 All right I'll get started then. James Pepper chair of the Vermont Cannabis Control Board. It is February 22nd 2022 our second meeting of the day on 2 22 22 and I'll call this meeting to order. This is our typical last Tuesday of the month after hours public comment session and we don't have any business of the board to go over today. So we're just here strictly to take public comment on anything that's going on. I would just say before we do that we've had kind of an extensive public comment period last last Friday. And so you know I can't expect there's too much more on people's minds at this point. But maybe I'm wrong and you know we'll be here for the next hour you know again just we try to prioritize first time commenters over people who have already commented. If you'd like to comment just raise your virtual hands and you know we try not to just answer direct questions. We do walk into kind of a little bit of a ethical gray area when we just kind of give our advice our opinions about specific questions that relate to specific perspective licensees. But I will just say at the outset you know we did receive a comment last Friday about what sort of legislation the board or is is moving related to cannabis. So I figured I might just start by addressing that issue first just so it's not kind of in response to a question but kind of just in general. The board has made a number of recommendations to the legislature. Some of them have been kind of brought into various pieces of legislation. The first and probably most important is the fee bill. So our recommended fee structure has been adopted in H-701 and that bill is kind of in the Senate currently. It's past the House and in that bill you can see kind of the various license types and associated tiers and then the kind of associated fees with all of those license types and tiers that the House passed. There will likely be some modifications in the Senate and hopefully that bill kind of moves pretty quickly because obviously we can't open the market until we have our fees in place. Another bill is the Budget Adjustment Act. This bill contains the requested positions the staff that we've asked for and you know this bill has passed the House. The House gave us three positions. The Senate gave us eight positions and right now the bill is in a conference committee and the kind of I mean this bill does a lot of various kind of adjustments to the overall state budget so it's not specific to cannabis but this you know whether we get three or eight or some number in between is you know being negotiated by the House and the Senate currently. We have S188. This is a bill about regulating small outdoor cultivators as farming and that bill is was taken up today in the Senate Finance Committee. It really kind of clarifies that small outdoor cultivators you know kind of clarifies some of the issues that apply to small outdoor cultivation including whether or not Act 250 applies local zoning. What's the kind of interplay between small outdoor cannabis cultivation and the current use program and other exemptions for farmers. It clears up a lot of those issues. And then finally there's a bill in the House of Ops Committee currently H548. This is just kind of a technical amendments miscellaneous bill. This does currently it does 6 things. It eliminates the prohibition on solid concentrates above 60 percent. It clarifies that cannabis products can contain both THC and CBD. It allows cannabis workers to move from one business one cannabis establishment to another without having to reapply for a new cannabis license or employee ID card. It allows testing facilities to operate in multiple locations and it ensures that all licensees including integrated licensees have independent third party testing for their products. And you know we also because we submitted a report after the introduction of this bill so there might be some additions to the bill you know around allowing authorizing delivery authorizing special event licensing potentially authorizing on-site consumption online ordering and then giving the authority to the cannabis board to regulate synthetic cannabinoids. So those are the main pieces of legislative legislation related to our related to our recommendations. There's other cannabis bills that are out there but those are the kind of primary ones related to recommendations that we've submitted to the legislature. So with that introduction I would just open up to public comment and again if you have joined via the link joined by video feel free to raise your virtual and once we get through kind of the initial round of those we will pause and move to people that have joined by by phone. All right. If you've joined by phone and you'd like to make a public comment please just hit star six to unmute yourself. Chair Pepper this is Ben Mervis on you to have a phone would it be all right if I make a comment. Yeah please go ahead. Thank you and I'll go I thank you for hosting these I think this is a really important session that you all have dedicated yourselves to. My comment is just about application periods and something that I've mentioned briefly before but I just continue to hear from folks who are still getting themselves together to apply still deciding what licensees they will apply for of course every line myself included so that we are against the clock for the opening bell of the market. Hopefully that will all be on time but I think any communication that you all can provide just on future application windows I know that it may not be firm information quite yet but I think there's a lot of questions about again what if we are not ready to submit our application during the application periods will those periods strictly be limited to the 30 days or will they be extended. So anything that you all can do on the board to think about that and communicate it I think it would put some folks to be especially in the social social equity cohort of folks who are not only trying to figure out what business is viable but also looking for funding and everything else needed for the application and with that thank you so much. Thanks Ben. So again you know this is our public comment period we don't have any business of the board. If you'd like to make a public comment please just raise your virtual hands. If you join by phone you can hit star six to unmute yourself and we'll try and call in the order that people raise their hands. If if no one's commenting you know Julie Kyle feel free to kind of turn your video off. Otherwise you know I'll I'll we'll be here for an hour regardless. So Fran do you want to join. Yes thank you for taking my comments and for your late work hours. I'm going to pick up where Amelia left off today. As I've seen especially today in your meeting you are severely limited by statute. This is something of course that you cannot overcome at this time but we really appreciate you bringing these points up especially in these recorded sessions so that we can have legislators go in and really dive a little deeper into the needs of the medical patient. Amelia's right and Tito's right. First of all people need more plants immediately. I don't know why we're restricting medical patients at the legislative level but anything you can do to show legislators that this is a logical and safe step to take. You've been generous not to restrict caregivers too much. You've been generous to consider expanding caregiving but that will not happen as I understand it right now until legislative changes are made. So we are working we are contacting legislators. Another issue I spoke recently at a meeting in Bellows Falls and I was concerned that they had just gone to a meeting with a senator who's involved in this and not gotten any real information from them. And I wonder what is going on there because we were able to three of three of the advocates were able to inform these people better than the legislators. So I'm concerned about the bills passing at crossover and I'm hoping that they will. I'm hoping anybody listening to us now will hear this because we've got people that have suffered through this medical program since its inception one point. I said that I felt that it had failed and you disagree with me to some degree but my statement is made based on the people that I saw that did suffer from a lack of clean effective and affordable medicine and in some cases suffered loss of life. So anyway that'll be my comment for right now and I thank you for taking this evening. Yeah thank you Fran. And I guess I should have mentioned also at the outset that S186 there is a bill that's been referred to the Senate Health and Welfare Committee specifically on the medical side of things. It's not explicitly from our recommendations but it does encapsulate a lot of the well I should say some of the concerns that have been brought before the board around patient to caregiver ratios plan counts, et cetera. Thank you but I'd say one more thing if I may. In S186 for some reason there's a poison pill of sorts that would limit a patient from being a caregiver to two patients only a person who's not a patient could be a caregiver to two patients and I don't understand that I would be concerned about that. Again when we got the initial okay to have patients be caregivers for other patients that was due to the fact that was an S16 way back and that was due to the fact that then Governor Shumlin his father chose to use a registered patient who wasn't allowed at that time to caregiver for others to do that. And so that shows you how important caregivers are so thank you. Yeah. So just anyone who's joined since we started this is our public comment window. We don't again have any business of the board other than to receive public comments this evening. If you joined via the phone you can hit star six to unmute yourself. If you have joined via the link feel free to just raise your virtual hand we'll call you kind of in the order that you raise your hands. And otherwise we're just going to be kind of sitting here in silence. And you know I recognize that a lot of the folks that have joined tonight you know attend our meetings regularly and have provided public comment pretty regularly. So maybe you feel like you don't have anything new to say but you know I got to just reiterate that you know your public comments have been instrumental in kind of getting us to where we are today. And so just feel free to kind of you know bring up some of these the same issues. Otherwise Julie Kyle I'm totally comfortable with you guys turning off your cameras if you guys want to kind of do some other work while we wait for comments. Nelia. Yeah I just wanted to take a second and recognize all of the all of the work and all of the care that you guys have put into improving the medical program. I know that you're bound by insane restrictions and by some really crappy legislation before you. But you guys have really been like a pleasure to work with for the last year. And I think that all of us at least on my team can tell that you really do have the best interest of the patients at heart. And I really don't have anything new to say. I think I've beat so many dead horses at this point. But I just wanted to recognize you guys and say that we appreciate you. Well thanks Nelia. You've been with us from the beginning. So we appreciate you too. I don't think it's been quite a year but the fact that that was even mentioned is crazy to me in a sense. Getting pretty close to a year. Well that's right. So I have one email I need to write again. Just anyone who wants to publicly comment please just kind of chime in raise your hand. We'll call on you or hit star six if you'd like to unmute yourself if you join via phone. And I see maybe a three or four three three four number that unmuted. Hi this is Ben again. I wasn't sure if I had shared this before but in case anybody has missed it Massachusetts I'm not sure if they've actually moved forward with this yet but there are discussions about moving forward with social or on-site consumption with a data test of I believe the last I checked on it was six locations and that is still exclusive to the social equity applicants. So just in case you had not seen that thought that was very exciting. Yeah good to know. As I mentioned you know we made that recommendation to the legislature and you know I think that the Housegov ops committee is open to hearing more testimony. I don't know how if they're willing to commit to it quite yet but it's nice to know that at least if our neighbors are doing it then maybe we can figure it out too. It did look like a number ending in one nine four five unmuted. OK yes thank you again. This is Joseph Carter playing field. I raise this issue during one of the previous meetings. It seems to me and perhaps I am not fully abreast of the evolution of the rules and regulations at this point. But a couple of weeks ago my takeaway impression was that the price of admission for a tier one cultivator was inclusive of product liability insurance and an escrow account requirement that theoretically could approximate fifteen thousand dollars. And that's just for that to to meet those requirements. It doesn't include any of the inputs and other costs associated with being a tier one cultivator. And I'm wondering if there's been any movement on that or consideration of those costs potential cost barriers to the high participation of small growers. Yeah thank you for your comment. We don't generally respond to questions directly here. But I would say that we require reasonable commercially reasonable levels of insurance and the escrow is a backup if you are unable to secure insurance. So we do have specific escrow amounts which are really to cover your liabilities for people that are working at your facility or people that are for business owners. So it's commercially reasonable levels of insurance or an escrow account. Has there been thank you for that. Has there been any how do you say update on the possible cost of that insurance for someone who's growing 125 plants with only family and members working on the endeavor. So again it's it's hard for us to answer your specific questions before without us kind of getting into the gray area of us giving you advice or kind of providing specific legal advice to anyone you know these are kind of advisory opinions which we should really shy away from. I can say that we're having a banking and financial services networking event on Thursday from 5 to 7 p.m. this week and one of the people we'll be hearing from is the director of finances and accounting for Vermont Patients Alliance and that's a dispensary that's been in existence for a number of years now. They've had to get insurance for their operation and one of the questions I'm going to be asking them is what does that insurance look like? What was it like getting it? What sort of potential security upgrades that you need to get in order to secure insurance just kind of walk us through that that process. So and that person will be open to questions from members of the public as well at that event. OK. Thank you for that. One one further related question. I've heard from some people that they're they're getting insurance out of Colorado. Is there any requirement that the insurance be provided through a Vermont based broker? So no we don't have that as one of our requirements. Thank you. Yep. Thank you. Ivan. Yeah. How's it going? I do have a few questions like the gentleman just asked. Is it instead of asking you where you can't answer? Is it possible to just email ccb.info to find out? Answer those questions or do I must I chime into the boards and ask ask manually? It's nice. You know essentially the problem is we can't kind of give specific advice to specific perspective applicants. But if we see kind of the same questions coming up over and over again we can provide guidance to them guidance to the public the general public. So it would be best if you have specific questions like the prior caller to email the board the website you just gave and you know we can provide kind of I know it seems a little bit of a like two step dance but it's just easier for us instead of kind of saying well you know you need to do this or you should do that for us to kind of give general guidance to the public on all of these issues. Yeah no worries that makes sense. It's quite literally questions just something like an application checklist just things I want to make sure I have an order to apply you know simple things that I've read the regulations I've read everything I mean they're just small bits in between that I just want to make sure and I guess yeah it would be pertaining to us personally but mostly general generality as well. So I'll do that. I can say that you know we recognize that our regulations leave some ambiguity. I mean just think about just commercially reasonable levels of insurance or kind of what can you add to kind of cannabis products if you're you know creating an edible for instance or you know so what we intend to do is to have both policies and guidance that are kind of easily accessible easily digestible for folks to walk through all the areas that might be ambiguous and that's why it's very helpful for us to hear the questions so that when we create that guidance document that we can make sure that we're addressing kind of people specific questions. And I don't know if I don't know if you did mention it but Thursday as part of your the conversation you're leading I know that you're planning at least to go over some of the pre qualification you know application parameters and I don't know if now is a time to to say whether or not we're at a point where we can start sharing things because I know we're rushing to to make sure we're ready but that might help alleviate some of Ivan's you know initial concerns as as it relates to the application. Yeah if you're able to tune in on Thursday from five to seven I think that's more of a kind of question and answer format situation. So I think that you know when it comes to the pre qualification process certainly when it comes to kind of banking or insurance issues our panelists you know we have a person from VSECU that's been in charge of kind of their cannabis portfolio. So the the person who's kind of you know we have three dispensaries. They are all banking with one institution so that you know VSECU is coming to kind of discuss their perspective about banking and we have you know one of the dispensaries kind of directors coming to talk about their perspective as a licensee about banking. Then we have the person who kind of literally wrote the book or the chapter of the larger book about cannabis banking kind of giving us a broad picture of the national situation with cannabis banking and then I'll be discussing the pre qualification process. So that's kind of going to be at our event on Thursday and our panelists certainly are able to kind of answer questions to the best of their ability and I'll be there to kind of discuss and answer questions about our pre qualification process. And just another and just another general comment because you kind of alluded to fact the fact that we do have some ambiguous language amongst a lot of our rules just just for folks listening. I think between the three of us there's like 10 to 15 guidance and policy documents currently being drafted and worked on and reviewed by staff and agency partners and other you know around state government. So there's a lot of information kind of coming. We recognize that it's not all out yet but you know we're working on everything. So I'll just mention again to anyone who's joined since we started. This is our kind of public comment after hours public comment period you know we're trying to accommodate people that can't join our meetings or stick around throughout all of them waiting for our public comment period. So you know if you have a public comment about anything we're doing or specifically about any of the rules we drafted you know now's the time. This isn't the last time but now is a good time to kind of raise those with us and you know if no one's commenting we're going to just sit here until 7 o'clock and so feel free to kind of maybe think about your question but anytime you want to make a comment just jump right in. This is Joseph Carter again. Yep. Not to belabor the point but though your language concerning insurance may be vague it's my understanding from talking to some people in the insurance industry they have sort of a minimum level of coverage and currently the premium on that that's for everybody not it's not on an individual basis it's just what the insurance industry would charge in Vermont for insurance. Despite your category of participation tier one manufacturer or whatever the minimum insurance is currently going to cost around $7,500 so I'm wondering in the meeting on Thursday is there going to be someone there from the insurance industry to talk about this. So no this the meeting on Wednesday is mostly around banking however I was going to just talk to our panelist who is a dispensary director about the insurance question so he will you know having been through this for kind of a small to medium size grow operation in Montpelier he'll be able to kind of speak to what hoops he had to jump through and what the kind of conversation was like with his insurer but no we don't have anyone specifically from the insurance company is coming and you know again we're not trying to endorse anyone insurance company we're not trying to give the impression that we're endorsing anyone so really it's hard for us to kind of bring in an insurer and say you know this is the company that's willing to do this you know so we're trying to kind of keep things general with you know a financial institution that's actually banked cannabis money here in Vermont and actual licensees had to deal with banking insurance issues and then one of our personal consultants they can talk about the kind of national national scene and what to expect you know maybe down the road and what to expect if no insurance companies in Vermont or financial institutions in Vermont are willing to kind of step up and fill this kind of gap. So that's encouraging is there someone who could come from the Vermont nature of insurance state insurance commission. It's possible. Maybe on the Thursday. Yep it's possible for sure we can kind of put that in the queue of potential issues to deal with. Appreciate it. Thank you. Tree frog. Hey so this is kind of just a comment as to what I've seen I know is late to this meeting so it might have been discussed or commented or planned on for the Thursday meeting but in terms of the pre qualifications and this will be true for the applications just in trying to get fingerprinted. I can't get fingerprints until they have a number associated to an agency to send those fingerprints for the federal background checks. When I talked to the guy in Waterbury he said that you guys were working on that with the federal government to try to get some kind of released form for us to follow. I didn't know if that's something you guys are working on or we're aware of it or where that stood. And as far as I understand the VCIC is where I can get my state record the the fingerprints are for a federal background check and you're going to require both of those right. Yeah. So everything that we require is in statute. Feel free to kind of peruse title 7 around cannabis. And you know we can't get around what's required by statute. And so yes we are going to require fingerprint supported background check and state background check. It can be done simultaneously. I will you know this question specifically I will be addressing on Thursday so I'd prefer to just do it in that venue because I'm I'm sure I will have to cover it there as well. Some of that information is on our website right Pepper. I believe it is. Yeah I didn't know it's put up. Yeah. It's cp.vermont.gov slash qualify maybe. Yeah I think I've seen most of what the qualifications were I guess my I figured that the background the fingerprinting would be for the federal check and that the C. V. C. I. C. is for the state. My only real concern was that the required form with the number for the fingerprinting because I've been told I can't get fingerprints done at all without that they won't just fingerprint and turn it over to a person for fair of contamination or you know other things. So I was I was just curious to make sure that that we were going to get that number and that we were going to have to try to sidestep this whole thing. But it sounds like you guys are working on that. Yeah. All right. I I'm I guess I'm going to it now. I mean essentially what's going on is that the federal government the FBI needs to approve our application to receive fingerprints through V. C. I. C. the Vermont Center for Crime and the Vermont Crime Information Center. They have not done that. You know there's about 300 agencies in Vermont that are approved to receive fingerprints you know whenever the legislature authorizes a new agency they have to send a letter to the to the federal government the FBI. They need to approve it. They seem to be backlogged right now and you know because we submitted this last year. And so we expect it to happen any day. But I guess the kind of bottom line is is don't rush out to get fingerprint right now. You know the window has not opened yet for pre qualification and you know there's no real rush to get your fingerprints done right now. And if we do not get that authorization authorization by March 16th which is when the window for pre qualification opens then we do have an alternative and we can kind of walk people through that on at the event on Thursday. That sounds exciting to hear that sounds perfect. My other question I guess would be do you still envision us being on target for May 1st licenses being distributed or do you guys seeing any hang ups as we come into the final home stretch of this. So I really want to avoid answering direct questions. I'll do this one last time but essentially we have done everything we can as a board to be prepared for issuing licenses on May 1st. There now we're at the point where there are only things that are outside of our control that will dictate whether or not we can actually do that. One a fee bill has to be passed. We can't open any licensing windows without a fee bill being passed. Two we need staff to actually review those licenses. Currently you know there's a negotiation happening between the House and the Senate between how much or any when they're going to give us any sort of staff. Three we need to have a licensing portal opened. We are we have signed a contract with a company to create a licensing portal and they know that it needs to happen by April 1st. And so that the wheels are in motion there. So all of those things are somewhat outside of our control and we need this fingerprint issue resolved as well. So you know from a purely kind of a regulatory standpoint we're ready to go as a board but those other pieces need to fall into place. Nate. Hi thanks for taking this time I really appreciate it. What you guys are doing here. My question is if when one of you could speak to whether franchises will be allowed to enter the Vermont cannabis space particularly as retailers. Yeah thanks for the comment. So I mean the short answer is no. And that's that's there's a statutory provision that prevents franchises in the state. Understood. Thank you. Yep. So again you know just we're here to receive public comments. You know we are trying to kind of expand our access to the public. So we hold these kind of once a month after our public comment sessions. If you have any comments at all please feel free to kind of chime in. You know you can hit star six to unmute your phone or you can just kind of raise your virtual hand and we'll try and call on you and well we'll call on you as soon as you raise your hand at this point. Ivan. Would it be possible to open up the the text chat feature if anyone would want to network. I mean I would share my info with anyone you know to to connect with. Is that possible or no. So I would just say because of the public records laws we would have to publish the chat so we just decided to disable it's a little bit easier for us and there's some gray areas about what's a public comment and what's kind of a side conversation. So. Yeah that's that's it. That's the exciting that's the exciting part about COVID and all these you know software teams. What is a public record. I will say the three of us typically don't join all together at the after hours events that are going to be happening every other Thursday this one this Thursday and that's so we don't inevitably create a public record or one of the one of the reasons and to give folks that comfortability. So the chat feature will be available on Thursday. I was going to say that our the chat's been very active in those after hours meetings. But again it's not it's not a formal board meeting so the rules are different. Got you completely understand. Thank you. Jared. Yeah hi I don't know how to phrase this it's not going to sound like a question but will there be a tax on wholesale sales to retailers. I know that sounds like a question. Is that something you can answer. You know I can direct you to the section of the law about taxes and I can direct you to a bill that's proposing to impose a wholesaler tax I guess the short answer is no. No you can't answer no there won't be. No there's no tax on wholesales except there is a bill that is proposing to impose one. The reason I ask is because I've read that in California particularly the taxes are so high and the supply is great driving down prices that a lot of the supply is being siphoned off into the black market just because they can't finance their legal growth business. That's that's a comment. Yeah thanks for that. It's always helpful to kind of get get a national perspective on what other states are going through. Benjamin. Hello thanks for everything you guys do. I just joined and sorry if this was already covered but I just want to try to clarify on some of the fencing requirements for outdoor cultivation. For example I'm wondering if I have a six foot fence woven wire with wire on top and I also have all of the you know applicable measures like floodlight security cameras and all those check marks for my tier grow. Is that going to be sufficient fencing? Thank you. Yeah so I mean again we try not to answer questions during these sessions. I know I've been breaking that kind of cardinal role a couple of times but it's specifically for these reasons. If we if we were to give you an answer right now that's not legally binding but you would probably take it as such and then you might do it and so I mean we just can't give advisory opinions like that during these meetings. So I'm sorry you know if you want to submit your question to the board you know again we do collect these questions and it's not going to get lost on us that there's questions around fencing and what's required and what's allowable and what's not. We are producing as Kyle mentioned a guidance document specifically around security requirements for outdoor and indoor cultivation that will have guidance to you know perspective licensees about this issue but we can answer kind of every potential hypothetical here because it just gets us down to a road where you all are relying on our comments in our in our responses and we just can't kind of get into that position now but I will say that we recognize that there are a lot of questions. The licensing is right around the corner and you know we are in the midst of providing extensive guidance documents on every aspect of our rules. Well thank you for your time Mr. Pepper I appreciate everything you guys do. Thanks. We will we will have a guidance document specifically around fencing as Pepper alluded to and if I can't remember what the data that meeting was where we had like a robust discussion around fencing a couple of weeks ago but if you go to Orca and sift back a couple Mondays there was a presentation that I did specifically on what we would consider appropriate fencing. Is it right to say Pepper that you know some of these questions could be answered for folks through the pre qualification process. You know if they're putting forward some of their information it's an opportunity to to sort of put like a draft in front of the board and get that pre qualification approval. Is that I mean I mean probably not for fencing but for some of the other questions that we're getting is that a good opportunity for folks if they're doing the pre qualification process. On this issue I would say probably not you know pre qualification really is about ensuring that prospective licensees aren't going aren't making capital expenditures without getting some clearance from the board that they can actually participate. And I say that because there are because of the dual status of cannabis because it's federally illegal there are certain people that the board has to categorically disqualify from owning a cannabis license. Those are folks just from a very general standpoint that have ties to organized crime that have kind of recent embezzlement or fraud convictions. You know everything is contained in the FinCEN guidance. And so really the pre qualification process is aimed at ensuring that anyone who wants to participate in this industry kind of puts forward you know their financiers their kind of business partners and ensuring that all of those folks can act can actually are actually qualified to eventually get a license. So I don't think fencing or kind of security requirements would fit into that. I think it's just too much of a kind of strain on the board to kind of focus on pre qualifying folks and then also kind of pre qualifying people's business plans or kind of specific aspects of their business plans. Real quick I know I just spoke but Kyle could you maybe point me in the direction to that specific talk that you were talking about there regards to fencing. It was probably the seventh right February 7th. They all honestly have blended together in my the weeks have blended together. Yeah let me let me look it up really quick and I'll just I'll just I'll share that out loud. Give me one second. So I think it was on the 6th of February. Should sound right. Is that a Sunday. Maybe that's the day I made the presentation. Yes it was probably the 7th. I mean yeah it definitely was the 7th. If you go to Orca Media and you just explore and you search the Cannabis Control Board as a keyword they should have all of our our videos up there. Thank you. So we have about 10 minutes left. You know it's just for the last time is a public comment session. You know this is an after hours meeting we we generally hold board meetings on Mondays at 11 where we actually do kind of substantive work. We have we held one earlier today on rules 3 and 4 and but but these are an opportunity for people to kind of give us direction give us comments give us their concerns their thoughts let us know the direction they'd like the board to go in any number of areas either kind of more short term or more long term. And we try not to answer questions just because for some of the reasons I've stated in the past. But you know we do collect questions and try and you know have them shape our guidance documents which we are in the process of drafting. So if anyone has again any comments feel free to just kind of chime in. You can hit star six to unmute your phone if you join by phone. You can raise your kind of virtual hand if you if you want to do it that way. You know just a few other things to note. I'll be on Vermont Vermont edition tomorrow at noon with Susanna Davis and Karen Horne from the League of Cities and Towns. We're doing our kind of traditional or kind of our new kind of networking events social equity economic empowerment networking event on Thursday from five to seven that kind of link is available on our website. That one is specifically going to be around banking and financial services. We have a number of panelists that have experience in those areas that can really answer questions. And again that session is devoted to kind of networking. So the chat will be live. People can ask questions. We'll try our best to provide answers. And you know other than that you know feel free to kind of just give us your thoughts for the next couple of minutes here. Adam. So I saw I guess two phones unmuted. What is that Ben and one that ends in two five nine four. Ben do you want to go Adam or Adam do you want to go first. Sure I just I was going to point me in the direction of so if you were doing a point if you're like a mixed here a small mixed here one mixed license and you're going to go make addables and but cultivate for your addables to make an extract. Do you need a manufacturing the same manufacturing license that people who are selling extracts externally would need if you are only you're not telling them and you're only using them for your line of addables. Well I could find more information about that. So I think the best place to look on that would be our rule number two which is available on our website. And if you just kind of look at the table of contents around product manufacturers you can see what the kind of various tiers are allowed to do. All right. Thank you. I appreciate it. Yeah. Ben did you have a comment. Thank you. So I will try to phrase this with our comment. I may have missed it. So I apologize if I have but if I have not missed it in the guidance or the rule does not exist. I was thinking about lab testing recently specifically when it comes to dosing because this is something that has come up in other established markets when a product either tests under or over the dose that it's labeled as. So say you know by statutor we were required to have five milligrams dosing with products. So a chocolate bar that's 50 milligrams 10 pieces of five milligrams a piece goes to the lab and it turns out that the pieces are testing closer to four and a half milligrams or even five and a half milligrams putting the the product total over 50 or violating one one requirement of the other. You know some states have allowances there you know 10 percent over or under means that all you have to do is relabel that the product can still pass testing. So again just comment wise if that guidance that rule doesn't exist somewhere that specifically acknowledges not every product is going to be exactly five milligrams per dose and 50 milligrams per package that type of rule requirement or guidance would be crucial once the market is standing up. Thank you. Yeah. So I'm just I have rule two up in front of me so I'll just point you to two point nine point two. And then we do have kind of allowable variances in potency. Thank you. Hello. Hi. Hi. Yeah once again I apologize in advance because I'm going to violate your request not to pose a question. But I don't know how else to formulate this but it's I think it's a benign question. You mentioned that you're developing guidance documents. Will it include guidance on the escrow requirements specifically in terms of dollar amounts. So I don't have the rules in front of me but I do think that we get very specific on kind of escrow amounts for various license types and it's different based upon the license type and I think it's rule one possibly rule two. I actually think it's rule two that I think about and it's divided out by license type. So you know small cultivators need a different escrow amount if they can't secure insurance or if they would prefer an escrow account to insurance. There are specific ones for small cultivators versus large cultivators versus product manufacturer etc. Is it correct to understand that escrow could function an escrow deposit could function as an alternative to insurance for a tier one small grower. That's the idea. That's great. Okay. Fantastic. It's in rule one I think Pepper one point four point five I think. Yeah great one point four point five. You can look in there and see kind of what the alternatives to insurance are. Who holds that money. So the idea would be a bank would hold a financial institution designated by the CCB by the state. Designated by I mean you just need to kind of show proof of the account to the board. It's not. Okay. Great. Thank you. Yep. So any last comments I see that you know we're a minute away from seven and again I know I know that there's a lot of anxiety and a lot of questions out there. We're trying our best to kind of collect them and try and answer them in a kind of systematic way and I know it's frustrating. But you know if there's any last kind of questions or comments happy to take them. Amelia. OK I'm going to be really really annoying for like two seconds. I'm sorry. But I know you guys were trying to stream on YouTube the other day and it didn't work out. I would say the better way to reach people would be if you're trying to add another streaming place. Go on Instagram live because that's where all of the growers hang out. And that's where a majority of them will be able to come in and see. There's a lot of misinformation like getting thrown around the grower community right now. Obviously as is going to happen right before any market opens. And I think for clarity's sake I know I have been on your on your butts about Instagram and I know that you just don't have the staffing for it right now or the budget. But if you're trying to add another streaming area I would recommend going there before you go to YouTube. That was all. Yeah I understand. I think Nellie told told us she was successful with YouTube today for what it's worth. But that was kind of a soft launch. Yeah. But appreciate that Amelia. Town meeting day is one week from today. I can't help myself. It's the justice of the peace in me to remind everybody to get out and vote and get involved in their local government. Yeah. This is the issue of whether to allow retail establishments within your jurisdiction is on at least 20 ballots for town meeting day. So you know it's a really important one for the kind of proper functioning of the market to get that approved in as many towns as possible. And you can register to vote even at the polls. Any any final comments from people either on the phone or the join via the link. I was just going to say I looked real quick and I couldn't find that video on the 7th. It doesn't seem like it's posted. That's all. Thank you. If you could reach out to Nellie. I think she does have a way of kind of accelerating the posting of those. So you know Nellie's web or email address should be pretty readily available on our board or if you just submit a comment just asking for the video from February 7th that should she should be able to get it to you. Thank you. All right. Well thank you all for the comments. Again I know that there's more questions and there are answers right now. We do all recognize that we are trying to really focus our attention now that our rules are kind of on their way to their next phase to focus on guidance and policy to help kind of fill in these gaps. And so continue to kind of submit your comments your questions. We do have a kind of online portal to receive those. But thank thank you all for the time tonight. We have again another event tomorrow or on Thursday from 5 to 7. And hopefully we see all there. Otherwise I'll adjourn the meeting. Thank you.