The Committee on International Relations & Economic Development met on February 19 to hear invited testimony regarding the USMCA, tariffs and their effect on the state, transnational labor flows, economic development programs, and tax incentives.

This report is intended to give you an overview and highlight of the discussions on the various topics the committee took up. This report is not a verbatim transcript of the hearing; it is based upon what was audible or understandable to the observer and the desire to get details out as quickly as possible with few errors or omissions.

 

Opening Comments

  • Chair Anchia- This is an organizational meeting that allows us to know what jurisdictions we have.

 

Carlos Gonzalez Gutierrez, Consul General of Mexico

  • Discusses the positive effects of NAFTA; since NAFTA was signed in 1993, the value of 2-way trade has grown 6-fold.
  • Mexico is Texas’ biggest market with 37 percent of Texas exports going to Mexico and 62 percent of Texas exports go to Mexico.
  • Since NAFTA was signed, unemployment in the Rio Grande Valley has decreased from 21 percent to 6 percent and the labor force has increased by 80 percent.
  • The new trade agreement is still pending, and we must work hard to make sure it is ratified soon.
  • President Obrador and the new administration are committed to maintain fiscal discipline and will try not to increase our public debt.
  • Mexico’s economy depends on private investment both foreign and domestic.
  • President Obrador supports NAFTA.
  • Anchia- What is the President’s position on NAFTA 2.0 and what will the composition of the Mexican congress allow for ratification?
    • President Obrador’s party has a decent lead in both chambers. USMCA has sparked debate and not everything is popular in Mexico. We expect to have the support of Congress to a large extent thanks to the comfortable majorities in the chambers. President has said he aims to have a relationship with the U.S. and will honor Mexico’s international agreements.
  • Anchia- In respect to ratification, what does the timeline look like in Mexico and is there an important tipping point where all countries need to ratify at the same time?
    • The leadership in congress is waiting to see about the calendars; we might be the first ones, but do not want to be the only ones.
  • Anchia- Is the U.S.’s government the same as Mexico when ratifying a bill?
    • USMCA agrees there will be protection for generic medicines for 10 years and to some in Mexico that will be considered a no.
  • Blanco- Regarding the President, can you talk a little bit about what Mexico is doing along the Texas-Mexico border and what that does for infrastructure trade?
    • President Obrador has honored his campaign promise to lower taxes at the border.
    • The stimulus package for the border is designed for people who have lived there for several years
    • It is a reimbursement process; it has been very well received in Mexico.
    • Regarding social spending and infrastructure, President Obrador said we have two Mexicos: one south of Puebla and one north of Mexico City.
    • He wants to focus on bringing down the gap between those, therefore he has signaled different regions that will receive most of his social spending budget, particularly in Durango.
  • Blanco- Are there any details on the type of infrastructure? What is Texas doing to take advantage of any kind of infrastructure spending in Mexico to help with cross border trade?
    • We haven’t made the infrastructure plan public to the whole country.
    • I would be more than happy to come back.
  • Blanco- Has President Obrador made a declaration at the U.S. Mexico border?
    • No, he has said he understands the process behind President Trump’s statement as purely driven by domestic politics and would prefer to stay away from that to be prudent and build a longterm new relationship with the U.S.
  • Blanco-The Mexican government does not perceive a national emergency at the border?
    • No, we do not.
    • In terms of our immigration policy, The President believes that at the core of the policy there should be full respect for human rights.
    • What we are doing is allowing those who are seeking asylum to register with us and continue their way to the northern border.
  • Blanco- There is going to be a diversion of federal dollars to the border region as a result of the national emergency. What would Mexico like to see as to how the U.S. spends money on the border. What are some recommendations that Mexico would make on how some of those federal dollars are spent on the border?
    • I think that on both sides of the border we have failed as a filter that fosters commerce, trade, and investment.

 

Douglas George, Acting Consul General of Canada

  • Canada is the largest trade partner behind Mexico, the U.S. exports $23 billion in goods to Canada annually & import ~$18 billion; the biggest export you send to us is crude oil and vice versa.
  • The U.S. has a $250 million trade surplus with Canada.
  • Our trade is almost perfectly balanced; you sell us $938 million and we sell you $918 million.
  • Discuses Canada and U.S. Trade.
    • We are your number one export country; we buy more from you than anyone else.
    • $9 million in U.S. jobs depend on trade with Canada.
    • 47/50 states have Canada as their 1st, 2nd, or 3rd trade partner.
    • You have a trade surplus of over $40 billion.
    • $2 billion a day crosses the U.S. and Canada border.
  • We need more pipeline capacity; Want to thank you for your support to get the pipelines built.
  • North America has the opportunity to be energy self-sufficient which is important for economy and security.
  • Things are not going as well as they should with regard to steel and aluminum.
    • We object to the U.S. administration’s claims to levy these tariffs on Canada on National Security grounds.
    • It is time for the U.S. to drop these tariffs.
    • In return, Canada imposed tariffs on imports from the U.S. as well.
  • Anchia- Give us a sense of the sequence. Domestic politics, the timing and whether or not there is a fast track mechanism in Canada.
    • Canada has a familiar system to U.S.
    • We have to pass through parliament and the first step was to notify parliament which we did in December.
    • After 21 days, the government will be in a position to introduce legislation.
    • After 2 meetings we go to committees.
    • We do not change the agreement, but we will be subject to discussion.
    • The liberal party has the ability to carry it forward.
    • It will work through our system and come to a vote sometime this year.
    • Elections are in November and that will affect our timing.
    • We have issues with the concessions made on dairy, the Green Party has raised questions on environmental issues, and the Democratic party has labor issues.
    • Canadians have reacted generally positive.
    • Once we have passed, it would come into force once all parties have agreed.
  • Anchia-Last year we passed a “By America” bill that dealt with procurements, TxDOT, and we were going to establish a preference for American steel. Is this a concern?
    • “By America” is a concern, because we do not think these forms of legislation do what they are supposed to do.
    • Has issues with economies of scale and it disrupts supply chains.

 

David Whitley, Texas Secretary of State

  • Our two most important trade relationships are with Mexico and Canada due to NAFTA.
  • Since 2016, we have seen a marked import and export increase.
  • Mexico is our top export destination.
    • We saw an increase from $92 billion in 2016 to $97 billion in 2017 and more than $100 billion in 2018.
    • Texas imported $98 billion from Mexico in 2018.
  • Canada is 3rd largest import source; $18.7 b in imports.
  • Free Trade has been successful in Texas and the new bill maintains the original parts of NAFTA that has produced increases in the past.
  • BTAC allows us to have the right infrastructure, establishes a Texas-Mexico task force on trade transportation, a tradeline program, a public awareness program, implements technology at the border, and allows us to have an active dialogue between public and private sectors.
  • Anchia- We have the largest portion of the border in Texas, what is your office doing in respect to our federal partners? Has your office or the Governor’s office put out anything related to the declared emergency?
    • The Governor wrote a letter urging congress to approve the new NAFTA agreement.
    • I am going to the border this week to ensure that Texas acts as a conduit between businesses, the private sector, and the public sector.
    • Regarding the emergency, I think we should focus on the increase of trade in the Secretary of State’s office.
  • Anchia- Who is your counterpart in Tamaulipas?
    • Governor Francisco Garcia Cabeza de Vaca.
  • Anchia-Who do you work with in Tamaulipas?
    • David Zapata.
  • Anchia- There are a number of Mexican border states, have you been talking with those states?
    • We are focusing on points of entry.
    • My office’s focus and anyone who wants to increase trade should focus on building up the trade structure; can build up the infrastructure by expanding bridges and roads.
  • Anchia-Is there a binational entity you work through when there needs to be declarations?
    • There is a border commission.
  • Anchia-In 2015, when there was a deployment of troops it cost the region millions of dollars, are you familiar with it?
    • No, I am not.
  • Anchia-It would be interesting to understand if declarations of emergency are costly to the Texas economy, especially the border regions. Also whether or not the Secretary of State’s office should be proactive if the economies are proactive.
    • Trade has increased over the last 3 years, but I plan on focusing on ports of entry and strengthening the infrastructure.
  • Blanco- The majority of drugs cross through ports of entry. What is your office doing to influence some of the federal spending to be directed to ports of entry?
    • We are trying to maintain communication between our federal partners and Mexico.
    • The more communication the healthier the recommendations will be.
  • Blanco- Will your office will have a formal proposal to the federal government on national security diversion funds?
    • No, we do not have a formal proposal yet.
  • Blanco-Are you open to sending a formal guidance to the federal government on how to improve on ports of entry as it relates to the declaration of national security?
    • Of course.
  • Romero-What conversations do you plan on having to focus on human rights and the people coming in mass numbers? Have you had conversations about how you are going to deal with those discussions?
    • I had a meeting with the Ambassador from Mexico a couple of weeks ago.
  • Blanco- The five goals you mentioned did not pertain to immigration policies. Have you had specific communications with Qualia and what the cost has been?
    • I know my office has conversations with them very often.
  • Blanco-Given that there we have a surge of DPS troopers, you didn’t talk to anyone down there?
    • I know members from my office were.
  • Anchia- I am trying to find out how proactive you were since the government thought that it was important to send almost 500 troopers down there. I was shocked at the cost and I was wondering how we were assisting them. What would be the costs if we were to shut down one bridge? Did you do anything specific to be prepared for that situation?
    • There was communication about the status of the bridge with my office as it pertained to the focus of DPS resources on the border.
    • I do not have a dollar number for the impact a bridge closure would have on trade.
  • Anchia-Did you offer an official recommendation with DPS and was there communication with your office and DPS?
    • DPS told my office they were diverting resources down there.
  • Anchia-So, there was one-way communication?
    • I do not remember specifically, but I do remember I was informed DPS was sending resources down there.
  • Blanco- I am curious, has there been any discussion on how the Secretary of State’s office could utilize border security funds to improve safety reports? What is the Secretary of State’s position and what are y’all doing to influence dollars to ports of entry? What can we be doing with $700 plus million in the budget, we could use those to secure the border? I support modernizing ports of entry.
    • It is important to differentiate the mission of BTAC with whatever the legislature decided to do with those dollars.
    • My focus is on infrastructure and most of the money is in TX dot’s budget.
    • None of it comes from the $700 million that is appropriated to DPS for border security.
    • We are focusing on beefing up ports of entry to make it as efficient as possible.
  • Blanco- Is it accurate to say you would like to see some of the border security dollars to modernize borders/ports of entry?
    • It is not up to me.
    • I would like to focus on trade and our relationship with Mexico.
  • Blanco- How can you advocate for security dollars to be spent in ports of entry to improve trade?
    • Is your question whether or not there is a roll for our states to play?
    • TX Dot dollars are being spent on that.
  • Blanco- Regarding trump administration, have they been in contact with your office?
  • Blanco-Have you been in contact with your counterparts in Mexico?
  • Blanco-On an institutional basis, you have not had communication with your counterpart in Mexico?

 

Lee Rector, Texas Workforce Investment Council 

  • Discusses history and information about the council.
    • The council was created in 1993.
    • Our role is to develop the highly skilled workforce and advocate for an integrated workforce system.
    • Since 1995 we have been attached to the office of the Governor.
    • There is a council in every state.
  • Between state and federal, the council has 50 “to do”s that have 5 areas.
    • System strategic planning
    • System evaluation and perf management
    • System research
    • Plan approval
    • Maintenance of Texas skill standard
  • The Council is paid through federal workforce funds.
  • Anchia- Near the bottom of your handout it shows an entry about trade adjustment assistance. Can you talk about the silo within the trade adjustment assistance?
    • The council does not look at the specific programs.
    • We look at performance at the program level.
  • Anchia- Could I get the first data set from you? Some say that trade adjustment assistance is not helping, and I would love to see your data.
    • Ed Serna from TWC is invited to answer this question.
    • Serna- We have a specific strategy to help trade affected workers. This year we received $19.9 million in funding that we use to identify and help the individuals with training programs.
  • Anchia- During a trade war where we have tariffs and retaliatory tariffs, if someone was hit hard by retaliatory tariffs, can they apply for trade adjustment assistance?
    • Serna- They can reach out to us and we can help them adjust their skill sets.
  • Anchia- One would be eligible if they were adversely impacted by the impacts of the trade war?
    • Yes, sir.

 

Ed Serna, Texas Workforce Commission

  • There are 13.9 million people in the Texas civil workforce.
  • In 2018, over 96,000 businesses and 729,000 individuals participated in workforce services.
  • In the 2021 biennium, we received $3.7 billion with 83 percent funded by the federal government.
  • TWC helps customers identify the right form of employment through training.
  • Discusses the 8 programs associated with TWC.
    • Federal Work Innovation and Opportunity Act
      • $211 million is allocated to WIOA.
    • Choices Programs
    • Childcare and Development Fund
      • Largest program that TWC administers.
      • In 2019, the TWC is projecting it will fund childcare for 132,000 children per day.
      • Our budget is $810 million.
    • Adult education and Literacy Program
      • In 2019 budget is $80.8 million.
    • Skills Development Fund
      • The 84th legislature transferred the administration to jet program to the TWC.
    • Vocational Rehabilitation Program
      • Legacy VR programs have been combined into a single VR program.
      • $313 million budget.
    • Texas Operation Welcome Home
    • State Unemployment Insurance System (UI)
      • The program ranges from 10 weeks to a max of 26 weeks.
      • There was a low of $68 given per week to $508 per week.
      • In 2018, Texas received 519,000 claims and paid $2 billion in claims.
    • Perez- I represent House District 144, and every time I speak to them, they say we do not have enough skilled labor. What are the top 3 demanded occupations that you see?
      • The high-demand labor is in energy.
      • We struggle in identifying individuals to participate in those programs.
    • Romero- Do you also work with employee and employer relationships and whether or not that person is an employee or subcontractor. What is the potential cost would be in unemployment benefits?
      • I do not have those numbers.
      • The agency takes action to address the misclassification.
    • Romero- How do you find those groups?
      • We get individuals that will contact us and complain they are not getting compensated enough.
    • Romero- So, it is complaint based?
      • Yes, but I am not 100 percent sure.
    • Romero- Do you have anyone investigating those when they are not complaint based?
    • Romero- How many people in that department?
      • Not sure.
    • Romero- How would you find an organization that solely work through 1099s?
      • We have compliance officers that audit businesses’ taxes.
    • Anchia- Of the five bills, three of them relate to misclassification. It would make sense to get those bills together and talk with TWC about how they investigate this type of activity.
    • Romero- Can you explain to the council what you are evaluating?
      • The rules are intended to more clearly define the working relationship between an employer and an employee; that is identified through a marketplace.
      • There will be a check off criteria to determine if the employee is a GIG employee.
    • Romero- So your understanding is that if anyone is hired by marketplace that person is an independent contractor?
      • Even within that, there is a check criterion
    • Romero- Do you believe that that rule could unintentionally increase the number of people who should actually be employees?
      • We are not intending to promote that.
    • Romero- I would like to see what protocols are being placed to make sure that does not happen.
    • Raney- I am more interested in those who are out of the employment cycle. How are we going to increase their opportunities?
      • There are several programs that can help people who are unemployed because of their skill sets.
    • Raney- How does the unemployment rate take into account the people not hunting for work?
      • The challenge for any measurement is those who do not intend to be counted.
      • Some of it is accounted for.
    • Raney- Those who have dropped out of school, what are we doing to seek them out?
      • We have education and literacy programs that can introduce them to new skills.
    • Raney- How can we seek them out, though? Are we going to the Boys and Girls Club?
      • We take advantage of local resource boards.
    • Raney- Can you go broader into your use of community colleges, etc. I am interested in how we are doing this, because we are leaving people behind.
      • I will reach out to your office and go into further detail about this.
    • Anchia-There is a universe of people who have quit looking for jobs and may not be captured in the data set related to unemployment. Do you have a general understanding about the universe of people is regarding what Raney was talking about?
      • The group uses information from the federal government including labor statistics.
    • Anchia-How many people more or less?
      • Not sure.
    • Anchia- Are we talking 100,000 or a million people?
      • Not over a million.
    • Blanco- Can you elaborate on labor shortage in skilled professions post Harvey?
      • There are shortages because of the booming economy in Texas; especially in Austin where the economy is strong.
      • After Harvey, we were working with local community colleges to provide training in construction, plumbing, etc.
    • Anchia- And your recommendation for law making?
      • I think we got the funding and tools we need.
      • HB 1 and SB 1 matched our requests.
      • We just need to continue our efforts in identifying and training them.
    • Raney- A couple years ago, I heard the average age of plumbers was 62. What are we doing in that regard? I am concerned we are leaving people behind, because of technological advances.
      • We concentrate our training dollars on those high demand occupations.
      • We offer high demand jobs for CLSs, pipefitters, electricians, and plumbers.
    • Raney- Should community colleges be funded in the same way or a different way?
      • With our skills development fund, we only give money to community colleges who are partnered with companies.
      • It does not have anything to do with community college funding.
    • Perez- With respect to funding, what is the procedure TWC grants to each region?
      • It depends on the grant type and it is like a procurement.
      • We receive and review the applications.
    • Romero- In dealing with shortage of workforce, have you had cities and counties reach out to you about the competitiveness through their bidding project.
      • I haven’t had any experiences of that, but I know it is an issue.
    • Romero- How, on a percentage basis, have the costs gone up?
      • I do not know anything specifically but can get you a number.

 

Wes Hambrick, Office of State-Federal Relations

  • Gives background on the agency.
    • State-Federal has 4 FTEs in budget structure.
    • We advocate in Washington and promote the interests of Texas.
  • NAFTA 2.0 has been signed and is being sent to Law makers on Capital Hill.
    • We would like to retain the important investor state dispute settlement provision.
    • We want to scrap the idea of a 5-year sunset provision and we do not support the tariffs on steel.
  • Discusses how State-Federal Agency assisted with Hurricane Harvey relief funds.
  • Anchia- We want to make sure that the funds that are still being appropriated are protected. What bout military funds that might be diverted to fund the call up of federal troops at the southern border?
    • We are still waiting to see.
    • I heard that $3 ½ billion will be diverted from military construction projects, but I am not sure what that means quite yet.
  • Anchia- What is the feeling of members at State-fed about this?
    • We will hear in the coming weeks.
    • There will be a process for Congress to disapprove if they want to.
  • Anchia-The administration has not reached out to Whitley about the declaration. Has anyone from the administration reached out to State-Fed?
    • I talked to the White House and counterparts in other states in a joint call.
    • My main takeaway was that the army core funds were not being considered.
  • Anchia- Was it a consultated call?
    • There were communications to our office before the government shut down in December.
  • Anchia- Specifically, there was no input, or did they say he this is what we are doing.
    • Yes, in that range.
  • Blanco- You said $3 ½ billion in military construction, how much of that is slated for Texas?
    • It is not clear where the money is coming from, but I think the $3 ½ billion will be going towards resolving the national emergency.
  • Blanco- What is the state’s position on beefing up security and technology on the border?
    • Are you asking what our offices position is on what that money should be spent on?
  • Blanco- Yes, related to ports of entry.
    • We will take input from the Governor and whatever the legislature recommends.
  • Blanco-We were funded $800 million last biennium, what is the status of reimbursement from the federal government?
    • It is an uphill battle.
    • It is a challenge to ask the federal government for money that we have already spent.
  • Anchia- Is there a concern that $2.4 billion has been spent to secure the border and that the administration is sending a mixed message about the status of the border?
    • My goal is to make sure that the state and federal perspectives are aligned and now they both support border security.
  • Dominguez- Why don’t we have a standard definition of what standard border security is?
    • I am not going to make that call on the hands of the legislature.
  • Dominguez- If the state chose to define border security you would follow that mandate?
    • Of course.
  • Dominguez- Whatever measurement we choose to adopt?

 

John Villareal, Comptroller’s Office

  • Introduces colleagues Russell Gallahan and Frank Alvarez from the comptroller’s office, will be speaking about EDCs, reinvestment zones, abatements, and TIRZs

 

Russell Gallahan, Comptroller’s Office

  • Provides history and overview of Type A and Type B economic development sales tax & Economic Development Corporations (EDC)
    • Type A was authorized in 1989 to promote industrial development and has grown since 1991.
    • Divided into two types of corporations, industrial development in Type A and quality of life programs in Type B
    • Texas is a state full of small cities with a 60% of EDCs are in cities of 5,000 people
    • Type B is much more numerous and have a wider variety of programs.
    • Funding for Type A can be used on a large list of programs directed towards maintaining and creating primary jobs that in turn create exports; difficult to see how some make exports like telephone call centers, but idea is that they would drive orders
    • Type B have a much larger variety of projects as they can do all Type A projects as well as additional Type B list (i.e. retail business incentives, etc. other things that communities decide to pursue)
  • Affordable housing provisions were rarely used as only $9 million out of $700 million was spent on it.
  • Water supply and conservation projects must have voter approval.
  • Presents the committee with a list of Type A & Type B approved expenditure; though Type is less popular due to project restrictions, they have a much more limited amount of oversight
  • If you want to do a Type B project there must be a public hearing and can be petitioned against.
  • Anchia- Where would I run across an A or B corporation in the Dallas/FTW area?
    • Frisco, McKinney, and Arlington has one.
  • Would it be called the Arlington EDC?
    • Actually, Arlington has abolished their EDC, because they are using funds for replacement baseball stadium.
  • Anchia- And EDCs have ability to draw down on these types of sales tax?
    • Yes, can go to voters.
  • Anchia- Is it usually paired with bonded expenditures?
    • Yes, it is probably an EDC’s biggest expenditure, largely due to expenditures on infrastructure projects

 

Frank Alvarez, Comptroller’s Office

  • Works on abatements, reinvestment zones, and TIRZs
  • Provides overview and history of Ch. 311 and 312, Comptroller’s Office has the state’s central registry for TIRZs, Comptroller is statutorily required to maintain central list of reinvestment zones, abatements, TIRZs, etc.
  • Report is compiled from this info & submitted to the Legislature and Governor each even-numbered year; 2018 report is available online
  • We assist local government and the public if they have questions about reinvestment zones, etc.
  • Abatement through Ch. 312 is a local agreement between tax payer and taxing unit that exempts from taxation all or part of increase in value of real or personal property not to exceed 10 years, designed to incentivize & maintain new investment
  • Tax Increment Financing (TIF) is a financing method that local governments use to pay for improvements to draw private investment to an area; redirects some ad valorem tax from an area designated as a TIRZ to pay for improvements
  • County Appraisal Districts (CAD) submit forms for new or modified abatements and reinvestment zones
  • 85 percent of abatements are active assigned abatements, roughly 780 across the state; in effect and assigned to specific business.
  • 560 reinvestment zones known to us, 91% traditional reinvestment zones, but other could include enterprise zones or TIRZs that have abatements included
  • Currently 317 TIRZs on file in 145 cities across Texas
  • Listed key highlights from 2018 biennium report.
    • 105 cities with active assigned reinvestment zone & at least 1 abatement.
    • 60 counties with active assigned reinvestment zone & at least 1 abatement
    • 19 cities with active modified reinvestment zone and 1 abatement.
    • 17 counties with active modified reinvestment zone and 1 abatement.
    • 14 local governments that provide abatements for residential purposes.
    • Sherman and Waco have largest number of residential abatements.
    • 107 cities with at least one active assigned abatement given to industrial commercial business.
  • From 2016-17, total base value of property receiving an abatement was $2.4 billion, total property value abated is $26 billion
  • From 2016 to 2017, total appraised value grew by $1.4 billion, of that $1.3 billion came from county-designated zones, and ~$116.8 million from city zones
  • In 2018 report, 169 abatements and have increased over the years since 2012
  • According to data, there are 317 TIRZs, $422 million value, $1.4 billion in principal & interest due, and $32 billion tax base value of all property located in TIRZ at creation, capture appraised value total of $69 billion & combined total taxable value of $100 billion
  • Anchia- We are not capturing the $100 billion worth of value, is that right?
    • The captured assessed value is $69b, total including this is a little over $100b.

 

John Villareal, Comptroller’s Office

  • Providing overview and history Ch. 313, created in 2001 and HB 3390 changed aspects about the program in 2013
  • Most recent change was last session with SB 277 which limited development that can occur within a certain range of military aviation facilities.
  • In general, an appraised value limitation is an agreement between a company and a school district.
  • In exchange for limiting property tax value, the company creates jobs and provides incentives back to the district; only for the M&O portion, I&S is not part of this
  • Agreement is between districts and companies, Comptroller plays an administrative role
  • Presents data on active projects, over time the program is growing, investments and gross tax benefit have been increasing
  • Data shows participants, two main players: renewable energy & manufacturing
  • In renewable energy it is mostly wind and solar; solar has been playing a larger role, but wind and manufacturing are our largest industries.
  • Presents biennial reports on EDCs, reinvestments, and Tax Code provisions, also present on the Comptroller’s website (Link to reports page)
  • Blanco- Have you created a map where the different agreements are in place?
    • We have that for 4A and 4B.
    • We can look at developing something for 311, 312, and 313.