SmartTranscript of House General - 2025-02-06 - 10:45AM

[Chair Marc Mihaly ]: Thank you. Welcome, everyone, to the House Committee on General and Housing. Today is Thursday, February sixth. It's ten forty six or forty seven. That clock is fast. And we're going to start this morning with testimony on the governor's housing proposal from Josh Hanford, director of intergovernmental affairs at, at the Vermont League of Cities and Towns, and Samantha Cheat, also from the Vermont League of Cities and Towns. Then at eleven thirty, we will have testimony on manufactured housing from VHTV. And then at one o'clock this afternoon, we will have a joint hearing with the House Committee on Commerce and Economic Development and this committee in room eleven [Speaker 1 ]: on tax increment finance. [Chair Marc Mihaly ]: So that's that's and then we have a break under the floor. So that's the day. I think it's fair to say, Josh and Samantha, that you know the committee. So I I'm I'm sorry we have a few people out ill, and we have one is Leonora. She's not joined yet. She's not joined yet. We may have one member online. But so you wanna introduce yourselves for the record and comment for us what you're coming. Thank you. [Josh Hanford ]: Josh Hanford, from Vermont League of Cities and Towns. For the record, thanks for having us again. [Samantha Sheehan ]: Samantha Sheehan, also from New York, Vermont League of Cities and Towns. I'm the municipal policy specialist. [Josh Hanford ]: We plan to, share sort of a high level overview of our thoughts on the governor's housing proposal, VLCT's priorities again around housing, and then open to questions and discussion with you. I I think we shared some of this when we were here briefly before as a more general overview of VLCT. Housing continues to be a top priority for municipal powers across the state. It's the number one issue when we do surveys that communities want to address, both housing availability and affordability. Through our policy setting, process this past summer, we had a housing, policy committee. We met several times, and and sort of drilled down to some some pretty specific, priorities around housing. In the past, we've had a ton of priorities around act two fifty reform and and land use. A lot of that is underway right now with with some of the changes. And so our, policies and priorities around housing are are much more, specific this this time. And we start out with the fact that, a lot of what was passed around, building housing through this, landmark reform of act two fifty and municipal zoning directs new housing to where there's water and sewer. So we're going to meet our housing challenges in water and sewer. And not every community have water and sewer and even the communities that have water and sewer, just because there is might be capacity at the water treat water or the treatment plant doesn't mean there's capacity to connect down the line or that new development is. Infrastructure is expensive. Building new water and sewer is expensive. Extending is expensive. Maintaining is expensive. So our number one priority is to help, pay for that infrastructure that municipalities, need to borrow and bond for using performance based, contracts or other tax stabilization methods to support this infrastructure for the ultimate housing development. [Chair Marc Mihaly ]: Josh, we're gonna want you to go into more detail on that. [Josh Hanford ]: We'll stop there. We've got [Samantha Sheehan ]: a couple more slides on [Chair Marc Mihaly ]: that. Yeah. [Samantha Sheehan ]: One topic. [Josh Hanford ]: Other big topic that, sort of preview into some of what the governor's housing proposal, proposes. Permit appeals. This is stop projects, delayed projects, added costs. We also want to increase threshold, thresholds for permit appeals, specifically in projects located in the designated areas that communities have gone through extensive public processes to, support housing growth in those areas. They've already had the public input multiple times through multiple processes. We need to stop those appeals, from happening again. You wanna let's let's switch it up here. [Samantha Sheehan ]: Yeah. Yeah. I think when, Josh was here with you last, you discussed short term rentals. We know you had some municipal officials in recently to talk about short term rental regulation. But we also see this as in relationship to act one eighty one and before that act forty seven, which preempted, municipal zoning in many ways with the goal of increasing housing density and with, changes statewide and community statewide to encourage infill scale development. So ABUs, duplex and triplex conversions, and the like, cottage courts, backyard cottage courts. We our members would like the additional regulatory tools, including tax authority, to ensure that the new infill infill scale housing being created, does not lead to a further proliferation of short term rentals. And many of our members, see great opportunity in the emerging or recently had has emerged short term rental market for supporting their own local economy and in particular for tourism and recreation during all four seasons of beautiful Vermont weather like we have today. But they also are managing very real impacts at the local level on wastewater, on fire safety, public safety. So making sure that they're, you know, the right number of guests is staying in the right size, rental unit. And they need some help, developing the resources and the authorities at the local level to do that to just ensure safety and and fair impact on public infrastructure. And then lastly, certainly, it is a municipal interest to work with the state on supporting and preventing families living in homelessness and in particular unsheltered homelessness. The dramatic increase in unsheltered homelessness has had very real pressing urgent impacts on many municipalities in Vermont, and are looking for action from the legislature in those areas as well. So the next I like I like to give a little preview. So here is a very top level outline of the governor's big housing bill. And then we're gonna take a deep dive into a shared priority that is in the governor's proposal as well as a top priority for VLCT, which is a tax increment program for public infrastructure that supports housing development. So I know you heard from commissioner Farrell recently, so I'll just run through these bullet points really fast. But we see, sort of four categories of frankly agreement with the governor's proposal. The first being funding and a new program to support communities in building and expanding public infrastructure to allow housing. Second is funding directly to, programs and housing partners for the, purpose to build and revitalize existing properties including mobile home communities. Third is further reforms to, act two to, both permits at the local and state level and to act two fifty. And then lastly is streamlined permitting for municipal water and wastewater connection as well as modernized wetlands regulation. So remember that in order to realize a project, act two fifty is not the only state permitting regime that a project has to navigate. You know, I need feedback. Sure. K. [Josh Hanford ]: It's a reality that to save taxpayers and ratepayers money, we need to grow the grand list. That's where we raise more tax revenue that we can put to good projects we need. And if we're not building more, we're falling below. I think you've seen statistics about how over the past years, we've seen our housing, building not increase. In fact, the natural rate of losing homes to fire, conversion, disrepair actually means we are probably losing net homes across the state. So we need to grow. We need to grow in a responsible way in the right places, and that brings in more tax revenue. This is what I was alluding to earlier because you said so. We need this infrastructure. Because in act one eighty one, it binds the future housing density to municipal water and wastewater services statewide. So unless we're only gonna unless we've decided we're only gonna grow in the places that it have it already and it meets all the needs, then we need it. We need support to grow the infrastructure to build the housing because that's what we all agreed to. I mentioned this before. Often, there's capacity at the plant, but not on the line. And there's a lot of communities that their engineers are having to have very hard conversations with great housing development proposals to say, yeah. You have water and sewer. Yeah. We have water and sewer, but we can't connect you. We can't connect a thirty unit building there. It's gonna be five million dollars in pump upgrades and line upgrades. And so, I know the the the new law says that we need to now your size of building in this place, but who's paying for our infrastructure? [Speaker 4 ]: Maybe it's coming up or but I'm just wondering when I over the last year, when we were off session, met with a lot of developers and other people in different town cities and towns who talked about some of the ways they would like to address things that fell short now that they've seen the bill kind of unfold. Do you take list of some of those things where we could kind of continue that work to make things better now that we've seen how things have panned out? Or do you think it needs more time to [Josh Hanford ]: Are you thinking, like, technical corrections to some of the density requirements? [Speaker 4 ]: It's like we had one community that, like, you know, they had water and sewer across the street, but not, you know, in shell the Shelburne situation. Like, things like that. Are you paying attention to some of those things from different from your members? [Samantha Sheehan ]: I mean, we certainly hear from our our members are municipal officials, but in many cases, we have the opportunity to talk to builders. A lot of what we hear about Act twenty one implementation comes from zoning administrators Okay. Who are they're the ones who interface with the permit applicant. And, I think one thing that is important for you to hear is that municipalities are still in the process of implementing one eighty one. Those that have professional planning staff were able to quickly, come in line. Others, already were. Many, Fairly, Burlington, Munitsky, South Burlington, the list goes on, had already Waterbury had gone through ambitious upzoning ahead of act one eighty one and forty seven. But others are literally waiting for the RPC planner to come to their planning commission so that they can take a look at what is being asked to change and whether or not they want to go further or do more in terms of density bonuses, setbacks, etcetera. Oh, that is totally complete. But what we hear is, like, it's generally going well and in particular because of the exemptions that housing projects are able to move forward as this process goes forward with the LRB as well as at the local level because the exemptions are, very productive. [Chair Marc Mihaly ]: Clear. What Yeah. [Josh Hanford ]: That has given people certain No. [Speaker 4 ]: That's great. I just wanna make sure that we know where we can continue to build on those things if there were issues or other things. But [Samantha Sheehan ]: Yeah. Be helpful. Thank you. [Josh Hanford ]: We think that, you know, expanding the number of homes and businesses connected to municipal water and sewer in these areas that we want more density and more growth meets multiple goals. Environmental goals. Yeah. Municipal goals, saves people money from traveling far and wide, and and there's a lot of benefits here. Just we have to [Chair Marc Mihaly ]: find a way to pay for it. Right. Okay. Yeah. And I think it's safe to say we we've heard a lot of testimony Yep. About the governor's plan also from others, and these are pretty much shared goals. And we're down now to how exactly how. So we would like your thoughts on that. Yeah. What a board. [Samantha Sheehan ]: Yeah. Real quickly, wastewater and water are not the only public improvements that maybe need to be made by the municipality. Right. So you need to build a bus stop. Yeah. You need to build an intersection. [Chair Marc Mihaly ]: Yeah. [Samantha Sheehan ]: So now we get into the nitty gritty a little bit more. So back in the summer when the LCT was developing its own, our own legislative priorities, we were calling a program like this a performance based contract. It's important to know those exist in municipalities across the state, although they're very resource and labor intensive, and they're like a one off agreement between the municipality and the developer and sometimes other stakeholders in the community as well. But so we were seeking generally, the authority for all municipalities to enter into a performance based contract where the contractor agrees to build certain infrastructure at x cost. That happens to the broad public benefit. And then over time, the grandlets growth from that project, housing or multiuse project, could go to paying the debt incurred for the cost of the public infrastructure until that was paid off. There is the governor's proposal, which is much dissimilar and that it's modeled after after a tax increment, foundational tax increment approach where you, have a developer, private or nonprofit. You have a municipality. They plan a project together in a formal agreement. And then same thing, the money that gets added to the grand list later pays off the debt that goes into financing that infrastructure. Our friends in the Let's Build Home Coalition, which, VLCT is a part of, has proposed a very similar program that is built around the tax increment model that they're calling HIT. It used to be called HIP. It's very similar to Spark with a sort of more narrow eligibility and focus explicitly on housing and with a sort of tighter connection to the exemptions from act one eighty one. [Speaker 4 ]: We what what we want you to [Samantha Sheehan ]: hear is we generally support all of these proposals. We support the concept. We think it is a good and necessary step forward for the legislature to take in order to realize the promise of Act one eighty one. This list, which we'll go through now, are what are is our priorities and how we're assessing these various proposals and considering what we would support. And we hope that you would understand and apply these priorities as well from the municipal perspective. [Chair Marc Mihaly ]: Could you before you do that, I mean, we see them here. Yeah. And I guess we're at the point where they're pretty clear. Sure. Tell us just a little more. It's interesting. The performance based contract concept, was that your sort of original concept? In other words, before before the spark and the home for everyone came out, you were kind of thinking on a contract basis? [Samantha Sheehan ]: Yeah. And I I can't say it's VLCT's original concept, but these happen. [Chair Marc Mihaly ]: Yeah. Yeah. [Samantha Sheehan ]: Yeah. Like, there's examples of these projects being developed. [Chair Marc Mihaly ]: Like a development agreement Correct. Essentially. And Yep. Is this not generally authorized under state law? [Josh Hanford ]: Not not not to the extent that you can use any tax increment. [Samantha Sheehan ]: Yeah. [Josh Hanford ]: Then it is beyond the municipal control. And the municipal twenty to thirty percent isn't enough usually to finance the need. But some, performance based contracts for specific projects, municipalities have have been able to work out. It's because the deal, structure allows something other than that. One that I'm aware of, you know, they would extend some water and sewer. It wasn't massively expensive, but it was a couple million dollars. And the developer agreed in a contract to assign half of the lots to the municipality if they weren't able to produce that. So the municipality could recover their investment by selling those lots in case the whole deal crashed. That just how that deal worked. And so a municipality can do things like that, but they can't obligate They can't obligate the taxes that often are the level of, of revenue to pay back the significant debt needed. [Speaker 4 ]: Right. Outside of it. So Yeah. [Chair Marc Mihaly ]: But right now, are is any town prohibited from entering into such a contract? I know they don't have the tack they don't have the tax increment authority, but if they wanna do other elements of the deal, they can. It's just they don't. [Josh Hanford ]: Like, overland and and agreements like that, they typically can. Merchants don't. [Chair Marc Mihaly ]: Yeah. It's worth it. Yeah. Yeah. I know. [Samantha Sheehan ]: It's there have been really creative. So, for example, Cambrian Rise at at your legislative briefing that's ended the h a FBA's presentation for Joseph Cambrian Rise, which is currently the largest housing development in the state in Burlington. There's an element of that development agreement which, will build a a better a better intersection on North Ave, which is necessary because of the density being built. The contractor is obligated to a certain amount of work and cost, But that's sort of like a that's great. That's great for the city of Burlington. That's great for the developers and the future residents of Cambrian Rise. But that's sort of like a creative, problem solving deal negotiation that may or not be able to be replicated by other municipalities looking to accomplish the same goal. What we're looking for is a more well defined accessible program that municipalities of all size supporting all types of housing development could utilize to meet their local goals. [Chair Marc Mihaly ]: One of the concerns that we've heard is that TIFs, whatever you call it, how do you do it, But they're quite intense. They're labor intensive. They're administratively difficult. A lot of projects in true through rural Vermont are, like, you know, two fourplexes or eight units is a big project, and the increment for eight units is tiny. So how do you feel do you think a TIF based solution works for small projects in small towns? [Samantha Sheehan ]: Yes. With these critical components. So one there's two I'll shout out from this list. One is that the tax increment formula for state and local property tax supports both development and redevelopment. So to be more specific about that, the governor proposes a tax increment formula based off the prior taxable value. That would likely pencil out for the redevelopment of raw land or underdeveloped land such as a parking lot. That is less likely to work out for the redevelopment of a historic building, a former college campus, a former multi use, you know, like, a mall. So if the floor [Chair Marc Mihaly ]: is higher, in other words, the increment will be less? [Samantha Sheehan ]: So increment will be less and the likelihood that it would support the scale of infrastructure needed to redevelop is less likely. The Let's Build Homes Coalition proposes an eighty twenty. So eighty percent of the new, tax revenue goes to the debt. Twenty percent goes respectively to municipal property tax and to state ed fund. There is probably a rainbow of formula in between those two that would work. But what's important to us is the value that would help redevelopment because that's Main Street development. That's Main Street, Vermont, small community, housing projects. I'm [Chair Marc Mihaly ]: I'm confused. I I understand the problem. [Gus Seelig ]: Yeah. Just for members of the committee, well, I think [Chair Marc Mihaly ]: the problem am I right that you're alluding to is tax increment financing takes the difference between the value of the project, the value of what's there now, which may be a parking lot or a field, which isn't generating any reasonable amount of property taxes because it has no value, and then projects what's the value gonna be when it's built, when the thing that you wanna do is built. And that is the increment. And that increment can either be used on a pay as you go basis or frequently. It's the basis that projected income of increased property taxes is the basis for issuing bonds. What I am I correct that I'm understanding your testimony of the problem when you have a use that's there now that is not an empty parking lot with grass growing out of it, but it's buildings and things that are there that you're trying to improve. It's the start within it. You start with a higher value. Correct. So that the difference isn't that great. What I don't understand what the solution to that is. So another sorry. Go ahead. [Josh Hanford ]: I mean, one solution is incentives. We do it all the time [Chair Marc Mihaly ]: Yeah. [Josh Hanford ]: With deals that don't work. Tax credits, grants. [Chair Marc Mihaly ]: Credit. Okay. Non non Yeah. But not It TIF. [Josh Hanford ]: Mix that pencil out. That's one solution that keeps a structure of a TIF that could be used a project based TIF concept, used uniformly across the state and those properties with a value that's already high enough that the increment is enough to pay the debt, you have to incentivize. We have lots of programs. You can have a deal with the housing developer. They maybe bring some money in through the municipality. So that's one solution. [Samantha Sheehan ]: Revolving loans. But another but an important consideration here is that in in the current TIF program, there is a, but for approach. So the developer and the municipality has to prove to the state that without the tax increment, the economic development would never happen. In order for small rural communities to use a program like this to a scale that's appropriate for them, for the simple public good of having housing built in their town, they need to not have that test. Like, we have to agree and it has to be in the statute that it is good enough that this is a build housing that people can then live in. Right? And if it if that's the case, if if the bar is not so high that you have to prove a certain amount of broad economic development, new jobs at certain wages, and so on and so forth as built into the TIF program, then this could be applied at a small a smaller scale. And it may not pencil out perfectly. But together, it would be possible for the municipality and the other common stakeholders and the developers Mhmm. To work together to get it done. [Gus Seelig ]: Okay. I understand that. Yeah. [Chair Marc Mihaly ]: But in terms of the size of the increment, the smaller size Yeah. Are you proposing that well, I just wanna understand. Are you proposing because you mentioned the home for everyone. Are you are you proposing that we change the percentages so that we take more of the EdPlan? [Samantha Sheehan ]: I don't know what you mean by more from that EdPlan. [Chair Marc Mihaly ]: Right now, in the under a standard TIF, we take seventy percent of the EdPlan. Right? Well or you could [Samantha Sheehan ]: say you contribute thirty percent to [Chair Marc Mihaly ]: the Yeah. Yeah. Yeah. You you leave thirty percent with the Ed Fund. I'm Yep. And you take seventy percent for the bonds or whatever. [Josh Hanford ]: Yep. [Chair Marc Mihaly ]: Is there a proposal to change that for you? [Samantha Sheehan ]: Let's build a home proposal that I understand is eighty LCT does not propose a specific formula and [Chair Marc Mihaly ]: That's what I wanted to know. You're not you're not backing a specific percentage. [Samantha Sheehan ]: No. But and we, in fact, are we are specific to the extent that we say we support a formula that does contribute some of the new brandless revenue to the ed fund. Got it. That's a key component for us to support. [Josh Hanford ]: And and to get to your other point that current TIF structure is rather complicated and and seems unachievable for smaller communities. The last bullet is we need to pair whatever we do if we really wanna serve municipalities across the state with technical support, municipalities to get this done, to have the financial understanding of the deal and to get through the processes. That can come in a lot of different forms, but it's gotta be part of of whatever this new solution is. [Chair Marc Mihaly ]: I'm sorry that I'm interrupting you. It's just that I We have fifteen minutes left, and I wanna make sure that we I wanna I want you to understand that we're at a certain level now, and we're get beginning to get into the nitty gritty. Yeah. Absolutely. I think the same would apply to you were talking about tax stabilization, other tax Mhmm. Incentives we'd like to hear. Yeah. [Josh Hanford ]: You know, so we don't have, exact proposals on the table, but there has been ones in the past, from from developers and some communities that would show a deal penciling out if they literally just had ten years of tax stabilization of all taxes, state and, municipal. They could leverage that ten years of tax freeze, turn it into the investment needed to build the project. I think we need to be more creative. And one thing I think I mentioned to you, chair, yesterday when we were passing in the cap That's [Chair Marc Mihaly ]: what I didn't really understand. [Josh Hanford ]: Yeah. Is that there is a lot of financial authorizations to modernize municipal finance that need to happen. We have proposals and bills in talking with various committees to authorize municipalities to sort of operate in the current best practice for government financing world. And we don't. We don't have level debt bonding authority. We don't have the authority to put in reserve accounts, unrestricted reserve accounts to save up for a rainy day. We don't have authority to do emergency borrowing for more than one year. These are all modern best government financing practices that the municipalities haven't been authorized by the legislature. We're a Dillon's rule state. We can't just do that. And I think Michael Gaughan from the bond bank, our finance operations, that assistance college would happily talk to any committee why these are best practices, and we need to modernize to get at these creative solutions. [Chair Marc Mihaly ]: Is the tax stabilization concept you wanna talk at this for a minute about that? What's that involved? [Samantha Sheehan ]: So that would the the purpose of tax stabilization would be to control the financial risk being taken by the developer so that when they're putting together their financing deal, increasing the whole post twenty twenty to do, that they would understand what their property tax bill state and municipal, both sides, will be for a period of time. [Chair Marc Mihaly ]: So in a way, it's kind of the flip of a tip. Right? Mhmm. Instead of taking the tax differential [Speaker 4 ]: Mhmm. [Chair Marc Mihaly ]: And bonding it, you're saying there ain't gonna be a differential. We're gonna hold your taxes either flat or down for a period of time. Mhmm. How does the developer capitalize that? [Samantha Sheehan ]: Because they know what their ongoing cost will be once the they give keys to people that move in, and so they know what their ability to [Chair Marc Mihaly ]: pay in their own construction. Yep. When they when they do their pro form a, which is their spreadsheet, one of the lines of the pro form a is gonna be less. One of the lines is tax expense, and it's just less. [Josh Hanford ]: Mhmm. And they're able to, you know, obviously, borrow more. They're able to leverage that to more. Okay. Yeah. And, you know, there's a developer in Southern Vermont that really put forward a a comprehensive proposal on this. I could dig that up. It didn't get any traction, last few years, but, you know, had a couple projects modeled out that this ten percent increase, but it has to be all taxes. A municipal isn't enough. Yeah. [Gus Seelig ]: That would have to be the whole thing. Yeah. [Josh Hanford ]: And in this same sort of concept, when municipalities are asked to abate projects because the house was damaged for a flood, it was a fire. Once again, the municipal portion of the taxes isn't really enough to benefit the homeowner. And we don't have the authorization to give away the state education tax that the municipal has to pay regardless. So these concepts have to work work together. [Samantha Sheehan ]: I I just wanna say recent report Yeah. I [Chair Marc Mihaly ]: understand. As the committee understand, we're essentially that is sort of the inverse of a TIF. [Josh Hanford ]: Inverse of a TIF. Yeah. [Chair Marc Mihaly ]: It's just saying, you know, there's not gonna be taxed. [Josh Hanford ]: An increase tax [Samantha Sheehan ]: at all. Increase. But not an increase. But that does not help the municipality pay for the infrastructure to [Chair Marc Mihaly ]: make the have to be state. Yeah. [Speaker 4 ]: Yeah. But it would only really work if it's longer than five years. [Samantha Sheehan ]: The the length of the financing required to build the project. Yeah. Yeah. So for, like, a duplex conversion, I don't know. Yeah. I'd ask a contractor. Maybe that's five years. But to pay off what it costs [Chair Marc Mihaly ]: ten year to yeah. [Josh Hanford ]: Is sort of a minimum buyer per [Samantha Sheehan ]: so many. Yeah. So for, yeah, like, a twenty unit half hotel development on Main Street, I'm sure that that would be much more complex. Yeah. [Chair Marc Mihaly ]: Can I ask you another question about permanent skills? Mhmm. [Samantha Sheehan ]: Yeah. We have a whole little video on fields here. [Chair Marc Mihaly ]: One of the [Gus Seelig ]: okay. [Chair Marc Mihaly ]: Ninety days is an appropriate timeline to reserve it resolve appeals. You you mean in whatever body the appeal has occurred? Correct. Right? Ninety days. Okay. [Samantha Sheehan ]: For municipal and Right. The court and yeah. Mhmm. The period. [Chair Marc Mihaly ]: I guess I'm gonna repeat a question which, Josh, I asked you in the hall. One of the governor's proposals, which is, well, personally to me, I think quite interesting is a it's it's more a kind of standard of review, and it kind of elevates the proof standard that a that an appellant you know, someone who appeals a permit would have to meet. And it says that essentially, the permit appellant the the one who appeals the permit would have to demonstrate that the permit is inconsistent with the applicable planning and zoning. And I'm wondering how you feel about that and whether you think it's realistic given that it would have meaning given the variety of planning and zoning that's out there. [Speaker 4 ]: I [Samantha Sheehan ]: I think we need more information. And and, in fact, maybe my impulse because I think the language is even different. I don't know if someone has a pull up. It's, like, substantially Yes. Yeah. Incons substantially inconsistent. Substantially inconsistent. That's a great question for an attorney who has maybe defended appeals, whether that would have an adequate effect on limiting the frequency and duration of future appeals for housing projects. I'm not a lawyer. I just occasionally play one on Zoom. [Josh Hanford ]: You know? And and I couldn't answer any more words than that too last night. I think that it's interesting, but there could be a lot of loopholes to find ways that that is not the case and then we don't solve the problem. You know, VLCT has long supported the elimination of when it was ten, now it's twenty that that eliminate all folks that that don't have an immediate abutting property or interest. Once you've gone through, as we've said, multiple public process, democratic processes to make the decision in town plans, regional plans, ordinances, zoning changes, permit approvals. There's numerous opportunities for the publics to weigh in and be heard. We get to the point where it's being built. You have another chance. It just it it seems like it's it's it's overkill at that point from our perspective. [Chair Marc Mihaly ]: Are you would you be would VLCT support? What you're talking about is standing. You're talking about broadening the concept of traditional standing, of saying you have to have a case in contra you have to have a conflict that affects you. You know, we can't have advisory opinions. You're talking about that instead of the current broad ability for anyone in the town to challenge a permit if there's an up. [Speaker 4 ]: Yeah. We're talking about [Samantha Sheehan ]: Are you narrowing standing. [Chair Marc Mihaly ]: Standing. [Samantha Sheehan ]: Yeah. Controlling [Chair Marc Mihaly ]: Yeah. [Samantha Sheehan ]: The number of people who would have standing to make an appeal. So that it is not just any twenty people who might drive by it or see it out their window, but just the abutting property owners who may have an impact. Like, a legitimate impact that could be resolved through an appeals process. Like, they're claiming stormwater impacts on their driveway. That's a good reason to appeal a project. [Chair Marc Mihaly ]: So you're, in a way, taking a somewhat different approach from the governor in that you're not saying it doesn't matter whether there's two hundred of them or three hundred of them. That the people who or one. It has to be somebody who has a case in controversy that is concrete as to their property. I'm just trying to get the [Josh Hanford ]: Yeah. [Chair Marc Mihaly ]: Get where you're at. Okay. [Samantha Sheehan ]: Yeah. And we think that, you know, there have been discussions and ideas that I'm aware representative Stevens is coming to talk to you about a bill, about a housing board of appeals. We're sort of less focused on what happens after the appeal is made and how it moves around and to whom. There are merits to various proposals. We're more focused on trusting the broad, robust public process that goes into setting a community's vision for what can be built, where, and why, and limiting the number of appeals at all. [Chair Marc Mihaly ]: This would only have be able to apply prospectively, I think, legally. But what would be l does VLCT currently have a position on the concept of saying that anyone who appeals a project going forward has to have exhausted their administrative remedies at the plan level? [Samantha Sheehan ]: I position, but I mean, I think know. That generally happens in the municipalities that are resourced to make administrative changes to their own municipal permits. That's just not the case in most towns, that they don't have that robust administrative, like, code enforcement permitting department to administer in a timely and effective way changes that may come up from either the permit holder or the appellant. So I think [Chair Marc Mihaly ]: What I'm thinking is is that in the tier one and in the tier one areas, so tier two, as you said, Josh, in your openings, towns are gonna have to go through a whole they're gonna have to do some work in the future. Right? And they haven't done it yet. They're gonna have to make demonstrations. They're gonna have to apply. Right? What if we said, if anyone wants to challenge a project, they have to have exhausted their administrative remedies in that planning process. [Samantha Sheehan ]: So, like, if they never went to the GRB and complained before the permit was issued, [Chair Marc Mihaly ]: then they would Well, that, yes. Okay. That's part of standing, usually. You have to have exhausted your administrative remedies for the project. That's part of standing. I mean, that wouldn't be a huge departure to say that if someone if you if we were following your approach of saying we want to say that you have to have been damaged. It's very typical to say, and you have to have exhausted your remedies of the you have to have protested. You have to have appeared. You can't just come out of the blue after the decision has been made. You have to participate. What I'm asking is, have you ever considered the possibility that we add that you have to have participated in the determination on the planning determination. If you didn't appear on the zoning and you didn't appear on the planning Yeah. And then you don't have standard to protest projects under it. [Samantha Sheehan ]: I don't think we can answer that. [Josh Hanford ]: Yeah. We we have to capitalize on [Chair Marc Mihaly ]: our plan. [Josh Hanford ]: Attorney. Use. [Chair Marc Mihaly ]: Yeah. What? I'm sorry. Yeah. [Samantha Sheehan ]: I'm just sort of thinking Yeah. I'm [Chair Marc Mihaly ]: thinking to probe the limits of where you guys are. [Samantha Sheehan ]: Yeah. Just where I'm going with that, it's like, then is there a liability in the municipality if they didn't like, does that push the requirement on the municipality side to prevent more process in order to create a zoning or ordinance change? [Chair Marc Mihaly ]: Right. Yeah. [Samantha Sheehan ]: And if so, I think we could yeah. That That could be correct. Doesn't help us do the thing we're trying to do, which is build housing quickly. Yeah. [Josh Hanford ]: Let's should we skip to the the programs that were funded and how we feel about these? [Chair Marc Mihaly ]: Yeah. Well, and it it you you know, let's take another five extra minutes since I've been obstreperous and asked you so many questions. Go ahead. [Josh Hanford ]: Yeah. I I think it's fair to say that we're in support of these these programs in the governor's budget that build housing, that rehabilitate housing, support mobile home communities, offer new tax credits, brownfields. If we're gonna build in these places, we need to clean them up. That's a win win win from lots of folks' perspectives. So there is, broad support from our our members for these programs and what they do and and feel, that they're impactful. You know? That in setting some of these as permanent programs means that we can count on them going forward, and we can point municipalities to these programs and have some confidence that they're gonna be there. And you you know, don't rush and, you know, worry that this is gonna expire. I think that BeHIP is, you know, someone that's been around since the very beginning of that. It's been hard to realize its full potential with having one ops every year and having to redesign it every year and not have, some sort of permanency there. The manufacturer home repair program, I mean, we're keeping people housed for hundreds of dollars sometimes when they could be out, at homeless and meeting the fire. It's just something we should have had around for a long time. And so all of these programs, I know I I feel very, lucky to be part of some of the development of them and seeing where they are now. And so we fully support these programs. [Chair Marc Mihaly ]: Do you remember the [Josh Hanford ]: But the note see the note on the bottom, though? We need the infrastructure to fully realize what we're engaging on here. We we know you know that, and that's the struggle of how to right size that, pay for it, and and reach consensus. [Chair Marc Mihaly ]: I did hear you say you know, in the in the last time you appeared before us, when you were commenting on short term rentals, you said, don't mess with it on the state level. Let let communities decide what they wanna do. But I do hear an exception, which the when you were talking about that new housing should not be con short term rentals, That would take legislation. Right? [Josh Hanford ]: I think what we're saying is we're fearful of all this new housing density, support. If if there aren't the right incentives and ability that majority of it turns out to be short term rentals. And then maybe some communities there's a need for short term rentals, others there isn't. And municipalities have some tools to regulate short term rentals. We can add a registry. We can add an inspection. We can, you know, have some enforcement, but what we can't do in a way that the state has is actually tax them to mitigate the impacts and help support more affordable housing, help, down payment assistance. We can't mitigate the impacts by collecting revenue from them other than the one percent, which we share with the state seventy thirty right now. So it's really, you know, point seven percent of, of the impact of a short term rental on our community that we can reinvest to mitigate the challenges. So you're proposing [Chair Marc Mihaly ]: authority to tax like Burlington did, but they did through their charter? [Josh Hanford ]: Exactly. Yeah. [Samantha Sheehan ]: They have a nine percent. [Chair Marc Mihaly ]: Yeah. [Samantha Sheehan ]: And that nine percent, Burlington chooses to put to the housing plus one. It's not Yeah. Raising almost a million a year. Other municipalities just want money so they can have inspectors go in and check fire code to make sure that the short term rentals before they become available to rent are fire safe [Josh Hanford ]: Yeah. [Samantha Sheehan ]: Buildings. Yeah. [Josh Hanford ]: I mean, I think you're aware, you know, the three percent surcharge that was enacted last year on short term rentals only. Mhmm. But that funding is going to the Ed Fund. The communities that are hosting short term rentals and some maybe more than they would like, others, they support more. They're not able to benefit from those short term rentals in a way that they can invest back into their community and mitigate the impacts without some sort of authorization. And communities that choose to offer a one percent rooms and meals tax, they also are, impacting their major major employer. If there's a resort community, in an unfair way, when they see these other impacts, you could it's even a transportation impact. People are driving on roads more, larger trucks, SUVs, and they can't recoup the, recoup any of those that revenue to put back into their community with the way with the authorization that exists now. [Gus Seelig ]: Have [Chair Marc Mihaly ]: you developed language on this? [Josh Hanford ]: We we we could easily. It's it's it's, you know, change the one percent option tax on rooms to allow a certain [Chair Marc Mihaly ]: I would I think we would appreciate Yeah. If you have a specific proposal, we'd like to know it. [Josh Hanford ]: Okay. [Chair Marc Mihaly ]: You have a question? Cool. [Speaker 4 ]: Alright. So feedback slides gonna be available? Yes. [Chair Marc Mihaly ]: These are on our website. Yeah. [Speaker 4 ]: Those are not listed. [Chair Marc Mihaly ]: Oh, they're not on our website? [Josh Hanford ]: We'll we'll send them. I'll send them right right here. [Samantha Sheehan ]: Sorry. We hopped them. We're just making sure we didn't mess anything. [Josh Hanford ]: Oh, that [Samantha Sheehan ]: was a help. That's a help. [Speaker 4 ]: Yeah. Very much so. [Chair Marc Mihaly ]: Alright. And thank you so much. And I'm sorry to that we're time limited. And we may be in touch. But we There's more [Josh Hanford ]: more a conversation around housing and and how we're gonna pay for this infrastructure as a support one [Chair Marc Mihaly ]: of it. [Josh Hanford ]: So thank you for your time. [Chair Marc Mihaly ]: Thank you. Again. [Gus Seelig ]: Thank [Chair Marc Mihaly ]: you. So we'll stay live here. Can I just Yes? I'd [Speaker 4 ]: love to move on. [Samantha Sheehan ]: Just because I can't see. [Chair Marc Mihaly ]: Yeah. I moved in. [Samantha Sheehan ]: So put [Speaker 4 ]: them on top of [Samantha Sheehan ]: any trip. Oh, or They [Speaker 4 ]: Sorry. I'm just like Yeah. Witnesses. [Chair Marc Mihaly ]: Now can you see it? Alright. [Samantha Sheehan ]: Thanks. Sorry. What? [Chair Marc Mihaly ]: Same pissed. I was just, like Thanks a lot. Thank you for having I don't know if you'll question. Next witness is, from the housing of Vermont Housing Conservation Board. And, Gus, you wanna come and grace us with your presence here. And is it although Polly is on our agenda, I see that it seems to be huge. [Gus Seelig ]: It is nice. Day care is closed. K. For her. [Chair Marc Mihaly ]: That's important. It's perhaps more important. I wanna tell us your name, and I know you know our committee. And, Keith, Gus is addressing manufactured housing issue. [Gus Seelig ]: So for the record, Gus Seelig, Vermont Housing and Conservation Board, I have not had a chance to read the report that you received and heard about the other day. We have not been involved in that process up to now, though. We're very happy to be and excited about the work that's been done. But I did I'm happy to also share our experience on this subject, which goes to both working on modular housing over a long period of time, really intensively dating back to Irene. Now our partners are using panelized construction on a regular basis today. Our experience we did it we did actually have an inquiry. I think I described to you our rural economic development initiative that does grant writing for smaller communities. We had an inquiry from Fairhaven about whether the plant there could be the subject, and we said, sure. As long as there's an entrepreneur who wants to take it on. So we are ready to look at getting that plant back in operation. I will, though, tell you what our experiences and Before you go on, I I just wanna make sure there was a term here. I know people on the committee have heard the term panelized construction at least once [Chair Marc Mihaly ]: Mhmm. Yesterday. But perhaps it might be valuable. At some point, you tell us what that involves and how it relates to your projects and where these panels come from. [Gus Seelig ]: They're coming from a variety of plants. And panelized construction means you're getting panels and walls essentially delivered on-site rather than having to construct them on-site. So it's one more way to speed the manufacturing of a home up. It is essentially doing what you're doing when you build a house indoors, but not the whole house. And it's being used very more than I was aware of in terms of multifamily housing development. So I think those panels are coming from Pennsylvania. They're coming from Quebec, wherever people can source them. And I think the fundamental you know, we were in here at the beginning of the week to talk about cost. And while the costs, as I have said, scare all of us, it's in any developer's interest to lower their costs as much as possible. And so when I asked our construction guy that we described the value engineering project on Monday and all the different things that go into, you know, are you gonna have pavement? Are you gonna have something else? Is the siding gonna be vital or something stronger? Are you gonna have, soundproofing or not? Same thing with panelized construction. And I was surprised to learn that on the projects since twenty twenty, thirty two of them involving almost over nine hundred apartments have used panelized construction. And I asked our construction guys, so is that what percentage is that? He said it's well over eighty percent. It may be over ninety percent for new construction projects. Generally, the estimate is saving about five to seven dollars a square foot. So people are thinking about those issues. But what it says to me in terms of, using the plant in Fairhaven for panelized construction is you'd have to have a company that could produce at the same rate as the big companies that are competing with them or or why do it. So it's a there's a market issue of can this thing work for penalized construction? The story I'll tell you in terms of our experience with modular housing and mobile home like buildings goes back to tropical storm Irene, and a philanthropist philanthropic entity approached us and said, lots of mobile homes were destroyed. We don't wanna see people replace them with cheap inefficient housing. Can we come up with something better? So we and the Ron Energy Investment Corporation sat down together, and they identified a fellow in Hartford, Vermont, who wanted to, open a facility. And he opened a facility called Vermont, and we and the No. Vermont. Vermont. And we and the, foundation helped subsidize the first homes that came out of that factory. I think I showed you a slide from Waltham, Vermont where the whole mobile home park fourteen units was replaced with Vermont. So it was a derelict park. Most of the homes had been abandoned. We used that same product in, to do some infill in hardwood Vermont on six or seven homes. Maybe it would and when the experts originally said, let's do this, then we said, how much is it gonna cost? At that time, you can buy a mobile home for about sixty thousand dollars, a new one. That was Energy Star, and they wanted to get something that would be net zero. The first homes that came out of the factory were supposed to come out at eighty. They came out at ninety. And the costs went up over time. We probably did work with them on thirty homes over their early years. When the prices got into the two hundreds thousand dollar range for net zero home and this is not a mobile home. It's a modular home like Huntington Homes builds. It was but in the shape of a of a mobile home, and they had other products. But that's what [Chair Marc Mihaly ]: we were [Gus Seelig ]: acquiring. No. The fellow who owns this factory had not in his DNA to scale up. That was not his goal in life. They were producing about a house a week. So as the price went up, we found a company in Maine called PBS who we worked with, and they were able to produce the same product. They're producing probably closer to a house a day. There, we bought a number of homes from them that also went to a number of mobile home parks around the state at a cost about thirty thousand dollars less. A decade ago, Clayton Homes, which is owned by mister Buffet, whom some of you have heard of, really national leader, not very interested in zero energy homes. And they're they are the big dogs in this business. But over recent years, they have and the energy standards for an energy store home are quite a bit less than what would get you to zero energy being able to electrify the building. In recent years, though, that's changed. Their perspective has changed, and they are now there is now what's called a zero energy ready product. We helped do seven units of infill at the Willows Mobile Home Park in Bennington with that product. There's, I think, nineteen more scheduled to go to Tri Park, and they're at a production rate well above they're coming out of a factory in New York well above one a day. So I think one of the lessons that I've Their cost is Their cost all in with solar, about a hundred and fifty. So I'm told the difference, at least by according to VEIC, for the box, bet between them and an Energy Star home is about fifteen thousand dollars. Obviously, you add solar and other things that may have more expense than that. So, you know, we we've used that product, but I think the lesson from it is, for me, is that if you're not willing to really scale up, that's where the efficiencies come from in a manufacturing process. And I would just say whether you're looking at modular housing or mobile homes, you've gotta be able to scale to a high level to really get to some core the kinds of efficiencies that will save money. So that's a bit about our question here. [Speaker 1 ]: Are the materials used between a modular and a mobile home much different? [Gus Seelig ]: Mobile home means it's coming on a chassis. Modular home is a is much closer to, you know, a stick built home in terms of its quality and ruggedness. We think that these zero energy ready mobile homes are good products. How long they'll last? I can't tell you. What I can tell you is that, you know, homes built to a whole different lesser standard are still out there that are forty years old and older. So I but I'm not the construction expert looking at the different materials. I'd say a modular home is always gonna be a more a better built home, but it's also gonna be pricier than than a than a mobile home will be. And the delivery is different. They come on cranes. They've gotta be set down with a crane as opposed to being on a chassis and being able to slide off. [Speaker 1 ]: Right. [Chair Marc Mihaly ]: Yeah. [Gus Seelig ]: So that's a bit about our experience with that work. I'm really glad that we're using so much panelized construction today, and I'm glad to be able to report that, you know, that our developers are using it as a cost saving device much more than I was acutely aware of. So it's it's become part of the standard of work. I don't know that I have a whole lot more, to add other than, we'll work with anybody to reduce cost in any way we can. We are funding some of the homes that some of you heard about that Huntington Homes is gonna deliver to the new neighborhood in Middlebury. And we have a number of other partners, including Down Street in your part of the state, mister chairman, who have two or three sites, including one in Berry as part of their flood recovery that they're hoping to put some of those some thousand square foot homes from Huntington Homes in. [Speaker 1 ]: Yeah. Does the modular home, the Vermont home, is septic or sewer? [Gus Seelig ]: Any of these homes can be set up for either septic or sewer. And so one of the issues in a mobile home park is do they have access to public water and sewer, or is it on the ground? Vermont made a and they have I I just got told yesterday they've now stopped production. But they sold to lots of people who had their own land and just wanted a home. And my guess is if it was in a rural area, it was an on-site septic system they were using. And if [Chair Marc Mihaly ]: it was in a more urban place where they can connect to public sewer system, they did that. You you said that you were involved in this we heard yesterday about an infill, I guess, mobile home, series of homes that were purchased. Mhmm. Were they built from in hunting by Huntington Homes? [Gus Seelig ]: I believe they have been ordered through Vic Fecto who was a mobile home dealer, not Huntington Homes. So I think those are mobile homes that we did have a lot of discussion with the administration last summer about that project. We were ready to go on it. They wanted us to use the funding that was gonna come to us from ARPA if it was available, then they identified another funding source and decided to work with the state housing authority on that. So we have not been involved in the ordering of those thirty homes, but those are mobile homes that have come in. I don't think they may have ordered a few that were net zero. I think they've just been ordering what the Energy Star homes in general from my what I understand. [Chair Marc Mihaly ]: You one of the one of the things that we heard yesterday, there were various proposals in connection with Manufacturers Now. But one of the proposals on the report, which isn't ready to operationalize yet. But, nonetheless, one of the proposals was that that what we needed was a bulk order of, let's say, I think, one hundred to two hundred homes. Mhmm. And that in order to make that work, there would have to be a certain amount of, public process and market rate studies to ensure that the one or what would have to be just one or two designs to get that scale where there was a market for them. And then that a nonprofit or a for profit builder would buy pledge to buy those units, and the state role would be some sort of guarantor to facilitate it. Do you have any comments on that thought? It isn't ready because I understand we heard that it needs to be studied more and awkward. But do you have any thoughts preliminary thoughts on that? Well, [Gus Seelig ]: if you ever watch HGTV, and I know you don't, mister chairman, and you watch any of the house flipping shows and real estate shows, people get really fussy about what it is they want in their home, You know? What kind of floor plan, all of that. So I think the idea that there needs to be a market study, you know, we don't have the population in Vermont that surrounded the building of Levittown, which was probably a very similar, you know, two bedroom, one bath. Put them up fast. Eight hundred square feet is what happened in the nineteen fifties to build places like that without lots of choices. And so whether there's a big enough market all over the state to for a hundred homes of only one type with little variation is a good thing for somebody to look at of will the market absorb it, what level of risk if we're gonna provide guarantees. I think the other question is, you know, if what Huntington Homes or a similar company can do is to deliver a home that's gonna cost five or six hundred thousand dollars, and it's between fifteen hundred and two thousand square feet. How much of a market do you have for that, and how much is the public willing to write down the cost of that home? Because the average home that got sold in Vermont last year went for three fifteen. So if, like, you know, if you're trying to get people who make sixty or eighty thousand dollars into homeownership or even a hundred thousand dollars into homeownership, the gap may be significant. I think we calculated it should you know, for the that six hundred fifteen thousand dollar average new construction home built in Vermont in twenty twenty three, you'd need hundred twenty thousand dollar down payment, twenty percent down, and you'd need an income of something like a hundred and eighty four thousand dollars to buy it at today's interest rates. Interest rates tend to be the most powerful thing as we all have learned with a doubling of interest rates in terms of who who's in the homeownership market and who isn't. And, really, the the aim of the doubling of interest rates has pushed lots of renters from thinking they could buy to thinking they couldn't. [Chair Marc Mihaly ]: So what as I remember, the testimony that we received in the last few days indicated that the cost of the new unit is north of five hundred thousand dollars no matter whether it's a market based unit or whether it's and what you seem to be saying is if, market if these new if if these off-site built houses are the same price, they pose exactly the same issues that we face having to do with, well, who can buy them and what's the subsidy and where do we get it? [Gus Seelig ]: Yeah. I think there's there's two different market market research issues that you've identified here. And one is if you buy a hundred homes in bulk of just one or two types, will there be market acceptance of them? And then the second market issue is for those homes you're buying, who can afford them at the price point they're available? The the homes that were ordered for the project in Middlebury, you know, are in that same stratosphere. I and I think Huntington Homes is a terrific company, and [Chair Marc Mihaly ]: they do good marketing. They got [Gus Seelig ]: a really nice product. There's probably more variation in the floor plans for the forty five homes that have been off ordered so far for that project. [Chair Marc Mihaly ]: Do you know what those numbers cost? [Gus Seelig ]: Well, there's we and VHFA have both agreed to subsidize some percentage of them. So with the subsidies at the lowest point, you get into the mid two hundreds and some in the three hundreds. But for the market rate units, I think they're in the mid five hundreds to six hundred. I don't I don't have those numbers in front of me, but I can get them for you. [Chair Marc Mihaly ]: Any further Please. [Speaker 1 ]: For the modular home versus the the Chatzi mobile home, is the interest rate from a bank better for the modular? [Gus Seelig ]: So here's what I can tell you. You're asking a really important question here. It's really it it's probably always gonna be better for the modular home on its own land. There are companies that provide financing specifically for mobile homes. And sometimes if you get the wrong company, you're gonna pay a credit card rate. However, Vermont's credit unions have been really supportive. And so when we were working with the administration on this, we identified a credit union that was willing to make fixed rate loan of seven percent but with a twenty year term. Now that's gonna that's a good rate, but twenty years is a lot less than thirty, so your payment is gonna be higher. And it's great that it's fixed rate rather than a floating rate. There there was a company out of Tennessee that had been recommended, and I went on their website and with twenty percent down, they were charging Fourteen percent and with a higher down, they were gonna charge eleven. So you you really have to be careful about the financing stuff. The other thing in a mobile home park is and VHFA has done this and others have done this. If you're willing to give somebody a thirty three year lease, we've been able to get USDA to finance those homes. We actually got us permission for a special pilot project back some years ago, and they have loans that go all the way down subsidized loan rate that goes all the way down to one percent. But you've got a most mobile home park owners do not wanna give a resident a thirty three year lease, and that's maybe one of the advantages of a nonprofit owned park or a cooperative is that they they can extend those land leases much longer than most private sector players will. And that will then open up some other financing possibilities, including VHFA financing. [Chair Marc Mihaly ]: Thank you. Do do committee members understand? I just wanna make sure that in a mobile home, you own the home, but you don't necessarily own the land. [Gus Seelig ]: Oh, in a park, you don't own the The mobile home park. That, I think and, Chad, [Chair Marc Mihaly ]: I don't know if you [Gus Seelig ]: know the numbers. I think close to half of state parks and the balance are on privately owned land. Any [Chair Marc Mihaly ]: further question of, Gus, I know, from the committee. Gus, is there anything else you wanted to say? [Gus Seelig ]: I think the only other thing I'd say is I think, it's a terrific idea to do infill in parks. I also think that we need to Double hover. Yeah. Because the parks are there. I think we do need to look at what's the quality of the park, what's the infrastructure level, is the owner taking good care of it. And and then the last thing, if we really make a big investment in a mobile home park, if we give somebody if we put ten or twenty homes in a park, under Vermont law, currently, residents if a park owner decides to sell, residents have a first option to to buy it. That has to be exercised pretty quickly. So if you add ten or twenty homes to a park, you fix the pads, fix the infrastructure, you're gonna have increased somebody's cash flow by forty, fifty thousand dollars at ten homes, twice that at at twenty. And so I think something to think about if we go big on this is do we want there to be a discount for the public investment rather than somebody decides two or three years after their park has been expanded that it's now gonna appraise a whole lot more because it's got more cash flow. And then the residents are gonna be faced with having to buy the public investment, if you will, if that makes sense. [Chair Marc Mihaly ]: So you're saying if it if if you have two parks, they're both privately owned. Let's say they're the same, just for discussion. Park number one doesn't get any public investment. And you're saying that when the residents want to buy the park and to make it cooperative, The price will be negotiated based on income that the park generates. And in case number two, if we invest public money in that park to make it have ten or twenty new houses, the income generated after that, which is an advantage to the owner, will be higher. And so if there's the residents wanna buy it, they'll have to pay me. So in return for us having invested public money, the park owner gets more money, but the residents have to pay me. [Gus Seelig ]: Right. I'm I'm saying that's what we and and I am not troubled by a home here, two homes there. I'm just saying if if you end up going big with a particular park owner, there ought to be some negotiation about if they sell in five or ten years what the sale price would be, At least if we're if we're making the infrastructure investments, which I think is [Chair Marc Mihaly ]: part of what we're what we're doing here. Like the shared equity arrangement? Yep. Well, limited equity. Yep. Is there authority to or who who would be the for whatever entity is putting the mobile homes in, is there an authority for them to negotiate better, or is the state legislation that's [Gus Seelig ]: Certainly, if we if we end up playing a role on the next round, we work on those issues, and I think we're authorized under our statute. If somebody else is taking the lead on it, maybe you need to think about what you ask of churn for making a more public investment. But [Chair Marc Mihaly ]: Any other questions for Gus? Thank you so much for your touch, Monique. Okay. Thank you. Alright. Welcome, Gus. So we briefly begin at one o'clock in the room.

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