Vermont Legislature SmartTranscripts:

[Chair Amy Sheldon]: Alright. Welcome back to the House Environment Committee. With us is Harry Shepherd from Green Mountain Water Environment Association, and he's here to testify on two bills. I want to make sure we get to both of them, and our following witnesses have some pretty pretty tight timing constraints. So welcome, and thanks for your flexibility, Harry.

[Harry Shepherd]: Okay. Thank you, and and you're welcome. And I think I could be relatively brief here. I'm Harry Shepherd, the public works director and town engineer for the town of Stowe. And I'm also currently the vice president of Green Mountain Water Environment Association. And I was also previously a member of the the study committee for municipal connections. And so I participated at that level also. I think on behalf of the Green Mountain Water Environment Association, we are still supportive of s two twelve. We've long recognized that there was some redundancy and overlap in the permitting review and processes associated with with municipal connections. And I think the proposed bill goes a long way into at at least potentially simplifying that some. I'll share that Stowe had a very village centric water and wastewater system. Then in the early two thousands, there was major expansions to our water and sewer system, basically extending water and sewer all the way up the Mountain Road to the resorts, and then another branch that goes up to traps. And so that much of that work occurred in the early two thousands. And since I've been public works director in 2010, we regularly, probably a dozen a year or more, are pretty active in the review and permitting of, connections to our municipal systems. I think the bill, as it's evolved, to incorporate general permitting kind of provisions to hopefully simplify the process some with the state is a step in the right direction. I I I think it could be helpful in in terms of the overall goal of trying to kind of simplify, you know, what needs to occur in this in this realm. I will say that as the representative, the owner's representative, if you will, of the water and sewer systems, Stowe probably has complicate Stowe probably complicates the permitting process more than than the state folks. And, that's because, as owners of the system, you know, we have a lot at stake, in terms of making sure that these connections are done right. If the water service, you know, leaks or the, sewer collection lateral leaks, That's either wasted drinking water for us or, you know, unacceptable inflow into our sewer collection system that, you know, affects our capacity. And so we've typically do a pretty rigorous review of these things. And one of the things that would be important for us is that we still maintain the ability to do that. And I think that the flexibility that's worked into this bill allows for that. And the general permitting piece of it, you know, following up a technical review, If if someone was to be a municipality was to be delegated that, you know, would would possibly help simplify the process a little bit for people trying to advance connections and and the redundancy that may exist now with the state process. I I share I also agree with the goal of of trying to separate kind of connections manual for municipal water and sewer connections separated from the WW rules. Brian, previous witness there was very correct in noting that the WW rules are really more soils based and and intended for on on-site water and wastewater supply. And it's it will be very helpful to the development and engineering and municipal community to have a separate document that kind of focuses specifically on, you know, what's what's required for municipal systems. One of the realities on the drinking water side, that's not really addressed at all in WW rules, and I hope can be incorporated in, you know, a guidance manual coming out is that really in Vermont except for kind of single family or duplex type residential structures, most of these water services really need to be designed for fire protection in addition to, you know, drinking water. And those aspects of what's necessary for, you know, accommodating both fire protection and drinking water aren't really addressed at all in the WW rules. And oftentimes creates some misunderstanding in the development and engineering community as to, you know, what's really acquired. And my hope is is that this future manual, if we're able to get to there, will focus some on recognizing that reality that fire protection systems need to be a part of what's thought about for drinking water connections to the buildings. And so I think that that really kind of summarizes what I would say there. I I I would point out that in a couple of spots where it's talked about in the bill regarding the secretary giving deference to licensed designers. I'll note that in a in one spot, I see the use of the word may, which I think I encourage. And then in another spot, it's shall. And I think that that should be used with some caution. I think I prefer the word may. Not all licensed designers and engineers are the same, and I would like to not you know, I'd I'd suggest that the secretary not get boxed in with that. The the word shall, I understand the goal. But in in some of the language that I see towards the end of it, where talking about if the town were to take the partial delegation to do the technical review, it says that, you know, we shall follow that same, deference to licensed designers. I I I I think we would we would like to maintain, you know, the the technical review authority whether we're receiving the partial delegation or not. As a representative of as the owner of owners representative of these types of systems, I think it's important to kinda recognize that when the developer is gone and the engineers are gone and the permitting regulators have have done their job, we're left with customers. And, you know, having that having this situation where the state is permitting and regulating connections to municipal systems, you know, creates that tension where some of the state's prescriptive goals may not go far enough for, you know, what individual municipalities think they need in order to, you know, protect their ratepayers and do the right things for their systems. And so that for two twelve, I would offer be happy to answer any questions.

[Chair Amy Sheldon]: Do members have questions for mister Shepherd? Representative Austin?

[Rep. Sarah "Sarita" Austin (Clerk)]: Yep. Could you give an example of, where the state may not go far enough like with STOW, like what you would like to add?

[Harry Shepherd]: Well, sure. The state's standards in the WW rules, I would call prescriptive. You know, they require separating distances and, certain types of materials, all that is, you know, minimum standards. But particularly with like changes of use, sometimes the state is really not aware of situations. We had one situation, a resort on the Mountain Road. We knew that the existing water service to the building was undersized. And there were already some issues during Columbus Day week or Presidents Week when we're, you know, lots of customers, lots of demand, lots of folks using the system where that water system was really not functioning, sufficiently for providing adequate water to the resort. We were aware of that, but then, changes of use and additions and extensions of the water system were proposed. And it it got processed and approved through the state system. And and we had to say time out. It's only a one inch water service, and that's not adequate for that expanded use.

[Chair Amy Sheldon]: Thank you.

[Harry Shepherd]: You're welcome.

[Chair Amy Sheldon]: Further questions? Alright. Thanks for that. And now we can go on to the next.

[Harry Shepherd]: Alright. Great. Thank you. Yeah. I think the next is one that we're hoping to ask for a seat at the table for the Green Mountain Water Environment Association. Our members are water and sewer operators and taking on increasing roles within the stormwater world. We produce and treat and clean amongst our members an estimated 40,000,000 gallons a day of drinking water and and wastewater. And so we're really actively engaged in the water needs and community. And one of the challenges that we sometimes come across is that the anti degradation rules sometime make it so that we can't revisit things. There are aspirational goals in our water quality standards, And there are rules that sometimes evolve. And then, you know, practice and trying to deal with those, we discover that there may be requirements that get embedded in rules that frack frankly, are not practically achievable. And so, you know, when when that type of thing occurs, we hope to be able to revisit it with the regulators and our our rulemaking authorities so that we can have potential revisions to things that we are concerned about that we cannot practically achieve. I think the the goals of not having any degradation of our water quality is fully understood and agreed. But when things that can't practically be achieved, get embedded in a rule or a general permit or things like that, we want to make it so that there's some provision in future anti degradation rule or policy or statute, however that kind of falls out so that if in fact something isn't practically achievable, that it can be revisited and the anti degradation rule isn't used as a, reason for not being able to revisit something like that.

[Chair Amy Sheldon]: So it sounds like you have you have some experience with this. Can you provide an example of how this has played out in your world?

[Harry Shepherd]: Sure. Yes. I don't have the exact dates on the year, but I think late twenty twenty four, there was a new general permit progamated for, the discharges from drinking water infrastructure. And that that rule established effluent requirements, that, frankly exceed drinking water standards. Stowe is on a quest to try to find a new PFAS free water source. And we are in the midst of doing due diligence investigations on a piece of property that we hope will prove to be adequate yield and PFAS free. Permitting a large water supply like that is appropriately onerous. But one of the things that's required is hundred and twenty hour yield test. That is also appropriate for a large water supply well. But the effluent standards that have been embedded in this general permit have adopted secondary maximum contaminant levels for iron. They aren't even and also move the decimal point one place to the left for arsenic. And really for this type of effort, we can't we we don't have groundwater in Vermont that doesn't have iron in it. And it's pretty common for public water systems to be treating for iron. And what we've encountered is that we're not gonna really be able to perform that yield test with a, you know, temporary short term discharge because we can't meet those standards. And another thing that's embedded in that permit is that we also can't use chemicals. And so even if we were to attempt to try to implement a temporary filtration system to meet those effluent requirements, we we wouldn't be able to use chemicals. And chemicals are important in terms of trying to properly filter and and make filtration effective. And so with the cooperation of the department, we've worked we've come up with a workaround where we're gonna do a temporary spray field in order to avoid that discharge permit. But it's it's a it's a pretty significant effort. That talks specifically about what it would require for, like, a yield testing on a well. But soon after the original rule was adopted, it got amended to include everything that we do with hydrant flushing, flushing our distribution system. And honestly, we we can't comply with what's being asked for that discharge in that permit to to to be able to flush our distribution system. Most of the water distribution system piping in Vermont is ductile iron. And when we're flushing the distribution system for maintaining our water quality, it's it's we're we're pretty much flushing iron oxide. And it's it's when our guys are doing the flushing, they they kinda keep a look at the color of the the water that's being discharged on that very short term localized basis at a particular hydrant. And when they see that the, you know, the orange or red tinge associated with the iron oxide is is is not flowing anymore, that's when they know that, you know, they've successfully flushed that section of the distribution system. And so there's an example of one where it gets kind of embedded in rules, or a general permit, and then we we physically can't comply. And so that's what we're hoping to have part of the conversation include in the future so that, when something is, embedded in a rule or or a permit, that is not technically feasible, it could at least be revisited.

[Chair Amy Sheldon]: Yeah. And that was that was really helpful. Thank you. But understanding that that's that's a general permit, and then it sounds like you got a a regular permit in order to address the drinking water effluent situation. Not I do hear your point, but I I get it. Like, a general permit is for those cases that are within the bounds of whatever the constraints are.

[Harry Shepherd]: And the and the department did offer the for the for the yield testing, the department did offer the opportunity to, you know, go through an individual permit. Our challenge is that it took us about three years to find a site that hopefully is PEEF is free and has the yield capacity in the in the aquifer. We're reasonably confident that that's gonna be proved true. But we also have a purchase and sales agreement with a property owner who wants to get to a closing, and we were only able to negotiate a sixteen month window for the due diligence efforts that we have to undertake. And the the, you the individual discharge permit processes and requirements in in themselves take a long time. There's some seasonal testing that's required. It it it it can it could really extend for an extended period of time. In the case now that it's added to now that it's just drinking water infrastructure, you know, in the case of our of our with our flushing of our distribution system for our normal water quality efforts, you know, for top for a system like Stowe's, which is very linear, and, you know, we we we can't entertain that concept of going through kind of individual permits for dealing with hydrant flushing. There's hydrant flushing in the past has not been permitted at all. Maybe it should be. Maybe a general permit is a good option there, but we can't have effluent requirements that we can't we can't technically meet.

[Chair Amy Sheldon]: Yep. Alright. Thank you. Got it. Thanks for joining us and for your testimony, and we we hear your request. We'll we will take it under advisement.

[Harry Shepherd]: Thank you very much.

[Chair Amy Sheldon]: Thank you. With that, we have Megan Moyer here from Burlington via Zoom. Welcome, Megan.

[Megan Moyer]: Let me just get my little presentation thing going. How's everybody how's the weather down in, Montpelier today?

[Chair Amy Sheldon]: Great. Springy, overcast, a little chilly.

[Megan Moyer]: Yes. Okay. Let me see. Share this. Sorry. Zoom's a little bit different than the rest of than the teams. But okay. Thanks. Now I've got it. I also have way too many screens for anybody's benefit. Can you all see can you see that?

[Chair Amy Sheldon]: We will in a second. Yes. We do.

[Megan Moyer]: Awesome. Okay, thank you so much for this opportunity. I know many of you. Hi, Amy. It's been a long time, but it's good to see you. Good to see you. And others on the committee. Just a little bit about myself. My name is Megan Moyer. I have about twenty years, over twenty years of experience in the water resources world. My first eleven years were focused on stormwater and combined sewer wet weather management. And over the last ten years, I've been in charge of what we call the one water world as the head of Burlington's drinking water, wastewater and stormwater utilities. And today I wanted to talk to you about two issues that are thematically related, although they do or would touch different parts of the statute. And really the primary focus of what I wanted to share with you is how do we leverage existing resources and how do we These questions that I have on my first slide, think are things that I've been thinking about as somebody in Burlington as well as somebody who cares about what's going on at the state level, but you know really the struggle of how do we increase the number of affordable housing units, right? We all know we need to do that while we maintain and uphold our commitment to public health and the environment. And frankly, I'm concerned that unless state staffing levels increase significantly, you know, Vermont Environmental Review infrastructure going to be able to adequately keep up with the, at least the number of housing projects that we would like to see? And in that same vein, how can we leverage existing local review to ensure that those state resources remain to support the places that don't have the sort of local technical capacity that maybe a place like Burlington or some other communities have? I also think I we think a lot about how do we support densification of housing in appropriate places that have established infrastructure, right? So that as much of Vermont's open space as possible can still be maintained. Frankly, though, at least in a place like Burlington, this may apply to some other places that are already dense or sort of prime for density. The development of those areas isn't necessarily easy, and so how can the regulatory framework sort of adapt to cost effectively support the need for what in many cases is fairly significant and very technical local review. Now, just some examples, I don't know how many of you know Burlington, but we've got lots and lots and lots of pipes and these pipes, I think you've heard from others, when we're doing a review for water and wastewater connections, it's not just about the water treatment plant or the wastewater treatment plant and whether that has capacity. That can actually be a quite simple exercise. What gets really challenging and what we spend the vast majority of our time looking at is all of these systems of pipes and whether or not there's actual space in the pipe to get the water either to the wastewater treatment plant or from the water treatment plant and the various other storage systems to a given project. In order to do that and do that well, we've had to do tons and tons of inventory and mapping and for both the collection system as well as the drinking water system, we have calibrated computer models where we can actually run scenarios and look at what the impact is going to be of a given large development such as the one that's planned for the South End on our system and make sure to the extent that there is going to be a problem that we can address that problem either on-site or through other projects. Another example of where things get a little bit complicated in Burlington, this plays a big role on the storm water and on the wastewater collection side. You know, each of these colored areas of Burlington have different challenges and considerations, particularly the combined sewer service area, which is the areas that you see in purple or in pink. Those projects in those areas, they are possible but they require an additional level of review. Fortunately, we do have and we are blessed with an amazing team of people. This is the sort of whole breadth of the team that works on water resources in Burlington. It's about 64 total people, but if you zoom in, there's a number of different positions that are either directly involved in reviewing connections as well as supported by engineers, asset managers, people who can go out into the field and double triple check something before a project comes forth. The stuff on the right is just a list of all of the things that we are looking at when we get a project at the local level. I think part of what was discussed in the study group that I and Harry and others were a part of when we looked at how to kind of unlock a potential different track was, you know, we're already redoing a large portion of the review that the state is also doing. We are very supportive about the manual that's going to improve the consistency and how people are evaluating capacity review throughout the state. We're very interested in the opportunity to reduce the duplication of technical review. Right now, a project has to come to us to get that initial capacity, ability to serve letter, and then they have to go to a separate office and pay fees for presumably a separate review while they're still going through all of that extensive review that I talked about where we're looking at sewer water and storm water. The other piece that I really, really like about what S212 is proposing is the smart and efficient and frankly cost effective leveraging of the existing strengths of the state water wastewater database. I like that database. I use the database. People throughout Vermont use the database. My engineers use the database, and we don't want to create a whole additional system. So this really, this is one of the pieces I think when we looked at sort of going through the old way of getting delegated authority, we got stuck on this one because I didn't want to set up an entire database and have to maintain it in perpetuity. So this cost that's been established of $100 per general permit, I think is reasonable to be able to access that system. And then for us, it leaves a little bit of financial room for local communities to be able to charge reasonable connection review fees. We're not currently charging for our review but we would like to, but we feel a little sheepish about laying on an additional permit fee on top of the permit fees that folks are already paying at the state level. So with that, that's sort of my, you know, speaking specifically to the language that is currently in S212. There is a related issue that does not touch the same portion of the statute and should you choose to advance it within this bill, certainly it needs to be called out as a separate provision, but for us in Burlington, it is related. Chair Sheldon, would you like me to go through the rest of my presentation or would you like to stop with the S212 stuff and then I can touch upon the pretreatment piece separately?

[Chair Amy Sheldon]: Well, we can pause, see if there's questions on the first part, but not seeing any. I'm fine with you going ahead. Go ahead. Thank

[Megan Moyer]: you. So the other piece, and we had provided some language to the Senate side, but I think it was a little too late in their process as they were advancing two twelve. But we have presented a proposal to your committee to consider the ability to delegate or change the current approval framework for pretreatment permitting to allow for local POTWs, publicly owned treatment works, to have sort of direct authority over their industrial users. I don't know how much of you have spent time looking at pretreatment. I don't know that it's come up recently. But basically, pretreatment are federally, so this comes from the feds directly, federally established regulatory requirements to control, reduce, or eliminate pollutants from what we call non domestic sources of wastewater. Most commonly, you're looking at food, beverage production, the breweries, but there are a number of other types of industries such as metal finishing that have very specific requirements. These users are required to be regulated and they're broken down in a couple of different categories. The categorical industrial users, those are the very specific types like metal finishing. Then there's a large sort of category of what they call significant industrial users. These are users who are larger in volume, who discharge usually high strength waste, or who have a reasonable potential. An example would be maybe somebody doesn't necessarily trigger the bright line test, but they've got large vats of high strength liquid on-site, and if one of those spills, it could negatively impact our wastewater treatment plant. Folks often forget that wastewater treatment plants, they're not just systems of pumps and mechanicals, they're actually living systems full of biology and when something gets discharged that the bacteria are not used to, it can kick off a whole set of processes that then make it difficult or sometimes impossible for those bacteria to do their amazing job and then you can end up with violations of permit and impacts the water quality because the process has been affected. The other users that can be regulated basically include any other non domestic user that discharges a pollutant of concern or something that could potentially harm the wastewater treatment plants. Some of you maybe remember back I think in 2018, there was an audit by EPA that kind of looked at Vermont and how it was administering this program. Some deficiencies were noted and from where I'm sitting, the state has been making a lot of steady progress towards compliance. However, I think anybody would disagree that the state program on this issue is still very much likely understaffed. Since 2018, it's been a little bit of a background project, but we have been working towards at least looking at what our industrial users are in Burlington, and we've identified quite a number of them, only some of which have, I think only two of which have existing state permits. So, there's a whole long list of folks that need to be brought into the fold to get compliant with these federal regulations, and doing so is going to take significant effort even if we look at phasing those permits in. We've also done the work to develop local limits, which are the limits that would go into Or the limits of pollutants that would then get allocated out to industrial users, which would be necessary whether or not we had a local program or the state was permitting these on their own. So the tricky wicket here is that Vermont is one of five states where the states have all of the direct responsibility for administering these programs. You can see on the right hand side, the POTW, that's us, is there. We are consulted, we are involved, but we are not directly regulating these industrial users. For many other states, and this, the framework on the left hand side is not off, it's not currently authorized or allowed in Vermont due to how 10 VSA twelve sixty three is written, and from what I could tell and from past presentations, there's often a trigger in other states as to when they follow the framework of EPA regulates the state, and the state sort of regulates the POTW in regulating the industrial users. And this is usually for larger systems such as ours that have a combined design capacity of over 5,000,000 gallons per day. I believe we're around the 8,000,000 gallons per day in total for all three of our plants. You know, why are we asking for a voluntary I'm calling a delegation, it may end up being a different word. Well, frankly, we believe there's some significant benefits. We are the ones who are most familiar and are closest in proximity to our users, the collection system and the wastewater treatment facility. We believe this will pay dividends not only in bringing the existing users, right? We're not talking about new users, although we would also regulate those, but we have a whole cohort of existing users who I'm sure are doing their best, but they're going to have to do more in order to get fully compliant and frankly to help us and help the community not use up more of our organic treatment capacity than they really need to be using if they were just doing some best management practices. But once that program's running, you know, when something happens, it's going to be Burlington's wastewater treatment plant operators that are going notice something weird going on at the wastewater treatment plants. It's going to be our collection systems crew who pops a manhole and sees that there's a large amount of grease that's never been there and there's an industrial user upstream, we need to engage them in what their practices are. So it really gives us a little bit more operational control and understanding of what's entering our facility and being able to be nimble. We acknowledge that while this is a new thing, if we're able to go this direction and there's lots to be worked out regarding the framework for delegation or the state sort of having being the control authority for us, And there's going to be, and I would expect that there would be periodic audits, and those are going to use Vermont DEC resources. Ultimately, we believe and I think this hopefully, the state would corroborate this we believe that the local POTW pretreatment approach could result in potentially faster implementation of permit coverage for these users and won't add as significantly to the pretreatment program that is already overcapacity. At the end of the day, similar to our comments on S12, it will also allow us to charge reasonable permitting fees to support our ongoing additional local capacity without getting into that duplication of effort as well as expense for industrial users. These users are going to be probably incurring some additional costs in meeting the requirements, and we're just trying to make sure we're not overcharging when we don't necessarily have to. It is our belief or intention that the updates, the language that has been proposed to update 10 VSA twelve sixty three, it's intended to enable this framework to be an option. Again, a voluntary option, you know, I think Burlington is the only one that's raising its hand. I don't think that the state is necessarily looking to implement this in any other places. So, we do know that it's a little bit of a narrow focus for us. And then I just provided the language, and I think with that, I will take any questions.

[Chair Amy Sheldon]: Thanks for your testimony. I have a question. I guess just to help us understand further how this works now, I actually, and I think all of us were offered tours of treatment plants in the past year. So I did one in my own town. It was incredibly interesting and educational. But we covered in that tour how Middlebury works with these types of pretreatment operators in our industrial park, which I know we're much smaller than Burlington. How would this be, in your mind, different? I mean, it seemed very much relational. They had very close relationships with the different industrial folks and could coordinate their needs. And I guess I'm curious how you work with yours now and how will how would this be different?

[Megan Moyer]: So right now for most of our industrial users, not the full list that I the sort of expanded list that I mentioned, but our big industrial users, we do have surcharge agreements where we already do charge them for sort of the increased strength of their waste as a way of maintaining equity for with our other rate payers. But what we're not doing and I certainly should talk with Middlebury, my understanding is that Middlebury has a local program, but then additionally, those facilities are permitted by the state. So the Middlebury permits or relationships don't supplant or serve as the sort of regulatory mechanism. In our situation, like being able to permit them would enable us to have stricter compliance regulations as far as what they could discharge and have an upset limit, sort of like there's a surcharge limit above which you may be charged a surcharge, and then the regulatory limit would be sort of a thou shalt not ever exceed type limit. And by us doing a local program, we sort of, you know, check the box that already needs to be checked. These facilities need to get formal pretreatment permits, whether they're from the state or from the local community. And my suggestion or our hope is that instead of having both, that we if we're going to be doing a program that meets the rigor, why not just have that meet what would otherwise be required by the state and therefore allow the state to focus its limited resources where else it needs to? I don't know if that answers your question.

[Chair Amy Sheldon]: Well, is the state system limiting what you would set as your regulatory limits right now?

[Megan Moyer]: No, it's not. No, so we could have a local program. It's really just about the duplication of effort and whether or not why expend state resources if we're already going to be doing it at the local level and we're already prepared to do a program that meets all of the requirements of the federal regulations.

[Chair Amy Sheldon]: And

[Megan Moyer]: frankly, to be able to charge our own fees, it doesn't mean that we couldn't charge a local pretreatment permit fee at the local level and then also still have those same people have to go through the state for a very similar review and very similar compliance requirements and so on and so forth. But in this day and age of limited resources, it just seems like it's worth exploring an alternative program for folks who are willing to voluntarily redo it.

[Chair Amy Sheldon]: Yeah, and we had an opportunity to briefly talk with our legislative council, and maybe this is why you were saying it might be a different term than delegation, but there is potentially some concern about whether it would meet the requirements of the Clean Water Act.

[Megan Moyer]: I guess, and we do need to work that out. I mean, is done in other states, right? So, I know that Heather Collins has reached out to Nebraska about how they do the work because I believe they're one of the ones that are in the five. So, my understanding is that it has been done and certainly anything that we would do would have to meet the federal regulations.

[Chair Amy Sheldon]: Yeah. Do members have questions? Further questions? All right. Do you have a question? Representative Chapin.

[Rep. Ela Chapin]: Guess I was just curious a little bit about just going back to the general permit piece. Does it work in the rest of the country? Is proposed general permit for connections common with your colleagues in other cities?

[Megan Moyer]: I don't know actually. Harry, do you know I don't know what other states do. Certainly when I do you know googling of connection review, lots of other things pop up so it would seem that there must be some mechanisms in other states But do you know

[Harry Shepherd]: First half of my the the first half of my career was in Connecticut, and I share that in Connecticut, municipal water and sewer connections were permitted only at the system level, not by the state.

[Chair Amy Sheldon]: Thanks.

[Megan Moyer]: Yeah. I mean, I suspect that, right, the whole state water wastewater permitting program was set up, right, because of our commitment to the environment and making sure that everything everywhere was getting some level of review. It's hugely important, right, for our environments, but different communities, you know, as things have grown and as we're dealing with densification in all these different areas, think local communities have organically started looking at it more closely because it's going to be my butt on the line when a manhole overflows and somebody didn't do the full check that they needed to do. We're going be the ones who are in trouble. So I think we've now started to develop a different framework, and this is just about rebalancing things from my perspective.

[Rep. Ela Chapin]: Great. Thank you.

[Chair Amy Sheldon]: Great. Thank you again for your testimony.

[Megan Moyer]: Awesome. I really appreciate the opportunity and reach out with any additional questions. Thank you.

[Chair Amy Sheldon]: Great. Next up, we have Josh Hanford. Hello. 212.

[Josh Hanford]: It's 212. Josh Hanford, Vermont League of Cities and Towns. I can be fairly fairly brief and don't have a a presentation. Definitely not an engineer or a permit specialist, but I was on the working group a couple years ago that dived into the duplication of permitting for water and sewer connections and the effort that resulted in 02/12 to try to reduce that. Certainly learned a lot in that group that I didn't know. And in the big picture, the league supports two twelve and the efforts that are put forward. It was very clear in that process that the sort of reviews that municipalities did to look at connections were pretty different than what the state looked at. The state looked at, is there capacity at the plant? The municipalities review is much more, do we need additional pump station? Are the pipes big enough? Are there other issues that were sort of missed in the state review? So that shed some light on where the group went and reached consensus on the full state delegation that had been in place for a while that only two municipalities used that you heard about clearly didn't work. They both turned them back. There were issues on both sides, as I understand it. The state also had to match up records that weren't done in the format and through the database that they needed. And it was clear that DC does keep, they're good stewards of these records of information. And so the partial delegation authority that's in two twelve, we support, We don't know, maybe as you heard from some other witnesses, how many municipalities will really pursue that. Maybe just the few largest will find that worthwhile. But we do support the effort moving into this general permit concept. Think that those fees are reasonable and the ability for municipalities to charge a technical fee is supported and is needed, frankly. Also support the manual that DC is working on that will improve this consistency and provide more information for municipalities and engineers benefit from. So, yeah, that's really all I have to say is this is a good compromise bill that moves the ball forward on something that's been talked about for a long time. Is it going to solve all the problems? Is it going to reduce all the costs? No, but it's the right step to take at this point.

[Chair Amy Sheldon]: All right. Thanks for your testimony. Well, no, we might have questions. You're not the first person to say a good first step, but you are might be the first person to say compromise. I guess I'd like to explore what two what do you mean by that, and what are the next steps, or what's the compromise?

[Josh Hanford]: Well, report laid out a couple different paths. Certainly DHCD's view that brought this forward about some of the length and time and the permitting and the wish that there was much more mapping and data available doesn't really come through in this bill. So when I say compromise, it just means some people wanted a little bit more. And there was also great testimony for some of the professional public works directors, Harry and Brattleboro and Megan and others that felt as you're seeing, they could even do a little bit more on their own and not have as much of the state oversight, but this also didn't fully go that far either. And so I don't use compromise in a way that there was horse trading about this is what we will settle with more that Yeah, like the work that we had, the time that we had, what we could agree to and get to from all the various interests and a lot of the technical side to this was what 02/12 resulted in. And just saying that this conversation probably won't stop. Mean, even what Megan is proposing new technologies in on-site systems, there's always more work to be done here. And yet there's capacity constraints on staff time, there's resource constraints on dollars, what we have to do. Just saying that I don't think this is the end of this conversation, but this is the right way to move forward at this point.

[Chair Amy Sheldon]: Okay, thanks. Other questions? I'm not seeing any right now. Thanks for your testimony. Thanks. Members, Thomas Weiss gave us a link to the report. Maybe Cath can provide that for all of us. Since we have a little extra time, I encourage folks to read that report. I'm gonna look at it. Well, my head's in it. So, that's it for witnesses for this morning. We will be back at 02:00 to hear more on we'll hear the the testimony we didn't get to yesterday on 03/25.