we'll be back to rural electrification but um i'm not holding my breath so with that in let uh sander ballon thank you i was um wanting to ask a question of peter earlier and uh faith and i were trying to get me off with newt and we could not figure it out because i was uh the the bluetooth was not allowed yet so um peter you had mentioned something earlier about a broadband coalition in massachusetts and i was not able to get the name of that is that a public private partnership or is that housed within state government i i'm not really not very expert on it i know that it has existed for some years i believe it's a state agency fred fred has worked with them in northern berkshire so could i yield to fred oh absolutely yes well there is a state agency uh called the massachusetts broadband institute now it's downscaled quite a bit it used to be fairly large it's it's residual at this point providing funding but there was a bond that uh funded them that make capital available to municipalities to bring broadband to underserved and unserved areas so uh that agency money is been has been distributed among the towns some are using it to build fiber basically the amount of money was that about one-third of the capital cost of a fiber build would come from mbi and the rest would come from the town and the subscribers uh now in the towns i'm working in the capital cost of a wireless network is less than one-third the cost of fiber so we were able to take the take the subsidy money that was intended to be part of fiber and use it to entirely build wireless these are relatively low tax rateable uh less wealth they're the towns that don't have the fancy summer homes to pay the taxes right and so our university right so so we're so we're building this network now um essentially the towns own it and it's being done by two companies otelco and y valley to uh actually build out the network well thank you i was uh very curious to do some reading about how long that they have been in operation and how many towns they've been able to service at this point it's an interesting model to look at and i thank you i did have someone from there come and talk to me like after hours maybe a year ago but at that point we had said fiber or nothing and i think what we've heard today is an argument that given what we've learned in the last six months nothing really is in an option and that perhaps if we want to do this quickly that wireless is a very viable option and if we want to get something um up that last house because you might have some camps but up there you got some folks living too and they've got school kids if we want to get it there um then wireless might be a way to go and there was a news item on last night about two little girls who were homeless sitting on the steps at the local i think it was a burger king tuned into the hotspot to do their schoolwork and my first reaction was yeah this is california they can do that in january but not in vermont and we have so many kids that the best we can tell them is hopefully you've got a car that'll start in january with tires that will go in january and you can drive down to some parking lot and download your homework and then go home and do it and come back and download it and that's also assuming you've got parents who are available and who can do that so not a real viable option for a lot of kids and i think the necessity of getting something out to them is uh madam chair may i close it was uh madam chair yes yeah yeah i'd like to close with one thought that the window is rapidly closing to uh engineer and install any fixed wireless around the state it's been engineered for cv fiber but they've declined to pursue it uh there are other areas of the state that don't have designs started yet but if if you want to consider the benefits of using these very quickly you're going to need to do two things you're going to need to immediately pull the trigger on getting those designs uh what i call auger ready and auger is the whole use the tool used to drill a hole instead of paul and secondly auger is you're going to need to ask for bail upon the governor to convene the the distribution utilities washington electric for monoelectric and green mountain power because the only way you'll get any fixed wireless installed in this short time frame is by mobilizing those utilities that have the auger trucks and the bucket trucks to uh mount this stuff uh it's it's a it's an urgent matter in my opinion and it hasn't been adopted instead in motion and that window is closing very very rapidly