 It's one o'clock, so I'll get started. My name is James Pepper, I'm the chair of the Remind Cannabis Control Board. Today is September 14th, 2022, and I call this meeting to order. First thing, the staff has recommended a social equity status denial. So we'll need to enter into executive session later in this meeting to discuss the specifics of that case. Additionally, another prospective licensee has a presumptively disqualifying conviction on their criminal history record, but based on the facts and circumstances surrounding the conviction, the staff has recommended that they have overcome the presumptive disqualification and should be allowed to receive a license. So we need to talk about each of these issues and recommendations in executive session. We've invited Susanna Davis, the executive director of the Office of Racial Equity, and Jake Green, who's a research and policy analyst for the Office of Racial Equity to that executive session, which we will do after Brynne has reviewed the applications that are up for approval and before we take a vote on them. I just wanted to respond to a question from last week about what we're doing in these executive sessions. So the vast majority of recommended social equity denials are in that category of applicants claiming to be from a community that was disproportionately impacted by cannabis prohibition. What we're trying to determine in executive session is whether the community that's being claimed is sufficiently defined, whether that community has been disproportionately harmed by cannabis prohibition in a way that's more than just the general threat of suspicion or prosecution that anyone who's even tangentially associated with cannabis experiences. And then finally, whether the individual applicant has been personally harmed because of their association with that community. These are the issues that we discuss in executive session with respect to the staff recommendations on social equity status. And then we come out and we describe kind of where we landed on the staff recommendation. A licensing update, today's list contains a number of cultivators, indoor, outdoor, and mixed, as well as an integrated license and two retail licenses. I've said it before, but I'm happy to say it again. The fact that we were able to stand this program up with a skeleton crew, a part-time legislature, is nothing short of miraculous. Bryn, the team you've put together is one of the most nimble, dynamic, tireless teams I've ever seen. It's in the private sector, the public sector, or a local state or federal government. It's hard for an outsider to really understand how complicated life at the CCB can get day to day. And there really is no playbook. Every state has a unique set of laws and priorities. Every state has a different political climate, a different actual climate, and a different access to resources. This team comes in with a positive attitude and really gets down to the hard work of problem solving. And these are seemingly impossible problems. We have a lot to get through today and in the coming weeks and months, so I'm not gonna dwell on this, but I wanted to take a brief pause to give everyone here my deepest gratitude for the endless dedication and determination you've shown to get us to this truly historic moment in Vermont's history. I also wanted to thank our partners at the Agency of Digital Services. You all built a highly complicated and yet highly functional platform in a matter of months, whereas other similar state projects have taken years. I know you all have called in favors, worked overtime, worked on your personal time, translated tech talk into plain English so that we could actually follow along with what was happening. And you didn't do it because of some love of cannabis. You really did it because you saw an agency that needed your help and you stepped up to the plate. Just wanted to mention quickly about these retail licenses and this integrated license. We always get the question here, why these businesses and not those. So I wanted to say just a quick few words about our licensing priority. First, with respect to the integrated license, I know that the very idea of these integrated licenses has been polarizing since the passage of Act 164. It's not our job to wait into the politics of this issue. Our job is to follow the law as it was written. The legislature directed the cannabis board to give certain priorities in the issuance of licenses. First, to social equity applicants. Second, applications from minority or women-owned businesses. And third, applicants that have an existing medical cannabis dispensary license in good standing. We have the ability to move people around when the needs of the market demand. We've used this overarching authority to focus on outdoor cultivators and now indoor wholesalers and product manufacturers. But as we moved into the review of retail applications, we had to start with the applicants that are either social equity owned or have a medical license in good standing. This integrated application had all the boxes checked so there's no reason for us not to proceed with approving it. With respect to the other retailers, one is a social equity applicant and the other is a standard applicant. Of the 25 or so retail applications we have in the queue currently, two are social equity and the rest are standard. We prioritize the two social equity applications. One is up for approval today and the other is still incomplete. We've sent the incomplete letter and we've conducted a site visit and then we moved on to the other applications based on the order that they came in. Of course, if we get more social equity or economic empowerment applications, we will prioritize those. One thing I wanna mention about retail is that our approval does not mean that the doors will open immediately. As any outdoor cultivator knows all too well, the legislature probably did not consult the Farmer's Almanac when it created the timelines in Act 164. The cannabis supply shortage that we have seen in the initial rollout of every adult use marketplace is gonna be exacerbated by, A, the time it is taking us to get through our backlog and B, our prioritization of outdoor cultivators. Are gonna harvest when the time is right and then they need to test and cure and dry and process and package. These things don't magically coincide with an October 1st deadline. Approved retailers will have to make their own business decisions about when to hire their staff, who their suppliers are and when to open their doors. We'll do whatever we can to increase testing capacity and manufacturing capacity, but we can't force entrepreneurial interest in these license types. They have some of the biggest barriers to entry in an industry that is already inaccessible to most. Another reason not to expect retail immediately is that retailers also have a few additional hoops they need to jump through, even after they're approved for licensure. There are potential local issues that they need to resolve. There are permits from the tax department that they need to get. And there's things like employee trainings that have to happen before a retailer can open their doors to the public. On the employee training, the board will maintain a list of approved vendors who have developed specific employee trainings for the requirements that we have in 2.2.5 of rules. We should have at least one of these vendors listed on our website by the end of the day and a few more by the end of the week. One final administrative point that our licensing team wanted me to mention, if you are listed as an owner, a principal, a finance or a financier on your application, you do not need to apply separately for a cannabis establishment identification card or pay the $50 fee for that card. You're listed as an owner, principal or financier on your application and went through that CSI check. You will be issued a cannabis establishment identification card as part of your license. So Kyle, I just wanted to turn things over to you just for a quick update on kind of packaging. Sure, thanks James. I appreciate it and agree with everything that you said thus far, especially as it relates to gratitude towards our staff. I wanted to take one moment and talk about packaging. I think that there's a lot of confusion out there as it relates to requirements for packaging in the state of Vermont. We do have guidance on our website with a list of definitions that should help you make good decisions as it relates to standards that we wanna see in the packaging world. Primarily that relates to the need for child resistance, which in the state of Vermont, you do not need child resistant packaging for flower or for pre-rolls. For cannabis products other than pre-rolls, edibles, concentrates, et cetera, those do need to be child resistant. We've made a couple decisions as it relates to packaging waivers. One is a lid from a company that I've done an extensive amount of research on. We put those lids out there to help folks in the concentrate or edibles side of the equation because we understand that plastic plays a heavy hand in meeting certain child resistant requirements. However, that's not the end all be all. There are many different options that meet child resistance from other sources, whether it's tin, aluminum, flip open cans. There's also a bunch of different cardboard options, believe it or not, that do satisfy child resistance for those products, especially vape carts. But I just wanna stress that the need for that in the flower portion of what we're trying to do here is not necessary. There's a lot of alternatives out there that you can really look to employ and just meet that child deterrent definition, which can be satisfied with a tamper proof sticker over the top of a metal lid or if that metal lid has a tamper ring, open a ring that you may see. Opaqueness can be satisfied with putting your label over the clear glass jar and on the bottom of the jar. It doesn't need to be completely blacked out opaque. We're trying to meet people as far as we can there. I think, again, we're focused on glass. There's gonna be a couple alternatives. There is a compostable bag that's up on our website that does not meet the child resistant packaging standard and we'll get more clear about that. We're gonna put forward some more information, I think on our website that really we think can help people make smart decisions, but your edibles don't belong in that compostable bag. There will be some other decisions that we're gonna make as it relates to packaging waivers. I'm getting some ducks in a row before we actually start to list a couple of things on our website. I would not expect any bioplastic jars to be at the center of how we're gonna move forward, at least right now. I really wanna see the market roll out with glass and alternatives to plastic, not plastic alternatives, as it relates to where we are at this moment in time. And I think we can all do that. I think all of us heard over the last 18 months how sustainable this industry already is without regulation, but that doesn't stop at the inputs that you put into your plants, in your growing operations. We need to look at this industry as a whole. And I'm confident that if everybody can work together to really try and weed out plastic in our industry, there's other states that are looking at what we're doing. There's plastic companies that are looking at what we're doing and asking us questions about the direction that we feel the packaging needs to go in the cannabis industry. But all the credit will be given to the folks like yourselves watching, who are looking to meet the spirit of what we're trying to accomplish here, not credit to us for requiring you to do certain things. So all that being said, no CR requirement for flower and for pre-roll tubes. There's glass cork top alternatives, bamboo top alternatives. There's a host of different ways. I've talked to a number of you that have found alternatives that are smart from a business decision. And yeah, I mean, I just wanted to kind of go over that one more time and we're gonna try and figure out more ways to make that as clear as we possibly can, but please take time to read the guidance that's on our website. There are a number of companies out there that will supply you with packaging, whether it's child deterrent or child resistant that meet what we're trying to accomplish here. There's a definition of child deterrent in statute. There is. People can go there to look for that. It's an Act 158 is literally the first four lines of that entire act. And the point of that really is because child resistance needs to be certified and there's a list, federally maintained lists and having a different definition for that removes it from that certification process. It's gotta be difficult for a person under five to open whereas easy for another person to open, relatively easy. You don't need a waiver if you're not using plastic in that area. And also the child deterrent packaging also removed the requirement for opaque opacity, past opaqueness. And so flower does not need to be in an opaque package. So you might decide you want to because it helps with your quality control, your shelf life stability, whatever the case may be but a clear jar with your label over it and a metal top. That is the direction that we want to go because once we can all get our ducks in a row I really want to push reuse programs into a lot of our retail operations and we're willing to help folks figure that out. I got a lot of things that I'm working on in the background to kind of help incentivize retailers to really move in that direction and consumers to move in that direction. So right now we're focused on glass. There will be a couple of compostable pouches that are gonna be available to folks as well but I wouldn't expect any bioplastic jars to be to meet our waiver criteria at the outside of the market. We want to see how things roll out. Thanks for that Kyle. Well, Julie, if you don't have any comments I don't know if you do. I don't have anything else to say. Great, then why don't we approve the minutes from our last meeting on September 7th? Have you guys had a chance to review those? Yes. Is there a motion to approve? So moved. Seconded. All in favor? Aye. Okay, inventory tracking requirements. I know a lot of people have a lot of questions about how to comply with inventory tracking. Our director of compliance has developed specific data points that each licensee will need to track. These are very similar to the data points that you would track with any inventory tracking platform. And you need to report these back to the board. Eventually we will have a system in place where you can log into your CCB account and report them through an extension there. In the meantime, we're going to ask that you report them through an electronic form that's available on our website. And today, Carrie, I don't know if you're one of those guests in the lobby, but if you are, Carrie is going to walk us through this form and the data tracking requirements for cultivators only. We're going to do similar walkthroughs for our other license types, but today we are focused exclusively on data tracking for cultivators. All right, I'm going to try and take over the screen. Thanks, Pepper. Can you guys see that? Yep. Yep. All right, so as far as the seed-to-sale tracking, we're in process of really building it and standing it up. And we've taken a lot of what other platforms, data points that they track and tried to make it a little bit more efficient. So what are we tracking? Basically seed-to-sale, it's all license types. And it's cannabis production, product production transfers and sales. And it makes sense to track by date of transaction, but we'd like to have this pushed out every two weeks. Let me see if I can. Did that change slides for you? It did. All right, excellent. In the interim, working with folks at ADS, we've built nine forms. One is a loss of inventory form. So any loss of inventory, whether that's from theft or you have a molar mildew problem or your product is out of compliance and you had to remanufacture or dispose of it. So we've built a form for tracking your losses. There are two forms for cultivators because they really largely had different questions associated with them. So there's an indoor and an outdoor. So if you're mixed, you're going to have to report your indoor and outdoor growth separately. And then transfers, we're tracking transfers. So there's three different reporting forms for transfers. One for the seller, one for transferring flour and one for transferring products. And then manufacturers, there's a form for manufacturers and there's a form for tracking retail records and retail transactions as well. There's another form, but it isn't really part of seed to sale tracking, and that's for product registration. And so for cultivators that are filling out the record for us, there aren't a lot of questions, but this is basically a summary of the data we want. And harvest lot, I know in the regulations, it says harvest lot is one specific variety, but what we're seeing out in the field is some of the small growers are growing multiple varieties in that field, but they're treating it all the same. So it's getting the same inputs as far as fertilizers, as far as crop protectants and will likely be harvested all at the same time and dried in the same room. So harvest lot is going to be important for you to help us with records tracking. And at this point in time, you're going to assign your harvest lot a number. And I would suggest using your license number and either the date of harvest or something or just sequentially number your harvest. But harvest lot is going to be important for us when you fill out this form, so we don't get duplicate records and you'll see what I mean, we'll walk through the form here in a second. But basically the data we're collecting from you on that harvest lot is the data was planted, the data was harvested, the number of plants that are in that harvest lot, the final dry weight of flower, the final dry weight of the usable trims so stuff that you may be selling to an extractor, the weight of the waste and the inputs used in the production of that profit. And I'm going to start walking through the questions that we have on the form. I wasn't brave enough to try and link you live to a web form for this presentation. So these are basically the questions, but I can't show you the dropdown menu. And also, okay. So this is for outdoor growers. These are the questions on the web form. Provide the name of the registered cannabis. So your name goes in the first line, that's required. The license type, this is a dropdown menu of all the different tiers of cultivation that we have registered indoor outdoor and mixed and integrated. And then your license number, so we can tag this record to you. And then this is where we'll be asking for the harvest lot number. Oops, sorry about that. Great. And then continuing with the form, if that slide is up. Yep. No, yep. The data planting, we already went through this and this is a calendar. So if you hit the button, it pops up and open a calendar. And the same is true for the date of harvest. And I know harvest may be over a couple of days, but the date that your harvest is final will be a good date to give us. So this is first strictly indoor, indicate the date of initiation of flower. And then select the growing style, because as we analyze the data that you provide us, the growing style is important, whether that's in the ground, outdoors, hydroponic, or containerized media, will allow a different set of analytics to be applied to your volume, weights and volumes. And there it is, the harvest date also is a calendar dropdown. I didn't realize how hard these were going to be to see on my screen, in this mode. The other thing I wanted to mention is, so the number of plants here, but some of the other measuring platforms ask for wet weight once you've harvested. And we decided that we didn't really want to track by wet weight. We can get all the information we need with a dry weight and there's no point in folks going out there and buying bigger scales to measure or weigh crop coming off the field. So we are asking for dry weight and you'll see we're asking for it in grams. I know you may be keeping track in pounds, but we can, if you could convert that to grams for us when you're filling out the form, that would be great. And here you're reporting us dry weight of flour, dry weight of trim and weight of the waste on that particular grow. And if you had a second strain or variety in that lot and you wanted to let us know, this pops open another series just for a separate variety and you can continue to do that for all the varieties in your particular harvest lot. So what to report and when to report. Anytime cannabis changes form, so if you're going from wet flour or from the field to the drying room, we want to know that all the plants that you were growing in the field made it or you're reporting a loss on number of plants that didn't make it. So anytime it changes form, so if it goes from flour or trim to extract, we want to know if it goes from extract to product we want to know and anytime cannabis changes hands. So it goes from a grower to a processor or a grower to a retailer, we do want to know. Growers are tracking based on harvest lot. The mixed tier will report on separate forms for indoor and outdoor grows, processes and manufacturers, how much material in, how much extract was produced, what was that extract used in the production of and how many products did that extract make? Wholesalers are going to ask what to track. It's more complicated than two bullets, but they're going to be able to have to track what came in and what went out to their wholesale facility and retailers are going to have to track what was purchased and what was sold. And we're looking at a two week reporting timeline. So some folks might want to modify that for their business procedures, but at a minimum, we're going to want to see that every two weeks. And this interim solution that ADS has built for us in forms, we should be able to finalize that in the next couple of weeks. But we're also in the process of doing discovery for the final solution that happens through your login directly in our Salesforce database. So the internal form should be up in the next few weeks and in the next few months, we should see the final solution up and running for folks to use. And Pepper, that's all I have. Thanks, Carrie. So really, this is a self-reporting system just like any inventory tracking. It's much less time intensive from a human capital perspective than some of the other companies that are out there. And yet I think the data is just as reliable as those and we are going to finalize a contract with our data analytics firm very soon. They're going to be taking this data and looking for irregularities and suspicious activity. We can always pivot and go for a much more extreme version of inventory tracking if we feel like we need it, but I think it's much better to start with this and to really analyze the data that we're seeing because I think this is the direction that most states want to move in. And if everyone could start over again, they probably would start with something like this. But a few things, there's a few questions that I've heard are can I use my own independent inventory tracking software in order to kind of help facilitate and automate some of this? The kind of final solution, when we move away from the form and into an extension of our licensing portal that we have the contract in place to build that, it will be ready later in the fall and that is a Salesforce-based platform. So if your inventory tracking system, third-party inventory tracking system can interface with Salesforce through an API, then the answer is yes, that can automate a lot of this for your business. And then you just have to make sure that your inventory tracking is tracking the specific data points that we need at the board. And then as far as this kind of initial rollout of this, Carrie walked through it for cultivators, I think the goal at the board would be to send an email out to all of our licensees with kind of instructions on how to input your first set of inventory records. But you should be tracking them now and it's just when you enter them is kind of the variable point. So anyway, any questions about that? I had one question, Carrie, when you were talking about when, what and when to report was like destruction and waste, was that on that list? Yes, yep. Okay. So everybody will, there's a separate form for reporting destruction and waste, but it's also captured on the grower's form though, the grower will report from any harvest lot, pounds of cannabis being sold as flour, pounds being sold as trim, and then the weight of the stems, as waste, yep. Yeah, I don't really have any questions, just driving home a point that you made, this is the direction that a lot of states, I think if they could do it over, what would go in? It certainly puts, it's at a low or no cost to everybody listening, depending on how much automation you want to really plug in here. But it also, it's a high degree of trust between the board and all of our licensees. And our compliance team is, some praises to everybody that they've inspected there, everybody's really trying to go above and beyond the cough or compliance here, and that's really exciting. But, as Pepper mentioned, if we're seeing too many irregularities, we can always make this a little bit more difficult. So please work with us at the beginning, so we don't have to move in that direction. Brent, I know we're on a little bit of a tight timeline for our executive session. Can we transition to reviewing the recommendations? Yep. So your adult use in medical cannabis register for this week, starting with the medical program, medical program received just under a hundred new patient applications, renewal applications from caregivers and patients, and has processed about 39 patient cards and approved for caregiver applications We're currently processing applications we're seeing on and after August 10th. Our license applications list this week. So we have 12 applications that are up for the organization this week. As the chair mentioned in the outset, we've got two retailers on the list and one integrated license. So that is very exciting. One thing to point out is that the numbers down here at the bottom are total numbers in each of these status categories up to the point where the application is pending the board review are remaining pretty static week by week. So it looks like though we've gotten about 53 applications in the door this last week, these numbers are remaining relatively static. So our staff are really processing applications at a steady clip and managing to keep our statuses around the same numbers despite the influx of new applications. We're gonna move on our recommendations for licensure this week. As I mentioned, we have 12. So we've got Pine Hill Organics being recommended for a mixed cultivator tier one. OGW cannabis is recommended for an indoor tier one cultivator. Pinnacle Valley Organics is being recommended for an indoor tier three cultivation license. Champlain Valley Dispensory is being recommended for an integrated license. Ernst Flowers is being recommended for an indoor tier one cultivation license. Birds Eye Botanicals is being recommended for an outdoor tier two cultivation license. District 802 is recommended for an indoor tier one cultivation license. YBNRML is being recommended for a mixed tier two cultivation license. Turkey Hollow Cannabis is recommended for an indoor tier one cultivation license. Trichome Ranch is being recommended for a mixed tier one cultivation license. Laura Cannabis is being recommended for a retail license and Mountain Girl Cannabis is being recommended for a retail license. And as always, this list of applicants have demonstrated compliance with all of the requirements for a cannabis establishment license that's contained in our rules and in statute. We've got this data here about our license amendments. I think this data is really just showing right now other work that is being done by our staff and it may get a little more interesting as time goes on, but we're gonna keep reporting it. And then we have three recommendations from staff for Social Equity Status Denial this week. We've got submission 637 and 913, and then we have one of those pending Board Review for a license this week. And then we have three recommendations from staff for Social Equity Status Denial this week. We've got submission 637 and 913, both of which staff are recommending denial of Social Equity Status because the applicant doesn't need the criteria for a Social Equity Business Applicant as defined in Board Rule. And we also have submission 845 and staff are recommending denial for this applicant as they don't meet the criteria for Social Equity Individual Applicant as defined in Board Rule. And before we move into executive session, I just thought I would put a finer point on one of the things that the chair, one of the remarks that the chair made at the outset about our Social Equity Status Denials, which is that the majority of our denials are actually for applicants that are applying under the criteria for Social Equity that's based on incarceration as a result of the cannabis-related defense. But because that's really an objective criteria that staff are able to determine without discussion among the board, we're able to kind of make those determinations without going into executive session. So the majority of our executive sessions are for applicants that are applying under that criteria of being from a community that has been historically disproportionately impacted. And that is what I'm suggesting. We go into executive session now to review because one of these recommended denials is for an applicant that applied under that status. Great. Any sense of how long this executive session might last? I've read the reports, I would say 10 or 15 minutes. I think that's right. We've got the one Social Equity Status Denial and the recommendation for a license, as you mentioned, for an applicant that has presumptively disqualifying offenses, both we have a memo for each. Yes, the board has a motion. All right, is there a motion? I move that the CCB go into executive session to consider confidential attorney-client communications made for the purpose of providing professional legal services to the body and that executive session is required because premature general public knowledge regarding such communications would clearly place the board at a substantial disadvantage. And I further move that the board invites Donna Davis, Director of Racial Equity and Jay Green, Racial Equity Research and Policy Analysts from the same department into executive session. I'll second. I need discussion. David? Hi. Okay, so why don't we say 10 minutes just so that we don't go short and then miss people? So we'll be back at 150, 150. Nellie, if you wouldn't mind just putting up the OA message indicating that. All right, Nellie, are you back at your desk? I am indeed. We are still recording, I think. We are indeed. Okay, I'll resume the meeting. It's 1.49 PM, September 14th. We are out of executive session. Again, the purpose of that executive session was to review two separate staff recommendations. One was a social equity status denial. And it was a person claiming to be from a community that had been disproportionately historically impacted by cannabis prohibition. And then another applicant that was presumptively disqualified because of events in their criminal history record and the staff had recommended that the person has overcome that presumptive disqualification and is able to be licensed. We had the discussion about that. I think we're now ready to vote on the entire staff recommendations for today. I move that the board accept each of the recommendations for social equity status and licensing approval as presented to us by staff in this meeting. Second. All in favor. Aye. Aye. Well, that's great. It's, you know, some retail applications on September 14th. That's huge. Not too bad. There should be snaps to the staff. Last thing we have to do today is do public comment. So we'll handle it the same way we always do. If you have joined via the link and would like to make a public comment, please raise your virtual hands. We'll call on you in the order that those hands go up. If you will move then to people that joined via the phone and we can start with our first one, Rose. Hello, I'm a 21 year old medical patient. Thank you for letting me speak today. My comment is regarding medical testing for just testing in general for the medical program. I'm speaking to the mandated education part of it as well. As a medical patient, it worries me that the medical dispensaries are not subject to the same education mandates, though they have much more money to do so and are using, and their outreach is to a lot more vulnerable patients who need that extra support and that protection. This is in line with the reality that medical dispensaries are not actually up to par in some cases and it's something that I feel it does need to be addressed. There gives no protection to me and other patients while adult use mandates that there's just no testing for medical dispensaries. And again, as a medical patient, canvass is expensive and my medicine is expensive and I can definitely vouch for others and say that canvass is expensive. And if we want access to clean tested medicine, we have to go to dispensaries and either pay a huge tax or not know what we're really getting. And I wanted to speak up as a young medical patient and reiterate how concerning this part is as well as many of you know, this information is all public. And yes, thank you very much. Yeah, thanks. Thank you for sharing. Any other people that joined via the link, please, if you'd like to make a public comment, raise your virtual hands. And if you joined via the phone, you can make a public comment. You hit star six on your phone to unmute yourself. I'm seriously concerned with the tracking system and I understand that you are trying to do what's best and from my experience and my knowledge, 23 states use metric and it is sufficient and well used. And I also want to know is Carrie Garnier and you guys going to give a training session how to implement all this information or is this just about free for all to retailers and everybody else put it in. How in God's name are you going to track every single sale, every single retail dispensary in the state without a proper track and trace system? That system dice all today on there, it might be good, it's from NCS Analytics and but it does not meet the standard of what is going on in the United States for track and trace systems nationally. And I've spoken to three other companies, Biotrack, Metric and Leafwire Tracing System. They all have decided to turn over to, most states have turned over to using Metric. And that's the best system out there. And I've sent you guys that emails a dozen times. I've sent emails for the last 18 months and not ever got a response from anybody at the CCB. I am a medical patient. I am just as concerned with that as I am for the retail market and the consumers out there because that system has no training, has no 24 hour support, has no way of doing anything to help anybody if they have a problem. Where's the support network in your track and trace system? There's no training for whatsoever. There's no 24 hour technical team to answer questions. It is a individual website put on your page that you put the data entry in freely with no backup of any sort. And there's no licensing to get in there. With Metric, you can go into the system. It has a 101% renewal rate. 23 states in the country of Guam use Metric. They provide news bulletins on contamination. They provide the hardware and software at a very low cost to the commissioners of the regulated cannabis industry. They use RFD tags to monitor everything that is being done. This seed to sale tracking thing is kind of behind the eyeball in my opinion because it says seed to sale means when those seeds got planted in the ground in this year, they should have been tracked all the way through to harvest. Instead of let people grow and then throw it out there to the consumers. God only knows what they've done with it. I personally will not buy any products in the state of Vermont from the retail sales market this year just for that reason alone. And I feel really disappointed that you guys did not investigate the market and went with NC analytics. And I know the guy that just was down in DC recently had a nice meeting down there as well. The holder for NC analytics held a nice meeting down there and I read his article recently. But anybody that's listening to this comment section today, please go and look at metric.com m-e-t-r-c.com and see in real time currently today 300 million sales in Massachusetts and 900,000 that have been given out easily. They track every single data point then in Massachusetts, metric opened a data catalog for police, schools, law enforcement and parents to know what the good products are and what the bad products are. I do not see anything like that in Keri Garnier's tracking entry system. That is, I could do that myself and though that's something I don't trust it and I feel bad for the consumers of Vermont and that's all I have to say to you for my comments. Thank you. Yep, thanks Keith. Dan. I just picked up the end of that last comment but just wanted to commend the board and thank you guys for your efforts. Just would like to comment about metric, metric is used in every single state except for the state of Washington is it's an incredibly flawed system. I have experience using it. It makes it incredibly burdening and difficult for farmers, especially small businesses. It's a really horrible, horrible tracking trade system and I just wanted to applaud Vermont and the CCB for trying to come up with something that can work for everybody. Thank you. Thanks Dan. Any other public comments either via the folks that joined by video or by phone and again, for phone it's star six to unmute yourself. I only have one comment really quick just to throw in about metric. Metric also does non-reusable plastic tags. So if you guys are trying to alleviate the plastic tag thing then I don't think that that really goes along with everything that you guys are trying to do in Vermont. Just my two cents about metric. Yep, thank you. How do we navigate to the seat-to-sale inventory tracking system? So we will be communicating out to our licensees about how to do that when it's fully up and operational. So right now every licensee should be tracking their inventory and getting ready for that first initial inventory input. I see. Rose, I see your hand up. We don't generally take repeat comments during these types of public comment sessions. But if you do have a comment, I really appreciate your comment from earlier. Please email the board, ccb.info at vermont.gov. We have a public input button that you can hit on our home page, ccb. vermont.gov. And that goes to all of our inboxes here. So we'll see it. If I don't see any other comments, Todd? Thanks, I appreciate the time. This is Todd Bailey from Trace. We're a Vermont-based seat-to-sale tracking company. And I'm just curious to know whether or not under the temporary system, our customers using our solution will be able to upload their data to the temporary system or will they have to do that manually? So again, we don't generally answer questions. I know I just broke that cardinal rule a minute ago, but we generally don't answer questions. If you want to send that question to Carey, I think he'll be able to get you an answer. Great, I appreciate it. Sorry, I didn't mean to break the rule. No, no, it's fine. I would know. We appreciate getting the questions. They're very helpful for us and kind of... knowing where we need to kind of provide the public more information. So I don't mind getting the questions. We just don't turn these public comment sessions into kind of question and answer sessions. All right, well, I will close the public comment window and just once again, thank just the tremendous effort of everyone here. It looked almost impossible to meet some of the deadlines that were in Act 164. And yet here we are today. So thank you all and I will adjourn the meeting. Okay, buddy. Thank you.