Vermont Legislature SmartTranscripts:

[Rep. David Durfee (Chair)]: Introduce ourselves to you and then have you introduce yourself to us. Sure thing. Since been some time, if ever, since you've been in here. So David Durfee from Shaftesbury in Bennington County. Represent Sunderland and Bostonbury as well. We can go right around here.

[Rep. Richard Nelson (Ranking Member)]: Hey, Zach. Richard Nelson. Orleans won the Derby. Zach and I spent quality time together this summer. K. Yeah. Jed Lipsky, William Will. Nice to meet you, Jed. Nice to meet you, though.

[Rep. Michelle Bos-Lun (Member)]: Michelle Bos-Lun, Windham Three.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Nice to meet you, Michelle.

[Rep. John O'Brien (Member)]: Brian with Orange one. That's Royalton in my hometown.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Nice to meet you, John. John Bartholomew from Heartland, also represents Windsor and more. Nice to meet you, John, as well. And, yeah, for the record, I'm Zach Czakowski. It's a very difficult last name to spell. Accursive was a challenge growing up, but I made it through. I am an agrochemical program manager with the Division of Plant Industry, formerly known as the Public Health and Agricultural Resource Management. And as one of my job duties, I oversee the Agricultural Residual Management Program, which you have asked for me to come and speak on the reports today. So, I'm happy to roll through just it's a very basic report. Answer any questions that you have. How And, would you like to start?

[Rep. John O'Brien (Member)]: Yeah, I was gonna

[Rep. David Durfee (Chair)]: say for those of us who weren't here right back in 2021 in this committee, some of us actually were, to the extent that, and I don't know what your experience or tenure is in your role, that might be helpful if you can give us where did this come from? Why are we asking for you to give us

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: this report? Absolutely. I'll do the best I can. There may be some gaps in my knowledge. I came on officially with the agency or I guess a little background myself. I began as an intern working with the pesticide enforcement program in 2021. So, yeah, and this act, Act 41, was promulgated in 2021. I officially came on as a full time employee with the agency in the 2023. So that was a couple of years after Act 41. That said, I cannot speak to you directly about the background on how this act came about. But what I can tell you is that it was passed in 2021, and what it did was it changed the definition of farming in Title 10, specifically section 6,001, subsection 22, to add an additional definition of what constitutes farming. So added 600,122. I believe it's G, and that is farming is defined as skip, skip, skip, the importation of less than 2,000 cubic yards of food residuals or food processing residuals for the production of compost on a farm, provided that the compost is either A, principally produced or principally used on the farm or B, the compost is or the farm is a small farm that produces poultry. This is what? It's a small farm that produces poultry. Okay. So a small chicken farm essentially. Yeah. Under chickens. So you have two avenues to fall under this classification of on farm composting. One being you import, and both, you have to import less than 2,000 cubic yards for production of compost, and either you use it on your site, use 50% or more of that compost that you're making on the site, or you have chickens. And so, predating this, there was a contingency, I believe, who, or a practitioner, so to speak, who use chickens as part of their composting process. So the chickens are kind of foraging on the food scraps, and that that was kind of another additional caveat to this practice. So, it changed the definition in ACT two fifty, and then it created a chapter within chapter two eighteen within Title VI, and that is the Agricultural Residual Management chapter under Title VI. And what that does is it's a very short chapter. It's just definitions. There's a section on rulemaking and purpose. And then also within this ACT 41, please stop me if I'm confusing you, and maybe I should have thought more about the background of this visual representations. Is that Act 41 included a provision that we, the agency, include a report annually that we provide to the ag committees at the legislature. And so those are the reports that you've been receiving. Predating me, the first report, I think that was submitted was done by Stephanie Smith. Stephanie Smith was my former supervisor. Dave, do you wanna introduce yourself? Dave is now my current supervisor.

[Dave Huber, Deputy Director, Division of Plant Industry (VAAFM)]: Yes. Hi, everyone in the committee. Dave Huber, deputy director of the division of plant industry. Thanks for having us come in. Just one thing to add to what Zach was saying on the background. Some of you might remember the the phraseology was chickens and compost. And so this was known a couple years ago as the chickens and compost bill. And I think the heart of the matter was a way for folks to have on farm composting where a small scale farm will be able to accept, compost and residuals from those in their neighborhood. And for that not to turn into a farm becoming a dump or a salvage yard, which previously this would have been regulated by agency of natural resources on the solid waste rules. And this was looking to either find a way forward without those rules or alternatively, those rules still work for on farm composting to keep everything status quo with those solid waste rules. Just a little bit more background.

[Rep. David Durfee (Chair)]: Yeah. The the title 10 references, and I think you said this, so it's creates an exempt an active 50 exemption. So a farm or somebody doing this would not need a

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: permit. Correct. Because it's farming. Correct. And on Act two fifty expert, there are additional caveats to the compost situation in there, but that is the general idea. Yes, if you're farming, you are generally exempt from various provisions of Act two fifty. So we passed this legislation and then

[Rep. David Durfee (Chair)]: we said, please give us a report annually. This is then the report. Maybe.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Correct. Yeah. So it's a short report. You ask the less slate tours at the time ask for four things to be included. An accounting of the farms or people that fall under this category of farming or this classification of farming and an approximation of the amount of food residuals or food processing residuals that are bringing onto the farm, an update on rulemaking, and then anything else that the agency wants to share. And then the third thing was any complaints that the agency received regarding people that are performing this specific type of farming. So just to give an overview of how this program works is when I came on, as Dave said, there were a number of facilities, so to speak. At least that's how the Department of Environmental Conservation classifies these, their entities that fall under their soil based management rules, they had a number of farms that were deregulated. So the law changed, 41 was passed, and in that transition time, we, the Agency of Agriculture, worked with DEC to kind of identify the people that were practicing farming as it now was considered under this new definition. I went out after discussing with DEC, receiving a list from them, went and investigated these sites, farms, to make sure that they fall within the parameters of the law. We identified from the list that they provided us, I think it was about, it was eight facilities or farms. There were eight farms that were either, they were all importing less than 2,000 cubic yards, and then they were either principally using it on-site or they were small chicken farms. And then, essentially, we issued them letters of The agency will, on request, issue letters of determination from people that ask that essentially say, You are a farm. You are meeting these definitions of farming, subject to the wraps. These letters are a little different than our standard ones and our standard practice, which is usually an individual who wants the services, but rather we didn't wait for them to ask for us to issue these things. We went ahead and issued them after doing site visits and investigations. Those sites are listed there in addition to several other sites. So that includes the amount of food scraps imported annually going back to 2022. All those eight sites that I mentioned that were on DC's lists are on that list. The additional sites that weren't on that list are essentially sites that I have come to know of either through not necessarily complaints, but just somebody says that this farm is bringing in food scraps and they get included on the list because that's what the ACTS request is that the agency report on farms that fall under this definition and are producing compost. So, that's what that list is. The agency, including myself, will go investigate complaints if we receive them. In that section above, there is a short description so that when we do receive complaints through our normal enforcement complaint process, we will go and investigate it to make sure that they're in compliance with what is currently the solid waste management rules. So a little caveat. Let me again stop, see if anyone has any questions. And it's a rather confusing area of law because it goes between several different regulatory programs as well as Act

[Rep. David Durfee (Chair)]: two fifty as The chart that's on the last page here, Dave, if you want to just pick that up again, it looks like 11 Yes. Including, you said eight that were originally identified, three or more have come on,

[Rep. Richard Nelson (Ranking Member)]: correct? Yes.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Come Some on and come off, but it is a relatively small field or a small regulated community. As noted also in the report, there could be more. It's likely that these are small, very importing, very small amounts of food scraps. Typically, it's not uncommon for a farm to have a CSA. And when their CSA members come to pick up their producer, rather, that they bring their food scraps from last time, and they take those food scraps and they compost

[Rep. David Durfee (Chair)]: And that may be happening without your knowing of it.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Right, and that's generally how, you know, think of it as if someone else from water quality has spoken to this, the RIPs work. If RIPs exist, farms are aware of them that they need to comply with them, but the agency is not fully categorizing every small farm that exists.

[Rep. David Durfee (Chair)]: I think that's an accurate Does statute either act 41 or a statute require somebody who's composting food residuals to let the agency know?

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Not necessarily, no. Well, no. I believe the answer could be no. Statute does not say so. The reporting does not require that we actively determine that everybody that could or could not be making, doing this practice be identified. What we have done is we have identified, to my knowledge, the people that fall into the upper echelon of classification, which is up in the nine hundreds and above, that gets to be a lot. I'm not sure. Yeah.

[Rep. Richard Nelson (Ranking Member)]: It's the smaller amounts. The third one down, Marjo Acres, Martin LaLonde and they right now, this week, their eggs are on sale in the spirit of Easter at three fifty a dozen. During the evening, influenza and eggs were $67 a dozen. They kept them static level $4.50 a dozen. They It's a big egg bar. No. We I don't know how many chickens are running. You know, they brought 25 dozen eggs in Agua the other day, Newport Farmer Garden. And they you know, this winter, obviously, it wasn't near that many, but the chickens were, like, strong. But they pick up compost from the hospital, the high schools, and everything. It seems to be a pretty good operation. You drive by and they got a pile out there and the chickens are it's a retired meat retired dairy farmer. He's got some beef cows, bunch of chickens and compost. You you ever had any problems with complaints on any these places or actions?

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: You know, the agency won't, you know, speak specifically. No. No. Not

[Rep. Richard Nelson (Ranking Member)]: specifically, but

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: We, you know, Very few complaints come in regarding this practice. We have received some complaints, and generally speaking, they were either resolved in the field or are currently, I guess the technical assistance has been the approach. Odor, know, odors can be a complaint with this. Degrading food material, but it's not any different than various other farming odors that come off of a traditional farm.

[Rep. Richard Nelson (Ranking Member)]: And this doesn't cover food though, food waste that would go to non composting facilities, like, if someone was collecting residuals to feed swine or something. And so there's no control on how they store that, how they handle it.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: You I don't want to venture into something that I don't fully understand, but other programs that the agency administers regarding food safety, there is a big I'm sure representative over here is probably aware of that, is regards swine and meat products. We have educational materials regarding that, but I'm not the expert necessarily on that. Part of the way the law was written, and this kind of touches on that, is that, again, a farm can import food residuals and food processing residuals. Food processing and processing residuals exclude waste from slaughter facilities. And yeah, so no slaughterhouse waste. And that's largely the concern regarding prion diseases. And again, I'm speaking a little bit out of my breath here. I'm not an animal health specialist, but I believe that was the concern of why that was included or excluded under the law. But if the meat were produced from the farm, then you could compost it, if that makes sense. It's similar to how the RAPs are done.

[Rep. Richard Nelson (Ranking Member)]: That leads to another question of composting and the struggles that our slaughterhouse industry is having with Rendering. Rendering. And some of that could be, you know, dairy farms render on-site whole animals, if you're aware. It would be not and and and, you know, with the main farms going away, you know, rendering used to be they would get paid for it, and now it's a they're terrific terrific expense. Not many sites taking it. That's correct. It was something that this body with the agency and A and I need to look into is how can we help this industry out responsibly.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Yeah, and myself, as well as my colleagues at the water quality division are in communication with solid waste looking, again, what is the statute is the statute. We can't change that, but we are aware of the issue regarding the disposal of slaughterhouse waste leaving fall, and we are trying to at least brainstorm solutions.

[Dave Huber, Deputy Director, Division of Plant Industry (VAAFM)]: Representative Nelson, if I may chime in, your question about the animal feed for the swine. So it's a little bit of a nuanced answer here. I think Zach was definitely on point about the awful and the conversations that are occurring as far as processing and composting meat residuals. But the heart of the matter here is really these are dirt farmers, and these are folks who are accepting who are accepting food waste from the local community so that it stays out of a landfill. And the point here is to get a clean product back and provide, as as Zach said, potentially members of a CSA with clean dirt. Things that could historically go into a landfill, we're trying to keep out and make it a reusable agricultural product. And the chickens help degrade that. Composting rules apply as far as, best management practices and the turning of the compost piles. And REPs play a huge role here because, these have to be managed in a manner that is compatible with the RAPs, meaning discharges and making sure that these importations to farms are not coming into, are not going into waterways and are being managed responsibly.

[Rep. David Durfee (Chair)]: I'm gonna say, we'll get to representative O'Brien's question, but maybe just have you go through, you've touched on a lot of it already, but just go through the four deliverables and Yeah, sure. Before you do that, Jed, did you want to follow-up?

[Jed Lipsky (Clerk)]: I was just going to say if we want to take a deeper dive into this, we should have micro gradient for half an hour because when he first arrived here in the early 2000s, there was the so called compost force, which was the battle between, I think, the agency of natural resources and ag, because solid waste would fall under ANR. And when you add an agricultural element to it, making compost or we're going to add, it's essentially food for chickens who eat it, make eggs, but they're also adding chicken manure to it, so it's a better compost, so you get a better product that way. And that seemed like an agricultural thing, so I know there was a huge battle then. And this report you referenced earlier of Ag 41 was a compromise. Yes. It's been a bunch of compromises, I think, in years. It's really interesting that it's just a diagram with

[Rep. David Durfee (Chair)]: most of the novel. One of these is about rulemaking, so it'll be interesting to hear that. Why don't we go through them one by one, one in order. Yep, absolutely.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: So Dave, you want to scroll up to the top. Inventory of operators of farms that are producing compost under 10 VSA section 6,000 one-22H. So, that's the list that was referenced earlier. That's the list that I maintain and that I report on every year. Happy to go through that again. Happy to also jump to the second one. No, I think that's good. We've covered that. We've covered that. Status report on rulemaking required under 60 S. A. Section 5,133. So, that section's within Chapter two eighteen under Title VI, and that requires the agency conduct rulemaking for this specific practice. It lays it out specifically in there. In that section, the secretary shall regulate this, you know, people importing food residuals onto a farm, and then we will adopt by rule requirements for management practices for this composting, including one, two, three, four, five enumerated items. So, as stated here, and it's been the same stated in the previous reports, the agency intends to have, I guess, moving back a second, the agency was given the choice to promulgate rules underneath the RAPs or as standalone rules. When I came on, we discussed which avenue we would go with, and after consulting with counsel, we had determined that the best course of action would be to promulgate these rules underneath the RAPs. And as stated for those reasons, it's protections from municipal zoning that you're afforded under Title 24. And that was the idea, is that if these rules weren't under the RIPs, you could potentially miss out on having those protections. And then the additional caveat that I added for this year is that we were, again, kind of thrown off by the Supreme Court case recently, and that we wanted to see how things would go this year in legislative session to decide on whether or not we're going to continue to push for these to be under the REPs, or whether we're going to go ahead and promulgate rules as stand alone. And I'm happy to do my best to answer questions on this. I'm not an expert on the municipal regulation zoning thing. I know somewhat. But yeah, we are we are a committee of experts as it happens. Steve Collier, our general counsel, said he would be if you do wanna talk further, he could

[Rep. David Durfee (Chair)]: reach out. Yeah. And I think maybe when Steve did next time, we might ask him if he wants to speak to this at his when he's available. I know it came up, somebody maybe on Small Farm Action Day, it's come up at some point, somebody saying, what's going on with the banking? And I think we don't know enough about the back, and now we know more, but what did the legislation say that the rules should do? Why do we need rulemaking?

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Right. So, a part of this, clarity, is that Act 41 also stipulates, and they did a good job about filling the gaps in the meantime. So, until such time as the agency promulgates its own rules, the agency is implementing the solid waste management rules. The solid waste management rules are very comprehensive regarding the proper methods of composting, and that's what is currently in place. It's not as though there are no. Absolutely not, no. The legislatures at the time had foresight to make sure that there wasn't going to be this kind of vacuum until such time that the agency would promulgate rules. So there is existing regulatory structure. And in every determination letter that we have sent to mostly these larger farms that are doing this practice, they're aware of the application of the solid waste management rules, which cover time, temp, all the essential components of what a composting operation should be in compliance with.

[Rep. David Durfee (Chair)]: All right. Then the third, you've covered, I think. Yep.

[Rep. John O'Brien (Member)]: One

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: complaint. But a complaint is not the same thing as a violation. Correct. No violations were found. The odor thing, as I mentioned earlier. There can be problems with odor. And the facility, the farm has a management plan. Every time we've been out there, it's in compliance with applicable setbacks. And it's a matter of managing like any other odor issue with a farm and a neighbor.

[Rep. David Durfee (Chair)]: Right.

[Dave Huber, Deputy Director, Division of Plant Industry (VAAFM)]: Mister chair, just to jump in real quick. When we have gone out because of the questions or concerns or this complaint, Zach goes out, I've gone out, and then we'll also take out one of our agricultural resource management specialists. Those are the folks who go out for pesticide inspections and investigations, feed and fertilizer, apiary, ginseng, any of our inspections or investigations. So we do treat this as serious when we get a complaint about composting as we do any of the other jurisdictionally, you know, sensitive areas that the agency manages. And, also, just just to clarify one other thing here, in the absence of more rules and regulations promulgated by the agency of agriculture, should the solid waste management rules work in the meantime, it seems like a good thing to keep it going with the solid waste management rules. We haven't found from our conversations or meetings with any of our regulated counterparts here that the solid waste management rules don't work as of right now for their operations. While other rules might be requested or contemplated under the statute, the agency has not found that the solid waste management rules are untoward or don't work for the regulated community at this point.

[Rep. David Durfee (Chair)]: Any other questions or anything else that either of you wanted to add? No, I guess nothing to add for number four.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: You can look back in my previous reports there. There is an element of of risk involved in accepting some of this material. That's. That's really the only other thing of note. But a lot of these facilities do a good job in working with their, I guess, science, as you could call it There's

[Rep. Richard Nelson (Ranking Member)]: a

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: plot. To reduce the amount of potential contamination of of the feedstock. But that is it's always gonna be a risk.

[Dave Huber, Deputy Director, Division of Plant Industry (VAAFM)]: Another thing, mister chair, and members of the committee, one big complaint that we get from the regulated community community is about PLU stickers. So if you think about Chiquita on the banana or that little barcode on the avocado shell, the exterior of the avocado, the rind, you know, should be removed before putting into a compost pile. And a lot of folks who are looking to compost are looking to do it appropriately and with common sense and they mean well, but there is always that added layer of maintenance, that when that's involved, it does make it a little bit difficult for people to stay compliant. And so what we hear from the regulated community is we really wish that those PLU stickers, maybe something were to change with those just to make it a little bit easier to accept the food scraps. Now it's not hard for somebody to drop off food scraps. Usually there's a bin where somebody will come around and collect the food scraps from the neighboring community. But it's it is pretty difficult to to tell people who are maybe not part of your CSA, I can't accept this because you haven't done your maintenance part. We have heard from those who have CSAs that it is easier to tell everyone in the CSA in a newsletter that, you know, here's the rules for the CSA. If you're gonna bring, back your food scraps, please remove all metal, all, PLU stickers or SKUs or anything like that to make it as easy of a transition to go through the composting process because certain things don't break down, and we wanna make sure that we're not putting things into our soil that we wouldn't wanna put into our body.

[Rep. Richard Nelson (Ranking Member)]: The upside is the bag with Chiquita.

[Rep. David Durfee (Chair)]: Are these food residuals typically coming from consumers or, individuals as opposed to businesses, retail, or other?

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: It depends on the size. So as you can imagine, the larger your sources, more institutional sources, the the potential for emanation goes up. So it's not just household? That is correct. Yeah. It's almost like you were listening into our conversation. A few of us earlier were having this very conversation wondering if Vermont can do anything to make these labels compostable. Yes. It's very weird that you brought that up. And thank you, Dave, for bringing that up. Yeah, it's that and silverware is a commonly

[Rep. Richard Nelson (Ranking Member)]: challenged. It's up there. Metals? Is that

[Rep. David Durfee (Chair)]: metal and plastic? Yeah, both.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: And more so when you get into the schools and the hospitals.

[Dave Huber, Deputy Director, Division of Plant Industry (VAAFM)]: That's another thing the committee might want to look at, the language surrounding compostable materials such as what Zach said, the bags or the silverware, whether or not they actually are compostable, know, I mean, they might be degradable. But is that something that is going to stick around? How long does it take to break down with conventional composting, practices? And if that's something that the farming community is worried about or they feel like sometimes they feel like they are a little bit of a dump because they do accept this material and then they're stuck with it. So just something for the committee to think about.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: And I do, I have reached out to the community and a lot of them do their best efforts to not accept what is compostable bags, but lot of times it's a farm. Farms are very busy and very understaffed. It's not always easy to monitor what is potentially coming in some of these things. Yeah.

[Rep. David Durfee (Chair)]: Well, you both for joining us and for the report. I just wondered, I mean,

[Rep. John O'Brien (Member)]: referencing what President Nelson said earlier that I remember Michael Grady telling us that there was like a bakery in Ticonderoga that their seconds are bought and actually fed to, I think even cattle, maybe even dairy cattle, and maybe some of the hogs. But just that whole sort of category of food residuals that's usually Guinness food. Where does that fall in this? Because that doesn't go to dirt farmer.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: That is correct. Yeah, baker's commodity, I believe you're talking about baker's commodities. That was I'm speaking a little out of my depth here. My understanding is that was traditionally a large Where a lot of fall and slaughter waste would go. I don't know exactly what they would turn that into. I don't want to speak incorrectly. I just know that was the traditional route. I do know that they raised prices. I believe that is to be correct. And that avenue is not necessarily available as it used to be. But that you're correct that that type of waste wouldn't come underneath this program as the law is written.

[Rep. John O'Brien (Member)]: Because it's not being for a problem.

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: Correct. Yeah. So the law allows for importation of food processing residuals and food residuals. The definition of food processing residuals specifically excludes waste from a poultry or livestock slaughtering facilities, which that would be classified as.

[Rep. Richard Nelson (Ranking Member)]: There's another four chamber fermentation process.

[Rep. John O'Brien (Member)]: You talked earlier about how, like the residue from breweries, for example, right? Bio digesters, but is it ever used for feed?

[Rep. Richard Nelson (Ranking Member)]: Well, yes. But brew goes to feed cows, to feed swine. Right. Now there's by bakery, by product. You know? And then I've heard of them getting by product from, like, Cabot. Right. You know? And I'm not talking whey. I'm talking cheese by product. Right.

[Rep. John O'Brien (Member)]: Like a swan. That would fall under wraps

[Rep. David Durfee (Chair)]: potentially if it's not solid waste? I

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: don't want to give you the incorrect answer.

[Rep. David Durfee (Chair)]: Maybe it's

[Zach Czakowski, Agrochemical Program Manager, Division of Plant Industry (VAAFM)]: generally solid waste. There are certain programs. There is another program within the water quality division that deals with non sewage waste. I believe you heard a bill this, right, that changes some of the elements of that. But generally speaking, slaughter waste is considered salt waste.

[Rep. John O'Brien (Member)]: Right, but the non slaughter like we're Right.

[Rep. David Durfee (Chair)]: It Food seconds and things like that. Right. Any other questions? Okay. Good. Well, thank you for getting us

[Rep. John O'Brien (Member)]: Yeah. Helpful.

[Rep. David Durfee (Chair)]: Absolutely. Thank you for for having me. Alright. Thank you. My pleasure, Lord.