ARPA Funding: Eligible Uses, Tracking and Reporting

7:54PM Dec 16, 2021

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Hello, everyone, and welcome to this week's EFA navigator program training and discussion on this week we'll focus on ARPA and just check in on where folks are at on that and kind of refresh our selves on eligible expenditures and a couple other items. My name is Nils Andreassen. I'm the Executive Director of the Alaska Municipal League and we are pleased to partner with AFN on this support, and I'll just check in is there anybody from the EFA navigator program who wants to say a few words of welcome before we get started?

Okay, I am going to try to share my screen and basically, I think you're familiar with ARPA by now. So I don't want to belabor the point. But it is an opportunity just to make sure that if you have questions, we can try to address them. And maybe if there are some high level pieces that you weren't aware of or you haven't addressed, and then the secret opportunity to do so. First, I want to make sure that everybody's familiar with the opportunity to basically take all of your ARPA funds and classify them as lost revenue. And we had sent out there should be available out there and ARPA revenue replacement calculator. It basically this is an Excel spreadsheet that if you don't have it, I'm happy to send out GFO a Government Finance Officers Association built it so it has a number of tabs that that feed into this main page to help you calculate your revenue reduction. And there's two ways to think about your revenue reduction. First, Treasury provides you a growth rate an annual growth rate of 4.1%. So if you look back at 2019 Compared to 2020. What they say is you can you know, multiply your 2019 revenue by 4.1%. And that should give you a 2020 number that you should be at. If the number that you actually had for for revenue is less that then the difference is available for you to use as last revenue replacement. The other calculation is to go back. I think you do both of these just figure out which one's greater. But you go back five years and you fill in for each year what your actual revenue was and determine the growth rate between yours. And if that average growth rate between those is greater than 4.1%, then you would use that and I've seen local governments across the state use both in different ways. And you know, in some cases, the 4.1% is really beneficial in others their actual revenue growth and maybe there was a really high one year revenue. Growth that kind of makes everything much bigger and they've used that but the benefits of paying some attention upfront to revenue replacement is that the ARPA funds basically become unrestricted if there if you're using that last revenue replacement, so and that's, you know, for instance, what the state of Alaska has done with its ARPA fund that have a billion dollars, they had plenty of room to use all of that for lost revenue replacement, which means they can apply it to just about anything in their budget. If you're if you're not sure what last revenue looks like, there is a this is a table provided by Treasury and unfortunately it's not really tailored to tribal governments. But you can kind of see what this looks like. So out of all your revenue, you know, really its general revenue, that that is the bulk of what's coming in what counts as revenue in this calculation is everything except for the federal government revenue, which makes it maybe challenging for some, but any revenue that you received from the state government, or state agencies, that wasn't federal, you would count as as revenue. For those of you who receive community assistance for for instance, that would count as part of your revenue calculation and community assistance has gone down over the last few years. So I could imagine a difference there any revenue that you've received from local governments would count toward your total revenue, any current charges that you have, so this is for your general revenue? You may not have tax revenue, but you might have fees and charges for use of different types of systems. That would, that would make sense for you.

Think clewd here sewer or solid waste systems, even though separately they count utility revenue as something you would exclude. But for utility revenue, they're focused on electric power, gas power, public transit and water supply. So think about that a little bit in terms of how you approach this revenue conversation. There's also miscellaneous general revenue that that you could count any interest earnings, donations. Lottery revenue, I'm thinking gaming applies there, but basically, I think you could put gaming are bingo under miscellaneous general revenue. There is tribal enterprise revenue is something that they say, you know, we're the federal government. We don't know how this works, but it counts toward your overall revenue. Number. So be thinking about how you include your any enterprise revenue. And I understand enterprise as basically outside of an arm of tribal government, you've created a special something to deliver a service it's almost a business but it's still under your tribal governments ownership or governance. So here's this is how Treasury thinks about what can be included in your revenue. And again, if you haven't done this calculation, I think, I don't know that you have to do it, but it is something you have to report on to Treasury. So if you haven't done it, it's something you can call AML will get you the spreadsheet. We'll walk walk you through what's in there. What's not look at your financials and help you plug in where you need to have these different numbers. I can show you what that spreadsheet looks like later if you're interested. So this is a an important piece if you do have questions along the way, be sure to even put them in the chat bar and we'll save time at the end or interrupting along the way with questions or answers, solutions etc. So I did want to focus on this last revenue calculator and P says important if you haven't done it, do it. It's ultimately beneficial for your reporting, and how you should think about what's what you can use these funds for. The other thing that I wanted to focus on and call out specifically is individual assistance. I know I've heard a lot of well, local governments, tribal governments have put in place individual assistance programs basically, distributing economic support to tribal members, residents, etc. And, and everybody should be keeping in mind that for individual or business assistance that you're you're putting out there you do need some kind of certification that that individual suffered a negative economic impact. And so there's plenty of different ways to do that. Having them sign a form. There's a number of our grant programs that tribes have put in place for individuals to request funds from from you. But I hadn't noticed this aspect of the interim final rule that basically instead of that self certification or proof from a resident that they have experienced negative economic impact. You can take a very broad brush to to assigning impact to a large group of households or population within your community or around the state. And and basically what they say is that you can you can say that everybody in the community, you know, as low income or as is impacted, economically that they're experiencing food or housing insecurity or unemployment. So if you've got high unemployment if you've got food or housing data for the community or for that time, or if you can show demonstrate that everybody is low or moderate income or some large portion of the community is and you can make those individual assistance grants

without that self certification or without requiring any kind of proof from residents. And I think that's important if you haven't been thinking in those terms. If you've put in place a process that requires a lot of individuals to demonstrate economic impact, it may not be necessary, because you can come at it another way by demonstrating that a large group of the population in the community or to whom you distributed funds is any is economically impacted otherwise, again, unemployment, lower moderate income, food or housing insecurity are all good justifications for getting aid out. I think we've gone through before in other webinars that that aid is not counted toward income by the IRS. This is individual assistance. That's that's going out. It's not it shouldn't be taxable and by the IRS, so if you haven't seen documentation of that effect, I think we've provided it in past webinars. There's a quick link that I could try to find if you if you need it from the IRS. Um, so with those two kind of areas that I really wanted to hit on, if you haven't looked at either of those, then that's that's probably important. This is just a summary of what's eligible and I'm sure you've been thinking, you know, in these terms and been through this list. It's worth kind of taking a break every once in a while and reflecting on okay, we've done this so far. What else should we be thinking about our How else should we be thinking about best utilizing ARPA funds? And I think it's important to know that for tribal governments, you have almost double the the amount of eligible expenditures, as states or local governments do so these first five bullets are what everybody can do. And these last four are what tribes specifically can do or others can do in qualified census tracts. But you're familiar anything that's related to public health COVID mitigation, medical expenses, helping with behavioral health, or paying for public health and public safety staff. Those are eligible expenditures. Anything that you're doing to address the negative impacts caused by the public health emergency is eligible. So that's helping with unemployment jobs, you know, doing job training, and supporting households who are struggling, getting grants out to small businesses in the community, making sure that their whole during this period and so on. So, so be thinking about, you know, what those negative impacts look like in your community? And, you know, in some ways, think beyond your community, who else out there that does our community depend on? That's, you know, providing a service in or somehow connected it. You're not constrained by geographical boundaries in your application or use of these funds. There's actually very little that keeps you from using funds beyond your borders for you know, people outside the tribe or businesses outside of the tribe. If it if you've got some connection back to to having an important and having these be necessary costs. We already covered you can use these funds for your lost revenue, and the calculation is out there to do that. You can provide premium pay for essential workers so anybody who's really bearing a greater health risks because of their service to kind of frontline workers, people who are in public health, public safety. People who can't work from home or you know, do those kinds of jobs and some have been using premium pay for that. Teachers would fall into that category for instance. You can use these funds to invest in water, sewer and broadband infrastructure

and you know, that's a wide range of infrastructure development. If you don't own the infrastructure or manage it, if it's the city or somebody else who does that. That's okay. And you can think through what are the cooperative agreements, memorandums of understanding that you need to have in place to make investments you know, in so that entity so that they can improve water sewer systems, drinking water systems, which ultimately benefit your members. i You can also mean for broadband. If the funds that you have don't really allow you to, you know, invest in fiber satellites, or whatever that is, that's also just about connectivity and making sure that, you know, maybe you can bring down the cost of internet in your community or upgrade, you know, assets that your computers and iPads or whatever it is make sure that people in your community have what they need to fully access or take advantage of available. Broadband or you know, do what you can to bring cost down the the for eligible expenditures that are specific to our addressing health disparities and social determinants of health. And that it you know, that's fairly broad it extends to things like community health workers, health nurses, public benefits navigators, so if you've if you want to hire somebody to help residents do job training or or more specifically file for unemployment, you know, get other types of benefits you can hire a navigator to help residents through that. lead paint lead hazards is on this list. But you know, I actually think you know, things like weatherization or or maybe even energy efficiency, which would would fall into health disparities, mitigation, community violence intervention, increasing some of your public safety needs, or addressing those would be appropriate. Another eligible expenditure is this building stronger neighborhoods and communities and you can for any of these titles, there's so much that you can put under them that makes sense maybe from your perspective. And if you're looking for guidance, or a specific can we do this? And so that's usually not out there and Treasury's been kind of standoffish about, you know, they're not going to approve a project they're not going to pre approve a project. It's up to you to determine that it's necessary and make sure you're consulting with your attorney or your auditor. Both of those will be able to help you make good decisions. But for this one, it's all about housing. And for services to individuals who are experiencing homelessness or overcrowded homes. You're working toward affordable housing, providing housing vouchers and in counseling. So it seems like there's a lot you could do around housing to build stronger neighborhoods and communities. You can address educational disparities, early learning pre K Headstart. You can if you're in an RDA or if you're in a in a district that's low, low or high poverty I guess you can, you know, work to make sure that they've got more funding during this period so that they can do more for your residents. You can also put funds into educational services or tutoring for at risk students. So have those conversations with your school district or even just your local your principal and say, What can we do to improve you know, what's going on in the community in the school to address educational disparities and I think that can develop into some strong partnerships. The final eligible expenditure is promoting healthy childhood environments. So that ranges from providing childcare, augmenting childcare services lowering childcare cost, you know, looking at investments into home visiting programs or enhancing services for child welfare, foster youth anything that you know, really comes back to that that childhood environment that's that's important in your community. Think about who's doing something there and in that space or if there's a gap, and whether you can help to meet it or support somebody make sure that they're into the future.

Maybe I'll pause there any questions or comments on kind of eligible expenditures, lost revenue calculation, assistance to individuals, any questions you have challenges that you've come across? Or you know, elegant solutions, any any real success stories that you've seen so far? Feel free to come off mute and raise your hand or or put it in the chat bar or not. It's okay. The think about it though. And if if we come back to it later than certainly interested in examples, and I know that you know, for others who will be watching this webinar at other points in time, they would appreciate any success stories that they can model off of and and learn from, you know, the challenges that you've you may have had. So, if if that's all kind of thinking about what's what's out there for ARPA eligible expenditures, I do want to make sure everybody's clear on the updated reporting timeline. And, and there's two pieces to this that apply to tribal governments

for those tribal governments who received more than 30 million, and so I guess we're splitting tribes out by into two buckets for for those who received more than 30 million. They had the interim report to do and then on January 31, and every quarter thereafter, they have a project and an expenditure report. For everybody else. Which is, I think, going to be the majority of tribes in Alaska. You should have already submitted your interim report was due by August 31. And and if you received yours later, by October 15, then you'd have a 60 day period after that to do your interim report. But otherwise, so make sure if you haven't done your inner report, I think you can, I don't know that you have a chance to go back and do it. But you you will need to update numbers and everything and plan for doing everything in your annual report, this project and expenditure report that's due April 30 2022. And I think for you that's all through the access through the Treasury website. They've got a portal where you'll where you'll do your report, and there is a webinar that we did that goes through exactly what that reporting process looks like. But be thinking now first, if you haven't done it in a report be aware of that and you might want to check them with Treasury, but really be planning for your April 30 report where you'll need to have been tracking all the different expenditures that you've made. Any sub recipients sub awards that you've they've had any contractors all of those anything above 50,000 that you've spent, you'll be reporting on that Treasury website, and, and so on. You'll also need to report your last revenue calculation, among other things. And I bring this up here because I think when we first did reporting a month or two ago, it was a different timeline. So this is the most recent timeline is April 30. Date, which we're just really glad it wasn't October 31. It was it was all due and I wanted to just talk through and so that's kind of the ARPA sisal for funds, the Coronavirus, state and local relief funds that we were just talking that's your kind of bulk allocation that you got through the Treasury's website. There's other ARPA opportunities out there. I know we've done a lot of outreach already on on some of these but I wanted to flag kind of this next round, kind of high potential grant opportunities that are out there and funded through different other portions of arpa. The weekend we'll do probably more work on outreach for each of these. It's important for you to know that right now for any grant writing that you want to do a offense kind of basically subsidizing contributing to our ability to do that grant writing for free. So if any one of these is something that you're interested in, and you need a grant writer or need to pay for a grant writer, then you know, contact AML and we'll connect you at first to grant writing hotline and make sure you've got everything in place. And then from there into a grant writing pool to to address kind of the specifics of your your grant. But these five grants seemed kind of very relevant for coming up. So the building resilient infrastructure and communities or brick program, I think, is through FEMA. These are due at the end of January. And this is really any any thinking you have related to climate change. is going to fit into this bucket. So responding to risk hazards and disaster mitigation. It's kind of your emergency response, but it is tied back to, to climate pretty specifically. There's a good allocation to rural Alaska or rural or under kind of lower income areas of the nation. So if you're interested in that, that's something that requires probably a lot of work. But you know, if if you were able to be successful then it would be really meaningful.

And and I know there's a number of different engineering firm or others who would be, you know, happy to help you work through the specifics of a project but you might already have one in place. And an easy one to do. And out of this list, the easiest is the Coronavirus capital projects fund. This is similar to your sisal for funds out of Treasury. This is the capital projects component. You have an allocation already with your name on it at Treasury. And and this is for capital projects that would strengthen work education and health infrastructure. Basically connectivity type things. It's due June 1 2022. But it's not a hard application. And again, you've got that guaranteed base level of funding. All of these grants are up on AFN Navigator Program website. They're all color coded nicely. So you know for those in green that they should be more straightforward or easy to apply for yellow is kind of moderate level of work and read would be you know a challenging amount of work or very competitive grants but it's a good resource and all these are at that site. The indigenous communities funding at EDA the Economic Development Association is out there. This is to help indigenous communities recover from economic impact or help with economic development generally. I think they're accepting these on a rolling basis. I've seen a deadline to September 30 of 2022 I think these are fairly competitive. I could imagine, you know, larger tribal governments or, you know, in the rest of the nation having a lot of opportunity here. I could I could also imagine that for these grants, the more that tribes can work together in Alaska to pull together collaborative arrangements or proposals. I think that could be really impactful statewide economic impact recovery for indigenous communities, those kinds of things would be I think it gives you kind of a greater leg up relative to what other grants might be coming in from elsewhere in the nation. I am not so I don't have a lot of experience with tribal self governance, negotiation cooperative agreements through IHS but there are resources out there. If you're going through a process like that, then these would help you defray the costs of negotiation. Those are due February 10 2022. And then this one is already past kind of it's the Childcare and Development Fund CCDF and it provides childcare stabilization support for the tribal agencies, not sure who those are but they should have applied for these and receive their funds by December 11. I think that the thing to note is that those have to be obligated by September 30 of 2022. So basically, by April, I think in their directive, they in their guidance by April, those the tribal agencies need to say we're able to get these funds obligated by September and and by September they have to have obligated those funds. And if not, I think they probably revert back to the grant granting agency. So that's a short list of opportunities that I saw that from the available grants out there. And if you've got any questions, I think, start on the AFN navigator grant opportunities page, follow up with AML to get connected to the grant writing hotline. And then let's make sure you've got everything you need to to take advantage of any one of these that that's interesting and important to you. And at the very least, you make sure you get your application in for the capital projects fund. I think I wanted to wrap up. Yeah. To to connect kind of everything that we've talked about related to ARPA to start thinking about the bipartisan infrastructure law, or what was the IGA the infrastructure investment JOBS Act? I know that there were good presentations about this at the AFN convention earlier in the week. I think you know, what's important, is, you know, 9 billion or more coming into Alaska

over the next five years through a variety of different funding streams focused on roughly five different buckets of infrastructure. Transportation is roughly 50% of that law, you know, split between ports and harbors and Surface Transportation and airports. Broadband is a significant element of the infrastructure package, water and sewer. You know, the claims that they will eliminate need in Alaska, with a $2 billion investment are incredible and important. The Another category is resilience broadly, it addresses climate and housing and other types of infrastructure. So you've got some really large investments coming in from the federal government. And I think this is an important time to, again, step back and think about what's coming in those different buckets of infrastructure funds. What do we have right now with our BOE funds, and how do we make sure we're not using our funds that are going to be paid for out of out of formula funding through the bipartisan infrastructure or long how do we leverage our funds for best effect? Yes, they can be used for water and sewer projects. Is there are our water and sewer projects on the list that IHS maintains, and that's going to be funded through through this infrastructure funding? If not, you know, how do you get them there? How do you get your projects addressed otherwise? So we talked a little bit about this last week with an THC? How do we, you know, kind of leverage what we have with our FDA, make sure we're not duplicating what could be done with the bipartisan infrastructure law and make the most about that same thing for broadband. How, how do you not address something that's going to get addressed? Elsewhere, but still make necessary improvements and have benefits for your communities? So be thinking about that now. And and we kind of talked about this last week, but I wanted to to reiterate. There's a number of challenges that you know, are out there right now as we move forward with an infrastructure package. One is grant writing capacity. We already know that's the case for arpa. We just ran through five different grants that you know, tribal governments are still working to, to address. So there's a huge kind of dearth of grant writing capacity in the state. Be thinking about for these infrastructure packet, package opportunities, what's the grant writing capacity you have? What do you need and what else do we need? And I would, I would say communicate here AFN navigator to help think through. What's what's our role, right. How do we all support Alaska communities, tribal governments and entities to be able to make the most of this package. What we heard from from Auntie HC and what we're hearing nationally and everywhere is that there are huge supply chain delays. So what you might think should be done this next summer is actually going to take two summers. So be thinking right now about how do we plan for over this next five years, applying for grants having a project that could actually be completed during the during a timeframe and addressing in any of your site supply chain concerns alongside supply chain delays is your workforce Seville availability question. But $2 billion investment into 90 communities, water and sewer needs over the next 10 years. It's gonna take all that anybody who's working on water and sewer all the contractors and consultants and you know, manual labor, everybody. They're gonna be sucked into this opportunity. At the same time, you know, there's ports and harbors and airports and broadband projects, so, we're gonna face some pretty severe workforce availability issues. And that's going to be you know, maybe a good thing for where there's high unemployment or where, you know, folks are struggling to get a job but would be qualified to participate in these opportunities. But it's also going to put just a crunch on projects and how fast they're able to move and I'm going to skip around a little bit and say that procurement is going to place that same crunch as supply chain and workforce. Everybody's going to be looking for you know, the same widget the same valve the same, you know, number of board feet of something.

And for the dozens or hundreds of projects that might be occurring around the state, you're going to have 1000s of those same projects occurring around the nation. And procurement is going to lead to supply chain delays, which is going to make everything else more complicated. And then, you know, as that, you know, complicating your lives along the way, shipping is gonna, you know, be constrained by all of those same issues and or is contributing to both supply chain delays and procurement challenges. So, here's what I think what I'm saying is, you know, as you're thinking about what you're doing with your ARPA funds and how to best leverage those, really spend some time putting some planning efforts into how you address for different projects that are upcoming How will you address any of these different challenges? Competition is in here. There will be competition between tribes. There will be competition between tribes and municipal governments and the state government. And they're all competing nationally for a limited pool of money and even though that pool of money is significant. It's still allocated in kind of finite amounts to lots of different things which will push everybody into a scramble over limited resources. Yet, the bipartisan infrastructure law, it is the funds coming out or over a five year period, which will kind of increase competition within each of those years that those who are ready right now will maybe be more able to take advantage of some of these programs, but yep, maybe you don't have to be part of the first round. Maybe you can spend the time doing the planning, getting design and everything right. And be able to plan for year two or three or four for some of what's coming. There's there's not a huge rush right you've got a couple months right now to get your feet under you make sure you've got a sense of where funds are flowing, and we'll help with that. We've got a sense of that already. I'm sure FNS is doing the same thing. And you know, everybody's here to make sure that Alaska tribal and communities and tribal governments and communities have what they need to be successful. But spend the time thinking about the next few months. What do we need? How do we fit into this broader picture? And then no foes will come out Notice of Funding Opportunities will come out. And you know, you'll have 90 to 180 days to respond to that. So we're probably talking about for a lot of infrastructure package, you know, a six month time horizon before opportunities really land on things that you need to respond to. And that won't be true across the board. Some of them more quickly. Some will take more time. But that's something to be thinking about. We don't have to rush into infrastructure while we're still dealing with and pandemic and the economic impact there. Finally, and we'll learn more along the way as these other funds, infrastructure funds become available, but if if ARPA funds can be any part of a match, then then if we're spending ARPA funds right now on some things and need to use them later for for match or for other components of a project that that are necessary, be thinking about what do you need in reserve to be able to do that? For ARPA, you've got till 2024. To fully expand those. You've got a roughly three year time horizon. So it again doesn't need to be a mad dash to getting all the funds out the door right now. There's not more coming. But be thinking about how do we spread this benefit out as far as we can? And, you know, in relation to the bipartisan infrastructure, law how do we connect the ARPA benefit to this next package of federal investment? With that, I I will stop sharing those slides and stop talking lots and fast and turn it back to what questions do you have anything that strikes you as an issue that you're struggling with or an opportunity or or just what questions are out there as for what when it comes to arpa?

Anybody you could put it in the chat bar to it's okay. Well, I know it's been a full week already. So I can imagine everybody's at a point to be to take a break. I did want to put a couple links in the in the chat bar. The first is I mean, just to make sure you have the link to the navigator program. The second is to the to some of those grants that I highlighted, the capital projects fund is there and again it's it's a pretty straightforward process for on the Treasury website. It's just the same as your sisal for process basically, your Coronavirus, state and local Relief Fund. There's the EDA opportunity indigenous communities funding program. And, and I don't know if this self governance negotiation cooperative agreement grant is something that you could use, but it's certainly one that's available right now. I am glad that this was helpful. There's I tried to be brief because we've gone over Arfa a lot in a number of different forums. And I didn't want to bore you with lots more details but if you have any questions about ARPA or Cares Act, you know, contact your your navigator, your AFN navigator who and I see Greg on here. You know, make sure they've got your questions. They're working closely with your attorneys and auditors and accountants and us to make sure everybody's got as much information as possible. You can contact AML around any of these grant opportunities, I'm putting Don's email in the chat bar, Don daws@html.org is kind of how you get connected to a grant writing hotline. And any of us AML maybe not any of us but a few of us prepared to answer more specific questions about arpa. And to be just generally helpful for anything you're you're struggling with. I think next week we shift from a Thursday schedule to a Tuesday. Schedule. We're going to focus on Cares Act next Tuesday the 21st Think of 11 and I think Chris Lottie will speak and provide an update on Cares Act. I don't know if everybody got an email from us or just generally saw that Treasury has announced or kind of revised its guidance on reporting timelines. And by when you have to obligate you're an expand your your Cares Act funding your CRF Coronavirus relief funds. And you know what was December 31 hard stop is now December 31. You have to have obligated your funds, basically identified where you're going to spend them on different goods and services. And then you have until September to actually you know, final finalize that expenditure and the reporting that's my general understanding of the FAQ and Treasury guidance. But Chris will talk more specifically next week from you know, kind of a legal perspective on what exactly it means how you should be thinking about it. Hopefully it's a little bit of a relief for those who are under pressure to get those funds out. But I know we've still got something of pressure when you have to obligate by the end of the year. Greg, anything, anything missing and all that or any other comments you would add before we wrap up?

No, no, it's I think you've done another good job here today, going through the available uses for this ARPA funding. I know that AML and AFM together appreciate the partnership that we've been able to establish so that we can help folks that are struggling with all these opportunities. I do encourage the folks that are listening to take a look at the FM navigator website on the AFN webpage offer the FN web page which is native Federation one word.org. And there you'll be able to go through and spend some time with the upcoming opportunities and the upcoming deadlines. The Navigators are in place to assist you in every aspect of being able to access this federal funding. So please take advantage of the navigators, I'd say 80% of us are are veteran attorneys and you know we have some skills that will hopefully assist your organization as you try and access all the federal funding that's coming to Alaska. So thank you. No,

thanks. Let's leave it at that. I really appreciate everybody joining us today. Thanks for joining us navigator. If a navigator program focused on ARPA, all the transcripts and recording will go up on the website afterward and you can see all the previous programs to within that calendar on the navigator website. So thanks, everybody. Have a good day. Happy holidays to

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