Vermont Legislature SmartTranscripts:

[Speaker 0]: We are eleven.

[Speaker 1]: All right. Good morning, everybody, and welcome to House Energy and Digital Infrastructure. We're going to be working this morning on hearing the report of the Building Energy Code working group. I'm representative Kathleen James from the Bennington 4 district.

[Speaker 2]: Richard Bailey, Lamoille two. Chris Morrow, Windham Windsor, Bennington. Christopher Howland, Rutland four.

[Speaker 3]: Dara Torre, Washington two.

[Speaker 4]: Bram Kleppner, Chittenden 13, Burlington. Laura Sibilia, William two.

[Speaker 1]: And in the room?

[Speaker 5]: Andrew Brewer with Downs Rackland and Martin representing today the Builders and Remodelers Association and separately the American Institute of Architects Vermont Chapter.

[Speaker 1]: Great. Alright. Thank you for being here. Over to you.

[Speaker 0]: Alrighty. And for the record, I'm representative Scott Campbell, Vice Chair of this committee and Chair of the Building Energy Code Working Group this year. In some cases, I'm cited as co chair. But the other co chair, I guess, was Senator Seth Vondartson. He really was just a participant. Not much of didn't have much to do with sort of lining up testimony and all that. So and this is something I've been working on for years. And that sets us sort of a newcomer issue. So I'm gonna talk to you today about the Building Energy Code Working Group report from that was submitted on November 15. This is the second year of this of this group. I'll give you a little background. Let me get rid of this thing here. Okay. This is the second year of this working group. It was included in a bill let's see, Act 151 of 2024, it's actually the third year of a legislative office session working group or study committee working on this issue. And the fourth year of me being involved in something like this, my first summer in 2019, I organized a sort of volunteer committee that actually had almost all of the same people involved, stakeholders and architects and

[Speaker 6]: administration officials and all of that.

[Speaker 0]: I've been working on this for quite a long time, trying to find ways to increase compliance with the energy codes, which we have had for many years, in case of residential since 1997, on the commercial side in 2007. And these codes are, in fact, actually they're not required, they're mandatory, but there has never been any enforcement penalty for not following them. On the commercial side, the codes are pretty much followed. Various studies have been done on compliance rates. In the commercial world, typically architects and engineers, licensed professionals are involved, and they are at risk of losing their licenses if they don't follow codes and the laws. On the residential side, we don't have licenses for contractors. We do have a registration process or registry, but there's, again, still no enforcement mechanism and no penalties. So as a result, the compliance rate on the residential side is much lower. There's been studies showing it's as low as half or for each flower, but that may actually overstate the matter. The compliance is probably much less. If you ask random a contractor whether they even or whether they follow the energy codes or or are even aware of them, you you might find them. Half of the people you ask don't even know that we have them because they don't have to follow them. R. Torre? Sure. You can ask questions right away.

[Speaker 3]: It's like they say a question. I'm just I always forget. When is it a duplex or bigger that becomes commercial?

[Speaker 0]: That's a complicated answer to that question. All rentals fall the jurisdiction of the Division of Fire and Safety, which does regulate or enforce commercial building codes. And they have promulgated what they call a fire and building safety code that applies to all buildings, including residential, three units and up. But they have jurisdiction over all rentals, which includes duplexes and single family, so they will or they can. They have jurisdiction over those buildings. They can go in and and and enforce code expectations. Typically, would be things like smoke alarms, CO detectors, egress, things like that. Okay. But I don't think they do an awful lot. Unfortunately, the the director of the Division of Fire Safety, Mike Dara Torre, who's been terrific to work with, is away this week. He's he does all kinds of national stuff. He would he would say that I think that I think he would agree with what I just said. Let's see.

[Speaker 3]: So an ADU would fall? An ADU

[Speaker 0]: What? Rented

[Speaker 3]: to a non family member?

[Speaker 0]: It's a good question. That is a good question. ADU.

[Speaker 7]: ADU is what?

[Speaker 3]: Dwelling units. Yeah. We think we're trying to encourage people to do an appropriate.

[Speaker 2]: It's a fancy horse. A a mother-in-law. Exactly.

[Speaker 5]: So it's a mother-in-law apartment. Yeah.

[Speaker 3]: I'll just put a little question.

[Speaker 5]: Yeah. The mother-in-law apartment used to be an exemption to all that egress and all the other code. There's a way I understood it why they called it. I don't know. See. In law department that you don't have to meet the codes.

[Speaker 0]: I'm the regular life person. Anybody ever asked that.

[Speaker 5]: But no. But those things that I mean, I'm an old fellow. I mean, so the mother-in-law of Parkinson syndrome truly was when you moved in, your in laws. Yeah. And and and moved out of it. Beyond that state now. Yeah.

[Speaker 1]: That is an interesting question because we've you know, a lot of our some of our recent housing form bills like the homes act and stuff have taken big steps to make it easier to build ABUs. So, you know, I I think it's a strategy we're trying to focus on.

[Speaker 3]: Some of my constituents are having some issues with compliance, and I I think the enforcement might be inconsistent right now.

[Speaker 0]: Yeah. New. Well, so a a rental unit, as I said, does fall out in the jurisdiction of Virgin Fire Safety.

[Speaker 3]: And always has.

[Speaker 0]: And always has. So I don't know what they do with the ADVs, if anything, but somebody could complain if there was an issue of no water, for example, or something like that. And Perhaps they come in and do something about it. That's a good question, and I can follow-up with that.

[Speaker 3]: Thank you.

[Speaker 0]: Not only do we have any enforcement of energy codes in the residential world, particularly single family and duplex, we have no residential building code. They may have mentioned that already, but that is a key structure or mechanism for creating an administrative mechanism of action to able to enforce or administer even energy drones. So that's a big gap. One of the things that we were able to do in Act '22 2022 was create a residential contractor registry. And we worked in collaboration with the Office of Professional Regulation to do this. OPR's interest was consumer protection in the nature of fraud. Say, a contractor requests a deposit to a project, and then never shows up again. That's the kind of thing that you read about in the papers. It was all too much relative frequency. So that was their angle on it. Interest in promoting Contractor Redshoe was as a sort of avenue to bring training and education to the residential contractor, in particular. So the registry is mandatory. Every residential contractor who does a project, any project in a year in excess of $10,000 is required to register. Fortunately, it was very little unfortunate see there, which we had found just in the first couple of years of this being in place. So there are apparently lots of contractors who are not even doing that. But the point was to have a mandatory registry for the purpose of being able to contact contractors about things like pandemics, are the working conditions or working requirements in the case of the pandemic or any sort of emergency issue. And also keep track of people who are practicing of under the table and not really under the table, but keep Friday people of deposits. And there's no credential or standard of practice for these contractors through Office of Professional Regulation, but there is this, it's a financial fraud kind of impetus for them. With this mandatory registry is a voluntary certification program so that contractors can obtain certifications on things like energy codes, high performance building, even safety issues in ocean or the ocean safety protocols. So that was the concept, and unfortunately it hasn't really gotten filled out very well yet.

[Speaker 3]: Doctor Campbell?

[Speaker 0]: Yes.

[Speaker 1]: Can you remind me? I ask you this every time we talk about the residential contractor registry. If you're a contractor who does I remember the $10,000 threshold. If I do three $4,000 jobs, so the cumulative total is $12,000 but each one of those jobs is below the 10, am I required to register?

[Speaker 0]: No. Not according to

[Speaker 1]: the A single job.

[Speaker 0]: Single job.

[Speaker 1]: Any one single job that in and of itself is more than 10 ks is the threshold.

[Speaker 0]: Yes. Okay.

[Speaker 1]: And that got bumped up a lot, Right? I feel like during all the original testimony, our our desire was to have the threshold be lower.

[Speaker 0]: Yes. I think it started around 2000. It started about maybe 3000, 3500, and and governor vetoed the original bill that included this registry and then said in his veto message that, oh, if the threshold was more like $10,000, he might go along with it. So this was a House bill that he vetoed. So after the veto, I worked with Senator Bray on the Senate side, and got bill basically incorporated into a housing bill with the threshold bump down to $10,000. The governor signed that bill.

[Speaker 8]: Do you have any idea what percentage of the universe that captures?

[Speaker 0]: Well, the

[Speaker 1]: I mean, compliance is low even among those who are supposed to register, but how many, you know what I mean, how many contractors are out there who never exceed that? Then we get into back of the Trump handyman ticket.

[Speaker 0]: Yeah, and we don't know. That's one of the problems.

[Speaker 6]: That's one of the purposes of

[Speaker 0]: the registry is to find out, well, who's doing this work out there? Mhmm. And so There's a lot. There are a lot of people out there with a pickup truck and a hammer and and that they're just doing stuff.

[Speaker 2]: There's a need.

[Speaker 0]: Yeah.

[Speaker 2]: Big need for that.

[Speaker 0]: Well, yes, there is. Asking them to have liability insurance, pay their taxes, and actually So there are some requirements. They have to pay their taxes, they have to have liability insurance, and they are required to have written contracts, which actually is not a bad idea. I've worked with a There's a template, isn't there? There's a template in the law as well, that the OPR has, the template required that OPR has provided. A contractor I worked with forty years ago used to say, Gotta write it down. People get in amnesia during the course of their job. Anyway, It's a good idea. Lastly, this idea of compliance is part of the Climate Action Plan. It wasn't one of the 10 or 12 top priority items that they named in their short sort of synopsis, but I think that it's 40 or 50 priority recommendations overall, and it was one of those. So let's see. This year, the working group members were me, Senator Baumgartz, Kelly Launder from Public Service Department, who's the Energy Division Assistant Director, Mike Dara Torre, I mentioned, members of, are recognized from efficiency Vermont, Steve Spatz, also from Burlington Electric and Bramont Gas, the current president, rotating presidency at AIA Vermont, half president of BBRA, Jim Bradley, the Executive Director of Associated General Contractors, Sarah Diporten, who also participated in these meetings, from Associated General Contractors, the Executive Director or designee of the big cities and towns, represented from the Regional Planning Commission, that was Chris Campany, the VHCB asset director, Craig Peltier, has worked on these issues also for a dozen years, about fifteen years or more and the director of OPR, Jennifer Howland, or Howland, I think is how she pronounce it, and then Peter Tucker, who is the public policy director for the realtors. A lot of these people are involved, as I say, last year and the year before, and even in volunteer that are committed in 2019. So there was a compliance study. The Public Service Department does, contracts for compliance studies periodically. The last one was in 2023. There's one underway right now, actually. And this was the takeaway on residential energy curve, residential building energy standard compliance from the 2023 study compared to previous study looking at the 2015 RVs and what the compliance rate was then. It's declining. It's, as I say, likely lower than this because the study universe is typically weighted towards where a lot of buildings get built, which is Chippinc County, where there are more contractors, more competition, often contractors are empowered to actually build higher public buildings.

[Speaker 3]: Question? How do you measure compliance?

[Speaker 0]: It's a good question. This is one of the issues that's been brought up by public service. There are requirements about following either a prescriptive path, which says certain amount of insulation in the walls, certain air leakage rate, appliance standard, There's things like also software that you can use to show that you're in compliance with it. Gives the building a certain, it's called HERS rating, home energy rating system grading, then just getting an actual HERS rater to come out and do a bill of door test on the building.

[Speaker 3]: Oh, so you're actually doing some billing tests and you're not just taking a survey to a contractor? Well,

[Speaker 0]: in the compliance days, I think they do well, no, I'm I'm not sure about that. I was going to say I think they do visit the building. I'm not sure if they visit all of the buildings. Right.

[Speaker 3]: So sample size. Probably it's a sample. Yeah.

[Speaker 0]: But one of the issues that the public Kelly and figures brought up is just failing to file or skipping it could be evidence of not of not destroying, but but the building itself might be in compliance. I think it's important probably to get a little bit more fine grained about what compliance means. So the photo on the right is from last year's report, and it's a little hard to see. I tried to blow it up as much as possible, and I didn't see all the screen there. But this is building that was built in 2002. This photo was taken, I think, in 2022. And you can kind of see that the building with the siding removed, is the sheathing that has all kinds of mold and actual rot going on underneath the sheet and paragons or siding, from lack of control of moisture migration. This is illustrative of the problems that you can run across, and many of the people participating in the working group have sort of anecdotal stories about building failures, from contractors insulating to what they think is the right standard, and doing air sealing, applying a poly vapor barrier on the inside, for example, or some sort of vapor barrier on the outside. Anyway, building a wall assembly or a roof assembly that they think is correct, but actually is trapping moisture and not allowing the assembly to dry out. The balance that you're trying to achieve is minimizing the wetting potential of the whole building and the assemblies, wall assembly, group assembly, and to build a great assembly. Minimize the wetting potential, but maximize drying potential. So there's actually things to know about that. What drives moisture migration? Where does the air sealing or air control there need to be? All these sort of technical details that we really need builders to understand. That's the focus, for me, that's the focus of this whole process. Why do we care about the plants? Because we want builders to understand what the dynamics are that they're dealing with.

[Speaker 2]: Yeah. Is not particularly even about energy. This is about health and and safety and finances because that's an expensive project. Right? You're Well, my I ask just, like, maybe we frame it in a broader context than energy code Yes. We can Yes. Compliance or adoption, education, etcetera, etcetera.

[Speaker 0]: But

[Speaker 3]: but we don't have residential That's the

[Speaker 9]: only need

[Speaker 4]: for a building code.

[Speaker 0]: That's the only need for a building code and the energy code involved. I sort of got into this world when I was a weatherization director in the '90s. Early on, and I've probably said this before, but early on in my experience there, I realized that, Gee, we're getting getting PhD units, but we're our our mission is saving energy, which is a great thing. But, really what we're doing is addressing, comfort issues, durability issues, moisture migration issues, health and safety issues. And if we do all those things right, we've also made the building a lot more efficient. And

[Speaker 3]: if we had a code, a building code, energy would just be a chapter in.

[Speaker 0]: Yes.

[Speaker 3]: And it would get updated with the regular, the whole code. Yeah. Seems like it's what a lot of people want.

[Speaker 0]: Yes. Well, it's what builders and architects want. It's what the builders and architects who are participating in kind of working group want. I think it's safe to say most architects would be in favor of of a residential building code and and enforcement mechanism for for an energy code. I think a lot of builders would say They don't want any government oversight of any kind. I was a builder for years, I never got Well, actually, I did get licensed in Massachusetts when I started the licensing in about 1982 because they're probably I happened to be working there at the time, and I do it applying. It was sort of a legacy kind of system. But I've never been in the place where in order to work, had to be licensed. But it does impose sort of bureaucratic requirements on contractors who feel like they do a good job. And most contractors do a good job, and they try to do a good job. They think they're doing a good job. But again, it's a matter of education and understanding what the dynamics are that they're working with. Buildings are actually energy systems. How do you understand what the dynamics are, how things interact When you put in a JennAir downdraft stove that sucks 400 CFM, how does that affect the fireplace? You know, the and and a building is pretty, pretty well air sealed. There was a story. I don't know if it was a true or or just a pirateful of of one of those one of those down direct fans sucking a fire across our from a fireplace across a rug. So, you know, it's possible for that to happen. Certainly, you can downdraft other combustion appliances like water heaters and and furnaces and boilers with with enough depressurization of other in other parts of the house or parts of the building. So people need to understand what the dynamics are they're dealing with, both in terms of health and safety like that and also in terms of moisturizing like this like this.

[Speaker 7]: So I'm I'm just need a little clarification. It seems like I remember last year in testimony, there was this international type building code, general building code. Yes. Right? Yes. And this is even exceeds that. Is that correct? And and we It's

[Speaker 0]: all kinds of.

[Speaker 7]: Yeah. Let me but my question is if this building was built to that code, that international one, which is a lower threshold, I understand it's not super high on the the thing, but it's still on the efficient building. Would that would this have happened here?

[Speaker 0]: Alright. Well, so just in general, there are what are called model codes. There's there's a group based in Rhode Island, I believe, that is called the International Code Campaign, and they publish a commercial code called the International Building Code, IBC, and a residential code called the International Residential Code, IRC, and also the International Energy Conservation Code, IECC. The IECC is actually, as I understand it, incorporated in the next generation of the residential code. I'm not sure how it intersects with the commercial code. But If this building were built according to code, would this have happened? I hope not. It certainly should have. Again, what's key is the builder understanding the dynamics that they're dealing with. I can't tell you what the details are in this building in terms of was there a poly layer on the inside? Was there some sort of house wrap on the outside that was not sufficiently vapor permeable? Was happening to the siding, whether it was wood siding or vinyl siding. So I don't know exactly what it like. It looks like there's probably wood to me too. One thing that I've learned is the strategy of spacing wood siding off of the sheathing is incredibly effective. I painted my house twenty years ago, and there's still no flaking of paint on the fibers anywhere. There isn't flaking on the on the on the failing paint peeling and failure on on the trim because there's solid wood behind the trim. But where there's an air space behind behind the fibers and and the collabers are sealed on all sides, in fact, on on anything that cut ends, this paint stays on forever. It's it's it's just a matter

[Speaker 9]: of it's just it's

[Speaker 0]: just a matter of of of managing the moisture flows, understanding that what the balance are managing moisture flows. That answer your question? I'm not sure if it's

[Speaker 7]: Well, I'm I'm just concerned that it's what little I know contractors. I mean, they're all building six inch walls, and they're trying to build a fairly efficient house. How much more is this going to increase the cost doing the residential energy code upgrades? We're trying to get people into affordable housing. Right.

[Speaker 0]: So this is a good point. I probably will get into it later. But yes, there is an additional upfront cost to building a higher quality, a higher performing building. The life cycle cost is lower, though. So you have to decide which how you're defining affordability. Is affordability just first cost, or is it also include the cost or this ongoing cost of managing the utilities and dirt and painting and and all the other things that you need to do to make maintain a building. Right?

[Speaker 4]: If I may add Yeah. It's a little bit of a false distinction, I think, with residences because they're all monthly charges. You gotta pay your mortgage, pay your rent every month. You gotta pay your heating bill every month. So the upfront cost is essentially a monthly cost. You've gotta Yeah. Well, you gotta pay a deposit for a rental or a down payment for a a purchase. You there is an upfront cost, but most of the cost is monthly cost, and it's monthly. So that's the real question. Yeah. Well So if your monthly bills.

[Speaker 0]: So if you can if if the upcharge for building a higher quality building is included in the mortgage and is spread over thirty years, then it's almost always going to be a cash positive situation. Your utility costs will be lower than the additional mortgage cost. You guys have some quick questions. I don't want get into too much detail, but cost effectiveness, which is how people determine whether this is a good idea to do, whatever the thing is, is a really slippery concept because it requires that you project out what the savings are going to be from adding insulation or more air safe, whatever it might be. Rejecting what the savings are requires that you know what the future fuel costs are going to be. Obviously, don't know that. We're just guessing. It makes it difficult to Also, the lifespan of the measure is the other guess, right? When you're building a building, adding insulation, doing a better job, air sealing, making a better building shell, that's the time to do that, because that's the time when it's the least incremental cost increase. Going back and doing weatherization later is more expensive. Again, that's basically what we're doing. We're going back and doing weatherization.

[Speaker 2]: And then the cost accounting doesn't include health and safety issues, which which is impossible to quantify. Right. Yeah.

[Speaker 0]: It it it doesn't include that because cost effectiveness is typically calculated, using customer economics. So it doesn't include social social benefits or health and safety benefits.

[Speaker 2]: Like the weatherization conversation from yesterday. Yes. Well,

[Speaker 4]: would say that the health benefits are not impossible to quantify. You can measure a reduction in respiratory illness and visits the ER and missed days of work and all those Well,

[Speaker 0]: those things are often used in calculating cost effectiveness from a program point of view, not from a customer economics point of view. They're they're sort of valid or or much easier to include in deciding what level of incentives to provide from a program for people to do more insulation or whatever. So that's, you know, another another nuance. The customer economics is is a is a really important way of of doing an analysis, from the customer's perspective. But you're trying to decide what incentives to provide to people to do better insulation or build compliant housing, it's valid to look at the societal benefits as well as actual cost benefits. All right, we're only on slide three. We

[Speaker 5]: don't know what caused this, whether there was a lack of a vapor barrier on the interior or a mistaken application of vapor barrier on two sides. You mentioned about the Hi, Beck. Sorry, sorry. Building wrap. Building wrap. I'm sorry. Use a trade name. But, I mean, you can see here, you see the vertical wall in between the two windows, which appears to be perhaps that was where a sidewall was framed in, so the lack of perhaps insulation being stuffed here at those two corners match. And then around the around the window, Both windows are there, so improper- Flashing around the window? Maybe not flashing, but insulation between the bottom of the window and It's been a long time since I drew a building plant, whether they just didn't get insulation or whatever.

[Speaker 0]: Yeah. So

[Speaker 5]: so you see the the red board there, which Right there. Right there. So perhaps that's the area where the top plate and bottom plate

[Speaker 0]: of the next floor was in. That almost looks like foam board to be.

[Speaker 5]: Foam board. Right. Right. So then some so somebody saved themselves a piece of two by four by slapping that in and not having to or not two by four, but four by eight. Yeah. They they they Yep. Eight feet down. Yep. Eight feet up, they got a gap, and they filled it for cheap each. It's positive. But we don't know. We don't Yeah. All we know is Savage came in for a mop. Yep.

[Speaker 1]: We should probably Yeah.

[Speaker 0]: Let's let's keep on going. Yeah, I mean, you're right. And and that's important. It's it's having contractors understand the moisture and and energy and airflow dynamics of of the structures is really is really critical. And for me, training is the whole goal. How do we get And there are a lot of training opportunities. What we have found, and Steve Spats, the guy from Efficiency Vermont who participated in the working group this year, is a trainer for VEIC, for Efficiency Vermont, very knowledgeable, conducts lots of trainings, and says, One of the problems that they have with trainings is getting people to come. So how do we get people to come? If you require them to go, then that would be one way of doing it. Don't know if I mentioned that here later, but contractor Actually, was talking to Representative Sweeney, who's, as you probably know, a building contractor, a really good sized building contractor somewhere in Chittenden County, Shelburne, I think. He And was talking to the other day, and he said, What we need is licenses for contractors, because then they would learn the codes, the rules, and follow them. That is probably the shortest path to increasing code compliance. Because as I mentioned, in the commercial side, compliance is very high. But in the residential side, it's not. One of the main differences is having licensed professionals involved on the commercial side and not on the residential side. Anyway, it's not likely. We're not going to get licenses for residential contractors in the current environment. We recognize that going into this year's working group. My thinking and what I wanted to get out of the working group was, how can we create more incentives for, not necessarily monetary incentives, but incentives for contractors to comply voluntarily. So how do we increase voluntary compliance? That's what we worked on this year.

[Speaker 1]: Scott?

[Speaker 0]: What came out of it.

[Speaker 1]: I'm really sorry to interrupt. I just realized our agenda had not been updated, so I I apologize. We have a witness of 10.

[Speaker 0]: Yeah.

[Speaker 1]: Okay. I thought we had until eleven. So I maybe I had not seen the latest. So I I apologize. I thought we had until eleven. Personally, so I was not moving things along here.

[Speaker 0]: I thought we had until eleven too.

[Speaker 2]: Yeah. I did do

[Speaker 1]: So I'm sorry. Who do we have who do we have from you? We have the PUC coming in at 10:00 to go over the act one forty two report.

[Speaker 0]: Oh, gee.

[Speaker 1]: Which is important. So I am I am really sorry. Okay. Apologies. Yeah. So we have we can we'll whatever we don't finish now.

[Speaker 0]: Okay.

[Speaker 1]: I think let's not rush through your presentation.

[Speaker 0]: K.

[Speaker 1]: Let's just go until five of ten.

[Speaker 0]: K.

[Speaker 1]: Whatever we don't get to, maybe we'll have time.

[Speaker 2]: We have an hour this afternoon from two to three that we could slot in.

[Speaker 1]: Okay. Let's just see how it goes because

[Speaker 0]: Okay.

[Speaker 1]: Because we do have Kelly coming in at eleven Yeah. And Andrew. Right?

[Speaker 4]: You can bump me any day.

[Speaker 8]: Okay. So we just bumped Andrew.

[Speaker 1]: So maybe we can finish after Jake. Okay. Okay. So apologies for that. Let's but don't rush. Let's just continue in our I would've

[Speaker 0]: I would've gone a little quicker too if I had real Sorry about that. I I didn't see the the agenda either. Alright. So the legislative directive that was in Act 151 from 2024 was these three things: recommend strategies to programs to increase awareness and compliance develop plans and recommendations for potential transition to a comprehensive program for RDs and CDs at Division of Fire Safety and consider whether or not to this state should adopt statewide building codes. So those were the and the powers and duties and and and the and the directive to the working group, the two year working group.

[Speaker 1]: So that's what you guys were told to work on this year?

[Speaker 0]: That's what you were told to work on, well, the last two years. Yeah. So the major recommendations that came out of the working group were, as has happened for all three years, actually all four years, if you include my voluntary group, was that the Division of Fire Safety, which handles all the other building codes, really ought to be the so called authority having jurisdiction for energy codes as well. The group voted narrowly in favor of continuing that recommendation with a timeline of getting there by 2030. Division of Fire Safety, Public Service Department, and some others, Associated General Contractors, declined to support that recommendation because they feel there's just not enough time and not enough resources for a Division of Fire Safety to take this on. Division of Fire Safety, Dara Torre, although he will say that he recognizes that is the ultimate goal, just doesn't see a path for getting there now. They would need to hire people, they would need to staff up to be able to handle not only understanding energy codes, but also adding plan review for energy code purposes to their process that they do now. Think that was the main reason. Everybody's worried about the additional cost of layering on another process into getting the housing bill in particular. The other major recommendations were to support code compliance work, not just above code, but code compliance work, with some funding from the regional greenhouse gas initiatives, which has accumulated some above revenues over the last three years.

[Speaker 1]: I really don't want us to rush. We'll get where we get. We're not going

[Speaker 3]: to finish to because you're out on a roll. Is this the first time you guys thought about funding for merging?

[Speaker 0]: Yes, I think so. And this was something that I had thought about along the way. Because when we, the major strategy that I that I was working on here, and I think other people too, was using the builder registry as sort of beefing up the builder registry an avenue to increasing clients. So the Builder Registry, as I mentioned, OPR has not had the resources to really make it something that is useful to consumers and even the contractors. It's hard to find on their website, and when you do find it, there isn't an easy way to figure out what builders you're looking for. You can find them by name, but if you're looking, for example, for ability to do a roof on your house, they have filters that you can filter by who does roofing, for example, or who does roofing in my area. So they need some funding in order to provide that kind of information. Also, they don't really have the expertise in house to get what certifications would be appropriate to provide for builders, as an option for builders to obtain voluntarily, what are germane to the kinds of issues that people are seeing, and then to figure out who the credentialing entities ought to be for those certifications. So there's a lot of practical stuff that we would like them to be able to do, but they don't have the resources to do. So it occurred to me that with that, a little bit of that money and Reggie, we could probably get an awful lot of funders.

[Speaker 1]: I had a question about the RGGI money too. I know that we we had invited Efficiency Vermont to testify, and they basically said that their Yeah. Opinions are already included in the report. Yep. But when Peter Walk came in to talk about their current DRP, I always forget what those initials stand for, but their current DRP process that's ongoing with the department, it sounds like they have other plans for the RGGI money, right? They've got it? Yes. Okay. I just wanted to make sure that Yeah.

[Speaker 9]: Well,

[Speaker 0]: so, and I actually, I should have shared this with all of you. I got an email yesterday from Peter, because I had asked him, you might remember, so how much is that pot of regi money that we haven't used? How much is that? And what are your projections for the next three years? And he said that the pot is around 8,000,008 point something million, and they're projecting, I think it was around I have to look it up again. They're projecting a little bit they want to keep a little pot, basically, in revenues fall off. Projected revenues are as a result of auctions. Well, I won't get into that. But anyway, they're a little hard to pin down at this point. The scale money that I'm talking about for doing this is on the order of $400,000 which is not in this report, but in bill that come out of this report. Haven't got back yet. Okay. So another issue is a consumer oriented website. Somebody just set that up and maintain it for at least a year or two, and then marketing to the public about the existence of a place to go to find out who you should get to do your work. And then the third thing that the third major thing that the working group supported was, recommended, was setting up a task force to really help OPR with the technical aspects of improving the contractor registry. Let's see. Other recommendations included using Rich, you asked about the international codes and the model codes. One of the questions that people were talking about was, Why don't we just use the model codes and not Vermont specific issues, or add a minimum to provide specific changes to those codes? That would make it easier to update the code, because the International Code Council does it. They do it already. It would make it easier for training and materials to make that available for contractors. So it would be less expensive. What that would exclude then are Bramotte's energy goals, which can now drive changes to the lobby codes.

[Speaker 2]: The code needs to adapt to climate, right? So do the international codes have a cold climate section that's

[Speaker 0]: I think they are. Think they are Robust. They do adapt to climate. Yes. I can't tell you the mechanism, but I'm sure they do. Let's the recommendation. Oh, I see. It's a centralized compliance certificate. Right now, certificates are filed with the town records, and then they're also supposed to be sent to the Public Service Department. Compliance with this particular requirement is not that high. Again, there's no penalty if you don't follow this. These compliance certificates are also self certified. The builder signs off on, Yes, I complied.

[Speaker 1]: Is the builder supposed to simultaneously submit to the town and the department? Town, are they supposed to submit to the town and then the town is supposed to send it along?

[Speaker 0]: I believe it's the builder's responsibility or the filer's responsibility. Okay.

[Speaker 1]: To send it to the two places.

[Speaker 0]: Two places. Yeah. And didn't we we got rid

[Speaker 4]: of a very similar requirement for the PUC last year.

[Speaker 1]: We did. That's what brought it to mind. It was for the It was file requirement

[Speaker 8]: everybody's Yeah.

[Speaker 0]: The Division of Fire Safety is in the process of updating their database. They're making a very comprehensive database for handling all of the projects, the commercial projects typically that they handle. And they're including in this update, in this database now, a place for compliance certificates for commercial building energy standards. They will also include them for residential building energy standards for buildings under their jurisdiction. They've been a little back and forth about whether they would be willing to accept residential certificates for single family or occupying buildings. They don't regulate single family or occupying now, if they don't want to. But it would make sense to centralize the repository of appliance benefits in one place and not have them scattered in different places. The recommendation from the group was that we should do that. I'll just finish this slide, and then we'll give a pause. Another technical recommendation was to make this the energy module training, which is in statute and is required of people in the building profession, people in the trades, and architects and engineers. There's an energy module that is supposed to train people on the existence of energy codes. But there was ever any description of what the energy module should include, except that it should make people aware of the existence of the codes and the statute. So what it turned out to be, in the case of what's available on the Division of Fire Safety's website, is just a twenty minute review of the statute, which of course is virtually meaningless to anybody, those of us in this building, and maybe even to us. So it's not very helpful. So the recommendation was to make this training meaningful and give people some idea of the relevance of the code to what could they do. And then the other suggestion or recommendation was adding ventilation testing. So if there is a ventilation requirement in the code, Currently, the 2024 version of R. V. Includes a whole house ventilation system. That's one of the expensive things that it does include. But you're supposed to have fresh air to breathe, we all all know that it's like being in a stuck in a room. So there is ventilation requirement. There is not a ventilation testing requirement, so there's not a, what's called a a commissioning requirement in the COVID breakdown. In other words, you can put in a system, but who's testing to make sure that it works the way it's supposed to, and I think the airflow is what it is supposed to be. So that was another technical recommendation. So I can leave it there. We'll come back to

[Speaker 1]: Yep. That's a good breaking point. So Joe was gonna update the agenda, but just so everybody here knows, Jake is here and we're really appreciative. We're very appreciative of that. This is an important study, a report that we're about to be hearing about. And I don't wanna that. So we moved the rest of the building energy code working group testimony to 02:00 this afternoon. Okay. Joe will get all this updated online. But Sure. What the plan is right now is we're gonna take a five minute break so everybody can, you know, go to the bathroom, whatever. Then we will come back with the PUC, and we will just leave that open until lunch. And I'll try to I think folks might have a lot of questions. It's a BP study Great. Report. Sorry. And then this afternoon we'll have Lisa come in at one to talk about IT investments. And that could also be a longer conversation. But she could come back anytime. So we'll get the rest of our building working group stuff in at two, and then if we have floor, and then we're done for the day. And Joe's gonna get all that online or it may already be, and we can go off live, and let's try to come back in four minutes. Cleared out the morning until lunch to make plenty of time for this report, this study, it one, it's an important one and two, it's something we all care about. And three, it could be the basis for drafting requests that are already in, current drafting requests, a committee bill. So I wanna make sure we allow time for questions. And if we wrap up early, we we wrap up early, but I just wanted to let everybody know, ask your questions. Is our big chance to talk about this important piece of work. So welcome everybody to House Energy and Digital Infrastructure. We are here with the PC to talk about their energy cost stabilization study. I'm representative Kathleen James from the Bennington 4 District.

[Speaker 0]: Scott Campbell from Saint Johnsbury. Richard

[Speaker 2]: Bailey, Memorial two. Chris Morrow, Windham, Windsor, Bennington. Christopher Howland, Rutland four.

[Speaker 3]: Dara Torre, Washington two.

[Speaker 4]: Graham Kleppner, Chittenden 13, Burlington. Laura Sibilia, Windham two.

[Speaker 1]: Alright. For the record.

[Speaker 9]: Hi. My name is Jake Marron. I'm an attorney for the Vermont Public Utility Commission.

[Speaker 6]: I'm Jacob Davis. I am the utilities analyst for the Vermont Public Utility Commission. Great. And I am hopefully getting ready to share my screen here.

[Speaker 9]: It's up. It's up. Okay. Great. And that's reading. Okay. We've we've introduced ourselves. I'll let you get a quick, look at the overview of where we're headed, and we'll get right into it. So thank you very much for having us. I'll start with just a quick overview of of what act one forty two asked the commission to report on, and that hopefully will sort of level set the rest of this this conversation. The overall arching question is whether the commission should recommend the creation of a statewide program to reduce energy birds in Vermont. And when looking at that that question, there were sort of two buckets, I'll call them, of statewide programs that they we were asked to consider so called direct energy assistance. So helping people with their bills either through, you know, discounted electric rates or, fuel assistance or things like that. And then also, programs that reduce energy burden by making investments in weatherization and efficiency. So those were the sort of two sort of broad categories of programs that we were looking at. Act one forty two required engagement with a broader right of stakeholders, including government agencies, those community action agencies that provide a lot of these services. Also, you know, the customers who actually use these programs and the utilities and the efficiency utilities who provide a lot of these programs. The commission was supposed to look at both programs inside Vermont and outside Vermont. So we did a survey of programs that are already being offered in Vermont, and then we also looked at what some of the the other states were doing, both for direct assistance programs and weatherization and efficiency program programs. And then the commission was also supposed to consider recommendations on how to coordinate existing programs and identify any obstacles or solutions for increasing coordination across existing programs and sectors and make a recommendation about whether any pro programs needed to be better aligned or even discontinued if we created a statewide program and identify a funding mechanism for a statewide program if it if it was recommended. And, obviously, we we submitted this report earlier in December. We conducted a very significant amount of process to, draft this report. We had three workshops, one of which was specifically to dedicated to hearing from customers who are income qualified to to use these programs. We also, you know, invited all of the electric and gas distribution utilities, the efficiency utilities, and government agencies to attend these workshops and to to give input. Those workshops were accompanied by three rounds of written comments, so opportunity for for, you know, folks to make their their thoughts and feelings available to us in written form. We also conducted five interviews with the community action agencies to get a better understanding of their operations and the the very important services they provide. We also conducted an online survey for customers who are income qualified for these programs, and we received dozens of public comments through EPUC and through email. So energy burden is defined as the percentage of income a household expense on energy related expenditure, including electric, thermal, and transportation costs. So, basically, you're totaling up all of your energy bills, including your your fuel bills, your gasoline bills, your electric bills, and then, you know, dividing that by your your household income, and you get a percentage. And, 11% is generally considered if someone is spending more than 11% of their income, they're considered energy burdened.

[Speaker 6]: That is in this act, it added transportation, which is unconventional in terms of energy burden. Usually people just mean the thermal and electric side. And so, on the thermal and electric side, I think people target 6%, something like that. It's with the transportation added in that's not kind

[Speaker 9]: of a learning perspective. And

[Speaker 8]: representative. Yeah. With energy burden in terms of income, is it strictly income earned from work?

[Speaker 9]: It's using the definition of income that's used for AMI, so I assume that's all income. But I'd have to go back and look exactly at the definition.

[Speaker 6]: Yeah, I think you can look at it either way where, of course, our measurements are only as good as what we can gather. So probably most people's income is income derived from work that will be on a tax return or something, but some people's might be reported. Yeah, and for those people it would be like, we might not know the real amount, but they know the real energy burden that they face.

[Speaker 8]: Just interesting to me in our region, we have higher than average levels of poverty and higher than average levels of wealth, including the folks from the wealthy way. And I'm always interested in this question of how we're establishing.

[Speaker 6]: And to talk about that, wealth is just not considered whatsoever. So, it's just income. It's just the flow variable, not the stock variable of what people are capable of. Think that's a

[Speaker 0]: little bit of income. If we're talking about AMI, we're talking about household income too. Yes. Not individual income. Correct. That's exactly right. And

[Speaker 9]: there's a lot of detail subject in a report that was drafted by Efficiency Vermont. There's a link to it on, I believe, page five or six of the report. So if you and that has really interesting data about sort of the geography of energy burden because, obviously, where you live can influence this if you have which utility you're served by affects, you know, your costs, whether you have access to natural gas, whether you live close to areas where there are jobs or not close to areas where there are jobs, can all influence the relative size of the pie. This pie is an average for the whole state. So it you know, each individual's experience, obviously, is going to vary quite a bit. And but on average, Vermonters, you know, most of the energy expenses come from the transportation and heating sector. The electric sector is is smaller. However, you know, depending on how successful the state is as in in encouraging electrification of the heating transportation sectors, this pie shapes could change over time, obviously.

[Speaker 1]: And I have a question about that pie chart, just a really basic question. Are you saying that of the average household energy burden?

[Speaker 6]: Yes. It totals to 100% of the energy burden. Okay.

[Speaker 1]: My energy burden is 11%, 20% that 11%, it's 20% electric, my electric bill, 35% my heating bill, and 45 my transportation bill.

[Speaker 6]: Yeah, so if I can simplify that a little bit, if we just hypothetically said it was 10% was your energy burden, then 4.5% of your income is spent on transportation, 20% or 2% of your income is spent on electricity, and

[Speaker 0]: so forth. And sorry, your hand was up first.

[Speaker 8]: And another question, and I apologize. I have not gone into the Vermont burden report recently. But is there any distinction that is made in terms of there is. You said geographically. Yeah. So is that by utility? Because we have some utilities that have much higher rates, like rec, for instance Mhmm. Than other

[Speaker 9]: So I believe they did it on a town by town basis. Mhmm. And so the utility service territories aren't drawn on that map as I recall, but if you know in your head where what areas of the state are served by certain utilities, you you might see that pattern, but because electricity rates are a smaller segment, it may not come out. It I don't think you're gonna see, like, you know, sort of the the different shades of colors neatly outlining the utility service territory.

[Speaker 6]: Yeah, to address a little bit, this is just a blanket average of all of Vermont attempting to account for all Vermont households regardless of where they're located. In Efficiency Vermont's report, they use census data, housing data to construct some different cuts that are maybe not directly in the report. It's like you click a link, it takes you to a table kind of thing. I poked around on that a little bit. And so, story changes a little bit, as you're pointing out, based on geography because, as Jake said, we would expect where you're located, how close you are to your job, if transportation is such a big portion, that to have a huge impact, things of that nature. So so it's possible to drill down further, but this really is just a No.

[Speaker 8]: An average of the state. When we did our update to the res, one of the things that was really important to me at least was to recognize that we had so many different types of utilities in different places operating in different ways, which makes, you know, policy Yeah. A uniform policy challenging sometimes.

[Speaker 4]: Presumably, it also varies depending on what altitude you live at, whether you're in a cold hollow, things like that.

[Speaker 9]: And the age of your hollow, and all of

[Speaker 4]: those things. And I also would like to make explicit in order to check something that's applied, what you said earlier, which is that heating component is nonelectric heating and transposed nonelectric transposing.

[Speaker 6]: To the best of our ability, I think Efficiency Vermont did make those cuts. I don't remember for sure, I have to check back. But to the best of our ability, we did that, but it's not really possible, as you're probably pointing out, to fully separate that with electric vehicles and with more coconic pumps and whatnot.

[Speaker 4]: It's easy in my house. It's all purple.

[Speaker 1]: It is easy. Dara, return.

[Speaker 3]: And follow-up to that. I'm curious just for the future in terms of data, having EV rates, maybe having a heat pump rate, seasonal heat pump rate, would we end up with more granularity then in order to say to have more insight into the other categories as electrification proceeds? Or is that data always going to be not available to the planner?

[Speaker 6]: I'll say, so partly, we don't know what the future will hold. But in terms of the EV rates that already exist, people have to opt into those. So it may be in people's best interest rate wise to opt into that, but if they don't, then we don't know. It's just electricity being used, not specific to that usage.

[Speaker 9]: Yeah, it also really depends on the tariff structure that the utilities use. If you have a separate meter for your EV, then it's really easy to get that data out. But if you just have a heating rate that encourages heating during off peak times, I

[Speaker 3]: got to

[Speaker 9]: But it's it's but it's mirroring the whole house still. You're not gonna be able to tease out Okay. You know, what's heating and what's other electric consumption.

[Speaker 3]: But we are able to get aggregated data from utilities to some extent.

[Speaker 9]: The utilities, yeah, they give us all of the we know all the load that they have, but you don't necessarily know what the load is being used for, whether it was used to charge a car or feed a house or run a toaster The smart meters, you know, they get a lot of cool information, but they don't necessarily give you that. And there are some

[Speaker 3]: I'm like we would need it.

[Speaker 1]: Well, and it seems like you know like, my car charger's all linked up with GMP. Mhmm. So aren't they they're knowing, aren't they?

[Speaker 9]: They are. I think the question is, you know, how is all of that data I GMP is one utility, not every utility has the same setup. And Right. I just don't know. You know, they they sounds like they're metering yours separate. So like I said, if they're metering a load separately, then yes, you will know.

[Speaker 5]: But if they're not, then I don't

[Speaker 9]: think you would be able to pull it out. But this is something that I would definitely recommend talking to either Josh Casten Gay or someone at GMP about what data is actually accessible.

[Speaker 1]: Well, and while acknowledging that they're not the only utility Exactly. Either. Right. So

[Speaker 9]: Yeah. Every utility has an entire smart meter throughout yet.

[Speaker 3]: Right. Getting there. Right? Yeah.

[Speaker 6]: And even with smart meters, there can be kind of telematics timing issues that make it harder to see what's really going on. So it's I mean, like, there's not a great cellular signal, things like that. Only want to know more, but there is some limit to the measurement as it is.

[Speaker 9]: So I'll start with just the recommendations first, and then we'll get into the the details of the of sort of the existing programs and those other things that we looked at. But, basically, the commission's overall conclusion is that there are several tested statewide programs that we have going on right now that are very successful at addressing energy burden. The issue is that the demand for services outstrips the funding, And so more funding from stable sources needed to to run those programs to help providers with their energy burden. And so instead of recommending a new statewide program, the commission is recommending a new a funding source to fund what we've already set out to do, but to do more of it. Specifically, the Low Income Weatherization Assistance Program or the WAPs that that we call them. They have extensive experience, you know, fixing people's homes so that they can be weatherized and be more efficient and save money in the long run. However, it's it's been acknowledged that it just costs more to weatherize a lot

[Speaker 0]: of these homes. They tend

[Speaker 9]: to be older. They need significant work or even vermiculite remediation. The costs can be very high. So the commission is recommending an increase to the tax on heating oil, procaine and kerosene, and other and other diesels so that there is a steady income stream to fund that increased weatherization program. The commission also Sorry. Yeah.

[Speaker 1]: That's currently 2¢ a gallon?

[Speaker 9]: I believe it is. I'd have to look at the statue again. Yeah.

[Speaker 0]: It is 2¢. These two. Straight. No. Okay. It's also a sort of an outline of a lighter not lighter. BGS. But it's it's it gets complicated, but, basically, 2¢. It's complicated. Quick question.

[Speaker 3]: Yeah. Quick question. I don't know if you know the answer, but how does that tax compare to other states in New England? Are we on the high side of fuel taxes or low side?

[Speaker 6]: That's a good question.

[Speaker 0]: I don't know. Yeah. I know. I Vermont was the first to have a state authorization fund that augments the department the US Department of Energy's privatization fund. And I and I think some other states have set up set them up. I don't know how they fund, but Vermont has always been funded through a few tax since 1990.

[Speaker 1]: And when you say and we voted to increase that that tax from 2¢ to 4¢ in 2019, but it died in

[Speaker 8]: the senate. Is that the last time you voted on it?

[Speaker 0]: It was it it died in the house, actually. It didn't it didn't survive the floor. It was in that yeah.

[Speaker 1]: And the the fund should also be made available for weatherization readiness repairs. Is that the pre weatherization, health and safety Yes. Herbiculi, asbestos Exactly.

[Speaker 6]: Leaf roofs. Yeah. Roof. Yep. This is right.

[Speaker 9]: In talking with the community action agencies and the the the reps, you know, these were the situations they encountered that they identified as things that made it challenging to to provide assistance and where there's a acute need for more funding to do these things. Our second recommendation comes in this context of great uncertainty about the availability of federal funding. The Low Income Heating Assistance Program is a critical direct assistance program for energy burden that we have in Vermont, and we recommend that the legislature consider allocating general fund dollars to support that. That is a direct anti poverty type of measure that can really address energy burden in a real way. And I think it complements the first recommendation. One is addressing the acute need now and the other is a long term investment to help people lower their bills over a longer term. Obviously, fuel tax can be regressive because everyone pays it regardless of their income. So the commission recommends that the legislature investigate some sort of way to try to offset that for low income from either through a tax credit or if there is some way to create an upfront rebate when people purchase their oil, if they can demonstrate that they're qualified through DCF or something like that, then they wouldn't have to pay this extra 2¢ tax or whatever it is that we recommended. That would be a good thing to keep them hold them harmless from this funding source. As part of the policy.

[Speaker 3]: Yeah. Yeah. As

[Speaker 9]: we've showed on the previous slide, you know, transportation is a is a major driver of energy burden, and the state had a pretty comprehensive suite of incentives for high efficiency vehicles. However, our understanding is that those funds have been depleted at this point. And so if the state wants to continue sort of making progress on addressing the energy burden and trans on the transportation side, there's going to need to be some sort of support to encourage people to get highly efficient vehicles, whether they're plug in hybrids or all electric. Anything that reduces people's gasoline consumption is going to help with that portion of the pie. And then one of the topics that we'll discuss a little bit more later, you know, was whether there should be a discounted rate for all customers at the state, regardless of what electric utility they're in. The commission ended up not recommending the creation of of such a program. However, if the legislature is looking for a way to provide bill credits to low income customers on their electric bill, all of our utilities have, affordable community renewable energy programs now or ACRE programs, and expanding those programs would provide direct benefits of income qualified customers. It would also support our state's renewable energy goals, but it would not necessarily have some of the issues that we identified with doing a discounted rate for all utilities.

[Speaker 1]: Is ACRE, some of the stuff we took testimony on last year, That's an off-site community solar.

[Speaker 9]: It is. The utility builds a five megawatt or so sized solar array and then allows customers to sort of participate in that in that That's right. Plan and receive credits based on the generation. Is that correct? That's

[Speaker 1]: So the utilities meeting their tier three?

[Speaker 9]: Tier two.

[Speaker 1]: Tier two. Yep. And low income or somewhere, putting more solar online, utilities helping to meet their tier two obligations under the res, and low income

[Speaker 9]: getting a credit.

[Speaker 3]: Yeah, learned about that last year. Sorry, Dara and she. Just one thing to flag for you, chair, is that while we're gonna be seeing our utilities very soon, we we might wanna inquire about their for an update.

[Speaker 1]: Let's do because it it actually was I didn't remember that. Did you say every utility is already participating in this?

[Speaker 9]: I believe that

[Speaker 1]: That's right.

[Speaker 9]: The the the municipals, I believe, have a a coordinated But I'll I'll double check that and get back.

[Speaker 0]: But

[Speaker 1]: Okay. And we have them all coming in. It's just remembering as a group to ask them about their acre of They're all coming in over

[Speaker 3]: the next couple weeks. Yeah. Just a quick question for you as well. Do we have utility goals for the tier two and tier three around low income? What percentage of those incentives go to low income? Are they defined? No.

[Speaker 9]: I don't believe there there's not a statutory request.

[Speaker 1]: Not a statutory Yeah.

[Speaker 9]: And so tier two requires the utilities to purchase a certain amount of their load from distributed renewable energy facilities located in Vermont. It doesn't have a low income component.

[Speaker 3]: And that's true for tier three as well.

[Speaker 9]: Tier three might be different. I have to look it up. Yeah. That's what I've got. That is not my bailiwick, so I'll fortunately have to pass on that question.

[Speaker 8]: Regarding not making a recommendation on A

[Speaker 9]: discounted rate for the outcome. Is there a rationale for why? Yes. Backing So, up, I'll just make sure everyone understands what we're talking about. A, some of our utilities, particularly GMP and BED, offer a discounted rate to income qualified customers. And the way they do that is they put a, you know, a charge on every customer's bill, like $2. They collect all that money, and then they use it to buy down the rates for in company and unqualified customers. You know, the commission looked at whether it made sense to require every utility to do that or whether it made sense to create some sort of pooled structure where all the utilities do that. A couple things that came out of that investigation were, one, even in the utilities where they offer this this discounted rate, only about up to 45% of income qualified customers take advantage of it, which means that a significant number of income unqualified customers are just paying the extra $2 on their bill and not getting the discount. So while the commission has approved these programs, and and I don't wanna say we're it's not that the commission disfavors them. We didn't feel that it was appropriate to recommend them for everyone. Each the commission can approve one of these. If the utility wants to volunteer to do one and design one, the commission can review and approve it. But in terms of forcing the utilities to do it, the commission didn't feel like that was an appropriate step. For the small utilities, if they go it alone, it can be an administrative burden, and also the amount of money that they would need to write raise from their higher income customers would would constitute a a more significant cost shift than $2, but because some of these utilities are very small, but have a higher percentage of low income customers in their service territories. Also, just the the administrative process of doing that, it might be a little bit much for some of our smallest municipal utilities to take on individually. So that raised the question of whether it made sense to create sort of a statewide program. And, you know, one of the issues with that is just a sort of nuts and bolts issue. There would need to be some a fiscal agent, someone who collects all the money on behalf of all the utilities and then it re disperses it to all of the utilities, and there would have to be an annual rate setting proceeding. That didn't that that seemed like a bit of a heavy lift, again, considering that, one, this was gonna be a benefit that wasn't necessarily going to be adopted by all low income customers. And two, this is we're now talking about a relatively small portion of the state's utilities, at least in terms of number of customers that don't have these programs. It's our two cooperatives and most of our municipals. And so, again, it was sort of a balance of again, it's not that the commission is necessarily opposed to this idea. We said recommend it. Yeah. Sort of neutral on it. The other issue, again, is that and and we can talk a little bit more. There are many ways to design these programs, but in in their most basic sense, you you end up with a little bit of a benefits cliff where, you know, if you make a dollar more than the than the than the income threshold, you're paying more for your electricity now even though you are still quite could be quite energy burnt. And the, you know, the benefit of these programs, it's usually a 20 to 30% discount on your electric bill. The average electric bill in Vermont is a little over a $100. So we're talking about a 20 to $38 benefit per month, which I don't wanna say that's meaningless, but it it might not be significant enough to justify creating this entire program for see.

[Speaker 1]: I have a question. Yeah. Just to make sure I'm understanding. So I I get how it works on the thermal side. There's the, you know, there's the 2¢ a gallon charge. It goes to the wax. And then on the electric side, there's the efficiency charge.

[Speaker 0]: Mhmm.

[Speaker 1]: And that money goes to efficiency per month. Yes. And I understand how that works. So for low income customers who get a discount on their bill through their utility, I I know I know each the GMP probably does it differently from others, but who pays for that? Just the other rate payers?

[Speaker 9]: Yes.

[Speaker 1]: Okay. So we don't have a statewide funding source for that. It's GMP just builds it into their business plan or whatever.

[Speaker 9]: It's it's in their rates. Okay. And and it's actually a specific line item charge. You you'll see a low income assistance program charge Okay. On the bill.

[Speaker 1]: And then sorry. One more question. Yeah. And then is it a and I think you said this earlier, but I was just trying to, is it a broken feedback loop where everybody pays it, but if you're low income, you have to know about it and apply to get it? Or is it automatically offered to qualifying customers? Because I think one of the problems we have in the legislature is when we try to design programs that have an incomplete feedback loop. We're raising the money for low income folks over here, but they have to do something, want to do it, care to to get it. So I'm interested, you were talking about direct rebate. I'm interested in things where we're raising the money and it's flowing right back to the people who need it without them having to do anything.

[Speaker 6]: So I believe GMP has kind of a mix in the sense that I think they work with DCF and DCF does some income verification for other programs. I think there's some kind of transmission between the two where they're able to, if not automatically enroll people, keep up the income verification for those people.

[Speaker 1]: This is actually ringing a bell because we did talk to GB about this last year.

[Speaker 9]: Yeah, in 2020, the commission had its own investigation into the creation of a low income rate for all Vermont utilities. And and as part of that, there was a study done by GDS for the Department of Public Service and evaluated GMP's low income program. And and there were, you know, best practices that a utility can take to make sure that participation is as as high as it can be. And that includes, you know, trying to streamline this enrollment process and and income verification. However, that report found that even in some of the best run programs across the country, it's rare to get uptake over the 50 mark. And it's not just I mean, there certainly is instances where people don't know about this program being available to them, but there are also instances of people who are made aware of it and they they just don't take it because either they they don't feel it's appropriate for them to to take the benefit or it you know, they just have reasons for not doing it. And so it's I mean, that is one of the the issues that the commission considered when it when why the commission says we don't necessarily recommend sort of directing all utilities to do this because under any circumstance, you're going to have people who are energy burned who are going to end up paying more under that program and not getting the benefit. And

[Speaker 6]: to add a little bit to that, to something we discussed earlier, is the wealth issue creeps up when you're looking at an income only variable saying you're going to automatically enroll people. But there might be wealthy people that say, I don't want to be automatically enrolled. Or they are enrolled and maybe they are using that programme, but they are not really the people that you are intending to target. But they are going to be in that, they might be in the numerator, but they are going be in the denominator for low income households. So, targeting becomes an issue as well. And then I wanted to say one other thing just to kind of level set us. It s tricky with this report, and I think we discussed this a lot, which is that you saw the pie chart earlier. Electricity is only 20% of the average renter s energy And so when we re talking about an electric program for the utilities that the Public Utilities Commission regulates, it gets difficult to say you're really targeting energy burden as a whole when it's only 20%. Right.

[Speaker 2]: And on average. Right?

[Speaker 0]: On average. Yeah.

[Speaker 2]: There are a lot people. Less than that.

[Speaker 6]: Yes. For some people, it's less than, in fact, the healthier people are probably the The highest. The higher electricity use they have. Right.

[Speaker 1]: Uh-huh. Yeah. But, Greg Howland is

[Speaker 5]: He said the average energy average electric bill is a $100, but that's the bottom line of the electric bill. All charges combined, the meter charges and and I believe so. Service charge. So the the service charge and energy efficiency charge will be between $18 just basic to have a meter, other bit It it really varies quite a bit by company. Well, right now, I I a GMP customer, so that's the meter I read or the bill I read. It's a dollar and a half a meter. So if somebody has a hot water meter and electric storage heat meter, You pay in $4.50. It was $1. It went back up. It was originally $1.50, went down to a dollar, went back to about 50. And people who participate in the program pay 75¢ on the dollar across the board service charges and energy charges. But the way I understand, I think about those restoration charges. Right. The. Correct. So okay. That's The electric car charging is true. Have to have a smart meter.

[Speaker 6]: Understanding is most would not have a separate meter. It would just be a charger. Right.

[Speaker 5]: Yeah. And it's computed between the meter and the charger's control.

[Speaker 6]: They would need to opt in as far as that's concerned Right. Done currently to any kind

[Speaker 9]: of moving rate. Yeah. And to further confound things. I mean, understanding is that I know at least with GMPs, charging units, they have, like, a smart inverter and some and some of them that can can Yeah. Maybe that's not the chargers. That might be the the the solar. So, anyway

[Speaker 1]: I think Rutland had a question.

[Speaker 3]: I don't know. I wanna ask some point. It could be deferred for later. But the GDS study you mentioned and also maybe during your deliberations, did a performance metric around disconnections ever come up? Because to me, if you're seeing lack of uptake in an offering, it it does beg the question, well, how are you rolling out? How are you implementing? Mhmm. And it does seem like an important enough issue to have some performance metrics developed around it. I wonder, has the PUC ever considered that and it worked and recommended in another report? I

[Speaker 9]: don't know. Where that would come up, it's in GMP's multi year regulation plan. That is where there are usually performance metrics. I don't know if there is one related to disconnection specifically. That's something we can look at. And I also note that we have an ongoing case right now about the next iteration of GMPs. So that's something I might be a little limited in talking about because it's not the case.

[Speaker 6]: And the disconnection, I reached out to the Colorado Bureau for instance. They started a program recently. We'll cover this in detail when we get to the programs in other states. When I asked them, Has it been successful? Has it reduced disconnections? Because presumably that would be one of the metrics you would use. Reducing everybody will be one, reducing disconnection, which of course is like the worst case scenario, would be another one. And they said, it's really hard to tell. Even though they're trying to figure that out, that that's a goal of theirs, it's still difficult

[Speaker 0]: to know how effective these programs are. Long do they have it?

[Speaker 6]: I think less than two years, but I'd have to double check.

[Speaker 3]: And Illinois is just starting to work.

[Speaker 6]: I think that's right. Ohio has had one for the longest time in The US, which surprised me.

[Speaker 9]: So I won't we've we've touched on this already a little bit. You know, these are some of the other cases that where the commission has been looking at lot of similar issues. And and if some of our recommendations in this report sound familiar, it might be because we we've studied some very similar topics over the the past few years about how to raise money for weatherization, how to reduce emissions in the heating sector, and a lot of that has led the commission to make this recommendation about increasing the fuel tax. It it is worth noting though, depending on what your goals are, how you implement that could change. If if your goal is to reduce greenhouse gas emissions, you're gonna fund a different suite of projects than if your goal is to reduce energy burden. Because like we said, helping low income houses with weatherization can often be much more expensive than targeting other houses. So if your goal was just reducing the most amount of emissions, they might be operating rebates to all income earners to install a heat pump or something like that because a very small incentive could induce a lot of activity. But if you're targeting poverty and low income customers, it's going to take a different investment in different programs. So while the funding source we've recommended is the same, each of these reports comes at it from a slightly different vantage point because the context and the goals that we were studying were slightly different. We asked all of the utilities, all of the efficiency utilities, and also the government agencies that we work with to basically fill out a chart for us. Tell us all the programs you're doing. Their response was very significant. There are just so many programs that are are coming that are going on, but a lot of them are very similar because they're arising out of the same sort of pots of money. The largest program that that we have in Vermont is Lightyear. That that affects the most customers and is is the most significant one. The other area where you see a lot is the efficiency program. So VGS has efficiency, an efficiency utility for its thermal customers. All of the utilities, electric utilities except for BED, get their efficiency services provided by Efficiency Vermont, and then BED has its own efficiency utility. So you'll see a lot of very similar programs from all of those entities targeting how do we encourage people to install efficient appliances, how do we encourage people to weatherize their home, how do we encourage people to use less energy. And so, there's just a big suite of those programs. But in terms of which programs really touched the most low income customers, it was the weatherization assistance program and LIHEAP were the were the two the two big ones. The the funding mechanisms for these, a lot of it comes through rate payers through our efficiency energy efficiency charge on our electric bill or on your gas bill, but also state and federal dollars are are added to these. Know, the Felco earns money by providing transmission services in the region. Some of that money gets put funneled into what's called V Lite, which is used for efficiency. And then we even found that there are quite a a few organizations that provide heating assistance based on donations, Wood for Good and Meadow Hill Heating Assistance. And these are all charitable organizations that are playing a role in keeping people warm in the winter that it really shouldn't be overlooked.

[Speaker 2]: Yeah. Dara Torre. Did you guys look at trends, like, is on on energy burdens? Is it is it increasing, decreasing? The heating is light heat, the demand going up or down, or is it did you guys have a, like, kind of fixed point in time?

[Speaker 9]: We were definitely looking at what's being offered right now. However, comments we received from the Department of Public Service did analyze, at least in the electric sector, the number of disconnection notices that were issued and arrearages that the utilities keep track of. And there was some evidence that at least since 2020 that the the amount of arrearages, amount people owe or behind on their electric bills had gone up or that the in in the cases of people who are behind, the amount they're behind has gone up. So there is some indication that energy burden has increased in their in their recent past.

[Speaker 3]: Just another suggestion for a witness would be the department to hear their They wrote really great comments and summarized, just like your report had a great summary of existing programs. They had some scenarios for what collaboration could look like that I think would be great to hear from them directly, and also from Carol Flint from the department who's with Kathy about those trends because they've been tracking and noticing because when there's a disconnection, it goes right into them.

[Speaker 6]: To speak a little bit more broadly just from the research that we did, we saw that countrywide there were increasing amounts of disconnections broadly. Like, it seems to be getting used more and things of that nature. Trend wise, it seems like everywhere essentially is facing an increasing energy burden.

[Speaker 2]: Right. We have good data on electric, but again, heating and transportation is harder to quantify, correct?

[Speaker 6]: Transportation especially. That actually made this report quite difficult, in my view, because a lot of the data, if you just looked at reports on energy burden, they're going to talk only about heating and electricity. They don't talk about transportation. In terms of heating, in Vermont we have many different vaccine types of reports, probably like all the possible ones. A bunch of other states don't. So some states, if everyone's on natural gas, it's way easier to calculate the thermalspecific heating thermal component and then the cooling thermal energy electricity.

[Speaker 2]: You didn't break it down between, like, if you're burning maple versus ash versus

[Speaker 0]: Yeah. Not for the superpower.

[Speaker 5]: The heating component, is that blue? Wood and pellets in that, or is that just fuels?

[Speaker 6]: I believe it attempted to include all Yeah.

[Speaker 5]: Types of fueling. Types of it's recorded. Of purchase of product. So if somebody there may be a lot of back home neighbor stuff that wouldn't be included in Yeah. That's hard hard to quantify exactly. Yeah.

[Speaker 9]: I don't know how they would count. One of my my twenty five hours of fucking that I did this year.

[Speaker 5]: No. No. Well, you but he brought the wood from somebody else raw, and you made it into hardwood. Yeah. You made it into

[Speaker 9]: firewood. My hourly rate was really high. So I

[Speaker 5]: think your hourly rate is pretty low. Cost is what you could be doing. Your opportunity costs are high. Yeah. Rafael?

[Speaker 7]: Oh, yeah. So your you GMP is charging $2 a month

[Speaker 9]: Right about. Right. Thereabouts. Per per invoice.

[Speaker 5]: Per meter. Per meter per per I believe my last bill would

[Speaker 2]: be No. No. Not the meter charge. You're talking about

[Speaker 9]: The the low income

[Speaker 7]: low income assistance. So Yeah. Yeah. Okay.

[Speaker 2]: On top of anything.

[Speaker 5]: On top of the. Yeah. Yeah.

[Speaker 2]: And do

[Speaker 7]: you know how much money that generates a year? And how much they're spending out on that program?

[Speaker 6]: So we had I guess let me back up a little bit about GMP's energy assistance program, or EAP, in general. It has two main components. One is the one we've already talked about, which is decreasing the bill by a percentage, by a fixed percentage for people that qualify. The other piece is paying for arrearages, would be arrearage forgiveness. And so, the money from that pool, which I do not remember, we had a recent proceeding about changing their EAP somewhat, which is why I know this piece of it. But I don't have top of mind figures I would have to go back and check. That fee that is paying into a fund is then paying for the discount and it is paying for arrearage forgiveness for qualified customers with the goal of the arrearage management programmes, which we can talk a little bit more about later, is to kind of get people back on a level footing where then they can continue to meet their payments. So, the arrearages portion of that, how much is spent on that fluctuates based on people signing up, how much those arrearages are. Jake mentioned the intensity, the amount of arrearages increasing, as well as people that have arrearages, so it's kind of on both dimensions. Broadly speaking, like about the country. So I'll have to look up the specific numbers, but as it stands, the money that is flowing into the program is enough to cover all of the program's costs, which is about the best I can do off the top of my head.

[Speaker 1]: We'll we'll have have GOPM obviously to ask them directly.

[Speaker 9]: With any of these programs, there has to be a rate setting proceeding where you do a forecast of how many customers do we anticipate qualifying, How much is it gonna cost to give them the discount? How many arrearages are we going to forgive? And then you so you estimate a cost, and then you say, well, how much would we have to charge each customer to raise that amount of money? And then that's, know, oversimplifying it, but that's that's what they're doing for that for that rate setting. And you you revisit it periodically because over time, you'll find that your assumptions, you know, drift off from reality and you need to reset the the rate.

[Speaker 6]: Yeah. And and in that proceeding, which, again, I would have to look at it at the specific numbers, but right now there's a surplus in the fund as of the last time they reported the information, which was earlier this year, or last year now.

[Speaker 0]: And

[Speaker 6]: in that proceeding, they did not change the fee. So, to give you an idea, essentially, the program is being able to more than fund itself currently is the situation as far as the last reported information.

[Speaker 2]: So was it within the scope of this study to assess different utilities or different programs, right? So did you guys assess best practices for career age programs? I don't know if I

[Speaker 6]: would say assess best practices, but I don't think the commission weighed in on that specifically. But I did look at a journal article about best practices around the world of different programs that included recharge management. There s some information in that report.

[Speaker 0]: It's in this report. Yeah. Yeah, I

[Speaker 6]: talked about Sibilia was there, and then there's a separate report that I could I have to get it from the shared library, Vermont library thing, but I could potentially send that around or let you know what the report is to request from the library.

[Speaker 0]: Yeah, that would be helpful. So

[Speaker 5]: currently, Green Mountain Power and BED have these assistance programs. The rest of the utilities do not. I agree. And is the proposal for each utility to stand on its own, or is there gonna be some sort of

[Speaker 9]: statewide mitigation? So under current state law, any utility can propose to have one of these programs to the commission, but there's not a requirement that they actually do it. And the the commission's recommendation is to keep the status quo. But, you know, if if the legislature desires to have there to be either a uniform or set of minimum standards, this this that statute would need to be amended to to to make that clear. You know, I think it it some of our utilities are just so small that it it it really will be a challenge, I think, to for them to stand it up on their own, and you should definitely have them in to speak about it. When we sought their input on them, they were not in favor of being required to do this. And it's also worth noting that leaving the two cooperatives aside, they have some of the higher rates in the state. Many of our municipal utilities have some of the lowest rates in the state. And so requiring them to offer a discount didn't necessarily seem necessary given that their rates may already be significantly less than other utilities. They're already effectively getting a discount. So it really is that probably one size doesn't fit all, but then if you don't have one big program for everyone, the small ones aren't going to

[Speaker 6]: be able to it on

[Speaker 9]: their own, which was an issue that the Commission has grappled with since we started these programs back in the early 2000s. The Commission has considered whether there should be a requirement for all of these utilities to offer this program, and we haven't identified a way to make it really make sense yet. One, it is suggested in in the report, you know, if there was a way to bring outside funds in to the utility system to to do this, that might be something to consider. But if you're using ratepayer funds, the commission had concerns about creating a statewide program for discounted rates.

[Speaker 6]: And I I do wanna just add that VGS also has a Yes. Income assistance program. Thank you

[Speaker 8]: for yeah.

[Speaker 3]: I think they just updated the percentage.

[Speaker 6]: Yeah. I think so. I didn't work on that one. I don't have it on top of mind.

[Speaker 2]: So there's also the different utilities have different policies on how they deal with arrearages in general. Right? So that would be interesting to assess, like, best practices within that. Even if they don't have an energy assistance program, there's certain ways to deal with it, are more effective than others. Right?

[Speaker 6]: And, recently, GMP in the proceeding I mentioned that was last year to update their EAP, they made it possible for customers to receive two instances of arrearage forgiveness rather than one at the time they joined the programme, which is how it had previously been, because they were seeing, kind of to your question earlier, that people were still burdened sufficiently enough that they were accruing additional arrearages even with the discounted programme. That was approved, now that is in effect. They have two instances of arrearage forgiveness. BED, I believe, does not have two instances, just

[Speaker 9]: as an example of how they differ. One interesting piece of context in this discussion that I noticed is that looking at other states, most other states fully regulate investor owned utilities. Cooperatives and municipal utilities are not regulated. And so we didn't find an example of a state that directed its municipal and cooperative utilities to implement a program like this. And I think the rationale behind that general regulatory philosophy is that those are sort of democratically run organizations, the voters and and ratepayers of that coop or town decide what are the policies and and in terms of rate forgiveness or or rate discounts that they offer. But, you know, Vermont's a little different that we do regulate the small utilities. However, the the feedback we received from the small utilities when we asked them this question, you know, should we should we do this? Is said, well, our our voters didn't support this or didn't ask us to do this, so they weren't in favor of of it.

[Speaker 6]: And adding a little bit to that, Vermont, we have municipal utilities that cover more than their municipality in terms of distribution. That's partly why the PUC regulates them, whereas other states don't. But that's a great point that I forgot to mention earlier about the other states not regulating municipal and co op utilities. So essentially, another thing that made this report somewhat difficult to kind of get the best information was, if you look at another New England state, for instance, when they say we require all of our utilities to have an EAP, they mean investor owned utilities. Which means by that logic, Vermont actually also has a statewide EAP because our only investor owned utility being GMP on the electric side and then BGS on the gas side, both of them have AAPs. So, it becomes difficult when you go to look for information to see how is it treated at the municipal level. And we did what we could kind of gathering that information and looking at different programs. But essentially, it's a very mixed bag because, like Jake said, it's all down to the municipality in other states. So, it gets a bit tricky determining, drawing that line of like, does a state require a statewide EAP? If you hold them to the standard that we're kind of considering here of the municipalities, then none of them do. But if you are holding them to investor owned, then a bunch do, including Vermont.

[Speaker 8]: So, I wanna go back to the recommendations the fuel tax, adding on to the fuel tax recommendation. And just some thoughts here that I'm I'm trying to arrange, you know, as we, as a state, are moving in a country towards beneficial electric patient, the markets are starting to move in that direction. And, of course, we know we have to reduce our fossil fuel usage for climate change. You know, Vermont is pretty unique in the I believe correct me if I'm wrong, in terms of a regulatory frame for our electric district. I mean, we much more heavily regulate our electric sector than our neighbors.

[Speaker 6]: I don't know if I would say not necessarily, but I would say terms of what we talked about with the municipalities in that situation, my understanding, like I've not looked at every single state to find and figure out in their statute, but my understanding is that

[Speaker 9]: What the representative is getting at is that we are vertically integrated. Oh, exactly. Which sorry. Yeah. Mean, we're not the only vertically integrated state. Actually, of the South still is, and we can have an interesting conversation about whether they're doing as much as we are in terms of climate change and things like that. But, yes, you're correct. We have a very direct lever on the electric utilities in terms of directing their supply, through the res, we already the the Vermont already has, you know, much wrung out most of the, you know, carbon dioxide savings you're gonna get out of the electric sector through that. The challenge is the unregulated fuel side. Exactly. And and so, you know, I think if you look at going back to the previous studies, the all fuels energy efficiency report was really looking at that that question. How do you how do we get more how do we bring more savings out of the thermal heating sector, you know, and, specifically unregulated fuels? And our recommendation in that report was almost the same, you know, is increase the fuel tax. Mhmm. But where that money was being sent to differed. That was focusing on, you know, that would that's money that would probably go into the efficiency fund and be used for all income levels. And the screening tool we use in the efficiency program is cost effective efficiency. When you're talking about trying to reduce energy burden, that it if you're and that is not the most cost effective way to reduce greenhouse gas emissions. It's it might be the most cost effective way to reduce energy burden, but you're spending more dollar per gallon of fuel avoided because we had to fix the house. We had to, you know, remove the vermiculite. We had a lot to do a lot more work. Whereas in, you know, the all income area, maybe it's first offering a thousand dollar rebate and people are buying efficient, you know, heat pumps or something and that's saving tons of of fuel, but we were able to leverage private investment to to make that happen. So it really is gonna be a balancing of legislative priorities, I think, with these limited dollars we have and, you know, recognizing that there are gonna be trade offs and tough decisions about where are you focused or or how do you do everything at once. Is that possible even?

[Speaker 1]: So Yeah. I guess it would

[Speaker 8]: be my assertion that in terms of rate payer protections, it's the electric sector where we have the most in Vermont because of this regulatory frame.

[Speaker 9]: Yes, but with the caveat that, you know, when in our regulatory system, you know, the utilities are able to recover their prudently incurred investments, including the ones that are mandated to meet state requirements. And so, I I guess I agree with you. We have lots of but I also want to that doesn't mean that we're gonna be able to keep rates low all the time. Right. You know?

[Speaker 8]: Understood. And that's not necessarily the assertion I'm making. Yeah. Just that when we're thinking about I mean, we have no we really have no oversight over Absolutely. Distributed fuels Yeah. The rates that people have to pay for heat or transportation. And that's

[Speaker 1]: one thing I wanted to make sure I was understanding the difference between the sectors.

[Speaker 6]: Yeah.

[Speaker 1]: So just to kinda reiterate what Rep Sibilia said, if you go maybe you don't have to go back there, but if you go back to the pie chart, electric rates are the lowest percentage of Vermonters energy burden. And the place where even if we can't artificially Yeah. Dampen rates, they have to be submitted. GMP or any electric company wants to raise their rates, they need to justify it. You guys have to review it. It has to be approved. So we have a regulated sector that has, even though I know New England has higher electric rates than other parts of the country, Vermont has, I believe, the lowest electric rates in the region at least.

[Speaker 9]: In the region? In recent in in recent time, Vermont's vertically integrated structure has, I think, insulated it. I'm speaking very broadly here. Insulated it from some of the market swings we've seen more recently. And that hasn't always, you know, been the case. If you look back fifteen years ago, especially as natural gas sort of starts to flood the market, there were significant rate decreases in those, you know, deregulated states because some of that that low cost, you know, electricity was able to go right to the those companies that are riding the market. Whereas we're hedged with long term contracts. Our costs are very stable. So if there's a decrease in fuel prices, we don't get that benefit right away. It's a much more graduate. Well, then but we also are protected on the upside. So it's, you know, it's a it's a deliberate policy choice that Vermont's made, one that served its us well, I think, in recent times, but it also you need to recognize that ultimately, the utilities do get to recover their prudently incurred costs. So, if I just want again, we have the regulatory ability to look and check and make sure they've done their their homework and that they've made smart investments and that they're prudent in managing their businesses correctly, but we can't prevent them from recovering prudently incurred costs. So there isn't this again, I just want to make sure that there isn't the impression that we can just keep rates low. No. You know? That's that's the the difficulty that we face.

[Speaker 0]: So

[Speaker 8]: you or me, madam chair. But I

[Speaker 1]: I think I'm done. I was just trying to understand the differences between those important sectors. Right. So it it is the electric sector that is handled in that regulated way. Then transportation and heating by I don't know where Vermont Gas Center there. They're regulated. Exception because BT gas is regulated. Yes. But for the most part, when you're buying heating fuel or or pumping gas for your car, that is a that is an unregulated market. Right. Mhmm.

[Speaker 8]: Okay. So, with regard to this potential, for this recommendation to increase, the fuel tax, let me not lose my question. Did the commission look at how that would intersect or interact or influence tier three obligations on the utilities? And I know you're looking at that in another proceeding, I believe, tier three,

[Speaker 9]: or I believe Well, so so the second bullet here, you know, what part of act one four two asked us to look at sort of what how's the coordination between all these programs we have going on? And and the our overall conclusion was that in large part, they're they're working well together. There's a lot of collaboration going on, a lot of good work that's being done by all of these various entities. We did identify a few very narrow areas where large customers were able to take advantage of maybe two incentives because there was an efficiency utility offering an incentive and the local distribution utility offering a very similar incentive.

[Speaker 0]: So they could kind of

[Speaker 6]: play against each other Yeah.

[Speaker 9]: And be advised. We opened up an investigation to make sure that that kind of coordination is is tighter Mhmm. And that we're not spending more money than we need to to encourage efficiency projects. Basically, you know, if you have a large industrial customer, we should be giving them enough incentive to make efficiency investments, but not overpaying them or giving them a windfall to do so. But aside from that sort of very discreet topic, you know, that there wasn't a recommendation for additional sort of coordination on on the tier three side. I've sort of lost track though, but your question was slightly different about tier three.

[Speaker 8]: Did we think about what the effect of this would be on tier three? Did the commission investigate what the effect of this recommendation might be I tier three

[Speaker 9]: don't think so, but I'm I'm maybe I I'm not quite catching the connection. There's no connection. It's curious.

[Speaker 8]: Yeah. Curiosity. And and Yeah. I'm seeing, you know, the other investigation. So Yeah. Obviously, if You're not understanding the connection on those three either. Yeah.

[Speaker 9]: I I'm I'm I'm just sort of trying to do it. It's that if if

[Speaker 8]: there Every time we are creating a program to reduce fossil fuel usage, thermal usage Yeah. Homes Alright. And heating, we are potentially setting up competition with the utility's obligation. And so just making sure that we understand the interplay there.

[Speaker 9]: And that is what is what twenty five ten ninety four is looking at is that, you know, the utilities have tier three obligations, and the efficiency utilities have greenhouse gas savings goals or efficiency goals that they need to make. And, yeah, you don't want them going after the same customer, and that's we're trying to claim credit for the same behavior. So that is one thing we are looking at. I think that's more just of an issue with tier three generally, is that at at some point, do we have have we wrung out wrung so much of the emissions out of the system that meeting the tier three requirements become more challenging? I don't but there is a alternative compliance product price Right. That sort of sets a cap on that. So I don't know Right. If that's really an issue. My last

[Speaker 8]: question is similarly, but looking at the what is it, distributed fuels, heating fuels, and I guess transportation fuels. So, it's the heating fuel sector. So, this increase in fuel tax, as you said, it is more regressive than something like a clean heat standard, which, of course, I support a more market mechanism for transition. And supporting that whole industry in its transition, which I think Vermont really has to pay very careful and close attention to as we're seeing greater and greater consolidation within that industry so that we don't end up with unregulated monopolies, which is where we're heading and we have in other sectors of telecommunications. Let me get to my question now after my editorial, which is in terms of the community action agencies, do you have a sense to what extent the any of the fuel or transportation fuel companies participate with the those agencies or offer any programs like the utilities do or efficiency?

[Speaker 9]: I I I don't, but I will use this opportunity to plug what I mean, I was just so impressed when we interviewed the community action agencies. They know their clients

[Speaker 0]: Mhmm.

[Speaker 9]: So well, and that includes they know the programs that their clients need help accessing so well. And so it wouldn't surprise me if they know the fuel dealer in the town because they make that call saying, hey. We got the funding ready for this person. We need the delivery. But and and I'm sure that they are plugged into those community charitable organizations that are providing fuel assistance. So I would definitely encourage you to speak with them. I mean, our recommendation is really give those organizations more money and let them do what they think is best with it because they they know this problem the the problem being energy burden. They know they know what it looks like in the real world in a way that we can't really grasp, and they will know how to use those dollars in the best way. We wouldn't be able to design a program that would be as effective as what they can come up with. So

[Speaker 8]: Yeah. To the extent, madam chair, that we continue to pursue this, and I have some interest in this, but I really am interested in the overall transition of that, sector. I would love to hear from the those agencies about what their experiences with our heating fuel folks in the state in terms of are are they participating in ways that is helping their business to transition to where we're going as opposed to just riding the wave and seeing this consolidation of, you know, just the biggest guy at the end, you know, one one fossil fuel dealer, you know, who says, oh, sorry. Snowstorm. We're not coming this weekend. So, thank you.

[Speaker 1]: It's fine. Or yep. Kathleen?

[Speaker 7]: I just wanna make sure. Does Vermont Gas paying the low income per gallon fee?

[Speaker 9]: Do do you so they have their own income or energy assistance program, which they they have as a separate charge on their bill to to to provide a discount to low income customers. They also pay the fuel tax. So fuel. Yeah. Electric fuel oil. Yes. Okay.

[Speaker 0]: It's a it's a percentage. Yeah.

[Speaker 9]: It's a yes. It's measured differently because they deliver it through a pipe instead of by the gallon. Yeah. Yeah.

[Speaker 0]: Point seven five percent. Yeah. How many grocery seats? Point 75% grocery seats diets on Yeah. And point 5% on electricity.

[Speaker 1]: Alright.

[Speaker 5]: I don't understand the point 5% on electricity. Yeah.

[Speaker 1]: We can

[Speaker 9]: It's a it's a funded source for weatherization. Yes. It's it's what it is. Yes.

[Speaker 0]: Separate from the AVT charge.

[Speaker 9]: So we only have one last slide, and it was I don't know if we need to talk about this. We wanted did we wanna go through the sort of various ways you could structure an EIP?

[Speaker 6]: Yeah. Yeah. So, first, about the first item of body of implementation in other states. It varies far more than I anticipated when I initially started to look into it. Some states, as I get to with the EAPs, actually use LIHEAP funds to fund EAPs. Some states use it for cooling needs. Vermont only uses it for heating needs. So there are some differences in how LIHEAP is implemented on its own. In terms of the EAPs in other states, bunch of different models. Some of these that I kind of call out are done by investor owned utilities, Some are a requirement from their commission that regulates utilities. Some are municipal utilities that have their own thing and are not regulated in the same way in the other states. So, a rate model would be something that is built into the actual tariff rate. So, it would say this is the charge for someone with low income, for instance. That's a relatively simple but blunt tool. There are flat discount models that are like flat, exist at GMP, BGS, and BED branch electric right now. Tiered discount models are just kind of one step further than that, saying, for the people with lowest income, they get this flat percentage of discount for people in maybe a different income category to try to avoid the cliff, the benefits cliff Jake mentioned, have kind of a different amount of discount. And then there are everyone else, the kind of market rate bucket. These are all essentially, with the rate model slightly different, but they are all essentially funded by ratepayers unless there is a specific situation in the state where I mentioned where they use LIHEAP funding in some way to kind of mitigate. Then in terms of prepayment, this was interesting and not used much in The US. I think it's in Arizona maybe is the one I found that uses it. But it's used a lot around the world apparently, where people are actually paying like you would for gasoline essentially, but for electricity. Like you go out to your meter and you tap a card that you're putting a certain amount of money into it. I don't really see that necessarily as an energy assistance program.

[Speaker 1]: I don't even get that. So, you can load funds into your meter?

[Speaker 5]: Yeah.

[Speaker 1]: So, if I can afford a $100 on my meter this month, that's what I load. And next month maybe I can only afford 80 and that's what

[Speaker 6]: I So, you still have to pay for all your usage, which is why it's a little odd to me that it is considered in the EOP by kind of the broad understanding, but it's more like better awareness of energy usage than really what I consider it to be in that bucket. I was fascinated. Apparently, like in Ireland, it's very common. Was like, Oh, okay.

[Speaker 9]: As you go, it makes people supplement their consumption.

[Speaker 1]: And Right. Because you can probably see Yeah. Like, oh, I'm getting close to what I budgeted.

[Speaker 0]: You did. Right. Exactly.

[Speaker 6]: So I won't run the dryer right now. That sort of thing.

[Speaker 3]: Right. Yeah.

[Speaker 2]: Can can I go back to the tier discount model for a second? Like, how do they determine income? Like, if the the low income, if you're enrolled in certain programs, then that's an easier way to determine whether you're eligible, but the middle section is a little harder.

[Speaker 6]: So some states use, like you said, the kind of automatic enrollment by way of income verification somewhere else, so say with DCF or SNAP or WIC or something like that. In some cases, they're well integrated. In some cases, they're not. It's like, probably they don't have to pick up the phone or something like that. In other cases, it's self reported. That surprised me, that is out there. I think California is the state that had, at least that comes to my mind, the tiered discount program that was most easy to determine from the outside exactly what's going on. They have something I think called CARES. I might get the two names confused, but CARES, which is for the lowest income people that get a certain discount. And then I think FAIR or something of that type that is for people just over that. But I think maybe essentially like a few thousand dollars more kind of idea in terms of the area median income being covered. California, my understanding, which I would have to look back to verify, they use all the tools at their disposal. So if they have income verification somewhere and they try to link it up, you apply through your utility directly, which is another kind of interesting part of this is that a state entity might be doing income verification, but then it's up to the individual utility to actually implement the discount for a customer. So, in one way that's cost being shifted to the state for the income verification. In another way that might be a good thing. It's not necessarily a bad thing, but that's kind of how it's done. I have to dig back in to really look at specific utilities or specific states and how they do it. But it ranges essentially from self verification to you show them your income tax return kind of idea.

[Speaker 5]: But the utility remains whole with

[Speaker 6]: a tiered income, so that's not shifting, basically with the tiers. In some form or another utility remains whole, whether it's by charging other customers enough to make up for it or it's using other funding sources to complement. Never reducing their rate of return. Essentially, that is my understanding broadly, and I haven't looked at that question specifically, but that they're just two unrelated, basically, phenomenon. Ability, like,

[Speaker 2]: Green Mountain Power, they're making money off of capital investments. It's a cap CapEx program. It's not an operational

[Speaker 5]: Right. They recover their prudent investments within a low rate of return. Right. So, yeah, just separate from the rates and volume. But the rates but the rates support that.

[Speaker 9]: There's a very sort of complicated process for dealing with the volume of sales to ensure that the revenue requirement is met. But basically, utility is indifferent to the volume of sales that it has. Right.

[Speaker 0]: So, yeah. And maybe

[Speaker 6]: to your point, it doesn't have to necessarily be that way. Rate of return can be regulated in all sorts of different ways, but typically it's done with the CapEx and conveying a different volume.

[Speaker 3]: My question's about what New Hampshire has.

[Speaker 0]: Okay. I I think want me

[Speaker 3]: to provide that New Hampshire has. Yes. Apparently, they have

[Speaker 6]: Sorry. What was that?

[Speaker 3]: New Hampshire has some kind of tiered discount? I believe so. Do I have it in the report? Do I have statewide? It's statewide.

[Speaker 6]: So again, when they say statewide, it's only investor owned.

[Speaker 3]: Oh, is. Hampshire is an example of statewide meaning only I owe

[Speaker 6]: Essentially, everywhere but Vermont is an example of. When they say statewide, they do not mean municipal. Like, for instance, Sacramento has a very well known

[Speaker 9]: municipal Yes,

[Speaker 6]: they are not regulated by the California PUC. I think they're not called PUC, but whatever they're called. But the Sacramento municipality does have its own programs as well. So this is something that came up multiple times when we had people commenting, is there's a view that Vermont doesn't have a statewide program while these other states do, but that's not really quite the truth because of the nature of Vermont's regulation. So it made it a little difficult to easy to talk around each other and talk in circles. So, I talked about pre payment a little bit. Budget billing.

[Speaker 1]: Think perhaps Sibilia, Sorry. We may go

[Speaker 8]: And it's actually just a comment actually for you, madam chair. And I I don't recall that we have done anything around rate making. Oh. And it's not something that I have. I would not have testimony on during my tenure here. So, I mean Off season? It could be I I know it's incredibly complex, but that would be something I'd be very interested in. It may be helpful.

[Speaker 3]: And understanding, like, what return on equity is and revenue requirement. Like, that's that would be really good for us to understand.

[Speaker 1]: So TBD on the parking lot on that one. I Okay. We just we've got a lot to try to do for crossover. So Got it. Remind me, but we could spend weeks on any one of these topics, and I already feel like crossover's tomorrow. So

[Speaker 3]: what was next? Yeah. No. No.

[Speaker 0]: I'm I'm set. I'm Okay. I'm waiting for crossover.

[Speaker 1]: Well, it's tomorrow.

[Speaker 6]: With budget billing, which Vermont, we actually do require budget billing, this is where it takes many forms because it relies on an average, a mean of people's boas. So, you can construct a mean in a whole lot of different ways. It can be of only twelve months, it can be the last twelve months, etc. But anyway, the idea is that you take a twelve month period of usage in a building. So, this could theoretically involve a previous tenant. Then you take the usage of a building and say, Okay, it looks like you're going to use this amount of volume over the course of the year. So, we're going to apply our rates to that amount. That's going to give us a dollar figure. Then we're going to spread that dollar figure out divided by 12 and say each month you're paying one twelfth of your total yearly expenditure in order to smooth what otherwise is a quite seasonally spiky usage, where with the shoulder seasons being much lower usage and then summer increasingly, if you have AC getting usage and then of course the winter being the largest one. My

[Speaker 1]: experience with that budget billing program has been that you don't necessarily then get to roll that into the next year. Do you guys require that? For for me, there's then often a pretty brutal, oh, you know, and you have 12, you know, 1,200 extra dollars due by June 30

[Speaker 5]: If you're

[Speaker 1]: When we restart your next budget year.

[Speaker 6]: Yes. And that and that is the case with with most of them. Is that is that it's

[Speaker 1]: So it's helpful for for for most of the year in until final account.

[Speaker 9]: Well, it's helpful if your estimated annual usage proves to be accurate. If you exceed what the estimate was, then you're basically getting a payment at the end that's

[Speaker 1]: not Right. If it's a cold winter.

[Speaker 6]: It's possible to come in below as well, right? Get And paid back, you're paid back at the end as well. It kind of has a

[Speaker 9]: Time value of money issue. Yeah,

[Speaker 6]: that's right. But the reason for that kind of potential payment at the end going either way is just to make someone whole before, like you said, starting the next period. Right. Some utilities use every three months they'll send you a

[Speaker 1]: Selling?

[Speaker 6]: Yeah, selling bill. Some show you your actual usage compared to your estimated usage based on the budget billing, you can track, was I over, was I under, that sort of thing. So, multiple ways to do that.

[Speaker 1]: Sorry, you require that of electric utilities, but electric utilities are required to offer that?

[Speaker 6]: We have a rule that requires, I think, all distribution utilities. So, all electric distribution utilities must provide it as an option, and VGS does offer it, but I don't think it's required.

[Speaker 1]: Okay, but not other heating fuel?

[Speaker 6]: No, because we don't regularly.

[Speaker 9]: Though I do anecdotally know that at least some fuel dealers offer that because I've had that program before.

[Speaker 1]: That's what I was actually talking about. So sorry. I veered into another Okay. I veered into another sector. Okay.

[Speaker 6]: So, then I think we get to the most interesting two here at the bottom, are percentage of income payment programs. Then arrearage management is kind of a part of all of these in order to keep people in the system, keep people a paying customer. But the percentage of income payment plans take a number of forms. We talked about energy burden, and if you remove transportation, so let's pretend that we're only talking about thermal and then electricity. This would include wood

[Speaker 0]: or

[Speaker 6]: anything used. Hypothetically, we're saying all electricity usage, all thermal usage. We want that to be some percentage of customers' income. So a lot of states use 6% for the combined total. Some have varying ways they calculate it. But essentially it's targeting energy burden directly. Because it's saying, Okay, energy burden is a percentage of your income. So what if we just make you pay a percentage of your income? I'm an economist, so this is economically complicated because it only goes one direction. People that make a whole lot of income, they're not paying the same percentage. If you would pay a lower percentage, that's what you pay, but let's say it's 6%. So, some people might pay 4% because they either make a lot of money or have very low usage. Someone that might theoretically use 20% of their income in a given month, which is averaged over the year and calculated in a reasonable way, but they then would only pay 6% of their income's worth of payment, which means that other 14% of their income, that usage is being paid for largely by other ratepayers. So, it's a similar mechanism in terms of the transfer of funds, but it is targeting energy burden directly rather than targeting a percentage discount on the bill, which might be largely unrelated to the energy burden itself. Again, this only really works if you take out transportation as part of energy burden, but multiple states have programs of this type. Some of them use LIHEAP funds to fund this in what I think is an interesting mechanism where they say, at the beginning of the year, you can either take LIHEAP benefits directly, the typical fuel assistance type of things that we discussed, or you can take this percentage of income payment plan. I forget which states do that off the top of my head, but Illinois. So, these types of plans, as I said, they're targeting energy burden directly, but they have a very large economic potential impact. And again, it has the issue of opting in and people that are choosing to use the program, so you don't want to increase the burden of people that need it or might not use it, or need it according to our interpretation of any burden. Some states would only do this on the electric side, some do it a combined method where the utilities talk to each other. Like, say, even some utilities are natural gas utilities and electric utilities in some states and they do it as a combined basis. Because it's working with averages of income, it's like your last year's income, things like that, it gets a little tricky mechanically. The general idea is just that you're saying your energy burden will only be 6% because by regulatory power we made it 6%. And then for people that would pay a lower percentage of their income but more are funding the program.

[Speaker 9]: It's definitely the most targeted of these options for addressing energy burden. It's the most administratively complex also.

[Speaker 3]: It also seems like it'd be really important to focus on efficiency for those customers.

[Speaker 6]: Right? And that is part of some of the states like Do they combine? Yeah. Some sort of point, like, effort to to do that. Yeah. Mhmm.

[Speaker 9]: But, yes, I mean, it's an interesting point is that traditionally in Vermont, you know, getting to rates and rate design, you know, you have a choice. The the the regulator has a choice, which costs do we put into that fixed customer charge that doesn't vary with how much they use and into the volumetric charge, the per kilowatt or per therm charge, and that varies with how much they use. And in Vermont, we've tended to put more costs into the volumetric charge to create incentive for weatherization and for efficiency. But anytime you change the rates, you potentially affect customers' usages and their incentives to conserve.

[Speaker 6]: One question that could come up with these percentage of income payment plans is what about people with no income? They typically have to pay a very small amount like the fixed charge per month and then otherwise do not. That's a small percentage of people that was accounted for by some of the states when I looked at how they do it. So, mentioned Colorado earlier. They recently implemented this type of program. They are the state that when I reached out to them said, We're not sure how it's affecting disconnections. It's hard to tell. Like I said, the trend is disconnections are rising. So if you implement a program, you might be reducing the rate of increase of disconnections and that would be a win. But the counterfactual is not observable because you've changed the program, so it's a bit hard to tell how successful programs of this type are. I think Ohio has had one since the 1980s. They might also use the LIHEAP funding, I forget. And then the last type arrearage management is a part of all of these other mechanisms and most utilities that I looked at have some form of arrearage forgiveness. If they are an investor owned, it has to be approved by their regulatory commission. If they are municipal, it's approved by their municipal group in other states. Arriers management programs take a lot of different forms as well. They can be as simple as everything you owed is gone now, it s zeroed out. Or it can be, if you want arrearage management, you have to sign up for a budget billing program and then every month you pay your bill on time, we're going to reduce your arrearage by a twelfth or something. So it's like, as you're kind of paying along, you're reducing your arrearage. So lots of different ways to kind of articulate it. But the general idea is to keep ratepayers as ratepayers and not have to disconnect people for kind of a long running arrearage if possibly they can keep up with their bills going forward, which of course increasing energy costs make that more difficult.

[Speaker 5]: Is there any forgiveness of reconnecting fees? $35 for a reconnect after hour fee on a 200 kilowatt hour a month arrearage. You're paying $40 for energy. You gotta pay $35 to get reconnected.

[Speaker 6]: Yeah. Rear edge, my understanding of most of the programs is that it's just an all in rear edge. So it doesn't matter kind of where the charge came from, whether it's a reconnection fee or paugraphic or volumetric usage, but it would be potentially forgiven. Then a lot of programmes only allow you arrears forgiveness once. Some, it's only at the start of the programme. Some are a little more flexible. It just depends on the exact implementation, which of course matters a lot to individual people, it's kind of hard to say broadly. It didn't strike me that there was some typical way a rearrangement was done. It was just varied by utility and by regulatory body.

[Speaker 3]: How often does a utility report on its EAP? And how much arrearages have told us for them uptake by customers?

[Speaker 6]: So, the only utility that I can directly comment on is GMP because I was the hearing officer for their last EAP case where they made the change. And I believe we have a yearly compliance filing that's required of them to check it partly because they had the surplus of funding. So, as a regulator, it is important that that number is as close to zero as you can get as long as there is not to keep funding the usage of the program. So if surpluses are too high, that means people are paying too much into it and the ratepayers are not actually seeing the benefit from paying into it. If it's a deficit, which it has been in the past, then that means people aren't paying enough into it, and so it's not able to fully fund itself. To answer your question, the commission can require compliance filings for those E and P For GMP at least, I can say definitively that we do. I don't know for the other ones. I would imagine.

[Speaker 9]: I mean, I'm speculating, but I think we do. Anytime you have a utility holding what we would refer to as a regulatory asset, money on the books that either needs to be paid out or collected, you're going be checking their non listed funds balance periodically. Wow. And, yeah. So, I think that that is the end of our presentation, but here are our emails. Elizabeth Schilling, another staff member of the commission couldn't be here today, but also participated in drafting this report, and we're all available to answer questions if you have them about this report. Thank you for having us. Yeah.

[Speaker 6]: Thank you very much.

[Speaker 9]: Thank you.

[Speaker 1]: Yeah. Sorry. I think we

[Speaker 9]: have one more question. Please move. Receiving. Oh,

[Speaker 8]: oh, okay. I do. So when you all you guys are probably not the right people, but we have retirement of copper application. And the requirements the federal requirement is to notify you, the governor, the secretary of war, and Okay. Thank you for doing

[Speaker 9]: that. Yes. I will never get over that. Yeah.

[Speaker 8]: And I believe that the filing that came was or the notice was in a 130 page document.

[Speaker 9]: Yeah. That's I I I've heard of of of this issue. I'm gonna refer you to Dan Burke, who's our telecom guy. But, yes, we receive these filings. They come in in the APUC, and and, I mean, we do review all reports that that come in. But when it comes to what exactly the commission does about notices of copper retirement, I would ask you to get in touch with Dan because I don't know. So

[Speaker 8]: as a mailed notice to you of a hard copy, because I believe that's

[Speaker 9]: That's how it came to us. It was not through EPUC. You would you

[Speaker 8]: all would load that up into EPUC? I'll have to

[Speaker 9]: talk to the clerk and find out exactly. That's in in ideal practice. Yes. Everything is ending up in EPUC. I don't know.

[Speaker 8]: Unless it's confidential. Unless it's confidential. That's right. Yeah. Thank you. Great. Thank

[Speaker 1]: you so much for coming in. Yeah. Really appreciate it. I just this is really important kind of stage setting work for our work. So, appreciate you getting here, and, I think