Planning Commission

Mr Villalobos would you please make the TV announcement?

be with us shortly.

Mr. Wilson can we please have the agenda status report?

Good morning chair and commissioners, the status of our agenda today is there's one item on consent which is a government code conformity determination, which is a request by our Real Property Division of General Services Department. And then we also have only one item on our standard agenda, which is amendments for the utility scale solar projects. Staff is here and ready to present on those items and I can move to the projection report Mr.

Chair. Please do.

Our next scheduled hearing is going to be March 25th and that will be in Santa Barbara. There are two items projected for that hearing, one is a Chick-fil-A project on Eastern Goleta Valley and then also a general plan amendment rezone in the Eastern Goleta Valley as well. Then following that, at our last hearing we took action to cancel our April 1st hearing.

And so that would put our next hearing will be on April 8th and that will be here in Santa Maria and that is to bring forward under the board's direction amendments to the oil and gas ordinance. And again that will be here in Santa Maria on April 8th After April 8th, we'll be back in Santa Barbara for two items. A development plan and also another project in the Los Alamos area which is a housing development project. Again that's April 29th in Santa Barbara.

And then nothing else is projected

Mr. Cleary is online if there are questions?

Yes, I'm available.

Since there are no questions.

So Mr. Chair, I believe that our general procedure is to ask if our commissioners anyone wants to pull it from consent and then take ask for public comment and the answer for both is no then we look for a motion.

All right. Is any any commissioner wish to have that pulled? Do we have any public comment either in person or Remotely.

I don't see anyone rising for in the hearing room anyone online who'd like to speak on our consent agenda item raise your virtual hand and I'll call on you no hands raised

okay so I guess it would be appropriate to ask for a motion to approve the consent agenda Commissioner Ford

so moved

second Okay all in favor of approving the consent agenda signify by saying aye. Aye. Approved okay so is staff ready to present? Item. Okay, Mr Villalobos could you read the item into the record?

Yes thank you, Mr Chair. The following is a hearing on the request of the County of Santa Barbara Planning and Development Department that the County Planning Commission consider case number 24 ORD 28 an ordinance amending in the county land use and development code as well as case number 24 ORD 29 ordinance amending amendment to article 2

First, I would just like prior to that if any commissioners have any ex parte, any meetings anything they feel should be disclosed prior to the beginning.

Mr. Chair Commissioners, just to clarify you don't need to do ex parte for a legislative act?

All right. Well myself I had a discussion with Claire Wyman from Growers Shippers, a brief one so thank you. So staff, if you could proceed.

Sure thank you good morning Mr. Chair commissioners Alex Tuttle with long-range planning and I'm joined here today with working down the line here Whitney Wilkinson supervising planner Matt Hernandez project planner and Zoe Carlson senior planner and project manager for the project. Zoe and Matt will be giving a presentation today and then all of us will be available for questions at the end.

Greetings Chair and Commissioner, my name is Zoe Carlson and I'll kick off the presentation and then pass it along to Matt. I believe we also have Chief Fred Tan from the fire marshal from the Santa Barbara County Fire District who is joining us today to answer any questions you may have regarding fire safety. Excuse me, that's the Santa Barbara County Fire Department.

I'll start by providing you with some context I am presenting the proposed regulations that are before you today. And then we'll discuss the environmental review, as well as policy consistency and the next steps. A little bit of history about the project. In 2014, the board adopted amendments to the Land Use and Development Code or LUDC as well as the land use element to allow for utility scale solar specifically a proposed project within a 600 Acre-Quiama Valley Overlay. And after this proposed project and a subsequent project were installed within the overlay, there was very little remaining room for utility scale solar projects within the county.

In 2019, the board adopted the strategic energy plan in order to stimulate local renewable energy They included several recommendations including amending the county code to allow for utility scale solar throughout the county. So in 2021, the board directed long-range planning to develop these amendments expand the opportunity for utility-scale solar throughout the county, including specifically within agricultural zone lands and a handful of other zones.

And the board also directed staff to amend the uniform rules to allow for utility scale solar as a compatible use on Williamson Act contracted land. To be clear, utility scale solar as I mentioned is currently allowed within that overlay. And solar is also allowed for on-site use throughout the county currently and is exempt from planning permits. We developed a tiered permitting system to clarify both the current allowed uses as well as all requirements for solar throughout the county.

Specifically, our amendments include clarifications and updated definitions regarding solar. Establishing permit tiers as well as development standards that I'll discuss on subsequent slides. And we use the term systems, as in solar energy systems for the smaller which are tier 1 or tier 2 size projects And solar energy facilities for those larger tier 3 and 4 projects.

The project also clarifies that standalone battery energy storage systems are currently allowed as within our code, as utility facilities or private services uses And these projects do currently require a major conditional use permit. And we are not proposing any changes to that, although unfortunately in the EIR there was minor error that mentioned a minor conditional use permit was currently required for those projects. So it is a major conditional use permit and will continue to be under our proposed amendments.

We are also proposing that battery energy storage systems or battery ESS are allowed as a component of solar energy systems, as well as facilities. As long as they are commensurate in size with the proposed solar system or facility. This table shows those smaller solar energy system Tier 1 and Tier 2. So the Tier 1 are currently exempt from the planning permit, so that's the lowest tier in the inland area.

And ground-mounted projects within the coastal zone would require a Coastal Development Permit. It should be noted that these projects, even though they're exempt from planning permits, will still require building permits, electrical permits and plumbing permits as well as solar use permits as applicable. These systems are generally intended for on-site use.

And the Tier 2 solar energy systems including ground mounted systems that are greater than half an acre up to including five acres. And these would be allowed with the zoning clearance or a coastal development permit within the coastal zone. Excuse me, my voice is a little tired. Tier 3 and 4 solar energy facilities. Permitting is shown on this slide, so generally solar energy facilities have the primary purpose of energy generation for off-site use.

And due to the size and commercial nature of these projects they are not allowed in all zones just Our 1 and 2 PIPU and Manufacturing Zodes showed on this slide. And I might have to pass the ball to Whitney, because I'm losing my voice. I apologize.

Okay, so to continue. Tier 3 or community-scale solar energy facilities are up to 30 acres in size and would be permitted with a minor CUP and a coastal development permit in the coastal zone. Utility scale or tier 4 solar energy facilities are over 30 acres and would be permitted with a major CUP and a coastal development permit in the coastal zone Tier 3 and 4 projects in the public utility zone would be allowed with a development plan in lieu of a CUP, and would still also require a CDP and the coastal zone.

This map shows the zones where Tier 3 and 4 facilities would be allowed. It's hard to see all of the zones at this scale, but we have an interactive project map available that we can pull up and walk through if you want to take a closer look at any of the zones here. The amendments include development standards for solar that become more rigorous as project size increases.

These standards build on existing solar standards for utility-scale solar in the LUDC, incorporate applicable measures from the program EIR and include best practices to improve consistency. These development standards include height and setback requirements for all solar energy systems, Tier 1 and 2, and solar energy facilities, Tier 3 and 4. Battery energy storage systems also have development standards and are included for all tiers with additional requirements for larger systems and facilities.

All battery energy systems, storage systems no matter the size would be reviewed for compliance with applicable building and fire codes. The regulations and design standards for battery energy storage systems have advanced substantially in the past few years. Additionally design standards for tier three and four solar energy facilities and tier two is applicable These include visual screening and landscaping requirements, and construction and operation standards that address noise traffic and safety controls and include fencing signage entrance transmission line requirements.

Development standards to protect resources and address project safety over the full life cycle of a solar facility include resource protection standards that address agricultural and biological resources, and include vegetation maintenance requirements. They also include hazard prevention standards that include geologic hazard and hazardous material avoidance requirements, and fire prevention and emergency management measures.

They also include decommissioning standards that include a decommissioning plan, waste reduction, and site restoration requirements as applicable. The project also include proposed amendments to the uniform rules per the board's direction. The proposed updates include updated definitions, compatible and those that amendments include sorry so Solar is a compatible use for on prime contracted land where our premises, sorry let me collect my thoughts for a moment.

Solar energy systems and facilities are compatible for off-site use on prime contracted land where up to 10% of the premises size or 10 acres, whichever is less with a minimum premises size of 40 acres. And on non-prime contracted land Using 15% of the premises size or 100 acres, whichever is less with a minimum premises size of 100 acres. It's also the amendments clearly state that solar would be an incompatible use on open space and recreational Williamson Act contracts There is updated language clarifying the solar use easement process.

Staff presented these proposed amendments to APAC and APAC was supportive of all of staff's proposed amendments and recommended changing the limit on non-prime contracted land to 10% instead of 15%. The APAC recommendation will be taken directly to the board for their consideration. The proposed project includes amendments to the Comprehensive Plan's land use element, which includes removing the utility scale solar photovoltaic facility overlay including deleting the associated Policy 15 Utility Scale Solar Policy for consistency.

Similarly for consistency there are minor updates to the Coastal Land Use Plan Just clarifying that solar facilities are conditional permitted use. I'll now turn it over to Matt to finish up the presentation.

Thank you, Whitney. I'll now pick it up from here to go over our outreach efforts, environmental review, policy consistency and next steps. This slide summarizes the key outreach steps described in greater detail within the staff report. First, staff held a developer and stakeholder meeting in May of 2024 to review the tier framework allowable zones and permitting approach.

Comments from that meeting were incorporated where appropriate. For CEQA, the notice of preparation was issued and the scoping hearing was held in November 2024. And the scoping comment period closed December of 2024. On the agriculture side because we are proposing solar on ag land staff met with the Agricultural Advisory Committee in August of 2024 and November of 2025 AAC feedback emphasized supporting on-site agricultural solar with minimal discretionary permitting where feasible and staff refined parts of the tier approach in response.

Specifically, this translated to expanding where Tier 2 systems would be allowed to include both developed and improved land. On February 18th, staff also presented the project to the Montecito Planning Commission where they voted 5-0 to recommend board adoption of the MLUDC amendments and to recommend that the County Planning Commission support board adoption of the CZO amendments as proposed by staff.

Environmental Review for the Comprehensive Plan and Ordinance Amendments was completed through a Program EIR prepared under CEQA Guidelines Section 15168. The Draft Program EIR was circulated for public review from August 19, 2025 through October 3, 2025. The program EIR impact analysis at a programmatic level determined that most of the impacts were related to the larger scale Tier 3 and 4 solar energy facilities with minimal impacts associated with the smaller Tier 1 and Tier 2 solar energy systems.

At a program level, the EIR also identifies significant and unavoidable impacts in three areas. Aesthetics and visual resources, agricultural resources, and cultural, tribal-cultural, and paleontological resources. The program EIR also identifies significant but mitigable impacts in the other topic areas listed on the slide. Air quality, biological resources, greenhouse gases, hazards, noise, transportation, utilities and wildfire.

The program EIR also includes a mitigation monitoring and reporting program to ensure mitigation measures are implemented as future projects tear off from this program level analysis. As a reminder, the EIR is at a program level and Tier 3 and Tier 4 solar projects will still be subject to additional project-specific environmental review as appropriate. As required by CEQA, the program EIR also evaluated a range of reasonable alternatives to the proposed project.

First, Alternative 1, a no-project alternative would retain the existing framework including the 600 acre utility scale solar overlay in the Cuyama Valley. Under this alternative there would be no streamlining or expanded permitting areas. Next, Alternative 2, the reduced Williamson Act allowance alternative would prohibit or further limit Tier 3 and Tier 4 solar facilities on Williamson Act-contracted agricultural lands and add additional footprint caps.

Finally, Alternative 3 would prohibit Tier 4 solar facilities in coastal areas. Alternative 3 was identified by the program EIR as the environmentally superior alternative. However, it's important to note that both alternative 2 and 3 would still result in significant impacts including class 1 significant and unavoidable impacts meaning that no alternative would avoid all of the key environmental tradeoffs.

For these reasons staff is recommending the proposed project as it best meets project objectives while still providing programmatic mitigation and project level review Within the staff report, you will also find a detailed policy consistency analysis that evaluates key resource areas. Staff's conclusion is that the project is consistent with the County Comprehensive Plan including the Coastal Land Use Plan and the land use element.

This analysis was completed at the program level and future non-exempt projects that require permit will still be subject to a project level policy consistency analysis. And to close, staff recommends that the commission first adopt a resolution recommending that the Board of Supervisors adopt the Coastal Zone Ordinance Amendments and make the required findings.

Next, to adopt a resolution recommending that the board adopt the LUDC amendments and make the required findings. And finally, to recommend that the board certify the program EIR and make the required CEQA findings for the project. After this hearing, the County Planning Commission's recommendation would be forwarded to the Board of Supervisors. The board will consider certifying the program EIR and adopting the ordinance amendments.

Following board action, the local coastal program amendments would then be submitted to the California Coastal Commission for certification. That concludes our presentation and staff is now available to take any questions that the commission may have. Thank you

Questions from commissioners? Commissioner Cooney.

I want to acknowledge the presentation by the team. We were presented with a number of communications just in the last couple of days. And going through that, some some of the objections of the submitters seem to be concerned with not enough review allowed and so I'd be interested in hearing whether there is anything among the submitted documents that we should consider adding or including, or is the process set to go to the board and then modified from there if the board so believes.

Commissioner Cooney through the chair. So yeah, there were a number of comment letters that have come in the last several days certainly If there's any comments or suggestions, recommendations from any of those comment letters that your commission wants to explore or discuss. We're happy to have that conversation and if you want to incorporate any of the recommendations into your action today or when you're ready to take action then you have that discretion And so we're going to be looking at that. And then incorporate those into your and any recommendation. So if there is any particular comments or material from the comment letters that you wanted to review in further detail, just let us know and we can talk through them.

I had three things I wanted to ask about. The first one will just be a follow up on Commissioner Cooney's comment. You know, I reviewed the various letters. There's multiple recommendations. It's hard for me to remember what they all are and so I think the best way to handle that And just what you've suggested, Mr. Tuttle is to take the coalition's letter Which at the end, the very end has seven or eight recommendations.

And just to ask you to briefly state those recommendations and what your response is? And then I can comment on the ones that I would think are a good idea but I don't want to do that right now because I think the best thing to do is to do that process after public comment and people can state what their recommendations are. Okay, so now I want to go to the two things though that I'm going to ask questions about.

One is biological. I think one of the slides showed that biological resources it would be impacted as stated in the Environmental Impact Report that they're significant but mitigatable And I'm just wondering what those are and how are they to be mitigated. And one, I'm particularly interested in is it kind of reminds me of the oak tree ordinance in wineries where we had a conversion of large amounts of rangeland to vineyards and a whole lot of oak trees were removed All of a sudden, and I wonder if these utility scale solar projects have the capability of doing the same thing. And what prevents that?

Presumably there are some development standards that would but but I don't know. So could you address what the biological resources are that are impacted as described in environmental impact report how they're to be mitigated and then particularly address oak tree removal

Commissioner Park through the chair. So the resources, biological resources that could be potentially impacted are numerous as we know we have a lot of important biological resources within the county particularly in our rural undeveloped areas Whether it be riparian corridors, oak woodlands, grasslands, native grasslands, foraging habitat for various wildlife species.

So the way and it's impossible at a programmatic level to to really hone in with any clear specificity as to what the exact impacts might be because it's going to be project-specific. But the potential certainly exists with any of those higher tier projects, likely the Tier 3 or Tier 4 projects which can occur on undeveloped land. So the primary mitigation is for any project would have to undergo biological, fairly rigorous biological resource assessment to establish what the baseline conditions are and what the resources are that are present.

And then from there depending on what resources are identified within the project site and I think we established a 500 foot buffer around the project site It's sort of an avoidance and then if you can't avoid, then you mitigate it by various ways. So avoidance is based on your resource assessment looking to see if it's feasible to site the project in a way that area that would avoid those resources or impacts to those resources.

And then if for some reason it was determined that avoidance was infeasible, then again a series of mitigation measures would come into play depending on the resources that were being impacted. I would also note that a project, Tier 3 or Tier 4 project would still be subject to consistency with all of our existing county policies. We have many policies within the county regarding tree protection particularly oaks so avoidance is always the first effort or first line of defense is to cite it to avoid those resources, and then mitigation comes in after that if avoidance isn't feasible.

So I think in all there's about 16 or 17 biological resource mitigation measures in the EIR that a future project would be subject to combine with And it's also set up where if the biological assessment identified a resource that wasn't anticipated in the program EIR, that additional mitigation measures could be identified based on the site-specific conditions because those future projects are going to have to do some level of environmental review.

They'll be able to potentially rely in part on the program EIR but in most cases there will be some level of supplemental CEQA review that would be necessary.

Well, let me cut right to the chase. If I'm going to convert some rangeland to vineyards then I run into our oak tree protection ordinance if I'm going to do the same thing and make it utility scale solar is am I gonna run into the same ordinance? Will it offer the same protections consistently as any other project would?

Commissioner Park through the chair. Yes, I believe it would because that oak tree ordinance and the oak tree regulations that we have in place aren't specific to wineries so they would apply to any type of development would be subject

You know, before I get on to my next topic. I want to ask just a factual question. I'm not familiar with utility scale solar panel projects in this county except for one out in New Quiama which I've driven by every week sometimes in the last few years and maybe because there aren't any others. I don't know. Does anybody know how big that one is? Because I kind of want to be able to visualize what a Tier 3 or Tier 4 project looks like. I mean, I think I heard today that it's a 600-acre overlay and there's not much room left in it so maybe that one's close to that 600 acres or I don't know.

Thank

you. Commissioner Park to the chair. I believe that the large there's 2, but they're kind of side by side. I believe the larger one is in like the 3 to 400 acre range. And then the smaller one is more like 50 acres or something around Together, yeah about 350 acres. So that gives you a sense of scale.

Let me move on to my next topic and that is the conversion of agricultural land. I think about this a lot because even in my legal practice which sometimes would involve litigation concerning the sale of agricultural land. And I've always been sensitive to the effect of pricing on, of agricultural land on, on, on the farmers and you realize once you get into that stuff that we think if we have these enormous acreages for agricultural land but really there's a high demand for every square foot of it from, from the farmers and I don't quite understand the economics of what happens if some of this is converted to utility scale solar.

And I would imagine there would be an economic impact on other farmers, because there would be less land available and it might even impact the ability to have service from companies and so forth. Because as agricultural lands shrink, they're less likely to have the people that conserve it. So is there a, how is that addressed in this ordinance and is there any kind of a limit on how much of our key agricultural land can be converted to solar?

Utility scale solar. Commissioner Park through the chair so there's no like Like with cannabis where there's a total county wide acreage cap. There's no such countywide cap for solar that's proposed as part of this project. Theoretically, every property could develop some level of solar on their ag property. I think the cap would likely be more dictated by market demand.

So while theoretically yes, Every property could develop solar. I don't believe that there's the infrastructure or the market to support that, so The strategic energy plan had come up with some sort of like maximum build-out scenarios and then a realistic build-out scenario and a realistic build-out scenario represented about 10 to 20% of the overall land as being more Again, that's probably I would anticipate be on the higher end of what we might reasonably see. I will say that for the Williamson Act contracted land and as you are probably well aware from our work on the Ag Enterprise Ordinance, Williamson Act contracted land covers approximately two-thirds of our agricultural land is under a Williamson Act contract And so with Williamson Act contracted land, there is a proposed limit per premises for the prime contracts no more than 10 acres on a prime contract.

And on a non-prime contract, the maximum size would be up to 100 acres. 15% or 100 acres, whichever is less. So there is a cap that you would see with that that would translate into depressing sort of the maximum build out potential within our contracted land.

I will state a reaction to the uniform rules that part and I get that and I think it kind of makes sense. And it really is for every size parcel which has percentages of it right? Okay. There are some odd size small parcels that are just sort of vestigial, that are Ag-2 and things like that. And if you had a small Ag-2 parcel that's non prime and not very useful I personally would rather see solar concentrated onto that solar development above and beyond the 10% or 15%, as opposed to sacrificing other land that's in more usable parcels.

That's something we can get to later.

I will also note that there is this, there's a state law provision that we've carried over and incorporated into the Williamson Act contract and to the uniform rules which are these solar use easements. So there's this pathway for a contracted land to kind of like through a cancellation essentially convert through a solar use easement that sort of pulls that land out of contract to allow for solar. So, that would potentially be something that might be suitable for the instance or scenario you're imagining?

So I'm done for now. I just want to get back after the public comment to ask about those recommendations particularly in the Clean Air Coalition letter. Thank you.

Commissioner Martinez.

Yes, good morning everyone. I'm looking at this and I and I'm thinking that the use of the terms solar is so welcoming in one sense but then once you introduce battery storage I believe that's becoming an apple and an orange because I think they just produce two different I want to ask you a question about. Concepts of energy and concerns. You were just answering the question, and I think this might address one of my questions in slide 14. You are indicating reduce Williamson Act allowance.

For tier 3 trip to your for but there's a lot out there. You're mentioning that would actually allow the property Limited to a certain amount of solar energy, and this is where my idea is coming from. Is agricultural farmers even loyal industry for their wells or pumps whatever they have out there? They're getting hit with more and more. I'm going to ask you a question about the concept of evasion of carbon emissions so there's solar concerns. There's all those these concepts are coming out. So it's it's a concept of saying this is what you shall do and then the business avenues are left with well, how can I do that without losing

Commissioner Martinez to the chair. So yeah, the proposed amendment to the uniform rules would allow a certain amount of solar as a compatible use on contracted land so if they if a property were to build within the allowances then they would be able to remain under contract and still receive the benefits of that It doesn't remove the requirement to continue to meet the eligibility requirements of the Wellington Act. So there's production requirements for a property in order to remain under contract, minimum production requirements.

They'd still be responsible for meeting those. But there's also distinguished language between solar that is used for on-site purposes to support the ag operation versus solar that is more intended as a commercial enterprise for off site

use. So it really depends upon what the proposal is for the solar I'm concerned about. For the use of the solar energy being produced through the solar panels, let's just say because I'm just worried about that Fresno situation where the guy goes out there develops a solar area and he used in the loses Williamson act contract through the Bureau equalization and that's what my concern was is that as long as you're That's my concern. And if the answer is not here today, then that's something I'm looking for in regards to it.

Right. Commissioner Martinez for the chair. So the proposed language that the Ag Preserve Advisory Committee landed on and staff presented and they supported was for the prime contracts which are normally premises between 40 and 100 acres in size You could have up to 10 acres, 10% or 10 acres whichever is less set aside for solar development. And then for the non-prime contracts which are those larger premises 100 acres or greater you could go up to 10 or 15%, depending on where the board lands, up to 100 acres of solar whichever is less and still remain So

that will move me on to the next one in regards you've already mentioned that. It's a major C U P application if they're going to be moving in this. So I think he said solar or maybe battery storage, but my concern really focus on battery And it's going to be a battery storage facility. Does it just use the word solar or does it use? We are doing this as a solar project, which is going to be Announcements about solar energy and they think it's a solar panels, but really what's hidden underneath that is a battery storage facility. So does it make it clear within those notices? That goes into the community within our regulations that it's going to be identified as a battery storage facility.

Commissioner Martinez for the chair, so if I could just clarify a couple of things because this was actually a comment that came up in a lot of the comment letters to is about battery energy storage systems. So. You know the board's direction with this project was to develop regulations for solar facilities, solar systems and facilities. Battery storage was not part of our charge with this project so What we tried to do is distinguish between a standalone battery energy storage system and not really touch that because that wasn't within the scope of our project.

And really focus more on solar, but recognizing that for nowadays for most solar projects certainly in larger solar projects there is often a battery storage component that is associated with that solar project. So for a standalone battery energy storage system, we're not proposing any new regulations or changes to those. All we're doing is clarifying where those are already currently allowed and not changing the program requirements or the standards for those.

For a battery storage system, that may be an component of or accessory to a solar project. For one it has to be sized appropriately so you can't have five solar panels and a 10 acre storage system as a way to get in what is essentially a battery storage system. It has to be accessory to and supportive of the solar project. But to answer your question on the noticing, our standard requirement in our code when notices are sent out on a project particularly you know especially something like a CUP is that there be a well-defined clear project description.

And so if a solar project had a battery storage component, that would be part of that project description. So that would be in any notices they go out to the community.

Okay? So what I'm hearing you say then and you correct me if I'm wrong is that what we're addressing here is solar It's itself and yes, I understand that the engineering of it. The solar is even though produces energy is going to have to go through some component of a battery system in regards to which stores the energy and then it goes into the system itself.

We're not talking here about a battery storage facility. That's a standalone that's right next to some Some other PG&E facility where it's just storing for storing the energy solely and then putting it back into the system. We're not talking about that here today. Correct. Okay, because that's where I was doing the apple and the orange because that's something completely different and I can see why people get mixed up because when people do get notices and I've seen this not in this county yet but I've seen it in San Luis Obispo County where they say we are having a solar project.

It's going to go right next to your house. People think great They wake up the next day and it's a battery storage facility standalone because right next to a PG&E. Facility and they can get energy alone where we're not discussing that today and as long as I'm not discussing that that takes me away from the fire prevention emergency management thing but when what it does bring me into in slide 9 your decommissioned site restoration requirements when you decommission these things My understanding is there any concern about what's done with the panels that once they're removed? I mean, because these are not things that you just break down and throw away into the dump. You just don't do that. These are things that have Well, they do have chemicals in them.