Vermont Legislature SmartTranscripts:

[Rep. David Durfee (Chair)]: Good. PFAS is another topic we might want to hear from you or others on at some point. But today we're focused more on the implementation of Act 41. And we had spoken yesterday, we heard from rural Vermont and just thought it might be helpful to hear from some of the folks who are actually doing the convo today. So please come up and join us. I should have asked earlier whether you had anything that you wanted to share on the broadcast on the screen, but

[Natasha Duarte, Director, Composting Association of Vermont]: I don't today. I just have some notes to try to help me be you know, concise and and tell the they got the timelines right. So I'll just be referring to some notes. Okay. Perfect. But I'm happy to follow-up with, you know, any further references.

[Rep. David Durfee (Chair)]: If you have anything you wanna submit to have posted on the website, we'd be happy to take that. But why we just start by having you introduce yourself, where you're from, and then we can launch right in.

[Natasha Duarte, Director, Composting Association of Vermont]: Great. Thank you so much for your interest in on farm composting, of food scrap residuals, as well as for the invitation to be here today. For the record, I'm the director of the Composting Association of Vermont. My name's Natasha Duarte. And I thought I'd just give a little just a snapshot of what the association is about so you have some reference for the folks we work with. We were founded twenty five years ago. We're a small, member based, non educational nonprofit based out of Hinesburg, Vermont, so Chittenden County. And our membership comprises solid waste management entities, compost facility operators, but also farmers and community composters, as well as organizations and businesses that share our mission and our vision for composting. And we have a growing number of concerned citizens who are just getting involved and trying to be more active in this, arena. And I just thought I'd also mention that we're also members of the US Composting Council, and so I sit on their legislative committee as well. And so I get have the opportunity through that work to hear from other states and then also reflect back what we're doing in Vermont. Our mission broadly is to champion, both production and use of quality compost as well as compost standards, to support healthier soil, cleaner water, and stronger communities. We see composting really as that integral link between sustainable agriculture communities and strong local economies. And I'm happy to talk more about that later. We also advocate for market development, access to resources, and compost standards, which just touches a little bit on what we're going be talking about today, to develop really an environmentally sustainable composting industry in our state, and also hopefully influence the those in our region as well. A lot of folks look to Vermont as leading the way, especially within New England. We organized the annual Vermont Organics Recycling Summit, which I think Carolyn mentioned a few times, in her testimony yesterday, as well as other educational events. And this annual summit is really where we foster conversation and a hold space for dialogue around everything from policy and practice, but also things like biochar and, connections between solid waste management world and food security in the state. And so it's sort of a broad, a broad platform there, and that's done in conjunction with the Agency of Natural Resources. They put out a a call to to host the the summit, every few years. As for me, I've been the director of the Composting Association for coming up on nine years, but I do have over twenty years experience with community based projects. I have a master's of science in soil science. I'm also the curator of the Farm to Plates Food Cycle Community of Practice, where a lot of the on farm composting work actually took root and grew from. Recently, we had two rounds of USDA funding to work with two cohorts of farmers to establish on farm composting, both in Vermont as well as in New Hampshire and the North Country in New York. But beyond that, my experience with on farm composting actually goes all the way back to my work in the Peace Corps in Senegal in the mid nineties, where composting and working with farms and both making compost and using compost was sort of the cornerstone of my work there. So I have a really deep experience with this type of work. I thought it would be helpful to maybe start with a little bit of background of the on farm composting work that led up to Act 41, and then what's happened since. Around 2018, within the food cycle community of practice, members of the community brought forward this idea of on farm composting for a number of reasons. One, we had been focusing on the universal recycling law act one forty eight and thinking how can a state like Vermont achieve our goals of diversion, especially in the rural areas, without finding a way to engage and incentivize farmers to be a part of solution. In many of our rural areas, we have challenges like root density for haulers or just the distances to a certified compost facility to to move the material. And then we have farms that are often the cornerstone of many rural communities who who are also buying in fertilizer in many cases, who have interest in composting, but may have some challenges around actually engaging in that practice. And so we set about looking into this to figure out what the challenges were. Survey of about 40 farmers and organizations working with farms to help identify gaps in closing the food loop. So, how can we make these more decentralized local closed loop systems in our state to help reduce nutrient rich resources? And then also to identify opportunities and barriers. And I think it's level summary of what that survey found because it sort of laid the groundwork for what came next. So opportunities that farmers identified were access to organic resources to improve soil health, water quality, and farm viability. Increased services for CSA, members or other farm you know, folks who are coming to farm stands or farmers markets, potential for converting part time employees into full time employees. Maybe a part time employee could then take on some of the actual composting work and become a full time employee. And then also the potential for adding revenue streams. Almost all of the farmers we ended up working with were thinking, we wanna we wanna make enough compost and understand how to use it to meet our own fertility. But as we keep doing this, it it there's potential for it to become an outlet to to sell, and or barter and have that actually be a revenue stream. So really directly linking it to farm viability as well. The challenges that farmers identified were balancing the agricultural practices with solid waste management practices, specifically around rules and regulations. So this was pre Act 41. And so if folks wanted to do this, they then were sort of having to fit within the Agency of Natural Resources Solid Waste Management Program rules. And one that was a little confusing, and as I'm guessing most of you here could probably relate to, a lot of farmers really rankle at being considered a solid waste management facility as opposed to a farm. Right? These are they're not thinking about it in terms of waste management, but these are resources, right, that are that have value to them, that they are managing responsibly, adding to the soil, you know, creating a compost product, adding it to the soil, and gaining, really, soil fertility from it. And so that was a really, really bright line that was raised. There were some concerns also raised about technical know how and having confidence in doing it well. One of the things, interestingly, that we heard from some folks who work with farmers but also from the community at large is this assumption that, of course, farmers know how to compost. And really, when we talk to the farmers, they might have sort of like an aging manure pile or a rock pile in the corner of their veg garden, but they don't necessarily have the skills to start taking in food scraps from the community and managing them well to create a quality product. There are Please, yes, anytime.

[Unidentified Committee Member]: We're talking about that, Natasha. Is there a definition of compost? Because I was thinking, at what point does a manure pile get close enough to being soil so that it's compost?

[Rep. Jed Lipsky (Clerk)]: Or

[Unidentified Committee Member]: is composted that's more

[Natasha Duarte, Director, Composting Association of Vermont]: Sure, it can be. So composting is the aerobic biological transformation of organic materials into a compost. And compost is sort of like that earthy it has high organic matter, it has that rich biology, which we still don't know everything about, and people kind of like, Oh, here's the chemical profile. It's really the biology, both in the composting process and in the finished compost, that are like the heavy lifters. They're the ones breaking everything down and transforming that material into something that's more stable and usable. And then the compost itself is really rich in that biology and organic matter as well. Does that so from a manure pile, for example, it's a little if it's totally hands off, you could think about it also just like what happens in nature. Organic materials break down, right? This happens all around us every day.

[Unidentified Member (farmer)]: Like leaf litter.

[Natasha Duarte, Director, Composting Association of Vermont]: Like leaf litter, exactly. One of the differences between that kind of decomposition and composting is it's an actively managed pile. There are some temperature requirements as well, whether it's sort of that mesophilic or medium hot, so maybe not getting, you know, like, 70 to 120 ish degrees Fahrenheit. And then there's hot composting, which is 131 degrees Fahrenheit or more. And that number specifically is the number for further reducing pathogens, and it also kills weed seeds. So from the point of managing these materials to create a product that can be used that is free of weed seeds, especially if you're managing any materials that might have pathogens associated with them, having some point reaching those higher temperatures through management and turning is important. And when you don't necessarily have those higher temperatures, you want more time because things do continue to break down and resolve. And so we often talk with the home composter, community composters, on farm composters. Municipal and commercial facilities have a lot of the science dialed in. But a lot of it is if you are going to do lighter management, you want more time before you're actually using it.

[Unidentified Committee Member]: So So is there almost a parallel with say pasteurizing milk that when you get too hot, besides killing pathogens, also, I would assume, kill some of the good microbes?

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah, so you really want and there's different management techniques to sort of not let it get too hot as well. So composting, need and a lot of people think of it as sort of like farming the biology, right? You want to create the conditions that the target biology for breaking down these materials can thrive. They need the right amount of carbon and nitrogen, which is their food and energy, and then air and moisture or water. Sort of like us or your pets, right? We all need food and water and air. And that's you can create a higher quality that's when you know that you're actually fully breaking things down and that you're going to end with a stable, well, higher quality product. Yeah, and please interrupt. I'm trying to give some background, any time, Flag me if I

[Rep. David Durfee (Chair)]: You mentioned aerobic. Does it have to be aerobic to be considered compost?

[Natasha Duarte, Director, Composting Association of Vermont]: Composting, yes. So anaerobic digestion, AD, is another way of managing and breaking down organic materials, but that is a different process. It's a different biological process. That's without air. Mhmm.

[Rep. David Durfee (Chair)]: You end up with something at the end that has

[Natasha Duarte, Director, Composting Association of Vermont]: got nutrients. You you do. But it's in a different it's in a it's in a different it's managed in a different way. So, for instance, if one of the things that we look for with composting and troubleshooting is if you're having a lot of odors or if it's gotten really wet, it will smell worse. And that's one of the clues that you need to either add drier material or something bulky to help create that porosity in there or even just turn it to allow air to get in. So it's it's a different process. And not that we want to get into this today, but at some point, if if you want to, I'd be happy to. There are facultative bacteria that that can switch between anaerobic and aerobic processes. And so the biology is a lot of fun. But, yeah, so anaerobic digestion is something different than composting. Composting by definition is aerobic.

[Unidentified Member (farmer)]: Is there another question? Representative Lipsky? Natasha, thank you.

[Rep. Jed Lipsky (Clerk)]: I had a little foray into composting about ten years ago where we have a neighbor who had a dairy operation, feed operation, but not much land. So he brought a lot of manure solids, but it also had a unfortunate number of, you know, deceased cows in there. Yeah. We had a wood chipping in Arboristas, so we're dumping piles of wood chips too, and we thought, oh, this is simple science. It's just can't blend it too. And then there were days I'd come into the yard, and it was, like, called the wild. There were so many coyotes up on top of this pile, then Addison, know, we don't know what we're doing, so we And that's blended stuff. Yeah. I think there's still a fair amount of compost in that vicinity.

[Natasha Duarte, Director, Composting Association of Vermont]: Cows compost that easily. Well, mortality composting is a thing, actually even with the avian flu I'm that

[Rep. Jed Lipsky (Clerk)]: not sure to wear.

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah, yes. Sorry to my back.

[Rep. Jed Lipsky (Clerk)]: But it came from, but not him. But anyway, are do you have resources that for peasants that might have some of these ingredients that Absolutely.

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah. I'd be very happy to share. And I did bring cards. I'd be happy to leave you with with a business card. We have a lot of free resources on our website. Happy always to, take calls for specific situations. But that's a great example, actually, of feeling like, oh, you you just throw this together, and it doesn't necessarily always go to plan. And that's when it's really helpful to have someone or resources to reach out to be like, we did this. And especially when mortality composting, which is a best practice for for managing mortalities, there's a lot of nutrients in there. It can absolutely be done. But like anything in our world, really, there you can do it poorly or you can do it really well. It might cause issues that are unwanted or nuisances, and it it might be really great and produce a high quality product. And so it's really all about providing education and training and technical assistance to help people dial in and get it right.

[Unidentified Member (farmer)]: Right. Yeah. So the amount of times you turn it makes quite a difference in the breakdown. It does.

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah, so I can elaborate just really briefly on that. So there are a lot of different systems and ways to compost. Some are in like piles and windrows that folks might be accustomed to seeing more, but you can also have them in bays, you can add air or not, you know, so it can be in tumblers or closed vessels. And depending on the type of system, there are different guidelines for how often to turn or mix. But basically, what that aerating and mixing does is it makes sure that the carbon and the nitrogen materials are all mixed up, that everything is somewhat equally wet or moist, and also that there's air throughout the system so you don't have pockets that are really wet, anaerobic, smelly, maybe causing problems, but other parts might be really too dry. And either extreme will slow that biological process down. So, yeah, again, it's just trying to create the environment for that microbial population to thrive.

[Unidentified Member (farmer)]: So we do like compost dead animals in an old bunker silo with a wall out. So you've got maybe a five year span of material. And in the back of that, which may be five years old, we don't turn it like maybe three, four times a year. Sure. But the stuff in the back, very back, it's just the blackest, nicest soil. Mhmm. And every now and then, you get a bone from a cow leg or a skull, the rest of that breaks Sure. Beautiful.

[Rep. David Durfee (Chair)]: Representative Nelson, did you want to comment or question?

[Rep. Richard Nelson (Ranking Member)]: No. The static pile, I've done static piles and I've done windrows. And a static pile takes a terrific amount of time. We'll make a decent product but if you put it in windrows and really work it you can take a bedded pack material that will snap your head back from the smell of ammonia in it and in six months it will smell like the forest floor. And that's when you know you got a product that's ready. When you grab it and it smells like you're in the hardwood forest and you reach down and grab that rich peat earthy material and smell it. That's when you got it made.

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah, and also that you don't mind reaching in and grabbing that material, right?

[Rep. Richard Nelson (Ranking Member)]: Well, hands clean up a lot easier.

[Natasha Duarte, Director, Composting Association of Vermont]: It's true. It's true. Yeah. So just back to some of the challenges that farmers do face, it's just the potential for contamination. And this you know, there was a lot of concern, and this has been echoed in my conversations with the agency of agriculture staff around creating rules, is like this perceived concern that if you take food scraps from your community, you are, by definition, inviting in plastics and contamination and all of this stuff. There is really good research that I'm happy to share that actually shows community and on farm composting as some of the cleanest separated materials, in part because I know you. Right? The community knows the farm. They often are getting the food from their farm. They understand that it's more of a relationship based diversion of these materials as opposed to, I have a hauler, I bring it down to the end of my drive, I don't even know where it goes. It's much easier to let different things slip in. I'm not saying in any way that it's a perfect system, because humans all make mistakes and need reminders, and they need training up front on what is accepted and why, etcetera. Like, why no plastics? Why no compostable products? If they're If a farmer is deciding not to take those, some do. But it's this ability to, again, when it's smaller and community based, to have the the communication systems often already exist. And so if a farmer gets stuff in or some contamination is creeping in, they often have a mechanism for letting their community know, and then it cleans back up again. Because it's not anonymous. It's like, Joe's going to have to spend two hours picking through this. We'd rather he actually make food for us. Right? So and so I just want to highlight that that is one of the differences, and certainly in the work that I've done farmers. It's very relationship based, both in the relationship I develop with the farmers that I'm working with and supporting, but also in the relationship between the farmers and their community members who are bringing them their food. And so I feel very hopeful that this is actually a very doable practice. For communities from that perspective, really, folks are looking for affordable, local, convenient, organic diversion options. A lot of Vermonters who I talk to, when they learn that a large portion of our organic material is being trucked to Maine, they think, like, are you kidding me? What are we doing here? What was the point of this? Aren't we supposed like, it just doesn't make sense. And they're paying a premium to export what is really a valuable resource out of our state. And we could talk more about that if there are questions about that. But then some of the challenges for community is understanding the real need for source separation and clean materials, and then also understanding their relationship with farmers and that farmers, you know especially when farmers are also trying to do the hauling and trying to do everything themselves, you know, being a farmer is really demanding. It's one composting is one of a bunch of things that happen. And so we've spent a lot of time working with farmers on systems. Some do choose to work with haulers, but often farmers are just saying, like, so we have a CSA, a community supported agriculture, program. Those members can bring their food scraps to us when they come to pick up their CSA produce or meat or eggs or whatever it is. And so it's an exchange, right? And that's really a nice, very tangible idea of what a closed loop system can be. I'm bringing you the scraps from the food, what's left over of the food that I just got from you. You're turning it back into soil, growing more. I'm bringing that food back home. And so that's the idea of this, the circular nature of this.

[Rep. David Durfee (Chair)]: Natasha, do you

[Unidentified Committee Member]: have any idea? I mean, you'd be the person who would know of, with universal recycling in Vermont, of what percentage of our food scrap, post consumer food scrap, gets actually diverted composting?

[Natasha Duarte, Director, Composting Association of Vermont]: To composting? So we could talk about data. That's of a big black box that I love to talk about. And there are some really good reasons why we have challenges around that. But we're composting I think it's around, like I think it was, like, 56%. And but how it's a little unclear with the advent of depackaging, which is a whole another conversation that is little bit of a rabbit hole. But how some of the volumes are reported, it's a little unclear as to because some of the that material was going to compost, but now it's going to the DPAC, and then it's going to anaerobic digestion primarily. And so it's hard to give you an exact number. And then the other holes in this number are we have sort of survey based best guesses of home composting and community composting, but we don't have it's not like people have to register, I have a home composter, and this is what I'm doing. And so there's always a little bit of a gap in the data that we don't know. Does that

[Unidentified Committee Member]: Institutions, restaurants, etcetera?

[Natasha Duarte, Director, Composting Association of Vermont]: Institutions? So, a little bit better, but it's really they don't report it, And so it's really we have data for what is delivered to certified facilities, but not necessarily it doesn't capture everything. But we do have better data for that.

[Unidentified Committee Member]: Yes. Yeah. I'm wondering I mean, so, like, I I compost at my on my own property. Mhmm. But my town doesn't have an option for, oh, we'll pick up your compost at the end of our driveway. So, like, how do towns deal with that? Like, I know some of my neighbors just throw their compost in their trash. That's not what's supposed to happen, but what is the alternative supposed to be?

[Natasha Duarte, Director, Composting Association of Vermont]: So every transfer station, including the fast trash for rural areas that have just the fast trash that sort of shows up, all are supposed to be taking food scraps and so food residuals. So that is an option. There at should be the transfer station.

[Unidentified Committee Member]: Maybe there is,

[Natasha Duarte, Director, Composting Association of Vermont]: but I only have a preference. I think there's, like, 103. And so some are like, Here it is, and there's signs, and there's carpet. There's wood shavings to put right over it. And some, it's sort of, we have it, we don't really we have it because we're being required to have it. We're going to put it behind the shed, and if someone asks, we can point them to it. And so, that's where there is a bit of inconsistency throughout the state. And then the other thing, just to make things a little bit, spicier, is, depending on where you are in our state and where that material is being managed, different things are accepted. So some compost facilities accept compostable products, like paper plates or paper cup, that kind of thing. And many do not. And so if I'm in Brattleboro, the instructions for what I'm able to divert is different than if I'm in Heinzburg or if you're in Hardwick or wherever. And if it's going to a farm, some municipalities have partnerships with farms. Like Hudak is a great example. Hudak Farm in I think they're in Swanton, but for St. Albans Yeah. So they're a farm. They take their solid waste district's food waste, food residuals, and they don't take compostable products. So everyone sort of has their own rules depending on where it lands. And then in terms of on farm composting, if you produce certified or if you're in the organic program, there are things that you're not allowed to take that other farmers outside of even if you're following generally the same practices, but you're not certified organic, that you can take. And so there's just a lot of confusion. That was actually one of the points of confusion for farmers. I spoke with a couple farmers who had, like they thought that everything that they took to compost had to be also organically produced, which is not true. Once it's compost, you can take orange peels from the grocery store and residuals from your own organically grown crops and mix them together and still use that as long as you're following the correct practices for making compost. So you don't have to have two piles, which then makes it totally onerous. So some farmers were like, oh, well, this is so much more accessible now. Right? And so it's just a matter of making sure that people have the information that's correct that they need to navigate that.

[Rep. David Durfee (Chair)]: Wanna do a time check here.

[Natasha Duarte, Director, Composting Association of Vermont]: Yeah. Out of the time. Almost out of time?

[Rep. David Durfee (Chair)]: Okay. Yeah. But if we can have you come back

[Unidentified Member (farmer)]: Yeah.

[Rep. David Durfee (Chair)]: Happy to. Before. Yeah. And I know the couple of things that you've mentioned that we hadn't intended to talk about, and they can also be good topics for conversation, but if there's anything that you want to cover in the few minutes that we have left that relates specifically to-

[Natasha Duarte, Director, Composting Association of Vermont]: I do. Yes. Thank you. I will just very quickly say that we have been well, one, I'll leave you with a copy of this. It's also available. We're we're running out of printed copies, but we have PDFs. It's a guide that we put together, regulatory and startup guide for on farm food scrap composting. This came out right as Act 41 was passed, and so there's references in it like, hey, this is coming. The legislative, you know, environment is always changing. Here are things to think about. But we've been working very closely since act 41 passed with the agency of agriculture when it was under, the rules draft rules were under Stephanie Smith, and it was gonna be stand alone. We gave them comments. Then the agency decided that it should be as part of the RAPs, which is fine. In conversations with Dave Huber and Zach Krasnowsky, we realized that they really didn't have a basis and the breadth of knowledge needed. So Carolyn, I think, mentioned this. We actually drafted rules. And we did this through the Composting Association of Vermont's network, rural Vermont, and the Food Cycle Coalition within the Farm to Plate network, and got a lot of feedback from practitioners and proposed rules for consideration, and we've really heard nothing from that. I do wanna say that we are, we feel that rules from the agency of agriculture would be very helpful, but really only if they are practical and actually based and grounded in incentivizing and making this practice accessible and well done for farmers. And so I do have, there's a labeling, and registration requirement as Act 41. That's being rolled out in the last maybe, I think, like, six months ish. And it is making it untenable for for farmers and composters broadly. And I was hoping to talk a little bit more about that, but, I would be happy to submit written comments or come back to talk more about that. And so, really, we need to what we are hoping for is a commitment from the Agency of Agriculture, hopefully supported by all of you, to have rules that incentivize and make this practice both done well. We're committed to protecting water quality, building soil health, doing a good job. But it needs to be accessible, and it it we don't want this to become one more barrier to this practice. We feel it's really important, especially for our state, especially in meeting our goals within the universal recycling law for diversion, but also our climate readiness goals in terms of building healthy soil that acts more like a sponge, that is helpful in times of drought and heavy rains. There are so many benefits that I could talk a lot more about, but I would just urge all of you to, in your communications with the Agency of Agriculture, to just help them remain grounded. Because on farm composting can be really tiny, and it can be right up to the 2,000 cubic yards per year limit in statute. And it's not a one size fits all. Someone managing 10 cubic yards should not be regulated and asked to follow the same rules as someone managing 2,000 cubic yards. And so we've made ourselves as accessible to the agency of agriculture folks as we possibly can, which has been met with you know, they're not always take what we suggest under consideration. I mean, take it under consideration, which is totally fine, but we work hard to keep dialogue open, and the same is extended to you all.

[Rep. David Durfee (Chair)]: Can you just verify, thank you, that was helpful, Sasha, but when you mentioned labeling and registration, so this has happened, Did it happen because the statute said it had to happen?

[Natasha Duarte, Director, Composting Association of Vermont]: It is. So there's a section in Act 41 that requires and a lot of it is around, like, how do you know what's in this product? But, for example, you can't say you can't talk about the biology that is so integrated into nutrient cycling and what you get from compost unless you're able to list every single bacteria, every single biology species that is in there, which is dynamic. It's not static. You could never do that, which means effectively, under the current rules, you can't make any biological claims at all about compost.

[Rep. David Durfee (Chair)]: I guess I'm just confused about where the rule came from. Is it the ANR rule?

[Natasha Duarte, Director, Composting Association of Vermont]: No, it's Agency of Agriculture. It just got some high level publicity at the Vermont Organics Recycling Summit. We had a policy and practice session, and we were hoping that Stephanie Smith Jill Jill Goss will come and do an online session for composters. So they're within the agency of agriculture. It used to be and I apologize, it used to be the farm division, and they've renamed it plant yeah, plant. And so it's all about consumer protection, which I understand is important. But the way it is is if you have one thing changed, like, if you change it from, you know, like, where you're sourcing or the type of wood shavings or wood, you know, carbon product you're using, you would have to throw away all your bags and get new bags because it's not updated. Or you'd have to put stickers on the like, All of the fixes around that don't make sense.

[Rep. David Durfee (Chair)]: I'm sorry to interrupt. Far as My question, Jill, about the process. Through the rulemaking process?

[Natasha Duarte, Director, Composting Association of Vermont]: It did not.

[Rep. David Durfee (Chair)]: So what is it if it's not rule?

[Natasha Duarte, Director, Composting Association of Vermont]: So I think it's and I'm happy to provide you with the links that we have. I think it's just regulation. Part of the registering process of a product that is claimed as a soil amendment has to be registered. And part of that is this labeling requirements. And it is based on national standards, but they're more focused on fertilizer than on a biological product like compost. And so you can say what NPK like, chemical fertilizer is very different in terms of labeling. And so that's I'm happy to follow-up with those direct links. But I believe that it came from that registration requirement in Act 41. And so, again, it's how that's then interpreted and rolled out by the agency that is has our community scratching its heads a bit.

[Rep. David Durfee (Chair)]: Okay. Good. That actually, I think, makes more sense when you said soil amendment because that's existing language.

[Natasha Duarte, Director, Composting Association of Vermont]: Right, so we dance around the words, right? So I will definitely follow with all of you with some of the links to the the the regulatory guide, the labeling, and maybe a summary of what we hope to see moving forward.

[Rep. David Durfee (Chair)]: Okay. Send that all to Patricia. Yep. She can make sure that we get it, and we'll also have it available to the public on our webpage.

[Natasha Duarte, Director, Composting Association of Vermont]: Wonderful. Thank you very much. Yeah, thank you so much.

[Unidentified Committee Member]: Are we going right in or a little break?

[Rep. David Durfee (Chair)]: Anybody need a little break?