Policy Onramps: Using Passive House to Accelerate Building Decarbonization
Hello, everybody. Thank you for inviting me to present to you. It’s a great honor to share further wisdom with you at the South Pacific for the South Pacific Passive House conference. I’m both honored to be able to do this and simultaneously devastated that I cannot be there in person to present this information to you. So today, I’ve been asked to share my experience and trials and tribulations with helping to accelerate Passive House policy, and I will be looking at how to do this and what experiences we have found here in North America that have been helpful to us. And hopefully those will be equally helpful to you. So I will start by telling you all that pretty much everything I’m going to cover in today’s presentation is contained in this policy resource guide that we developed for last year’s North American Passive House Network conference. All of that is online in digital form. So I encourage you to go back and find that I will share links to that and I will hopefully be able to send some print versions to you for distribution at your conference. So where do we start and how do we tackle this big challenge for transforming our built environment from this inefficient fossil fuel dependent structure to this more efficient, fully renewable, decarbonized framework? And of course, there’s been plenty of literature and information shared on this, and this is one of the early ones by a fellow South African architect, Denise Scott Brown, who collaborated with her rather infamous husband and another. Person who didn’t receive any much, very much credit as Steven Eisenhower and wrote this book, Learning from Las Vegas, and what I would like to say is. Absolutely, the idea of learning from a city built in a desert with no water and no access to really good, reliable water source based on gambling may not be such a great example for us to learn from. So what I’m going to recommend is that we choose a very different city and that we use Vancouver as a much better example and place to learn from. And I will be covering a lot more information about Vancouver’s policies and how they’ve really accelerated not only the adoption of Passive House, but a really fantastic transformation of the built environment using Passive House as one of the tools. And I have this quote from Shawn Pander that I highlight here, and I’m not going to read it to you, but if there was one thing I would wish for every city is that they would have a Shawn Pander as the green building manager. If he could be cloned, I would say send him or his equivalent to every city on the globe. We would have a really successful market transformation with somebody who is able to clearly think holistically and in an integrated, both vertical and horizontal manner. So to tackle this subject, I thought it very important for us to really grapple with how decarbonization policy is structured. So I’ve really spent some time trying to create an illustrated framework for how the policy frameworks that affect building decarbonization are overlaid with how buildings are typically developed. So I’m going to create this framework illustrating the various milestones that happen in building design and development. And then I’m going to look at the overlays of where these policies actually intersect in this development timeline, because it really is becoming apparent that those intersections have actually much bigger levers and can present much bigger opportunities for us, for our decarbonization policies. And seeing how they intersect is really helpful to help make decisions about what levers are the most effective for us to pull for implementing better policy. So the code overlays for these three phases of building development are really quite interesting to look at separately, obviously entitlement and preliminary design phase, zoning and local design regulations in my region play an enormous part in how buildings are designed, where they’re located and how efficient they actually are given allowed to be simply by virtue of where they are, how big and how how they’re allowed to be designed. And then during the development and the construction phase, obviously all the other building codes come into play. And I’m back at those all under this building codes title. And every region has slight variations on those. I’m not going to go too deeply into that. And then we have our energy codes and some regions have more rigorous ones than others. Some are developed slightly differently than others, but for the most part that the time frame of where they intersect with our building development cycle. And then finally, occupation and operation is something that, for the most part, our codes don’t particularly govern, but I do include them here because benchmarking is really a regulatory framework that does start to impact occupation and operations. So I I placed it here because it should be considered and be placed on this framework. So if we look at the typical code compliant building progression, it’s everything that any architect or owner and developer and and policymaker is familiar with the typical phases of project development. And what I’m really wanting to point out is where the energy codes and these policies actually intervene in this development timeline. And for typical code compliant buildings, the most, most bioregions, the energy code really only affects a building right before a building permit is pulled. Some projects might push this a little bit further up the the development time frame. But for the most part, we know that energy codes really are only required to be developed and and calculated right before a building permit is pulled. And if we then look at how passive house buildings are developed and where the Passive House energy model intervenes in the system and the time scale for how projects are developed, we see a little variation. So what I’m really trying to point out here that. Energy modeling is done a little further upstream in Passive House buildings, and the certification is also actually typically happens right after the final. It doesn’t all happen right before a building is occupied. So really just showing that the difference between a code compliant framework overlay and the passive house overlay. And what I’m really trying to point out here is passive house intervention a little further upstream gives it a lot more leverage because teams are allowed to actually make much better design decisions when they’re informed further upstream in the schematic design. So right there, that’s a huge opportunity for policymakers to potentially intervene by transforming their code and just literally shifting when the energy model is required for submittal. The other upstream intervention that we absolutely have to review and should not be left off out of this discussion. Is the zoning code overlay any decarbonization policy that does not look at how buildings are, how land use is distributed and regulated, is missing a huge opportunity to decarbonize their built environment simply by allowing more density to be developed? And this is a really simple function of the more disjointed and disconnected your buildings are from each other, the more insulation they require. So your detached single family homes, forms that are broken up and have a lot more surface to volume ratio actually require much more energy to operate and they require more insulation. So a very simple lever for decarbonization that can have a huge impact on your built environment would be to simply allow higher density, more compact buildings and for them to be ganged up together, as in multifamily buildings. So and just to illustrate the point, this is my city, San Francisco and San Francisco is one of the best cities in North America, and yet we still only allow multifamily buildings to be built in less than 30 percent of the area of our city. So this drastically alters the opportunity for us to decarbonize. And in our policy resource guide, Matt Hutchins wrote a fantastic article about this exact topic, and although it may not be specific to Passive House, it greatly affects how efficient and cost effective passive house buildings can be. So start always with zoning. This graphic that he included in his article shows how not only can you double the savings if you double the density for your housing, but you actually can also halve the transportation footprint. So the emissions, the CO2 emissions from transport actually also benefit. And it is this doubling and coupling of efficiencies. That, again, is something I will touch on a little further in this presentation. So the other upstream policy intervention that absolutely cannot be left of this conversation are local design regulations. Many of you will have seen very similar illustrations to this one, which comes out of a local city near me here in California. Where the building design regulations are encouraging architects to build these absolutely disjointed, cobbled together, crazy, crazily articulated structures in order to conform to what they are perceiving as neighborhood character, this is an overlay, a policy overlay that every city has here in California. And I am always amazed that this is never required to be reviewed through a carbon emissions lens. And for the most part, what I see is these local design regulations that give guidelines for creating these completely disjointed, overly articulated boxes are actually sabotaging all the other good work that you are attempting to achieve in your building energy codes. So make sure that you aren’t killing your carbon action plans by having your well-intentioned planning and local design guidelines, folks really requiring all of this ridiculous articulation. [00:15:56] And again, this is what’s required in San Francisco. The design guidelines show this subject building as the, um, you know, unsupported version. But the version that they are encouraging architects to deliver are also actually horrendous. If you recall the slide I showed with how complexity and additional surface to volume ratio really increases the amount of insulation required and the amount of energy used, this is really not a good idea. So I encourage you and I urge you to make sure you educate your planning departments on the cost and the carbon impact of excess articulation. And perhaps there is a third way that can be found that still does create a unified, integrated neighborhood character. But really, this may not be the particularly best design that I can create with the PowerPoint shapes tools. But really the point I’m trying to make here is find a third way. Keep it simple and make sure we design review. Guidelines are also viewed through a carbon emissions lens. [00:17:28] So as I’m at the point and the structure I’m trying to build here is to really start to look at our policies in a completely holistic and integrated way. And so not just in a vertical way, from the time frame, from start to finish of of a typical project, development milestones matter. But I would also like to look at our codes horizontally. So did a little bit deeper. And today I’m really going to focus specifically on the energy code development structure because it’s instructive and actually reveals quite a lot of additional potential barriers and hazards. So I’m going to be using California’s own energy code, which is is called Title twenty four, part six, and it falls under the framework of of the California Energy Commission, who have been fantastic in really keeping California’s energy consumption at a pretty excellent level in comparison to many other regions here in North America. And the framework I’ll be looking at also actually is is pretty similar to what is used by the International Code Council. And for the most part, the same structure applies to the ashtray ninety point one energy code, which is used for most commercial buildings here in North America. And this may vary slightly from your own policy and energy code framework, but I think for the most part, they all are structured fairly similarly. So how code is developed in California is each of the elements that are included in our energy code review are reviewed in a specific framework meetings and they are focused on separately. So workshops are held over the course of a three year code development cycle, focusing on the specific elements of each of these elements of buildings. And each is, for the most part, reviewed separately. So for somebody like myself, that has been sort of really looking at how to intervene in the code and use the energy code cycle to include passive house elements, it’s been a real challenge because I have and we’ll look at why that that may be further down the line. California doesn’t specifically deal with air sealing, it does assume a three air changes per hour on the air leakage for residential and seven air changes per hour leakage rate for multifamily, but no air seal air leakage testing is required and some bridges have also been discussed in the code development process, but are still also not accounted for. So I leave these on the page. [00:21:19] They have been toyed with and reviewed, but they are not included in California’s Title Twenty four energy code. [00:21:30] And the code is then all of the elements, once they’ve been reviewed and modified and improvements to each of these categories have been determined, they are all then plugged into the energy model. And each three year cycle, the code, the improvement for the energy efficiency is ratcheted up slightly. And the goal of the California is Title 20 for energy code and for most of these other codes, the goal is cost effective energy efficiency and this is important to remember. So keep that in mind what the goal is. [00:22:15] And if we summarize how the code is structured, the other elements that we also should consider is the California energy code uses a benchmark building as its baseline. [00:22:31] So your building is always compared to this benchmark building and your building is required to achieve a percentage better than this benchmark building. [00:22:46] So it’s never really looked at for its own specific efficiency, but simply as a in a comparison framework against this, how shall we say, fantastical building that is sort of that has been determined as the sort of baseline conventional building common to your building type. [00:23:17] As I mentioned earlier, the code is also updated every three years. So it is a three year code cycle with the codes issued and released and adopted. The last iteration that we are currently working on was issued in 2019 and formally implemented in January of 2020. And the next code cycle that is already being developed and reviewed is the 2022 code cycle. And really a very determining and defining feature of our code is it actually has no finite end goal. So this has been going on since the 70s and we really have no idea when we will ever meet a reach nirvana in terms of energy code efficiency. [00:24:17] So in comparison, the passive has a standard structure, is a completely different animal and at its core. Is this goal for hygiene, ventilation, and it’s really important to see how the Passive House standard structure works completely differently to our standard energy code framework and Passive House is defined by the end goal and quite interesting. Interestingly, during this pandemic, coming back to the original definition of the Passive House standard as one of requiring and meeting this hygiene ventilation target is extremely pertinent during this covid pandemic time. And really what I’m trying to illustrate here is passive. The standard works backwards where it is actually defined this in Target and then everything else that all the other elements in a passive house building, all are then are reviewed and work backwards in service of meeting this hygiene ventilation target. And lighting plug loads, domestic hot water are also included in the passive half standard, but not as specifically as they are in typical code framework. They are bucketed underneath the the primary energy target. [00:26:06] So they’re more peripherally reviewed than they are in our standard code structure. And really, again, what I am trying to really graphically illustrate here is Passive House has a very fixed target. [00:26:27] And it the model is specific to each building, so there’s no benchmark comparison to and percentage improvement over each building is modeled to the exact specific design that it is built to. It is revised periodically. And this is typically when the new version of the FTP is issued. Updates to the algorithms are typically then issued. But again, really the point I’m trying to show and illustrate here is the very different structure and framework for passive house development process. And it’s really distinguished very clearly by these defined targets and very clear end goal. So the million dollar question I am always asked by policymakers is, how can we integrate Passive House into our code framework? And I have really struggled with this particular question about how to merge these, how to harmonize these, and looked very deeply into many of the specific elements included in our code. But the conclusion that I have reached is. Perhaps that is the wrong question to ask because and as I’ve showed and tried to illustrate graphically, these are two very different animals. Trying to merge them and integrate them may not be the best pathway forward. And to be honest, because the end goals are also so different, really, the outcomes and the structure of them really may not be merging them may not be the best pathway forward. [00:28:46] So. [00:28:48] How do we harness the power of Passive House and how can we utilize its unique framework to help drive conventional code and transform our built environment? And I’ve been enjoying using this particular slide quite a bit lately because I want to show that all of us, every single one of us has seen the power and the efficiency that we can achieve by combining and integrating elements. And what I’m seeing here, particularly in California, when we apply this to our built environment, we have all our disparate components in our buildings. So our hot water systems, our ventilation and energy recovery systems and our heating and cooling systems. So this is a heat pump furnace. And unfortunately, we all these all get put together in very separate categories. They’re reviewed by our code as separate systems all together. But in Passive House, we are able to actually achieve these amazing efficiencies by being able to look at all those systems and figure out how to combine them. So really, this is something that I think our conventional code development people and policymakers really need to look at carefully, because this is the essence of Passive House, is this ability to combine and integrate systems to create these magnitude order of magnitude, better products that actually utilize all the disparate elements and integrate them in ways that actually can leapfrog over the conventional efficiencies about now still routinely available on that market. So my point I’m trying to make here is why if we can utilize the integrated holistic approach embedded in the Passive House framework for building products, why can we also not do that for our policy? So to recap where we have got to so far, what I’ve really tried to illustrate so far is that Passive House is an upstream intervention. And this upstream intervention actually can also be leveraged in many other of our code overlays and may really be the secret sauce of Passive House’s success. I’m also showing that zoning codes have the possibility to completely derail decarbonization policies if they are not also holistically reviewed and integrated into a decarbonization policy framework. [00:32:36] And the same flawed design, local design regulations and guidelines, so I’m really urging you as policy advocates and policy makers to make sure that you don’t forget those two huge levers available available to you to transform your built environment. They cannot be looked at in isolation. And I was also showing how your energy codes may not necessarily align with passive House’s holistic approach and trying to merge and integrate them may not be your best path forward. [00:33:22] So what are the opportunities for us to utilize Passive House and how can you leverage its holistic framework to help transform your built environment? [00:33:37] And I would like to use examples, specific examples where this has been successful and break down the specific policies that they that they have utilized to transform the built environment. [00:33:56] And, of course, Brussels has been for now, since early 2004, the poster child of this transition from this graph here that I’m including the the Brussels Environment Department of Environment, really did a remarkable transformation with engagement with this within a seven year time frame. To where they actually reduced the energy use per capita by 18 percent, so they didn’t just flat line it like we’ve done in California, they actually started to make this trajectory trend downwards. And this is the CO2 emissions per capita. Is this a T-Online, the yellow line? Is their economy a big part of their population and the blue line is their economic growth. So without harming both economic growth or being impacted by a growth in population, they still were able to bring both the energy consumption and the greenhouse gas emissions down by a fairly impressive 18 percent. And this framework that they used is the template that has been replicated now here in North America. And it was a very simple strategy that they articulated very clearly and really identifying the clear and goal, providing training and support to industry leaders, people already going beyond code like your Passive House advocates and professionals. They promoted these front runners with wonderful books, exhibitions and prizes, and only after the industry became comfortable with and felt confident that they could deliver at these high performance numbers, only then did they change the code. So this, in fact, is the exact same pathway that Vancouver has followed. And they have really been exemplary in being able to replicate that same framework in a really vertical and horizontal integrated manner. So the article from Chris Higgins in our Policy Resource Guide really outlined these specific first steps that the city of Vancouver took to help transform the building industry. And they did the whole remove the barriers to passive house. They added incentives to increase passive house uptake and they use their own buildings as pilot projects. So fire stations and city community buildings and their own housing and development projects to serve as catalysts to spur the transformation of their local city building stock. They went further once the early pilot projects were underway and they adopted this zero emissions building plan, which is quite remarkable in its scope and its depth. And I encourage you to dig deeper and take a look at how that structured. The link I’m sharing on the sauce tab here will allow you to really find that policy and really see how it’s structured. They also train the city’s office, so not only the planning department, but the building department also went through the Passive House training so that everybody was on the same page and could understand this holistic, integrated building approach. And then they further subsidize the trainings for building industry professionals in the region because they realized that in order to allow this to flourish and to thrive, they need to reach a critical mass for professionals who knew how to implement. And this is exactly the same pathway that Brussels did. Vancouver and the province of British Columbia are actually then went a step further and they transformed their code framework. The B.C. Energy Step Code is a framework that I am particularly excited about. They use their reach code framework as the starting point for this completely new code structure. And really, if we look at it a little bit more carefully, what they did was they identified an end goal. They set the timeline set for twenty seventeen to twenty thirty two. That’s the time frame where people in the built environment and cities would get to decide for themselves which of these levels, these energy improvement and efficiency levels they wanted to start on. And of course, the bottom step was the standard B.C. buildings code. And then each step ratcheted up incrementally to the final step, which included Passive House. And this really clear direction and clear end goal has been enormously successful in not only providing really clear information to the built environment, but manufacturers have also stepped up. And interestingly, manufacturers, because it is much more cost effective, have actually started to build to meet the performance targets of the end goal destination rather than determining, well, every few years we will have to improve the efficiency of our products. They went straight to the end goal. So very simple, clear instructions and very clear messaging to the market of where the energy code needs to go. And this same framework is now being replicated in other parts across North America here extremely successfully. So British Columbia event with Vancouver being the catalyst, was the first and the same framework. And the step code is now sort of being replicated and rolling out across the entire all the other provinces in Canada. Toronto is going doing amazing things with Passive House that I’m sure hopefully other presenters in your conference here were able to share details with you about New York State is also an incredibly savvy front runner with nice sort of really leading the charge and utilizing this the same framework principles that brought in that were implemented in Brussels and more recently, the state of Massachusetts with a massive program is doing all the same, pulling all the same levers as Brussels did and replicating this same industry transformation framework. And I suppose early workforce training and development funding grant was really particularly successful, and I wrote about this in the policy resource guide identifying what were the successful elements of that funding program that was actually a very small amount of money allocated over two years, a year and a half, really, and distributed to professionals at not only taking passive house training, but other high performance training programs. And you can see from this graph showing the number of certified passive house designers and consultants in New York City, New York City skyrocketed with the number of professionals able to design to pass passive health standards with Vancouver, British Columbia, fairly close to behind. And these numbers have taken from 2017, so are quite outdated already. I’m sure this is transformed again quite radically. But really what this did was it enabled the city of New York to include passive house certification in their request for proposal for it’s city owned affordable housing project. And now that same requirement is being replicating, replicated in many other places across New York State. And it is transforming the professional industry to where training is now becoming required and professionals are signing up themselves and they are no longer receiving a subsidy. So really, they only need to fund and subsidize the front runners to be able to then create a critical mass that is transforming those markets. An interesting program that it was not specifically code overlay related, has been very successfully implemented by the Pennsylvania Housing Finance Agency, which leveraged the low income housing tax credit structure, which allocates points for projects applying for this financing support by granting Passive House projects an additional 10 points. So projects that were pursuing Passive House would move further up in the the stakes for being able to be given this financing allocation, which is huge, a huge carrot and obviously has made it transformed the multifamily housing in the PA., the state of Pennsylvania. [00:45:24] And what was even more interesting about this particular program was that over three years, the the Pennsylvania Housing Finance Agency tracked the cost per square foot of the projects, utilizing both a code compliant pathway and passive house. And after three years, they found that the average building using passive house pathway actually cost less than the buildings being built to code that the conventional code standard so massively transformative program that really leveraged financing for affordable multifamily housing that didn’t have anything to do with any of the code specific overnight, but simply made Passive House more attractive to pursue. [00:46:28] New York City’s program, liver, that is also another outlier and again, incredibly innovative that I’m really fascinated to see how this progresses is actually utilizing benchmarking. So the code overlay that affects specifically affects buildings that are already built and occupied. And what this local law, 97, has done in New York City is set benchmark targets for greenhouse gas emissions that ratchet down over a 20 year period. So starting now and first being required for implementation in twenty twenty four, this is the the CO2 emissions per square foot per year, maximum allowed for buildings and also starting with the bigger buildings. So utilizing larger buildings as the pilot projects, because, of course, we saw from the the earlier overlay, it’s easier for them to be cost to to become more cost effective. And it usually costs a lot less. And they also usually have more budget available. So using the bigger buildings to drive your energy from your industry transformation. And so what Stasch Zakuski, who wrote the article in our policy resource guide on this local law ninety seven found was that his Passive House projects that he had InDesign in his office at the time, all three of them met the final end goal destination for carbon emissions for that building type. But the project that was not targeting Passive House did not, which means effectively that as soon as this building is built, once it meets the 20 30 for a limit for this building, tech will have to be retrofitted. So this is a fascinating energy code program or actually legislation program. It’s not nothing to do with the energy code, but using benchmarking to drive building performance retroactively, which any developer is looking at, this would actually then be forced to go further upstream and ensure that he’s building his or her building was built to the most efficient standards ahead of time in order to avoid the penalties and the fines further down the road that are clearly inevitable if it’s only if the building is only built to energy code compliance standards. [00:49:57] And then the last policy attempt that I’m going to cover is the one that I was quite involved with here in California, where we attempted to utilize our existing reach code structure to develop a passive house, which code for low rise multifamily buildings. We specifically targeted low rise multifamily buildings for all the reasons I have already illustrated and shared with you here previously. [00:50:38] And we developed this reach code in partnership with the city of Santa Monica, who was the initiator initiator of this breach code, because they came to us and said, hey, you know, if you want if we do want to see how we can incorporate pesthouse into our codes and what we found as a result, once our initial study was vetted, was that in every single one of California’s 16 climate zones, with the exception of Oakland, which was quite interesting. [00:51:23] Our passive house, low rise multifamily building performed exponentially better than even the reach code targets required for that building type here in California. [00:51:39] So we really confirmed that Passive House is still quite significantly way above what our current reach codes require of buildings and buildings here in California, revealing to us that maybe our Title 24 code framework really isn’t as rigorous as it could be. And there’s still a lot of headroom left in the performance and the efficiencies available to multifamily developers here in California. But unfortunately, the city of Santa Monica had still not adopted this reach code and it has been sitting like Cinderella at the ball waiting for the prince to come and invite her to dance. So I have to say, it’s with much sadness that I say really from the experience of policy, adoption and programs that are being used successfully here in North America, these interventions and attempts to work within the conventional code frameworks and structures have been the least successful. And so therefore I would sadly say, don’t bother, see if you can find other ways to work around your code for all the reasons that I have outlined here in this presentation. So to summarize what I have shared with you, really best practices and opportunities for utilizing Passive House in your advocacy and policy efforts, it’s really pretty simple formula which the Brussels and Vancouver, New York State and Massachusetts are all utilizing. This exact same formula is start by identifying the leaders. And these will always include passive House proponents and professionals. But most certainly there are others out there who are not utilizing Passive House that are also being similarly innovative and should be included. [00:54:25] Then set a clear target, as we’ve seen, and what I’m coming to see more and more is perhaps that is really the secret sauce of passive house is it just makes it very clear what you are asking of your project teams to deliver, whereas our current code framework really is very nebulous in that regard and doesn’t set a very clear end goal and in fact, doesn’t have one. [00:55:03] And then the third key is just to promote and celebrate successes. [00:55:10] This is extremely obvious, and yet we still don’t do this often enough and with enough resources and rigor to really make these projects visible and to show very clearly how fantastic and successful they really are. And the Percival’s plus magazine in the U.K. has been just fantastically successful. And there have been other publications we hear and North America have had the one wonderful support of Mary Jameses Low Carbon Productions books to also do the same. So I hope you have a similar framework for your local community building to house. [00:56:05] So very the other sort of super basics, how to promote on ramps to Passive House adoption start not with incentives, but with education. It’s really important. I see education gets missed all the time and policy policymakers always go straight for the carrots, leaving the education and the books behind. And the books really are where we have to start. That is the foundation. [00:56:39] So your training should start with yourself planning and building departments, if policymakers really are sincere and serious about transforming your built environment. [00:56:54] You cannot keep doing the same thing as you’ve been doing for the last 50 years. And clearly, it hasn’t been working or we wouldn’t be in the predicament that we are already finding ourselves in today. And of course, if you can subsidize these trainings for others, that is a fantastic investment in your local environment and pays dividends over and over again. [00:57:28] The incentives structuring them very carefully is also another thing to be very cognizant of, and they are plenty of them that are cost neutral. [00:57:42] Vancouver has some fantastic examples. I would recommend that you go and dig into their website, look at how they’ve structured incentives for policy. I think they are really the best example with the most clear vertical throughline for how they are really promoting specifically passive house projects in the region. Very easy to add floor area ratio, benefits, height allowances, zoning, all sorts of easy cost-neutral incentives. And then if you do have a budget, the finance ones that actually are meaningful are also readily available. So don’t forget to think about them very creatively and laterally. And then, of course, once you have done your education and your incentives, removing the barriers, really look to your code frameworks and think about what it is you really want to be incentivizing and how do you want to structure your energy and your zoning and your design review codes. Do you want to keep doing what we have been doing for a long time now? Business as usual, or do you want to go straight to the end goal? So with that, I thank you for your kind attention. I, again, am so grateful for this opportunity. I wish you great success in your policy advocacy and I look forward to seeing some fantastic work coming out of that and some even more innovative and exemplary policy frameworks that you can utilize all of the elements and the ideas and the examples that I have shared with you today to come up with things, with policies and codes that work for your specific market. Thank you and have a great evening.