 At least one page to make sure that we're seeing everything. All right, yeah, it's loading from over behind right now. Okay. See the flips? Yes, we're seeing the flips, yep. All right, beautiful. So before we dive into our topic, today's topic is we're going to spend a chunk of time on the local fees and the local licensing process. And then we're also going to talk a little bit about state fees, including some projected budget numbers. And then also I sent around everyone a survey of fees from other states. So you can just take a look at that and get a sense of where these fees are in other states. So we'll talk about that. But before we get into that, I just wanted to talk a little bit about kind of updates on where we are. Obviously, we ran out of time on the last call when we were talking about license types. So, and obviously we're short on time all through this initial recommendations on fees for October 1. So what I was thinking, and I think is what we'll do unless anyone on the subcommittee has major objections, but we'll go through, we'll kind of table the remaining conversation from last week for the time being, we'll go through local stuff today and the state budgets. And then our goal, we'll have to get some working over the next few days, but we'll be to kind of put all of this information that we've talked about into a document that you guys can look at on fee recommendations. Just like an outline of fee recommendations for the license types that we've talked about and start talking about that on Thursday. And they basically reserve Thursday's meeting and the meeting on Monday to kind of go over that, incorporating your thoughts, feedback, changes, things along the lines. So that we'll all be having, because I feel like a lot of our hold up so far has been talking about things conceptually. This will have some structure to look at and things that can be directly commented on. I hope that works for everyone. Does anyone have any issues with that as a plan? Hearing none, we will move on. So, and then just as always, here's the report language that we're building up to. Today we're going to finally talk about some of the stuff that we've been talking about, how the legislature in this report has asked the board to recommend fees that are covering all of the costs of their operations. There's also, as you can see, they have to have the local fees to be charged and that the local fee is kind of based on the costs incurred by the municipality. So those are kind of the chunk of what we'll be talking about today. And this is just some of the other language about the local fees and then it was too much there to link, but just in case anyone, I'm sure you've all read it, but the local control stuff is, that's the link to the chapter on local control. So we might as well dive right in to local fees. So we're, and this is probably a little bit more of a free-wheeling discussion than some of the others because we've been trying to figure out exactly how to try to account for all of the costs and fees. So what we were thinking was, or how we think this should be approached, is that we need to come up with fees that cover the costs of operating these businesses locally. But we also have to remember that all of the fees that are associated with operating a business aren't covered by this local cannabis cost fees. These businesses are still businesses subject to building permits, all of that stuff. So we don't need to incorporate those fees. So we were trying to figure out what sort of fees would be needed to require for state costs versus for local costs. And as we're looking at it, I think a lot of it probably will end up falling on the state. It should be incorporated into the state application licensing fees. Most of the, and obviously this is, some of this is still subject to what the board recommends and what the board puts in for regulations. But most of the inspections and most of those types of things are going to be state costs. So the state, the local municipality won't really incur any costs on that front for the most part. Under how we imagine this is playing out and how it plays out in most other cities. So what we're trying to capture is basically just those local costs of approving those facilities. So I might turn it over here in a second to my colleague, Jen, because she's been looking into some of these other local fees for other entities like alcohol, anything involving alcohol, similar sorts of comparable entities in local governments in Vermont to see kind of what those fees are like in that state. So Jen, if you want to jump in for a little bit and talk about what you've found, now would be a good time. I figure I'm on mute. I'm happy to talk about the fees. I think one of the biggest questions I have for the advisory board and the board is what are you going to consider a local fee? What does this need to cover? After looking extensively at the local fees in Vermont, there really doesn't seem to be, there's not a high level of fees. I mean, your largest fee in alcohol is $1,000, and that's for the third class license, which incorporates everything. Other than that, local fees are $100, $200. The question becomes... Jen, just to clarify, $1,000 for your talk about alcohol isn't even a local fee. That's a state fee. It's a state fee. So when it comes down to local fees, there's so much less. If you're looking at a max level of what you want a fee to be, because you have to cover the costs, right? That's what the legislature is saying, that the amount of the fee has to cover the cost. The question is going to become what is a local fee going to cover? Is it going to cover a clerk processing paper? Is it going to cover actual things that could come from having another business in town? And I think that's really where you need to answer the question as a board, as an advisory board. Local fees for permitting, for construction, for things of that nature are so low, I'm not sure where you want to look at for cannabis. If you want to make things on an even keel, then you're going to be looking at fees of $50, $45, things of that nature. So, do you have a question? Can you hear me? Hello? Can you folks hear me? Yeah. Yeah, I'm having major teens issues today, which is no surprise. Yeah, just not a question, but to give color on that, you know, local fees in Vermont, there is certainly a local tax that some towns and municipalities have chosen to implement, so the state tax is 6%, and some towns and cities in Vermont have implemented what they're allowed to implement, so a 1% local option tax on top of that. Those sales taxes already exist. Presumably, those would apply that someone buys cannabis at a retail store, if they buy anything else. But the other local fees you're talking about, in alcohol stuff, we see small fees that are meant to cover town clerks' time to process applications, $35 for this or $25 for that. Those things are quite common in Vermont. What I would welcome, I would ask maybe offer that the board should consider inviting this commentary, because I'd welcome some feedback from the Vermont League of Cities and Towns, which is the organization that tends to represent towns and cities, literally by their name. I can't speak for the towns. I don't know if there's a certain cash grab they have in mind that they're thinking, oh, cannabis is going to be huge, and we're going to put our own local 10% tax on top of that, which is probably dead at the gate, or perhaps there are specific things they are thinking about when it comes to they're looking for certain revenues to help cover increased law enforcement needs that they're at least projecting they might want. So I would be curious in that commentary from BLCT. I agree. I mean, I think it'd be interesting to find out, I mean, honestly, why the legislature put this in there and what it's supposed to cover. But at the same time, remember that cannabis businesses are going to have to pay the fees for the build out of their establishments anyway. So they're still going to be paying the normal fees that are being charged by the cities and towns. So the question is, is there going to be another fee on top of that? You know, I think if you're trying to help businesses, you wouldn't want to do that, but some people may think that this is a money grab and this is a one way to have the money grab. That's what I really think needs to be considered as the advisory board and the cannabis forward move forward talking about this. You know, there's rhetoric on both sides. Treat cannabis businesses as the way you would treat everybody else. And then treat cannabis businesses as a gold mine and we're just going to do a money grab and charge exorbitant numbers of fees. Vermont in and of itself doesn't have high fees. And so I think it's going to look, you know, a little onerous on the cannabis businesses if all of a sudden there are high fees that are suggested. It might be that you want to suggest to the board that they have a maximum level fee and that a city or town could charge anything up to that maximum level fee because again, trying to talk to the smallest town in Vermont might be a little bit more difficult for you with research purposes, but you know they're going to be part of the conversation once this starts to play out. I agree, Jen. And that's why I would want input from the Vermont League of Cities and Towns. You know, my recommendation to the board would basically be there's no local fees unless VLCT can give us an argument for what and why they want. So, you know, I'm fully agreeing that we don't want to just let everyone see dollar signs and just go for whatever they can grab, which would just be unhealthy. Yeah, and I know... Oh, sorry, Stephanie, jump in. No, I was just going to say, like the same thing. I was going to reiterate that if you're going to charge a fee, you have to charge a fee for a service or something, and we need to understand what that is. And zoning regulations, when you get a permit, there's already a fee. When you go for a sign permit, there's already a fee. When you're going for, you know, whatever, there are fees in place already. So why would there be any additional fees there? So I guess I need to also understand from the VLCT what service is being provided for any fee that needs to exist. This is just a question specific to Vermont. This is Andrew here. So in some states, there are actually statutory constitutional requirements that fees levied need to be directly tied to the administrative costs of implementing whatever service that is. In other states, that's not the case. And you can just set fees as a kind of an adjunct way to raise tax revenue. For those who are more familiar with the specific laws in Vermont, what is the case in this state there? So the law said that after the reduction or cost for administration and collection, the board pays the local licensing fees in order to reach the municipality. Your overall question, Andrew, I think Vermont has a tradition but not written law that fees and to be realistically tied to what they're for. But I don't think that as an overall legal framework for the whole state that that's... Okay, thank you. And so the one thing I wanted to add is that I know the board has already started outreach to a lot of municipal officials on a survey and all sorts of questions that could be concerning or how their towns are anticipating it. I don't believe it covers what they thought fee costs would be, but one thing that seems to be a takeaway from the initial data that I saw was... And it's something that is echoed across the country we see it in every state, but that local officials and municipal officials have a lot of uncertainty when it comes to cannabis. They have a lot of hesitancy sometimes around cannabis, but more often than not, they just aren't really sure how to handle the issue, and especially before the regs are released. So this is a time where a lot of local officials are unsure of where their feelings are just due to the level of uncertainty. I'm sure Jen can speak to her experience in Massachusetts with that, but that's... Sorry, I don't know if you had anything to add to that, but I think that's something that I thought we should know. No, I agree. I think that right now, if you talk to any town official, they're waiting to find out what their role is in all of this, and so they're not sure what their actual requirements are going to be or what action items they're going to have in their towns. If you survey them right now, they probably would tell you that they're waiting for guidance from the board to determine what that is. So it might be a little early... I'm sure the League of Cities Mutalities would know, but I think the town officials themselves yet may not understand what their responsibilities are going to be. In Massachusetts, Commissioner Doyle and I literally went around the state talking to officials and what have you, and a lot of the questions are, what's our responsibility? What do we do? Because as the implementation moves forward, the municipal level wasn't really at the forefront of having that conversation to determine what their role was going to be. And kind of building off all of this in the previous comments from Simone and Stephanie, it seems like there's an initial thought that with Vermont's kind of tradition of low local fees and the amount of other fees, and then I guess we could add in kind of the experience in other states where there really aren't as many ancillary costs as are often projected before the programs are run out. I think our thought would be to recommend a relatively, or not to recommend an exact fee but allow towns to set their local fee but with a pretty reasonable cap on what that fee would be, pending obviously future conversations with municipalities on what they need, but I think the idea would be to cover that processing fee for these applications more so than any of the other potential costs that could be associated from like angry traffic flow things along those lines. So Stephanie. Yeah, I just wanted to, I was thinking the same thing, it's just the administration of that local cannabis control board handling that application that feeds into the state cannabis control boards issuance of that license. That fee seems like a reasonable place to start. Just have that process. Anyway, thank you. We're going to add for a scale just compared to other Vermont stuff. If that's what we're saying, we should be saying it's a maximum of $100 unless and until BLCT wants to come and argue. But there's no reason for us to say hey, you can charge up to $1,000 for something that doesn't even exist. Unless and until they can tell us what it is they're looking for and why. There's really not much that's obvious compared to other Vermont industries. I would have to be a very low number. And if they want to come and advocate, I think all of us should be open to listen to what they're arguing for and why. But until then, I think it should be a pretty low dollar amount. I agree with that. I agree with the $100 cap. I think that's a smart way to move forward and have some sort of control over it. Sounds good. All right. Do we know, and Jen, I don't know if you checked this, but if we were doing like a statewide cap, we would want to just make sure we account for if there's different. Is that the same, like $100 reasonable in Burlington as well? Or is that like, so is that? Yeah, it's reasonable in most cities and towns. Okay. All right. So yeah, so that was the, that was mostly what we had on kind of this local fee front. We just wanted to just hear from the advisory members on kind of what, what they thought. I will say we probably, this is more, I guess for, for the board, but you should have to just see if there's other things that towns are anticipating. I love, we think that fees should stay low, especially at the local level. But I guess just, it might be something to add to your, your next municipal outreach to the board, if you just make sure there's not any major pushback there, but I'm glad we have unanimous consent on the advisory board to go forward with a low cap. So the last bullet point here was just about providing flexibilities. That was, we were thinking of a cap and allowing municipalities to set it whatever below that cap. And it sounds like that's the principle we went with a low with a pretty low overall maximum. So unless there's anybody else who wants to talk about local fees right now, we can kind of move on ahead of schedule to talk about the budget and state fees. Hearing none. First time I think we've been ahead of schedule for so far on any of these meetings. So for the, now turning to the state budget again, the same requirement happens at the state level where the fees are designed, the legislature would like the fees to cover the operational costs of the the board going forward. Understanding that in Vermont and every state and in every industry that's ever been stood up with a regulatory agency, your costs at the beginning are going to be higher because you have cost, your incurring costs well before you're actually bringing in any revenue. So the other thing that has been, that can be a particular challenge that we've talked about a few times is that while the legislature originally asked for the costs, for the fee costs to cover all the operational budget, there's also been a more recent push and certainly an interest in both the legislature and it seems like many in Vermont to try to provide as many low little barrier to access, like low low cost licenses and licenses for small folks. The easiest way to make back your cost would be to have a few licenses with very high costs that cover your operation but that does not seem, we don't think that's a smart plan for Vermont. I don't think it's a viable plan for Vermont. So we're going to try to figure out how to cover costs and with kind of a spread of licenses that both provide access and try to raise some revenue. So what we included here and I sent out earlier was the legislature during the passage of the two major pieces of legislation that set up the adult use program provided fiscal notes that estimated the board's budget over the first few years. We've been in conversations with the board and just from some of the things that those fiscal notes might not have incorporated it actually seems like the budgets will probably be a little bit higher at least in these early years. So then we'll have to try to take it into account a slightly higher fee. The other thing that's worth noting from the fiscal note is that it projected a $1.8 million kind of budget deficit by FY24 in terms of fees since the legislation anticipates that the fees will eventually pay back all of the money that was paid up front. Putting that all out means that you're going to have to have some significant fees that may not be super significant compared to other states but that will seem a little bit out of line with probably the size of the Vermont market. This is what we'll be presenting on Thursday hopefully again if we are able to get everything put together but Andrew's projections on market size some of our tiering recommendations some of the things that we've talked about before we're going to try to put together different fee presentations on what these different tiers would be in a lot of Thursday's meeting and the following Monday's meeting could be to talk about those but all of this is kind of a bit of guess work because we're not exactly sure on the final budget of the cannabis control board because both it's hard to project out what an agency budget is going to be 10 years in the future also it's still without regulations so depending on how that goes forward and how the agency is built it's going to affect your budget quite a bit so that's kind of where we where we are right now I don't know I can maybe for questions because I know that probably wasn't a particularly helpful segment but just wanted to give you a sense of like where we are for budget where we're going what numbers we're going to be starting to use for Thursday's presentation and then we can then go on and start talking about some of some of the other states or just kind of get into a general discussion of how you'd like to tier some of these things are there any questions on that Dan I got a question sure sorry this is James Pepper so it seems to me that what this is all like the fee structure is also dependent on what types of licenses we have I mean we looked at a number of potential retail licenses at the last meeting that I don't think anyone was really contemplating when they wrote the legislation and if we had for instance a special event retailer permit license that seems like a way to kind of defray the costs of some of the you know small cultivator fees etc so I would just not want that to get lost in the modeling even though you know we haven't made any decisions about those necessarily I do you know I think we're all on the same page with you know it seems like you just did a basic fee structure like for all the license types in Massachusetts you'd get one fee amount but then if you add in some of these specialty licenses or craft licenses that Massachusetts doesn't have that we could have a you know spread out the cost over more license types is that right yeah exactly I probably should have with that but that was my last bullet point was form of recommendations was kind of a note to myself to say I think one of the ways that we can present these recommendations is like using the enders model and kind of some of the stuff that we've been thinking we could put together a set of recommendations of if we have very basic like license types we're going to have to have these license fees that will be likely high in order to pay back that fee over 10 years but what is probably much more palatable and what I think would be a stronger recommendation would be here's license fees based on you know other comparable states what we think is reasonable to enter into the Vermont market things along those lines plus if we are able to in the future provide these other license types there's another that will raise additional revenue particularly in the out years that may not have been anticipated and try to get closer to the amount of that total number using a more creative approach and one that emphasizes trying to have more licenses of easy access to many of the both low level cultivators if we can find a way to thread the needle on some of those creative retail licenses some of the event licenses some of the things that aren't yet contemplated in this statute but are things that may be worthwhile exploring going forward the things that I think are worthwhile so is that kind of what your Mr. Chair? Yes that's exactly right thank you for that I'm sorry I'm short circuit of your presentation no I was we actually have some time I budgeted more time for that the licensing conversation then we went feel free to bring anything else up so that was our plan that's what I think the rest of the subcommittee members think that that's a viable plan like two sets of recommendations one based strictly on here's what the fees would need to be if we're doing just basic licenses trying to cover the whole cost within 10 years based on our best estimates and then a second one that says if you'd like to provide additional access to the market try to emphasize small cultivators in retail there's kind of creative ways to increase field revenue on the out years and I guess a very important part to mention in both the fiscal note and in our modeling is that the cannabis itself will pay for itself over time the fee, the tax revenue that's coming into the state will be much larger than the operating costs but it's kind of a question of whether that's going to other worthy causes or whether any of that's diverted to help operational costs at least in the early years Sabana? Yeah Dan, I post for your idea about two sets of recommendations but I would add the caveat this is just my gut we have to see, it's going to take us years to see how this actually plays out but my gut is there's not going to be much difference honestly even with the specialty licenses those aren't going to be the lion's share of the applications we get and the fee revenue we bring in so I wouldn't think they're much different I think the lion's share is going to be the meat and data of everything it's going to be a retail license it's going to be a grow license those are what we're going to see volume in and the other stuff, we'll see how it plays out more time but I would think that it's going to be concentrated in the ones we expect I think you're probably right on that I think part of it is and again this is for the board's decision and the legislature's decision it's trying to set it up so that if you want if if the legislature controls the first springs here thinks that it's valuable to maybe not require the not payback the entire kind of upfront costs on the back of some of these smaller guys and to use a little bit of the tax revenue in the first few years at least to kind of even out the costs which I think is a good plan in which most states do is we will be bringing in quite a bit of tax revenue through this and we wouldn't want I think it's not Saban just a scale question, Andrew if you could pull up or maybe come back in 5 or 10 minutes once you've found it what the current model is projecting the total number of licensees we'll have I don't need to know a breakout by category we're talking about 1,000 licensees across the whole state and we're talking about something significantly less than that that would help some of us at least myself but mental scale on what fees need to be at least an average to get the numbers we're talking about so right now the model looks at specifically cultivated cannabis square footage then also a little bit on volume of daily extraction capacity a daily extraction capacity differs quite a bit 500 pounds a day there won't be any days where we'll run out but you probably don't want that much because obviously you've got some seasonal shifts and some inventory can go month to month over so you're probably going to want more like 400 pounds of extraction capacity and the same sort of thing, we're talking about cultivation square footage the dynamic there and to being ok well is that 400 or 400 feet to 2,000 square feet divided by 2 inter cultivators it's like how small are each of these generally depending on how much local governments transition and allowing adult use what sort of limitations there are as time plays in zoning with those I think we're probably looking at somewhere in the mid hundreds I would be very surprised if there's more, if there's a thousand licensees across the board you're talking about retail mid hundreds of retail licenses to move them you're saying total licenses of manufacturers growers I would say I think probably total yeah, I think it would be low and I can try to that's a good that's not off of the right now we're not looking at how many exact retailers we need to sell this amount of cannabis I meshed this back and forth through it the commissioners on that last week as far as what it would look like for amount of volume through different store fronts but of course that's going to get substantially basable on whichever geography you're in as well as the specific season and just to provide some additional context again all of this as Inter mentioned is hard to project so we ran some numbers where we tried to figure out the ratio of retail stores would be to consumers based on kind of that ratio in other states so we basically looked at total number of consumers in all the other states the amount of retail that is pending in those states so if somebody's been like provisionally licensed we actually just counted as a retail in the other states as the markets filled out and it varied significantly obviously but it looks like if Vermont had retail stores at the state that has the most retail stores for a consumer is Alaska if Vermont had the same retail coverage that Alaska has it would have around 156.7 retail locations the lowest kind of ratio would have been California it would only have 18 so I would imagine probably the traditional retail locations would be in the middle a lot of the other states like once we started pulling this ratio there's kind of a couple of pockets like if it was the same we should think of a term for this kind of coverage but it would be for Colorado the ratio would be like 79 retail locations so Siobhan there might be a couple hands raised so sorry Siobhan on your question that was the old hand from the question disaster was there a question in the room yeah I was wondering if your estimates also included the fees but are are you considering fees for the individuals who will be working at the establishments so I mean it's actually included in we are considering that I hadn't reserved time for that I didn't know if it fit into the market structure conversation here but I know it's a fee that we need to recommend on it was kind of a survey of some of those fees was included in kind of this spreadsheet I sent to the members this afternoon I mean those are there's less variability there and the one thing that I've let some of our co-consultants and those working on social equity that's probably a pretty important question for them to answer if a lot of that's tied to background checks and trying to get people to work in the industry you probably want to keep those fees that are going on employees low but again I haven't heard back from the other I also haven't asked in a little while so I'm sure I'm sure we'll circle up when the other boards have finished having their conversations and see where everyone is on that So just in the medical program we have something currently in statute that says that the fee and background check fee must be borne by the dispensary establishment in your case so they would have to somebody working for a job that's currently unemployed you know they may not they need bread and milk right now are you guys looking at a straight fee like is there a higher initial fee and a lower renewal fee I think again this is hopefully have numbers on paper for next call but I think for the from what we have gathered from previous meetings of this group I think we're going to recommend some sort of provisional license or some sort of like an intentional apply license that would have some sort of initial fee then we would have like an application fee and an annual fee I don't think we can have if anyone has thoughts about whether the application fee should be higher than the annual renewal fee we can have that discussion I generally if you're trying to there seems like there's a push to cover to try to create lower barriers to entry so I don't particularly love having application fees much higher than their annual cost license but that's changes in different states and it's all in the spreadsheet so we can talk about how what people's thoughts are on that alcohol in Vermont just as an example at Roxy it's the same whether you apply the first time on all the various licenses yeah you know and if we think about it from a logistics but also like a rationale standpoint right so an application fee is designed to cover the administrative cost of reviewing and adjudicating the application itself right so that's a little separate but if we're talking about initial licensing fees or ongoing licensing fees initial licensing fees are essentially designed to help support the initial creation and structure of the regulatory agency which is going to be regulated at least when it comes to cannabis in which you have a lot of essentially everyone's a new application and so those might need to be balanced to cover essentially the relative difference between initial startup costs of regulation and then the ongoing cost of those regulations now ideally as you know a small state hopefully being as efficient as possible with streamlining regulatory oversight we can limit some of those upfront capital costs and work with other agencies as it comes to administering on the ground inspections and so far that we can reduce the difference between initial and then renewal licensing fees so these are some things that Dan and I had talked about earlier and I think I've been brought up a little bit some commissioners in the past I think also you have to keep in mind the fact that you've got to cover you've got to have money for the board to operate I mean that's just legislatively mandate so while we try to keep people low and try to help people with the operating costs of the board it's going to be hard to balance and then maybe one of our options and now we're just kind of brainstorming on the call but maybe one of the options is to present if we're doing two sets of recommendations one based on one where we're tied to paying back the fee one where we have a little bit more flexibility and relying on the licenses maybe there's a higher application fee on the first one to make sure that we cover costs the application fee and the renewal fee on the kind of second recommendation but open to hearing from some committee members if they have any thoughts or opinions or anything that you want us to incorporate as we kind of sketch this out for us and before we present it next week. Chris? I've been thinking this week keep going back to the HEM program and how a license is $25 and you know I'm sure somebody at the department has the statistics but you know there's a lot of people that got a license because it was only $25 and did nothing with it and I understand that the provisional license especially and maybe the lowest tier cultivation segment where we're considering the idea of unlimited is being used as a device like a barometer to see the interest. My suggestion is that that license should be relatively, I wouldn't say expensive but it should be a real number with maybe some lever where you can get a rebate if you decide to move forward if we're really going to use us to gauge the interest of those of the potential unlimited micro licenses I think you may get a more accurate read if you make that license like a real cost and then possibly if you move forward with the secondary license that comes back to you or part of it comes back. Does that make sense? Yeah so that if we are trying to gauge interest it's not something that's not just a nominal fee something that people need to pull up real money but then if you move forward you get all of that or chunk that back or you take it off the secondary cost of the final license Yeah I mean I think any other members have thoughts on that? I think that's definitely a way to to I would want to not just have that for low level licenses have that for all of the licenses so there's no if that's where we go it should be probably a standard provisional license fee of some real money and then have a discount or have that extended over I agree but I don't think we're speculating with the other tier licenses specifically in cultivation that it's really an ongoing concern of how many people are going to apply for these other tiers but I keep thinking about these unlimited licenses and how to really grasp what we're looking at a couple hundred is doable let's say which is probably unrealistic you have a thousand of the micro licenses like what does that mean for the control board regulations enforcement I'm really curious to see what the interest is on that micro level Yeah does anyone have any thoughts on what or should we have a discussion about what is a reasonable fee there that allows in but doesn't allow it doesn't have people just filing and not going forward I froze what Chris just said and I would take one more maybe a little level further we don't actually need to go out and rebate so much as we could think about if we're thinking about giving that money back it could just be credits forward to the next license yeah make people think about that early fee as a non-refundable deposit so they have to be serious and again just speaking to gut numbers it seems to me that nothing should be less than five hundred bucks like people take it seriously but I don't know that's I'm literally making that up but that's just a number that feels like people take that seriously in a way that don't take twenty five dollars seriously yeah I just keep going I agree with Yusuf and I keep going back to the Hemp program and I think that low license fee was you know it was the worst part about it I mean to start off in the wrong foot I got a question so just to provide some respect about the Hemp program in 2019 we did have it was a twenty five dollar fee it's no longer twenty five dollars it's been increased but we had I think thirteen hundred total registrants and a portion of those were considered processors of Hemp and we had nine thousand acres booked for cultivation however not all nine thousand acres were cultivated today we have about three hundred and forty three registrants total with the Hemp program I don't have the grower number off the top of my head but maybe Andrew remembers those numbers I can pull them up for you in my model but your question is that you went from thirteen hundred to three hundred fifty yes no definitely that's what I've said yes definitely I will add there's market there too like you know we're still sitting on Hemp for 2019 so but yeah I think that all makes sense we certainly don't want everybody in the state I don't think throwing in twenty five dollars or whatever so if I think I think that makes a lot of sense to me I wouldn't want to go too high but also we do want these are going to be something that the board is going to have to look at in process and just for their own work I don't know in process and just for their own work they should not have too many frivolous applications trying to make sure that the people who are applying and these things have to be reviewed are committed to moving forward well and once the board is actually enacting this you know those early indication of interest things with you know call it a non-conformable deposit or whatever I encourage people to put those in by saying that the order in which those go in will be the order in which the eventual permits will be reviewed so you can have people waiting on the sidelines you know yeah that's a good idea too I know I think and I think I saw that Gina joined but I know NACB was looking I think at some of the organization and some of the other things related to social equity or things like that so I imagine that there's some input from those folks on how to prioritize going forward but I think that's a good point and so just Dan at this time I know that we were going to try to get the on for social equity licenses okay yeah so we'll have to iron out exactly how to try our test to figure out social equity plus then in order of filing or however we want to however we want to structure it but we'll make sure that we incorporate the recommendations of groups any more thoughts on this I know we are now approaching time and I don't know if there's public comment in the room at all I didn't see any online submitted public comment so we don't probably need to reserve any time there but we might have a few extra minutes here for the discussion but we just want to pause and see if there's going to be 10 minutes of public comment I think we have one member of the public that would like to make a comment okay why don't we do that now and if there's a few minutes afterwards and if anyone from the other board members have more questions we can jump back on it thank you it's Dave Silverin first really appreciate the progress since last week and the creativity reported your last Thursday meeting on license types second the idea of a $500 provisional license application doesn't scare me in terms of you know thinking what my small cultivator clients are going to be able to afford I think $500 is a level that folks can afford and folks who are going to be investing in a licensed cannabis business are going to need to be able to come up with so that doesn't scare me the what does kind of what did kind of take me back was the idea that the order of submission of the provisional license applications or even the order of submission of full license applications would set the order of review and I just don't want you to create an incentive for people to rush their applications speaking as someone who will be preparing those applications for clients I want to make sure that we have time to go over it present you guys with full truthful information and not just slap that something together to get it in but we get reviewed quickly you know I think we want to present you guys good applications and good application just will take a little bit of time especially since there really are not very many lawyers working in this industry right now in Vermont and so you know we're not going to be able to you know the 3, 4, 10 of us however many there are just not going to be able to give you hundreds of good applications in a matter of a week if everyone's pressing right away to get mine in, get mine in, get mine in because they feel there's going to be a time benefit there so that's the one thing that I just wanted to give you back thank you that's great feedback Dave I appreciate hearing that as the person who suggested putting things in order and maybe there's something to be considered for you know a more chunky version of early versus late college role of admissions maybe there is you know in the first month or in the first wave being reviewed and the second month is later so you know still not wait forever but something along those lines maybe makes a little more sense than how I originally presented yeah you know I wanted to follow up on that as I think I also brought up the idea um you know or at least I had the idea that I may have not brought it up in last comment but ordinarily when I'm doing these things not necessarily thinking about the supply of attorneys on cannabis in the state of Vermont which is I totally recognize far smaller than it is in another state so totally understand supply and demand on that regard we don't have any other public comment in the room alright was there any um thank you was there any other uh anything else from the subcommittee members that they want to bring up now Stephanie I see you have a question yeah I was just I was looking at the Massachusetts licensing um tiers and you know the first one is one square foot up to five thousand is there going to be minimum like would we really want to go through the application process and maybe I'm interpreting this wrong but should there be a minimum size for true cultivation that's not a single square foot um I don't think uh again we'll we'll talk about this more on Thursday I don't know and I haven't talked really to um to to Andrew or January anyone else 19 about this I know Jeff brought it up a little bit on the last call I was thinking that um we would just set it at you know no minimum and assume that the cost would be enough to to make people not apply for a license to to grow two plants but if if we feel that there's some sort of um reasonable square footage requirement um I think that's certainly something that we could we could discuss I want to create like a tier of like you know one to ten square feet um but but like um but if you think that the uh the statutorily defined small cultivators isn't like defined uh small enough um we can we can certainly discuss that no no I was thinking that that would be the smallest thousand square feet like below a thousand square feet in the statute I think we're required to have a below a thousand square feet right okay um Siobhan yeah I would advocate we don't necessarily script minimums but that all the tiers are up to x um and I don't think that as you go higher the next year as a minimum that is the previous tier is maximum right if it's up to a thousand and then up to fifteen thousand whatever it is that's good because you want to give people the ability to apply for higher levels as they you know they're up to a thousand and they're going eight hundred nine hundred square feet and they're feeling pretty good about it and say you know I'm gonna apply for the five thousand license and start thinking about planning more give them the ability to get ahead of that um so that we don't force people into weird uh you know bending over backwards to fit into x or y at the right time and I totally agree Dan to the point of it not so even licensing fees but just the process of licensing and the other requirements going to come to what you need to do for compliance to be eligible those things will be enough to people will be encouraged to only do this if they're going to be serious about it and that's going to keep someone wanting to do five plants out of it because it's not going to be worth it to someone who wants to do five plants to think about the background check and the other compliance and the license fees etc so I don't think we have to worry about minimums yeah and I know um it's probably a little too late to get into it but Andrew I know has a lot of uh a lot of knowledge thoughts about you're exactly right about we wouldn't set like a minimum on those up tiers because um most folks don't cultivate to the up to the maximum um you know uh so uh definitely aligned on on that and you always want you always want to give a business the opportunity to choose for pausing things right so if someone was uh one thousand five thousand and they have some you know utility problems and need to stop cultivating and now they're not in compliance because they're less than a thousand that that would be an unintended you know disaster right so yeah so yeah our our total um it would just be for the the and you would think you know let the business decide which tier they want to be in um and pay for the the increased licensing fee but not not necessarily dictate that they have to maintain a certain uh as it pertains to both the two states are probably most analogous to look at for this uh Colorado and Massachusetts which both have program and also have the requirement that if you want to bump up tiers you have to show that you're growing at or around your plant limit and selling about eighty five percent or more of what you cultivated in both instances there is the ability for the regulatory agency to drop people down a tier it's less explicitly stated how it would be done to only be done at renewal but if someone is only growing you know with twenty to thirty percent of what they you know can grow and they're at your you know eight out of ten or whatever you know that we drop down and there's usually a longer conversation and discussion about that I imagine Jen um Jen Flanagan has some support first uh first hand experience in that um but I think that's probably the appropriate way to do it where you don't say this you know at this point they would exactly drop someone down but you give the board the ability to drop someone down if they have vast amounts of underutilized capacity that they're not intending to actually cultivate as that is kind of essentially extra string on the marionette when it comes to understanding the uh the movement of the industry honestly I'd rather not um give the board that to think about or worry about I'd rather that if the higher tiers of cultivation for example cost more that people have their own phantom incentive to you know get the one they think they're going to use and if it's a year later and they still aren't using you know all ten thousand that once kind of renewed they choose to drop down to five thousand you know I mean it's certainly always possible that the board upon renewal can say you're not approved for ten thousand because you're not using anywhere close to it um but I'd rather not give them that thing to have to think about or supervise unless the board feels otherwise obviously I mean the way we do it in Massachusetts it's a safety thing if you can't sell 85% in the last six months then for us it was more of a we're not going to divert so we're going to drop down your tier um it wasn't so much that we wanted to do that but it was people were getting in at tiers they thought they would be able to handle and if they couldn't then we decided as a commission that that's what the action was going to be at renewal immediately there was there'd be no conversation to be had if your numbers show that you weren't selling the product you're going down the tier any other final thoughts before we uh before we wrap up um we missed it by one minute on being perfectly on time so I'll take that as a victory um yeah I'll just share now we already know this but I'm going to be unable to make it on Thursday okay uh I will make sure that we uh get you all the materials and um lucky for you I anticipate that we'll probably have a conversation that will extend for the next two calls um so we'll probably be covering um we'll be able to catch you back up from today uh and get your input alright um so with that I will uh I'm to adjourn for the day I want you to adjourn so I can second it great uh thanks everyone and I have a great evening