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Breaking Down BEAD Funding Requirements with Nancy Werner - Episode 498 of the Community Broadband Bits Podcast
This week on the podcast, Christopher is joined by Nancy Werner, General Counsel of the National Association of Telecommunications Officers and Advisors (NATOA). During the conversation, the two talk about NATOA and its role in supporting community broadband projects, how the Broadband Equity, Access and Deployment (BEAD) Act is structured, and how exactly BEAD grant money can be used. They also get into the nitty gritty of funding MDU deployment projects with BEAD money, and what priorities need to be considered to access those funds. The show ends with a discussion about the promise and shortcomings of taking a simplified approach to setting right of way and franchise fees.
This show is 30 minutes long and can be played on this page or via Apple Podcasts or the tool of your choice using this feed.
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Thanks to Arne Huseby for the music. The song is Warm Duck Shuffle and is licensed under a Creative Commons Attribution (3.0) license.
Nancy Werner (00:07):
This is not a preemption issue. The bead language precludes states from making local governments ineligible and not just local governments, it co-ops, private companies. There's a whole list. You can't make any of them ineligible.
Christopher Mitchell (00:21):
Welcome to another episode of the Community Broadband Bits podcasts. I'm Christopher Mitchell, the Institute for Local Self-Reliance in St. Paul, Minnesota. And before we dig into this week's interview, I did wanna remind people that we have several other podcasts listeners of this show may be interested in the Connect This show. I did that wrong, I always do that wrong. Connect This! and that is on Thursdays regularly, but you can find connectthisshow.com. And we have other podcasts from the Institute for Local Self-Reliance, other programs including building Local Power local Energy Rules, and occasionally some composting podcasts. So would encourage people to check out ilsr.org. Now, today we are talking with Nancy Werner, who is the NATOA General Counsel. Welcome
Nancy Werner (01:14):
And thanks. Well, thanks for much for having me. Happy to be here.
Christopher Mitchell (01:17):
NATOA was has always been something that has very special to me because it was the first organization I joined in getting into this work. And and they made it easy for someone that was on a very tight, small budget. but for people who don't immediately know what those five letters mean it's one of the best acronyms because it explodes into a very long <laugh> acronym.
Nancy Werner (01:39):
It, it is a long title. We, we are officially the National Association of Telecommunications Officers and Advisors, which is long. And every time I have to explain that, like at a conference when I'm speaking, I'm like, okay, hold on everybody. It's gonna take a minute while I tell you our name. That's why we go by natoa. But I really appreciate your comments, cuz I do, I totally agree with you. That's what our organization does. It's a, it's an inexpensive way to get involved in an organization that's going to help you stay on top of and, and learn if you don't know already communications issues that impact local government. So our name is actually, I mean, it's long, but it's, it's descriptive. <laugh>, our members are officers and advisors. So local government officials and staff, and the people who advise local government officials and staff on communications issues. That's what we do. so we provide resources to members. Like I think that's what you're referring to. A lot of people join our organization when they first start working for like a city. And they're like, I don't know what a franchise is. You know, we'll help you out with that. then we also stay on top of all the issues at the FCC and Congress and advocate on behalf of local governments on those issues. We'll file with the fcc, we get involved in some litigation, all that kind of good stuff.
Christopher Mitchell (02:50):
Yeah. I recall when one of the major cable companies was gonna start charging people a fee to pay their bills in cash. Like Naau was there. a lot of times I feel like on the NATOA listserv, you see things early where someone's like, you know, our franchise our franchisee wants to do this thing. Has anyone heard of this? And you sort of see these things percolating around that way,
Nancy Werner (03:11):
Right? Absolutely. Yes. I, I've heard people's, you know, listservs aren't those old, maybe, but they're so effective. It is such an easy way for people, it comes into your inbox and says, Hey, you might be wanna be on the lookout for your cable operator doing this.
Christopher Mitchell (03:25):
So the biggest question I always have is, is it, is it advisors with an O or advisors with an E at the end? With an O? Okay, I gotta remember that. No, <laugh>. We have three subjects we're gonna talk about today. And the first one is bead the program from N T I A from the I I J A, the the infrastructure bill. then we're gonna talk about a municipal broadband and, and what to do about states that are not following congressional DIC dictate in terms of, of making sure that all entities can be eligible for funds. And then we're gonna talk about franchise fee issues. so let's dive into bead and we're gonna talk about a specific provision that you and I were talking about at National League of Cities trying to get a sense of how this is gonna play out. But, but as a quick reminder, what is bead?
Nancy Werner (04:13):
Well, see, I was gonna ask you, you asked me what my acronym was. What's BEAD - Broadband Equity Access and Deployment. I think I have that right. yep. <laugh> you got, I, I wouldn't have even had it. I just gave up on remembering what that one was.
<laugh> Well, yeah, I know. But you know, for the listeners out there who don't know what BEAD is mm-hmm. <affirmative>, it is a, it is a, a pot, a big pot of money. help me out on the money. $45 million...
Christopher Mitchell (04:38):
$42 and a half.
Nancy Werner (04:39):
I was close. 42 and a half billion. I said million billion. that the infrastructure law allocates two eligible entities, which are basically states, it's also territories. But you know, I'm gonna focus on states today to give out as grants. So the N T I A will be administering these. They will give the grant money to states, and then states in turn have to give them out as that money out as grants to other recipients to engage in broadband related issues.
Christopher Mitchell (05:07):
And if you read this, they are the sub-grantees. The sub-grantee comes up a lot, I think.
Nancy Werner (05:12):
Yes, yes. So the state is the grantee, meaning they got the federal funds, but the people actually taking the money and spending it to deploy broadband or whatever the, the project is, those are the sub grantees. That's right.
Christopher Mitchell (05:24):
Right. So there's a whole bunch of money. Most of it's gonna go to areas that are in more rural areas, we presume because it's areas that don't have the 25 megabits down, three megabits up. but what we wanted to talk about is two aspects of this. the first one is this issue of the multi-family buildings and those that have high poverty because that is an area in which some money can be spent. and it, but there is some disagreement. And I like to say there are, there are people that I trust to read law well who have equally high confidence that this says two separate things. And the question is whether one, a state has to spend all of the money into areas that don't have 25 3 before they begin spending any money on multi-family dwelling units that have a lot of poverty in them.
Nancy Werner (06:09):
My opinion <laugh> on this is that they do not, I, you know, people maybe don't wanna hear the, the numbers or the letters of the statute, but there's a subsection F entitled use of Funds, and it lists six potential uses of funds, five substantive ones. And then the sixth is anything N T I A adds as a necessary use to achieve the purposes of the act. So, you know, one of those uses under subsection F is unserved and underserved service projects, which are basically the deployment projects, which are defined with respect to access to 25 3 or 120 currently. then it goes on, you can use the funds for that and or community anchor institutions and or planning type projects and or these multi-family building situation that you were talking about. And then the fifth one is other deployment type access type projects like giving out computers mm-hmm. <affirmative>,
Things like that. So there's a variety of uses and I do not read them as being, you know, subject to any kind of a prioritization. What is subject to prioritization. As I mentioned, one of the uses is these unserved and underserved service projects under f1, there is another subsection H that says if you're using the money under f1, then you have to prioritize the funding for unserved areas first. Then underserved areas, then community anchor institutions that fit a certain definition. So in other words, you've got a whole bunch of uses of the funds, not a whole bunch five, unless N T I A sets up more under one of those uses for deployment. You have to prioritize unserved and underserved and community anchor institutions.
Christopher Mitchell (07:51):
Right. Because just to be very clear there, like you said, there's five uses. One of those uses includes both underserved and unserved. And there is no doubt in anyone's mind that underserved can only come about after you have certified that all the unserved areas are met.
Nancy Werner (08:08):
Absolutely. So that's, that's true. I think part of the issue here is that the way this was presented in the media, I'm not blaming the media. I, I think this is kind of the way blame Congress wanted it to, to be. Well, I mean I think this is the way the people who who voted for this wanted it to be presented mm-hmm. <affirmative>, which is, we're serving the unserved mostly these, these rural areas that have lacked service and we want them to have service. But when you actually look at the bill, there are more uses and the prioritization. So again, it is a little confusing cuz one of the uses is unserved and underserved service projects. So to do those, you have to fit the unserved and underserved definition. But if you're operating under that subsection, then you also have to prioritize unserved, underserved and community anchor institutions before you can do anything else for deployment projects. So there is a specific prioritization that applies to a specific use of the funds. Not all of them. Raise your hand if you don't understand <laugh>.
Christopher Mitchell (09:09):
I don't see any hands up. I think we're good <laugh>.
Nancy Werner (09:11):
I think we are, we're great
Christopher Mitchell (09:12):
<laugh>. and this is important because this is a question of whether we are going to spend all of this money or the vast majority of this money in areas that are and more rural in nature. or if we're gonna be able to spend any money in urban areas. And, and that's important because we have spent so much money in rural areas and we need to spend more, I'm a huge proponent of making sure we get this done, but it is incontrovertible that we have neglected the many more millions of people in urban areas. And this is a time to make sure that we are not just picking one or the other. And states should be able to be empowered to this. Frankly, I'd like to see the cities themselves have more say. but I think this is something that N T I A would do well to make sure it, it adopts your reading of it and passes that along so that states can, can do this themselves and then suffer the consequences as they may.
Nancy Werner (10:03):
Right. I I totally agree. And I, I wanna echo what you said. I, I'm not advocating to, to ignore the rural unserved or underserved areas. Just like you, I want service to those areas as well. But we do have to address the significant issue in more urban areas, and particularly where it might look on paper like there is 25 [inaudible] service, so they look served, but it's really not there or it's not affordable. you know, there's a lot of issues to address in more urban areas. And so we NATO filed comments with N T I a
Christopher Mitchell (10:38):
Nancy Werner (10:39):
thank you. I really like this. And other local governments did too, making this point like, hey, the law doesn't require just you know, unserved and underserved deployment projects to rural areas. It's much broader than that. Even if people don't wanna talk about that <laugh>, it really is. And we need to embrace that. Or we are going to have, as you said, more people left behind than we end up serving.
Christopher Mitchell (11:05):
So now we have another tricky issue, which is that many of the places where I think we would see this money used to address the poverty in, in low income public housing type facilities are cities where they may be making public investments. And the number of states have made those either quite difficult or impossible. And so Congress told N T I A that states are not permitted to prohibit cities from getting access to these funds or cooperatives. Although you and I will talk more about the cities here. and I think N T I A has a challenge on how to read that. because the question I get from the press is often, well, can N T I A preempt state laws? And, and it's tricky because I feel like congress is sort of like, well, you gotta overrule state laws, but we're not gonna give you the, that would allow the Supreme Court to agree that you clearly can preempt state laws. So I think you had a, you have a really nuanced way of thinking about this that is far superior than anything that I came up with. So I'd love to hear you explain it again.
Nancy Werner (12:07):
Yeah. because it's not a preemption argument. You and I were quoted in the same article and you kind of took the preemption angle and said, I don't think the statute preempts, I agree with you. I don't think the statute, it preempts state laws that restrict municipal broadband and we never argued it did. I think there was a, an attempt to confuse the issue that is somewhat succeeding. Unfortunately, this is not a preemption issue. We are not saying that the, the federal government is trying to preempt state laws. What we are saying is the bead language precludes states from making local governments ineligible and not just local governments. It says, I, I don't have the language right in front of me, but basically local governments, co-ops, private companies, there's a whole list. It includes private ISPs. You can't make any of them ineligible.
So there has to be, I hate this phrase, a level playing field for, you know, anybody to come in and try to persuade the state that they can do a deployment project. Well, and I should be clear on this, this restriction is only for deployment projects that subsection FH I mentioned, which talks about restrictions on use of funds under F1 for deployment projects. This is only there, so it's only in deployment projects that this has to happen. What we're saying is, N t I very clearly has to disapprove is the language in, in the statute. Any state initial proposal or final proposal that doesn't comply with the use of funds, and we just spent all this time talking about the use of funds, which if you're gonna use them for deployment, you have to follow the prioritization we talked about. You can't exclude anybody from eligibility who's in that list I just mentioned.
You have to make sure that a recipient provides low cost options. There are things that have to be done. And so our point is, if a state can't really let a city, for example, participate in the grant program because their law restricts the city from using the funds for broadband deployment, or o other uses allowed under the statute, then they can't comply with the bead requirements. So what we suggested, instead of having N T I A just say, okay, well this state can't comply because they don't let local governments build broadband networks. We thought the better option to make sure states got that money was to allow a state to say, yeah, we have this law, but we're not going to enforce it. We are going to let local governments be eligible for deployment fundings just for this purpose. Their law is still there.
They can enforce it in every other context, but if they're gonna take this federal money, then they need to comply with the federal conditions that are attached to it. So that's not a preemption issue. It's, it really isn't. It's a, it's a condition on federal funding, which the federal government is allowed to do within certain parameters. It's certainly allowed to say, if you're taking the money, this is how you're going to use it, which they've done here. And I think that that restriction or condition is quite clear. You, you can't exclude people. You can't pick and choose who gets to apply.
Christopher Mitchell (15:04):
And, and that's in part because of this issue that like, I feel like the people who are arguing that states should be able to continue ignoring that are the ones who are also shouting about the government not wanting to pick winners and losers <laugh>. And so, like this is an issue where like the, the federal government is like, states can't like arbitrarily pick winners and losers as who's gonna get this money. And a bunch of people are saying, oh, we think states should be able to do that, even though they're constantly accusing other people of doing that with mal intent. Now the thing that I think is, is important to include here is that if a state's program, if their plan is not accepted by N T I A, they don't lose the money. The money is actually still available to be spent in the state. It's just that it would go directly to localities via a process that N T I A will will have to develop.
Nancy Werner (15:49):
Yes. And I'm glad you made that point cuz that's an important part of the issue. I I think those arguing that states can just ignore this municipal broadband thing and just <laugh> say, Hey, our state doesn't allow for municipal broadband, but we want these grant funds anyway, Congress built in this, this contingency plan where if a state didn't apply for funding or wasn't approved for funding, then it would go to local governments or a coalition of local governments if they stepped up and wanted to step into the shoes and be the eligible entity. And if that doesn't happen, then it gets reallocated to all the other states that are participating. That makes it clear to me that Congress expected that if states aren't able to meet the grant conditions, there's another way out. It's not a, it's not a rubber stamp from N T I A. You've gotta agree as a state that you're gonna comply with these conditions or the funding's going to somewhere else. I, I mean I don't wanna get too much into the weeds here, but this argument that if a state has a municipal broadband preemption, they can just ignore it and take the grant funds. I mean, how far does that go? Can they redefine unserved and underserved as well and just decide to Oh I like that. Reallocate the money differently.
Christopher Mitchell (16:56):
That's brilliant. Yeah.
Nancy Werner (16:57):
Can they, can they say, you know what, we don't wanna have low in, we are not gonna make our sub-grantees have low income programs cuz that feels like rate regulation or we just don't really wanna get involved in that. I don't think anyone's arguing that, but for some reason on the muni broadband front, they're arguing, oh well the federal government can't tell the state that they have to comply with that condition. Why not? That's why I think the, the preemption issue has been brought in. That's where I think they're trying to confuse the issues because I agree, as I said at outset, if Congress is going to try to preempt a state, they need to do it really clearly. They didn't do that. They're not trying to preempt, but they are saying you have to use these funds in a particular way.
Christopher Mitchell (17:35):
Right. And this is something that I I've said before, which is that it is ridiculous to me that I'm gonna be subsidizing broadband in Tennessee because the state of Tennessee does not wanna allow Chattanooga to solve that problem, you know, in the areas around Hamilton in, in a really efficient way, which it could do without any taxpayer help. Instead my taxpayer dollars are gonna be going to like help some other company build it in a less efficient manner to charge more and deliver less. That, that's absurd. That's not how my taxpayer dollars should be used.
Nancy Werner (18:04):
Yeah. Yes. And I I was gonna make that a similar, I guess the flip side of that point earlier, which is if municipal broadband is as bad, I mean that's always the argument, right? That municipal broadband is, they've tried, they've mostly failed, they're not good. We know that's not correct. But if that was correct, what is the harm of letting these inept communities apply for grant funds? They'll just get rejected cuz they can't do it <laugh>.
Christopher Mitchell (18:26):
Nancy Werner (18:27):
Mean, I guess like why are you so concerned about municipal broadband options being up for the money. If it really is a, an inferior choice, then it's not a big deal to just let them apply. Right? I think we, I think the concern is that municipalities might have a better shot at the grant funds for exactly what you were saying because some of them, like Chattanooga maybe won't even need the grant funds, but if they took it, they could very quickly expand and do a lot of good that, you know, expand the good that they're doing now. I think that is more of the concern is that you're going to, that it is going to help prove the, the municipal broadband case, you know mm-hmm. <affirmative>, because if that wasn't the concern, why even put up a fus?
Christopher Mitchell (19:10):
So we're gonna move to our third topic, which is this issue of franchise fees and in particular, because this could be a, a multi-hour discussion in and of itself to really get into the weeds, but I think I, I'll just set the agenda by saying that, that some telecommunications services are taxed in different ways and some are not taxed at all based on federal law or, and or state law. and it's really quite complicated and there's a big issue right now with localities trying to figure out if they can recover some of the revenue they're starting to lose from how certain services that are taxed are, are declining in terms of gross receipts. And so you know, there's this issue of like whether certain other types of video streaming can be taxed, but what I, what I wanted to put to you is whether or not kind of everyone would be better off if we would just get rid of all the complication and just say that if you have telecommunications wires in the public right of way, they're gonna be taxed at a, at a, at a, at a, at a level that is, you know, more or less easy to understand <laugh>, I
Nancy Werner (20:12):
Guess. All right, so I'm gonna take your, your question that tries to simplify a complex issue and make it more complex.
Christopher Mitchell (20:20):
<laugh>, you're a lawyer that you're right.
Nancy Werner (20:21):
I'm saying <laugh> by saying, you know, in many, I would argue, and in many courts have agreed and some have not that when you are charging a fee for use of public rights away, it's not really a tax, it's a fee. You're, you're, you're being, you're collecting compensation more akin to rent. There is a Supreme Court case that calls it rent for use of public property, which is different from attacks. And the reason I make that distinction is there I think are pros and cons to the simplified approach of just if you've got stuff in the rights of way, you're gonna pay a fee. We don't care what kind of services you're providing. I love the simplicity of that
Christopher Mitchell (20:58):
In a, in a really bad world a cable or telephone company would have to negotiate with every single person that it wanted to run their lines over or under the ground. And that would be a world in which we did not have very many networks because it's impossible to do. And so local governments make this easy by administering property in certain areas that we call the right of way and, and make it a, a simple way to get into a comparatively simple way to get into to be able to build their networks and to deploy other kinds of networks like water and sewer and things like that. So, so like when you're saying it's a fee, it's absolutely right. Like there's, it is unimaginable that there's any other way for these companies to build their networks than to use the right of way. And it's a tremendous luxury that they get to do that because they wouldn't have businesses otherwise.
Nancy Werner (21:45):
There's nothing I can add to that. <laugh>, you said it exactly perfectly. Yeah. I appreciate you setting that up too. I'm so used to talking about it that I, yeah, forget about the, the rights voice and an evident idea to everybody <laugh>,
Christopher Mitchell (21:58):
Right? I get that. Right. So that's why, that's why they have to pay anything. And then, and then, and I feel like there's two issues, right? One is like, there might be like a set schedule for like having a, something in the right of way. Another is that that schedule might be a percentage of revenues o of something. So I think that might be a way you were leaning toward.
Nancy Werner (22:13):
Well, yeah, I mean, under the cable act that's been around since 1984, cable companies have to pay a fee of, we called it a franchise fee of 5% of their revenue from their cable service as the, you know, an exchange for using the, the local rights of way. and I should say, just cuz I have to, before the act, local governments were already doing this. It wasn't like the federal government came in and said, okay, cable companies, you're gonna pay local governments were already saying you wanna use our property, you're gonna have to pay. And then the federal government came in and said, okay, how about we regulate this across the country? <laugh> maybe a small distinction, but as a local government person, I have to make it clear that, you know, use of the rights of way it has always been managed at the local level.
And when you, we talk about state and federal laws, they're, they're generally limiting, I would call it organic authority that's already there. Sometimes it's not. Sometimes the state has to authorize it, it depends on where you live. But as I mentioned, I think the idea of this, this uniform fee that everybody pays, whether you're a cable company or a broadband company or an old phone company, if there's anyone left still calling themselves an old phone company it's so simple. I do love the simplicity of that. It would get away from away, the cable company pays 5% and in, in some states, nobody, broadband providers, phone providers pay nothing. Some states they also pay 5% or 7%. you know, it's, it's all over the place in terms of, and sometimes you can get cost recovery only, whatever that means, which is really hard to calculate for a variety of different users of the rights of way, right? So I love the simplicity of it and here's where I, I start to have problems with it. I mentioned cable act, cable act also, I would say codified what local governments had been doing before the act, which was requiring other customer service or community benefits, one of which is public education, governmental channels. So these are access channels. sometimes when I describe it, I talked about Wayne's world, I think maybe that is getting to be too outdated of a reference.
Christopher Mitchell (24:03):
No way. No way. It's, it's timeless.
Nancy Werner (24:06):
But I mean that's an access, you know, like a public access channel. What's probably more relevant today are the government access channels, particularly during the pandemic when local governments couldn't meet in person. and we're trying to find ways like they needed to do emer, take emergency steps, but the council couldn't meet because they couldn't be in the same room together. And how do you get around that and how do you make it public? You have to let the public in and mo you know, that's kind of a law I think probably everywhere. So in a lot of places with government access channels, that's how they did it. They were like, okay, well you're gonna be on the access channel and we're gonna let people call in and this is how we're gonna make this whole thing public. And it was great. It really worked out so well. I, and and also just with the, the loss of a lot of local newspapers and a lot of local media, public education, government access channels, I think are having a resurgence in terms of their importance. That is something that is required in a cable franchise agreement. So the permission to use the public rights away from a cable company also includes that obligation if the local government wants to include it.
Christopher Mitchell (25:03):
If they're offering video services.
Nancy Werner (25:05):
Yes. Right? Yes. Thank you. If they're a cable company under the old school definition of cable, absolutely. there's also build out obligations too in, in those types of agreements. I think you could lose those in this generic, like we're just doing a, a tax scenario. there's also, you know, if you just think of the old incumbent local exchange carriers and other types of utilities that have provider of last resort obligations where they have to serve everybody. Some states have customer service standards that apply to certain types of services, but maybe not others. So I think the con the tricky part is how do you retain those, you know, consumer protections and customer service obligations and particularly build out type requirements. Cable companies are the major providers of internet now because of the build out requirements in cable franchise agreements over the last 40 years.
Christopher Mitchell (25:54):
Right. Like 85 90% of Americans have cable because local governments said, you're not gonna pick and choose, you're gonna deliver it to everyone that hits a certain density standard.
Nancy Werner (26:03):
Exactly. And so if we decide, we don't care what services are being provided, I, I love the idea, but it's gotta come with these other, the ability to impose these other obligations so that people can't pick and choose where to serve and they can't, you know, have customer service practices that are deceptive. I mean, there are other statutes that deal with that, but being able to deal with that at the local level is super handy. It's nice because local officials
Christopher Mitchell (26:27):
Yeah, I was gonna say local officials are gonna get the call one way or another. The question is just whether they can do anything about it.
Nancy Werner (26:32):
<laugh>. Exactly. So the, so that's where I have a hard time with the simplified model. And so the reason at the outset I wanted talk about fees versus taxes is cuz one, one possible way to do it is con is, you know, we continue to have this fee for use of the rights of way, but then there's a separate taxing authority and you can say, okay, you're charging, we're gonna charge you the fee that's just your rent for using the rights of way. And on top of that, we can impose a tax that we are going to use to fund build out or to fund, you know, some customer service type things that are gonna help to fund our PEG channel. I mean, that might be a way to be able, I mean, I know that sounds terrible, like I'm saying let's do a tax INO fee, but <laugh>, but I'm just saying like maybe that would be a way that you could actually retain some of the, the good that we got for the co the community through these franchise agreements, but under a more simplified plan.
Christopher Mitchell (27:26):
Right. The model that comes to mind and to some extent is the 5G deal that San Jose struck with at and t where there are no buildup requirements under law. And at and t basically, I believe agreed to pay more to locate in higher wealth areas. And then that money went into a fund that was to help increase digital opportunity in lower income areas. And so the city had the flexibility to be able to do that and to strike that deal.
Nancy Werner (27:54):
Yeah. I think they had just even a, a, a pot of money that was set aside by the companies to, to do that. Yeah. And that's kind of what was my inspiration for that idea is if, if providers don't wanna directly do these community benefit <laugh> services then maybe they pay a little bit more and let the local government take care of it. That's, that's an option that I can you know, that might be worth pursuing. And the, the San Jose example is a good one.
Christopher Mitchell (28:21):
Excellent. Well thank you for coming on. This has been excellent. I don't, I think that, you know, you said you were gonna make things a little more complicated. I think I've seen people make things more complicated and, and I don't think you did that, so,
Nancy Werner (28:32):
Oh, I'll have to try harder next time then. <laugh>. Yeah.
Christopher Mitchell (28:34):
Well it's wonderful having you on. I appreciate your time today.
Nancy Werner (28:38):
Yeah, thanks. It was fun.
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