eNews February 4, 2022
Friday, February 04, 2022 - 05:27pm
This edition of eNews is sponsored by:
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Note – the articles with an asterisk below include updates to items that were covered in the VML 2022 Legislative Bulletin presented as part of yesterday’s Local Government Day.
In this issue:
- Preserve safe communities by protecting local budgets*
- Smart Tax Reform Committee receives bipartisan support
- School board unexpended end of year funds – Updates*
- School construction matching grant fund program – Update
- State compensation for inmates held in local jails bill progresses*
- Bill to strike jail fees amended and reported
- Marcus Alert measure amended and engrossed
- Senate committee reports multiple TDO/ECO bills
- Cybersecurity – Update*
- Sovereign Immunity: Civil actions against localities and local employees bill tabled
- Eminent Domain: Loss of profits and access bills improved, but need to be better*
- House and Senate bills deal with juror compensation costs in civil trials; House version is better for localities
- State Fair Labor Standards Act legislation update*
- Bills that passed out of Counties, Cities and Towns full committee
- Charter Bills that passed out of full committee this week
- Action in the Counties, Cities and Towns subcommittee: Cemeteries, historical sites, and charters*
- Senate General Laws: Bill to be heard again (and opposed); bills reported and passed*
VML News
Local Government Day 2022 is a well-attended success!
Yesterday, more than 400 local government leaders gathered at the Downtown Omni hotel a few blocks from the General Assembly building to learn about pending legislation and budget amendments that could affect their communities. The session began with VML President and City of Fairfax Councilmember Jon Stehle greeting the attendees followed by remarks from Secretary of Public Safety and Homeland Security Sheriff Bob Mosier and Deputy Attorney General Chuck Slemp. Staff from the Virginia Municipal League and the Virginia Association of Counties updated attendees on bills to support, oppose and monitor before the session adjourned. Attendees were encouraged to spend the afternoon attending committees and meeting with their legislators. A room at the Omni was set up with video feeds of the General Assembly committees for attendees. An evening reception concluded the event.
Materials from the event – including the 2022 VML Legislative Bulletin highlighting priority bills and amendments – are available here >.
VML Contact: Rob Bullington, rbullington@vml.org
Finance
Preserve safe communities by protecting local budgets
“That government is, or ought to be, instituted for the common benefit, protection, and security of the people”.
Section 3, Virginia Declaration of Rights; June 12, 1776
Article I, Section 3, Constitution of Virginia
The preservation of public safety is the original core function of government. At Local Government Legislative Day this week, Virginia’s Secretary of Public Safety and Homeland Security Bob Mosier, reminded VML members of this when he told local officials that public safety is a greater responsibility today than ever before.
Officers on the beat. Secure jails. These core services and more are provided by Virginia’s local governments, and they cost money!
As the General assembly considers legislation to exempt groceries from sales taxes, VML encourages legislators to fully replace the funding loss that would be passed on to cities, counties, and towns. If the General Assembly does not replace the lost revenue, localities will be forced to increase property taxes or make budget cuts to public services like law enforcement.
Bills to exempt groceries from state and local sales taxes include SB451 (Boysko), SB380 (McDougle), SB571 (Newman), SB609 (DeSteph), HB90 (McNamara), and HB1008 (Durant). These bills will be heard in the House Appropriations Committee and Senate Finance and Appropriations Committee next week. Please contact your legislators and encourage them to protect public safety and fully replace all lost funding to localities from the repeal of the grocery tax.
Putting the potential loss in perspective
Exempting groceries from the local sales tax would reduce that source of revenue by about 20 percent. Below is an example of the revenue derived by local governments from this local option tax, compared to the most recent law enforcement budgets for those local governments.
Wise County
- 2020 Law Enforcement Budget: $ 6,255,099
- 2020 Local Option 1 Percent Sales Tax: $ 2,864,553
Botetourt County
- 2020 Law Enforcement Budget: $ 4,001,293
- 2020 Local Option 1 Percent Sales Tax: $ 3,281,555
City of Salem
- 2020 Law Enforcement Budget: $ 8,029,268
- 2020 Local Option 1 Percent Sales Tax: $ 7,661,772
City of Petersburg
- 2020 Law Enforcement Budget: $ 10,835,757
- 2020 Local Option 1 Percent Sales Tax: $ 4,592,576
Loudoun County
- 2020 Law Enforcement Budget: $ 68,025,018
- Local Option 1 Percent Sales Tax: $ 80,478,625
City of Virginia Beach
- 2020 Law Enforcement Budget: $ 100,798,095
- 2020 Local Option 1 Percent Sales Tax: $ 67,855,536
VML Contact: Carter Hutchinson, chutchinson@vml.org
Smart Tax Reform Committee receives bipartisan support
Yesterday, a Senate Finance and Appropriations subcommittee recommended forming a special tax reform committee to meet after the adjournment of the 2022 Regular Session to consider bills to change the state income tax, as well as at least one bill to change state and local sales taxes. SB7 (Petersen), SB11 (Suetterlein), and SB560 (Norment) would increase the standard deduction Virginians can take when filing state income taxes, while SB736 (Ruff) would expand the state and local sales tax exemption for data centers. Budget leaders recommended these bills be studied in the offseason so that legislators will be better prepared to consider them during the 2023 Session.
Senator Hanger (R-Augusta), who is carrying the Youngkin Administration’s bill to provide income tax rebates of $300 for individuals and $600 for those filing jointly, agreed with the recommendation that the committee take additional time on bills that would make major changes to revenues.
Major changes to state and local taxes need to be considered carefully with all the facts presented. VML supports efforts by leaders in the General Assembly to act deliberately when it comes to funding core services like public education and law enforcement.
VML Contact: Carter Hutchinson, chutchinson@vml.org
Education
School board unexpended end of year funds – Updates
VML has been tracking several pieces of legislation on this topic during this session.
HB251 (Simonds)
This week the House Education Early Childhood Innovation Subcommittee voted to table HB251 (Simonds), which would codify the ability for local governing bodies and school boards to enter into a collaborative agreement to properly allocate any unexpended funds at the end of a fiscal year.
Currently, any unexpended school funds at the end of the year are returned to the local governing body unless the locality chooses to allow the funds to remain with the school division. This legislation would codify the ability to enter into such agreements while allowing local governing bodies to maintain.
SB481 (McClellan)
Yesterday the Senate Education and Health Committee reported and rereferred to Senate Finance and Appropriations an amended version of SB481(McClellan), which encourages local governing bodies and school boards to enter into a collaborative agreement to let the school board keep unexpended funds at the end of the fiscal and to set aside these unexpended funds in a separate fund for the school board to use for school construction, maintenance, or renovation. The amended bill removes the initially proposed penalty for failing to enter into the agreement and maintains local authority by allowing local governing bodies to keep unexpended funds.
VML supports SB481 as amended and urges our members to express support to their Senators.
HB608 (Bourne)
HB608 (Bourne), which would allow all school boards to keep any unexpended funds instead of the local governing body receiving the funds at the end of the year, was tabled in the House Education Early Childhood Innovation Subcommittee on a vote of 5 to 3.
VML Contact: Josette Bulova, jbulova@vml.org
School construction matching grant fund program – Update
HB563 (O’Quinn) would create a school construction matching grant fund and program to be awarded based on commitment and need as defined in the legislation for school construction projects and renovations. The bill was reported and rereferred to the House Appropriations Committee as amended.
Del. O’Quinn worked with VML to amend HB563 to change the definition of “commitment” from two of three possible requirements to one of the three requirements. This change would provide flexibility to local governing bodies wanting and needing access this fund.
VML supports this bill as amended.
VML Contact: Josette Bulova, jbulova@vml.org
Behavioral Services
State compensation for inmates held in local jails bill progresses
HB989 (Runion) to require the state to pay progressively higher compensation to a local or regional jail for inmates who remain in that facility after the deadline for them to be committed to a state facility was unanimously reported by House Public Safety and referred to House Appropriations on Feb. 4.
VML supports this bill.
This bill takes a graduated approach for additional state funding to local and regional jails after the date of the mailing or electronic transmittal by the clerk of the committing court to the director of the Department of Corrections:
- For the first 60 days following the date of the letter/transmittal, the state would pay $12 per day.
- For the period of more than 60 days, but not more than 90 days, the state would pay $40 per inmate per day.
- For the period of more than 90 days, the state would reimburse the jail for the actual cost of incarceration as calculated in the jail report prepared annually by the Compensation Board.
Del. Runion has introduced a budget amendment to pay the estimated cost of his bill: Item 404#22h. This budget amendment is also in the House Appropriations Committee for consideration.
Please express your support for HB989 to the members of the House Appropriations Committee.
Reasons to support HB989
- State per diem payments to localities are already lagging (i.e., no change in 12 years, when payments were reduced).
- Local and regional jails do not get a choice in keeping state-responsible inmates after the date they should have been transferred to Department of Corrections.
- This issue has gotten worse during the Pandemic; while the Department of Corrections has staffing issues, local and regional jails are not immune to these challenges but have no choice about keeping the state-responsible inmates.
- HB989 addresses some of the real costs faced by local and regional jails.
- Individuals who would be benefit from programs offered by state correctional institutions would be denied access by being kept in the local or regional jail.
VML Contact: Janet Areson, jareson@vml.org
Bill to strike jail fees amended and reported
HB1053 (Shin), was amended and reported by House Public Safety on Feb. 4. The amended measure is a Section 1 bill that directs the State Board of Local and Regional Jails to convene a workgroup to study reduction or elimination of certain fees associated with inmates of local and regional jails and to provide a report by Oct. 1, 2022. VML supports the amended measure.
VML Contact: Janet Areson, jareson@vml.org
Marcus Alert measure amended and engrossed
The Senate accepted and engrossed an amended version of SB361 (Stuart), which would make the implementation of the Marcus Alert protocols an option for localities of 40,000 population or less, and push the final implementation of regions into the program to 2026 to 2028.
All localities would still be required to comply with the local protocols to divert callers from 911 to a 988 crisis call center for risk assessment and engagement including assessment for mobile crisis or community care teams for dispatch, if available.
Localities of 40,000 population or less would not be required to develop protocols for law enforcement participation in the Marcus alert system.
A companion measure, HB1191 (Ransome), is assigned to House Public Safety.
VML is monitoring these bills.
VML Contact: Janet Areson, jareson@vml.org
Senate committee reports multiple TDO/ECO bills
On Feb. 3, Senate Education and Health reported and referred to Senate Finance and Appropriations several bills addressing temporary detention orders and emergency custody orders, including the following:
SB650 (Hanger)
A substitute for SB650 now incorporates SB176 (Peake). This bill would allow a primary law-enforcement agency to transfer custody of a person to the alternative transportation provider immediately upon execution of the emergency custody order. The alternative transportation provider would maintain custody of the person until such time as an evaluation is completed and custody of the person is transferred pursuant to a temporary detention order or is released upon a determination that they do not meet the for temporary detention, including during any period prior to the initiation of transportation of the person and while transportation is being provided. It also requires the Department of Behavioral Health and Developmental Services (DBHDS) to revisit and amend its contract with the alternative transportation providers in regard to the bill.
SB202 (Newman)
SB202 would direct the Secretary of Health and Human Resources and the Secretary of Public Safety and Homeland Security to study options to increase the use of alternative custody arrangements for individuals who are subject to an emergency custody or temporary detention order and to report his findings and recommendations to the Governor and the Chairmen of the House Committees on Appropriations and Health, Welfare and Institutions and the Senate Committees on Education and Health and Finance and Appropriations by Oct.1, 2022.
SB268 (Favola)
A substitute for SB268 would direct a magistrate to consider all options for alternative transportation instead of going directly to local law enforcement for transport for an emergency custody order. It also would allow a primary law-enforcement agency to transfer custody of an individual to the alternative transportation provider immediately upon execution of a temporary detention order. The alternative transportation provider shall maintain custody of the person from the time custody is transferred to the alternative transportation provider by the primary law-enforcement agency until such time as custody of the person is transferred to the temporary detention facility, including during any period prior to the initiation of transportation of the person from the facility to which he was transported.
SB593 (Newman)
SB593 provides that auxiliary police officers may execute emergency custody orders and provide transportation for a person subject to an emergency custody or temporary detention order; adds an employee or designee of the Department of Behavioral Health and Developmental Services to the list of persons who may provide alternative transportation of a person who is subject to an emergency custody or temporary detention order, and provides that, in cases in which transportation of a person subject to an emergency custody order or temporary detention order is ordered to be provided by an alternative transportation provider, the primary law-enforcement agency that executes the order may transfer custody of the person to the alternative transportation provider immediately upon execution of the order. It also directs the Department of Criminal Justice Services to establish compulsory minimum training standards for auxiliary police officers who are called into service solely for the purpose of executing emergency custody orders and providing transportation for such person subject to an emergency custody order or to provide transportation for a person in the temporary detention process.
Contact: Janet Areson, jareson@vml.org
Marijuana
Marijuana legislation update: Movement in the Senate, none in the House
The Senate Committee on Rehabilitation and Social Services this week advanced Senator Ebbin’s SB391 and SB313 on to the Senate Finance and Appropriations Committee for consideration next week. SB391 is the primary marijuana re-enactment bill and contains VML’s preferred language for the Marijuana opt-out referendum which clarifies that Towns have equal opportunity to opt out of marijuana businesses along with cities and counties. It is worth noting that SB391 expanded the opt out referendum to include all marijuana business not just marijuana retail businesses as proposed in SB391 as introduced and as proposed in both House versions of this legislation (Del. Herring ‘s HB430 and Del. Webert’s HB950). Marijuana businesses have already made clear they oppose this new and more expansive opt out language. We hope that members will continue to let their legislators know that it is important to expand opt out authority to towns while the expanded opt out language regarding businesses vs. retail establishments is not our primary concern.
Senator Ebbin also has a second bill (SB313) that provides for legal retail sales to begin prior to the establishment of the full retail market as proposed in SB391, HB430 and HB950. Early retail sales under this approach allows medical dispensaries to sell retail, not medical, marijuana to persons 21+ starting January 1, 2023. These sales would be subject to a local option 3% sales tax in addition to a 21% state tax and the Retail Sales and Use tax. SB313 is now the only vehicle for early sales of marijuana in the Senate and advanced out of the Senate Rehabilitation and Social Services committee on a partisan vote of 8-7.
There are companion bills for the primary re-enactment bills in the House (HB430 Del. Herring and HB950 Del. Webert) as well as early retail sales (HB211 Del. Hodges). Neither HB430 or HB950 include VML’s preferred language clarifying the authority of towns to hold referendums opting out of retail marijuana sales and HB211 does not include the local option 3% tax on early retail sales. These bills have not yet been referred to committee in the House so there has been no opportunity to amend these bills as a result. It is unclear why these bills have not been referred to committee and with little more than a week remaining for the House to act on House bills the absence of action grows more significant with each day.
Local Government Legislation
Cybersecurity – Update
The Senate General Laws and Technology Committee yesterday amended and reported SB764 (Barker), which would require all public bodies to report any known incident that compromises and threatens the security of their information technology systems to the Chief Information Officer (CIO) of the Virginia Information Technology Agency (VITA) within 24 hours from when the incident was discovered.
The amendments adopted change reporting from VITA to the State Fusion Center and creates a work group. These amendments alleviate concerns on State interference and allows for local input.
Although a step in the right direction VML is still concerned with the bill for these reasons:
- Lack of definition of “incident”
- Lack of guidance on what to report and how much to report
- 24-hour time requirement
- Reporting requirement
In addition, localities would still be required to report to the state during the work group’s study.
HB1290 (Hayes) was amended on the House floor to have identical language regarding the creation of a work group as SB764 and was passed to its third reading.
Please continue to contact your legislators’ expressing the concerns related to both SB764 and HB1290.
VML Contact: Josette Bulova, jbulova@vml.org
Sovereign Immunity: Civil actions against localities and local employees bill tabled
HB609 (Bourne) would create a significant change in the ability of citizens to sue local governments and local government employees. The bill would do away with sovereign immunity in suits regarding any alleged harm to a plaintiff. The bill would be extremely costly to all local governments and local political subdivisions.
By a 5 to 3 vote, a House Courts subcommittee recommended tabling the bill. The full committee is likely to follow the subcommittee’s recommendation.
VML Contact: Mark Flynn, markkflynn@gmail.com
Eminent Domain: Loss of profits and access bills improved, but need to be better
The two major eminent domain bills: SB666 (Petersen) and SB694 (Obenshain) were improved significantly in the Senate Judiciary committee, but a few issues remain. The original version of SB666 included lost profits with no time limit, instead of the current three years. It also greatly expanded loss of access. Those issues are now removed.
The remaining issue with SB666 is that the bill would apply the lost profits and access provisions to suits involving temporary action by a governmental entity. If the locality closes a street for three days for a festival or to repair a water main, under the bill that may be compensable to the landowner who can prove lost profits or access during those days.
SB694 (Obenshain) deals with condemnation procedures. The original bill required the locality to pay all the expert witness fees and the landowner’s cost of an appraisal. The bill was amended to remove those provisions.
The bill requires the court to order the locality to pay the owner for a survey the owner contracts for. An amendment to the bill limits survey costs to $7,500, up from $1,000. The original bill had no maximum limit.
SB694 requires a locality condemning a temporary construction easement to state the end date in its condemnation petition. That is practically impossible for larger construction projects. We are working with the patron on language to resolve this issue.
The bills are now to be considered by the full Senate. Senator Obenshain is open addressing the outstanding issues in SB 694. Senator Petersen is more committed to the current version of SB666, but we continue to work the issues. Any resolutions will be on the House side in the next two weeks.
VML Contact: Mark Flynn, markkflynn@gmail.com
House and Senate bills deal with juror compensation costs in civil trials; House version is better for localities
HB378 (Williams Graves) increases the daily compensation of jurors in criminal and civil trials, climbing from the long-standing $30 per day to $50 per day by 2024. SB370 (Lewis) increases the amounts to $100 per day, beginning July 2022. Cities and counties are responsible for the juror costs in civil trials.
VML prefers the House bill.
VML Contact: Mark Flynn, markkflynn@gmail.com
State Fair Labor Standards Act legislation update
HB1173 (Ware) and SB631 (Barker) both provide that government employers are subject to the Fair Labor Standards Act. Therefore, the issues regarding public employers giving compensatory time that was created by recent state legislation are dealt with. HB1173 has passed the House floor. SB631 is in the Senate Commerce and Labor Committee.
HB61 (McGuire) attempts to dictate that employees may serve as volunteers for the same employer. That law would, in many cases, violate the Fair Labor Standards Act. HB1017 (Guzman) adds travel time to hours worked. Those bills remain in the House Commerce and Energy Committee.
VML Contact: Mark Flynn, markkflynn@gmail.com
Bills that passed out of Counties, Cities and Towns full committee
HB277 (Coyner) Recovery residences; disclosure to potential residents that residence is certified. This bill states that a certified recovery residence shall be considered the same as a residential occupancy by a single family for purposes of conditions that can be imposed if there are 50 square feet per bed per sleeping room. There are also provisions about the credentialing of these facilities.
HB445 (Murphy) Broadband service; new residential and commercial development. This bill requires the Department of Housing and Community Development to convene a stakeholder group to evaluate local and state policies, procedures, or ordinances to facilitate the expansion of high-speed broadband service in new residential and commercial development. A report is due to the Broadband Advisory Council on September 30, 2022.
HB377 (Subramanyam) Charitable institutions and associations; local appropriations to faith-based organizations. Allows localities to make appropriations to nonprofit faith-based organizations if they provide community services within the locality without regard to the religious affiliation of the recipients.
VML Contact: Michelle Gowdy, mgowdy@vml.org
Charter Bills that passed out of full committee this week
- HB1 (Wright) Town of South Hill
- HB2 (Wright) Town of Victoria
- HB52 (Morefield) Town of Tazewell
- HB218 (Wright) Town of Clarksville
- HB219 (Wright) Town of Kenbridge
- HB220 (Wright) Town of Blackstone
- HB315 (Rasoul) City of Roanoke
- HB321 (Williams Graves) City of Norfolk
- HB339 (Simon) City of Falls Church
- HB556 (O’Quinn) City of Bristol
- HB700 (Keam) Town of Vienna
- HB822 (Torian) Town of Occoquan
- HB1028 (LaRock) Town of Lovettsville
- HB1163 (Greenhalgh) City of Virginia Beach
- HB1256 (Wright) Town of Chase City
VML Contact: Michelle Gowdy, mgowdy@vml.org
Action in the Counties, Cities and Towns subcommittee: Cemeteries, historical sites, and charters
HB961 (Roem) Cemeteries; registration, publication prior to sale. As introduced this bill requires every locality to adopt an ordinance setting forth a register of identified cemeteries, graveyards, or other places of burial located on private property not belonging to any memorial or monumental association. The bill provides that the official local register shall include an official map and that both the register and map shall be available on the locality’s website if one exists. The bill also provides that the governing body shall publish a notice in a newspaper having general circulation in the locality at least two weeks prior to the sale of any property on such registry, or as soon thereafter as possible, and shall also publish the notice on the locality’s website if one exists. As amended this legislation uses the word “may” instead of “shall” providing a tool but not a mandate.
HB1210 (Hope) Preservation of historical sites and architectural areas. This bill was significantly watered down during the Counties, Cities and Towns subcommittee this morning. As originally written if locality has adopted an ordinance setting out historic landmarks within the locality as established by the Virginia Board of Historic Resources or other structures as defined by 15.2-2201 an application may be filed to preserve or accommodate historical or archaeological resources. Under this bill the filing of the application shall stay the locality from issuing a permit to raze or demolish the structure until 30 days after the rendering of the final decision of the governing body. In addition, the affected property owner, the applicant or any resident who provided public input may appeal to the circuit court for review of any final decision of the governing body. The amendments this morning only allow for the affected property owner to appeal to the circuit court.
Charter bills
- HB83 (Kilgore) St. Charles, Town of; termination of township.
- HB904 (Kilgore) Pound, Town of; repealing charter. This repeal was extended to July 1 of 2023.
- HB1258 (Wright) La Crosse, Town of; amending charter, municipal elections.
- HB1311 (Avoli) Waynesboro, City of; elections and appointments.
VML Contact: Michelle Gowdy, mgowdy@vml.org
Senate General Laws: Bill to be heard again (and to be opposed); bills reported and passed
Oppose – Lobbying bill to be heard again next Wednesday, Feb. 9
SB224 (McPike) Lobbying local government officers or employees; notice; requirement; fee. This bill was heard in Senate General Laws Wednesday afternoon and will be heard again Feb. 9.
Items of concern:
- As originally proposed the bill would require notification to local clerks if compensated for attempting to influence certain local government actions.
- This legislation would require individuals who influence or attempt to influence a local government to provide notice to the locality’s clerk and pay a fee.
- The notice would have to be given 15 days prior to the first attempt to communicate with the local government and would need to include the individual’s name, telephone number and business address as well as the local government action that the individual seeks to influence.
- Qualifying “local government actions” include any enactment, repeal or modification of an ordinance or resolution including actions related to local taxes, the budget and land use proceedings. It does not apply to attorneys clearly identified on a land use application, any contractor or employee performing services for local government or local government employees or officers acting in their official capacity.
- The notice would be good for one year. Failure to comply with the notification/fee requirement would result in a class one misdemeanor (which includes potential jail time).
Reasons to oppose the proposed substitute:
- The proposed amended bill requires reporting to the Secretary of the Commonwealth instead of the local clerk.
- Also, it allows for a $75 onetime fee if the compensated individual is or will be providing notice in relation to two or more local government actions or localities in addition to the $25 fee.
FOIA bill reported from General Laws
SB200 (Hashmi) Virginia Freedom of Information Act; record exclusions; administrative investigations; onsite sewage complaints. This bill makes records of active investigations and the names, addresses and telephone numbers of complainants regarding active investigations of onsite sewage complaints discretionary when the complaint is with the Department of Health or the Department of Environmental Quality.
Bills that passed out of General Laws
HB615 (Roem) Sale of cemeteries owned by a locality; notice to descendants. Provides that no cemetery owned by a county or city shall be sold to a private owner unless the county or city has made a good faith effort to ensure, prior to sale, that the ownership of such cemetery is vested in the estate of the last owner of record or that permission for the sale has been granted by the family members or descendants of such owner. This is a problematic bill for localities, but Delegate Roem is discussing the bill with local governments.
HB429 (Bulova) Virginia Public Procurement Act; architectural and professional engineering term contracting. This bill will only apply to contracts entered into on or after July 1, 2022. The proposed legislation makes architectural and professional engineering contracts simpler by allowing renewals up to 3 years at the option of the public body and the sum of all projects shall not exceed $10 million or $2.5 million for a single project.
HB384 (Davis) State and local employees; freedoms of conscience and expression. This proposed legislation states that employees of any unit of local government shall not be penalized for failing to speak a message if it would violate the employee’s deeply held beliefs, values, or conscience. The legislation does not include persons appointed to a position.
VML Contact: Michelle Gowdy, mgowdy@vml.org
