 Okay, we are recording. Hi, I'll get started then. My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is Wednesday, August 10, 2022, and I call this meeting to order. Let's see. A quick licensing update, I think you'll see on our register for this week that our licensing staff has started to shift their focus more fully to indoor cultivators, product manufacturers, wholesalers. We have a few product manufacturers that are literally in the last stage of review and will likely be ready for approval at our next meeting. It should be clear that we are still reviewing outdoor and mixed-tier cultivators, but the needs of the market require us to think about the entire supply chain and have businesses licensed at every license type. So what does this mean if you're an outdoor cultivator with a pending application and your plants are already in the ground? I'm going to talk just for a minute about the board's approach to enforcement while we work through our backlog of applications. The board's primary job is to move the legacy market into the legal market. The last thing that we want to do is to punish people that have actually taken us up on this proposition and applied for a license. So here's our thinking. If you have a pending application, if you're doing your best to work through the process of getting licensed, if you're operating within the scope of the license you're seeking, and if you're following all of our regulations around inventory tracking, pesticide usage, youth access, and everything else, then we're not going to punish you for the time it takes us to review your application. But if you're doing things that would not be permitted under your license, including things like selling product to the public, particularly to youth, trying to bring cannabis from an illegal grow into the legal market, moving cannabis across state lines, these are the things that will not only impact your ability to get a license from the board, they're also crimes and they are subject to law enforcement action. So the bottom line, if you have a pending application, you know, act and operate like you have a license and we will too. I wanted to talk quickly about retail. So on retail, I know the kind of one thing that's on everybody's mind, certainly everyone at the cannabis board is, are we going to be ready to issue retail licenses on October 1st? It's hard to say definitively one way or the other. There was certainly a time when I didn't think we were going to hit any of our deadlines that were in Act 164 and yet here we are with over 130 licensed businesses. I can say that we're going to move as quickly as we can. Retail is, of course, the most complicated license type that we have. These licenses involve cross-jurisdictional input from the CCB, fire safety, local cannabis boards if they exist, and even if they don't exist, you may need local approvals from select boards and development review boards. There are Act 250 issues. There are tax department issues. There are product registration issues. If you intend to sell vaping devices or vaping cartridges, you are subject to the Department of Liquor and Lottery jurisdiction. More fundamentally, from the CCB's perspective, we have to prioritize public safety above all else. It probably doesn't surprise anyone listening today that there has been a recent uptick in targeted organized thefts across the country aimed at cannabis retail operations. Just this past Monday, over $100,000 in product was stolen from a retailer in California. There's been a rash of coordinated burglaries up and down New England at retail locations earlier this year. Washington State reported over 80 break-ins at retail locations in the first four months of this year. We don't want to micromanage our licensees, but we have a public safety mandate, and we need to inspect and feel confident about your establishment before we can grant you a license on the retail side. This is the primary reason why we opened our application portal as soon as it was ready. We're not under any illusions that this process of reviewing applications can be completed quickly, and certainly not in the one month period between September and October that the legislature anticipated. Just get your retail applications in. We've seen a number of them come through. We will work with you to get you licensed, but please just understand that the words that are on the paper and a bill that was passed two years ago are just directive. They do not create an entitlement, and we want to live up to that expectation, that October 1st expectation, but we're not going to do so at the expense of our overarching mandate, which is to roll this market out safely, effectively, and equitably. On that last point, I'd like to review again our equity directive and how that impacts our priority of licensure when it comes to retail. We're going to do what we've done for every other license type. The backbone of our priority system is first in time to submit your application first to review. The layered onto that, though, is that social equity applicants get primary priority review, and economic empowerment applicants get secondary priority review. Once we've completed our initial review of these applications and either licensed them or sent out incomplete letters, we will move on to general applications in the order that they were received. We will always prioritize the needs of the market, meaning we might move a product manufacturer above a cultivator or perhaps a retailer above a wholesaler, but only if we decide that there are bottlenecks or gaps in the supply chain for it. Just a reminder also that none of our application portals for any of our license types are closed or are closing. We have the authority to close them, but A, we have no intention of doing that anytime soon, and B, we will give the industry plenty of notice if we decide we're going to move in that direction for any of our license types. There's a couple of concerns raised at our last meeting regarding the publishing of towns in which licensed cultivators are operating, or even just the business names of cultivators. I want to acknowledge this concern. This is a valuable crop, and the board doesn't want to facilitate theft, but fundamentally application materials and their licenses and licenses generally are matters of public interest and public concern. The default presumption is that a record is public unless there's a specific exemption that protects it from public inspection. But it's important for the sake of transparency and our own legitimacy that the public knows generally who the CCB is licensing. There is a public records exemption in our statutes that allows us to withhold information related to public safety. We feel that the best way to navigate these competing concerns is to publish the towns in which a licensee is operating. Not the physical address, you know, not the span number, just the town name. And the average town in Vermont is about 40 square miles an area. Our rules require that your grow be physically shielded from public view, either by a fence or a natural barrier. Of course, we have increased security requirements for cultivators, depending on the size of your grow. We feel like what we're doing strikes that balance between transparency and public safety. However, if we need to reevaluate this decision, we will. Just wanted to touch again on inventory tracking this week. We should have signed contracts with our inventory tracking vendors later this week. We are very close to having the very specific inventory tracking data points finalized for each license type. We're going to post these to our website once they're done so that, for instance, a cultivator or a product manufacturer or retailer can know exactly what data sets they need to be collecting about their inventory and how frequently they need to report that inventory that inventory information to the board. At some point this fall, you'll be able to submit this data directly through your CCB account. But until we have that functionality, we're going to be asking that you submit this data at regular intervals through an online form available on our website. We'll likely do a training on this. Hopefully at our next meeting, which actually isn't until August 31st. Medical program, just a reminder that we're holding two roundtable discussions to solicit input on the future of the medical program. The first one is today following this meeting at 2 o'clock. The next one is tomorrow evening at 6 p.m. We have some directed questions we'd like to ask, but we want these to be open-ended discussions about the future of the program. They are fully remote. The links to participate by video or phone are available on our website. So, other than that, Julian and Kyle, you had a chance to review the minutes from our meeting last Wednesday? Yep. Is there a motion to approve? No, moved. Is there a second? Second. All in favor? Aye. Aye. All right. Moving on. Kyle, do you want to take over for a packaging discussion? Sure. Very quick. We don't have any categorical waivers to approve. This week, I think. Over the coming days, we'll probably look to approve some of the requests that have come in. And we've got a number of requests in right now. I also know that have been given a lot of packaging. You know, that even as child resistant, that doesn't have any plastic in it at all. I will say, like, there's been some questions that have been asked around vape carts, you know. Vape carts come in a host of different styles. If you're looking to use a vape part that has a very small amount of plastic within the chamber, so to speak, we don't need to see that. I really don't want to move in a direction where we allow vape carts that instead of a glass chamber, they have a plastic chamber, but some mouthpieces are ceramic, some are plastic, some are metal. There are some little components within that chamber that could be considered plastic. We don't need to see those. But I don't want folks to think that if they want to use the cheaper plastic vape cart alternative that that would also be allowed. So hopefully that was clear. If it's not, please let us know in the public comments and I can try to elaborate a little further. We are kind of before I get into more of the different biopolymers and actual like DRAM containers that may be useful and present in other markets for flower. I'm really looking at films and inserts and so on and so forth that might be necessary for the proper functioning of the market, especially as it relates to chocolates, edibles, that maintain shelf life in a different way than flower. There are some alternatives out there to your traditional plastic films. I know we've got requests in for like a PLA film. The problem with PLA, and I used to represent PLA interests in DC at one point in time, they don't break down under anaerobic or landfill conditions any differently than regular plastic. There are some woody biomass, meaning they come from trees. Alternatives out there, I'm encouraging folks to do some research and see what is out there. On the flip side, I'm really looking and digging into the polymers that can break down in a landfill without the need for an industrial compost facility. I've had a lot of great conversations, whether it's Michigan's head of composting or folks in DC or colleagues out West on how a lot of these resins that do compost are then put through a process that is confidential business information and turned into these actual drams that folks use and the thickness, even of a PHA or something like that can really determine how quickly these can compost under backyard composting conditions. So we have an issue with a whole lot of waivers. I don't want folks to think that we're not taking our waiver process seriously at the same time. We're really hoping that folks gravitate towards the glass alternatives that we've in the screw tops that we've put into the market. I recognize there's a portion of the LCA or the life cycle analysis that's apparent when it comes to shipping and all of the stuff around that. But if you really dig into the details, I don't want to get super wonky. I know that folks have given us feedback that sometimes I can be a little too technical when it comes to these issues. I don't want to bore anybody. When you look at the full life cycle, I'm still really confident in the direction we want to take the market and we really are encouraging our potential retailers and others to think about reuse and to think about our reuse programs because that's where we can really look to make a difference. So I'll get off my non-plastic soapbox and we can move on to the fun stuff. Yeah, I think just what I would add is we want to have a number of solutions for every product type. And so, you know, if people, you know, product manufacturers, retailers, whomever are seeing that we have gaps there, whether it's for concentrates or, you know, misters is one that I've heard about. If there is gaps in, you know, there's no product solution that you can think of or see on our website for a specific product type, that's the kind of stuff that we want to kind of prioritize. Yeah. And I will say like we are certainly aware of the way that concentrates are packaged. It's hard to work around plastic with how concentrates are typically packaged and, you know, we'll look to make some accommodations there. And, you know, once those waivers are granted, they'll be present on our website. We'll notify the folks to Salesforce that have requested that waiver and we should have some more soon. I've seen Mylar bags that are home compostable, which is really cool. But they haven't come through on our waiver request yet. So for folks out there that have given me this bag, person in particular, I don't know if she's listening, please put that through the waiver portal. I think, you know, that's something that should break down relatively easy under home composting conditions, but I don't have it in my waiver process at this moment. So, so yeah, that's all I got. Yeah. I think the point that I was trying to make probably ineliquently is that we're not going to prohibit a product that's otherwise, you know, allowed in our market strictly because there's a, there's no non-plastic packaging options for it. If there's a product that requires, because of the type of product it is, a little bit of plastic, then we're going to try and accommodate that. You know, we don't want to prohibit products that are allowed, otherwise allowed on this market. All right. Anything you wanted to add on this? No, thank you. And Kyle, for what it's worth, I don't find any of this boring. I'm slowly picking it up in a way that I should fully understand it. Yeah, it is a little boring. I'm just kidding. I'll acknowledge that. And, you know, I just want folks to know that we are taking this seriously, and I'm very pleased to see how serious some folks are taking it as well. And I see that coming through in a lot of, you know, the answers to questions that we're asking of folks in our waiver request. And, you know, it's a, I get a lot of questions from a lot of other states that are interested in this and they want to know how the process is going and what kind of accommodations we're making. And, you know, Vermont can be thought leaders in a lot of different spaces. You know, the more mature markets are looking to the newer markets to kind of see how they're fine tuning things after, you know, looking at what mature markets have done and something like this, if it takes off would be, would be pretty cool. But, you know, we know we're a little bit ahead of industry and we're trying to meet folks where we can. All right, Bryn. Thank you for the review of recommendations for licensure. Okay. Okay. So here is your register for this week. As usual, we'll start with the medical cannabis program. So here are the numbers from the last seven days. We've gotten about 90 applications received into the medical program. We've issued 41 patient cards in the last seven days and six caregiver applications and two dispensary employee cards. And the update on where we are in the queue is that the staff are currently processing applications received on and after the 14th of July. So we are still within that one month period for our review process. We'll move on to our license applications, which we cannot figure out how to numbers, which we can't figure out how to fit on one, on page with the heading here. We'll keep working on that. So this is your big massive numbers here. We have 18 applications for a license, actually 19 for your review this week. Numbers are down there. As the chair mentioned, we do have about 25 manufacturers of the different tiers in the queue. And a handful of them are quite close to being ready to appear before the board for your review. And we have, I think about eight wholesalers that are in the queue. And again, we have a couple of those that are nearly ready for the board to review. One thing I wanted to point out is that we have this dismissed status at the top of the page, which you'll notice there are a handful of people in the dismissed category. And I wanted to point out that our system does dismiss an applicant once they spend three months on incomplete status. So what that means is if we have reviewed your application and issued an incomplete letter to you and you remain in that incomplete status for three months or longer without getting any information back to the board, then that's when the system will automatically generate an email to you, send it to you that your application has been dismissed. And at this point, and I believe this goes out in the letter, all you need to do if your application is dismissed is to email the board, notify the board, that you would like your application to be reinstated and we will put you back in the queue. So as we're building our application portal, that is a functionality that we built in to ensure that there were not stale applications in the queue. But given that it's taking some folks longer to update their applications, all you need to do is to notify us that you don't want to be dismissed and we will get you right back. We will change your status and get you right back in the queue. I'm going to move on here to our recommendations for a license this week. So the list before you here of 19 applicants have all demonstrated compliance with the requirements for a license contained in board rule and in statute. So I will run through them. We start with, and one thing I'd like to point out is that the business name that's included in this chart is drawn directly from the application. So no amendments to these names, just what is included in the applicant's application. So we have BIG Intelligence Group, LLC, way high up there, LLC, the Mad Botanist, and all three of these. Actually, BIG is an indoor cultivator tier one, way high up there is mixed tier one small cultivator. The Mad Botanist, mixed tier one small cultivator. Cavalion, LC is a mixed tier one small cultivator. Stone leaf grow is a mixed tier two. Green state of mind is a mixed tier one. Mt. Gay Farms, mixed tier two. Flower first, outdoor tier five. Mend Botanical is an outdoor tier five. Island Craft Cannabis is a mixed tier one. Mythic Gardens is a mixed tier one. Brigham Hill Cultivation is an outdoor tier one. Cannabot Farms, outdoor tier one. Giving Tree Farm is a mixed tier one. Old School Weed Company is an outdoor tier two. Homegrown Health is an indoor tier two. Lucky Leaf is an outdoor tier four. Mad River Terps is an indoor tier one. And Rock Lake is applying for an indoor tier one. So we have four of our applicants that are up for licensure this week, our social equity applicants. So we have four social equity applicants pending board review this week. And we have one submission that is being recommended for social equity status. So that is submission number 769. And staff are recommending social equity status for this week. And we have four social equity applicants because they need the criteria for a social equity business applicant as defined in board rule. And we don't have any recommendations for social equity denial this week. That is your list. Any questions for Bryn? No. All right. Kyle, do you have the. Motion ready. I do. No, I move that the board accept each of the recommendations and licensing approval as presented to us by staff in this meeting. Second. All in favor. Hi. Hi. Hi. Okay, great. Thanks, Bryn. And why don't we move to public comment. We'll handle this the same way we always do. If you've joined us via the video link, please raise your virtual hand. If you'd like to make a comment, we will start with the folks that joined by the link. And then afterwards we'll join by a phone. You can we'll move to you. Okay. Love is first. Can you, can you guys hear me? Hello. Hello. Yeah. Yeah. Hey, thanks. I just wanted to first thank you all for coming off for interviews that has been really nice to you guys. I wanted to touch on the packaging a little bit because and James, this is something we talked about the other day in our interview. When you order glass jars in a box, it comes individually bubble wrapped on each container. So I, and like I said to you, I do appreciate the challenge of trying to move away from plastic, but I think there are some other considerations there that are worth looking at because each one of those glow, the jars is individually bubble wrapped and they are inside another box that is also bubble wrapped to protect that entire box. And I, I think that's just, and I appreciated Kyle's comments about the, the full life cycle of the product because I think that's really important to consider, but I think another thing that's important to consider is the transportation costs of how, how much extra does it cost in gas to transport that many jars, you know, and I just wanted to throw that out at you guys. And also James, I really, I was listening to your comment about robberies that have been going on and personally, I am worried about that. You said, I believe someone said 80 robberies in the first four months out in Washington and that's, that's a significant number really I believe in a fairly small state. And I, I'm wondering, you know, without the use of firearms, which we've also spoken about how dispensary owners and growers are to protect their products and their employees and all of that. And I'm going to, I'm going to leave it right there. Thank you guys. Thanks, Caleb. Tree frog farms. Hey guys, how are you guys doing today? Good. So hearing this, the incomplete status for the three months, then where that goes to being dismissed had a few kind of concerns about that. I didn't know, will that end up slowing down the process of the application. And I guess one of my concerns is I got my incomplete couple of weeks ago turned in the three forms that I was missing stayed in incomplete status was lucky enough to talk to Dominique there. She's wonderful. Got that stuff in. Got it on Alexis's desk. I think the week before last. And when I check on it, it still says incomplete. So I didn't know if there, I didn't, I didn't know if, if it stood in incomplete because action hadn't, hadn't been taken on some, on maybe your side, but I've submitted stuff. If there's a risk of that going into, you know, the disregarded portion. I just, it kind of seems a little risky. And I was wondering, is there so for submitting incomplete notices, would it be easier to have like a resubmission email box that goes out with your incomplete status so that when people email, they're missing components, it doesn't go under regular application questions and all that. So that maybe it's easier for you guys to pick apart and see that rather than going through 250 emails of just regular questions to look for resubmitted information. Thank you. Thanks for the comment. Edo. Hi everybody, hopefully having a great day. Just some more thoughts about the sharing of. Licensee locations. So I didn't see the point of that until now. So I guess. Chair Pepper was saying that the point of that is transparency. So how about as a compromise, we say the names of licensees and their county instead of the town. You know, indoor growers can't necessarily shield the view from the road in some cases. And I realized that to the average person, they might not realize it, but to somebody who's looking to steal from an indoor grow, there's definitely some, some pretty clear telltale signs that there's a commercial grow inside of a building. So that's my thought, maybe just a compromise there of, of switching the county because that feels like it still accomplishes the goal of transparency. Thank you. I guess. Thanks to you. Jeffrey. Hey, good afternoon, everybody. Can you hear me? Okay. We can hear you. Thanks, James. Hope everyone's having a good day. I want to extend congratulations to those that were approved today. And to the board, you guys seem to be. Licensing and approving our DJ members on a near weekly basis, which is very exciting. So we want to. I don't acknowledge. What James had mentioned at the start of the meeting about the. The public information. We recognize that this is common practice in other states. And those who are listening, just also recognize that this is public information out there on the secretary of state's website when you, you know, want to register a legal entity. This is information that's out there. We appreciate the concern and we do hear some of that within our member base. I do want to raise quickly a concern that is becoming raised amongst not just VGA members, but also growers and manufacturers throughout the state that we're hearing. So I want to raise very quickly in act 158, which was bill S188, this past legislative session. A couple of license types received new allowances, expanded allowances. The whole sale or license type received the new allowance to buy and sell seeds and living starts or living plants, all of these. And the cultivator license type. So all tiers also now have that allowance as well. So that's the result of 158. We welcome and we actually VGA and BCC, the college that have been, we probably spent more time in committee than any other group in the state pushing for these allowances for cultivators. So we welcome that cultivators. Appreciate that. The concern is with the wholesaler. They now have a plant allotment with no parameters. We are concerned about the wholesaler having pretty much a limitless plants for this new allowance. And we urge the agency, you guys to consider introducing fair parameters here. We think that it risks devalued the cultivation license. And again, we just want to press that we welcome the wholesalers having this allowance, but we do not think it's appropriate for them to have limitless plants and we urge you and we actually linear jurisdiction to prescribe a sensible regulation here. So thanks for your time. Thanks Jeffrey. Ben. Good afternoon. Can you guys hear me? Yeah, we can hear you. Hey, well, I think there's always everything you guys are doing. I didn't want to kind of echo Tito's comments there about security. Personally, I've already started getting mail to where my business is registered as Jeffrey just mentioned, you know, anybody who knows what they're doing can take a, you know, a company name and find out the principal owners and where it's registered. So in another kind of similar vein, I'd like to recommend maybe if possible, just listing the registered licensee and their name. And that way, you know, there's multiple names and you might not be able to get it down to the exact address. I've already been getting mail from people and I don't know who else could have that address. Secondly, I'd like to, I'm not sure if there's any sort of talks going on with kind of trying to connect law enforcement with the growers and the licensees directly, you know, to just kind of have a good relationship there and some sort of program to have quick response in case something does go awry in this high risk industry. Thanks so much and have a great day. Thanks, Ben. I don't see any other hands up. You know, if you do have a public comment, feel free to raise your virtual hand, but we'll move on to people that may have joined by phone. If you have joined by phone and would like to comment, you can hit star six to unmute yourself. Nellie, are you seeing any microphones on mute? I am not to know. Okay. Well, then I will close the public comment window. Thank you for those comments. We really do try and, you know, listen to the concerns and kind of fine tune our practices. So, you know, just keep them coming. We do have a portal on our website to submit public comments as well. And anything else? Julie, Kyle wanted to mention. Not really on the packaging stuff like, look, this is the direction that the board is going. I recognize some folks aren't necessarily happy with that, but this is the direction that we're going. And, you know, it's interesting to me because as consumers in the United States and across the world, like we're so used to plastic being the most convenient alternative that folks make so many excuses to continue to use it. But back to the point of how things are shipped, all of that is taken into an LCA. You really got to go back to how those boilers that are making certain materials are even, you know, what energy sources they're being used from, all the way through transportation costs, all the way to end use and reusability. All of that is taken into account in an LCA. And when you look at the full picture, I'm still very confident in the direction that we're going. I understand that the way certain things are packaged might feel a little, you know, off-putting, but you need to, you need to recognize that things go way further back, that paper trail is, goes all the way back to how these industrial processes function. And so I just want folks to remember that, you know, obviously scope three emissions and the greenhouse gases from something weighing more than your, you know, your Mylar alternative factors into the equation, but it is certainly not the full picture. It is one of the hardest things to actually measure when it comes to an LCA because there's so many little things like that that are really, really hard to measure. So we're not backing down off of this. I appreciate the concerns, but this is the direction that we're going. So work with us. We're trying to work with you, but I just want to make that quite crystal clear at this point in time. This is the direction that we're going. I'll get back off my non-plastic soapbox. No, I appreciate it. I mean, you know, there are very few, there's a lot of just copying and pasting that people do in adult youth states and they kind of just blindly sleepwalk into the future, honestly, and we're trying to do something slightly different here in Vermont. And I know it's not easy and we'll get there. You know, if we need to kind of make accommodations, like we have been, we will, but it's just, it's going to be a process. And I will say, like, you know, when I can find the bandwidth and we can come up for air, I want to talk to our industrial composters to figure out how we can be supportive in trying to get bioplastics back into the conversation at industrial compost facilities. But the fact of the matter is right now, these aren't breaking down on a timescale that fits their suitability for getting that product back to everybody to use as compost. And you know, a lot of the same arguments that I hear, not just in this meeting, but all the time is what I heard from the American fuel and petrochemical manufacturers when I was trying to advocate for bioplastics in DC and, you know, they're the same arguments and they're valid arguments. But we need to think about things in a different way. And everybody that I talk to recognizes this importance, they want to move away from plastic. It's just uncomfortable and it's not the most cost efficient. It's not the easiest to shift. I recognize that. But if you dig back through the details and you look at who's funding these LCA's, I think, you know, I'm very confident in the direction that we've chosen to go. That doesn't mean that we won't work, make accommodations as we talked to make sure the market is moving in a direction that's where there's a place for each individual product, but it's the direction that we're moving. I just want to make that clear. Pepper, I wonder if you would just revisit what you talked about at the beginning of the meeting, because there are quite a few people that joined just after you said that you talked about compliance and, you know, the piece about sort of cultivators and others and the difference between how we're going to kind of focus on compliance for those versus retailers. Would you just maybe, because there were just, I just watched a number of people join right after that and I think that that is something that folks are really interested in knowing. Sure. Yeah. I mean, the question presents itself where there's a, you know, cultivator with a pending application that maybe already has their plants in the grounds, you know, and our thinking on those types of situations is if you have a pending application, if you're doing your best to actually get licensed, if you're kind of making best efforts to kind of respond to our incomplete letters, respond to board inquiries, you're operating within the scope of the license that you're seeking. You know, if you're looking for a tier one outdoor, but you have, you know, 2,000 plants, you're operating outside the scope of that license. You know, but if you're operating within the scope of the license, you're seeking and you're following the board rules around inventory tracking, pesticide usage, youth access, and all of the regulations that apply to that license type, then you're doing everything that we want you to and we're going to use our enforcement discretion to let you continue to operate until we get you that license. You know, however, on the flip side, if you're operating outside of the scope of your license, if you're selling product to the public, if you're dispensing the youth, if you're trying to invert, illegally invert cannabis into a legal market from an illegal grow or if you're crossing state lines with cannabis, those are the things that we can't look the other way. We really need to, I mean, we can't, those are the types of activities where we will get in trouble if we issue you a license. And there are also crimes. I mean, I gotta say that that's also criminal behavior and law enforcement is, if they know about it, they're not going to tolerate it. So I guess the bottom line that I said before is if you have a pending application, act like you have that license in your hands, act like you're subject to our regulations, and we will as well. And just to clarify, Chair Pepper, did you mean, is that included people who've got pending retail applications or are we handling that slightly different? We can't allow retailers to retail. I'm talking about cultivators that maybe from the legacy market that maybe have genetics, maybe have plants in the ground already. And again, those kind of caveats apply to that situation, not to the other license sites. Thank you. I know that there's a lot of folks who've asked those questions. Yeah. Say one more thing, completely unrelated to this. So I've been seeing a lot of, I've gotten a lot of questions. I've seen some things around pesticides and the ability to get out of pesticide testing, depending on certain certifications from a third party that you may be looking to work with. We did put language that would allow that under a certain set of circumstances into our regulations. But a part of that is us having those conversations with those third party certifiers to make sure we're comfortable with that third party. Before we waive any testing for pesticides, for any cultivator. And to date, we haven't had substantive conversations where we've gotten to the point where we are comfortable granting that specific authority to any third party certifier. There's a number of them out there, from just trying to get off the ground to establish in this industry that I think could probably do a good job. But we haven't granted that authority to any third party. So just be, if you have questions about pesticide testing, please reach out to our compliance team before you make any assumptions as to whether or not your product needs to be tested. Because I can tell you right now, everything needs to be tested for everything. We haven't made any of those decisions as it relates to third parties and what they can do in lieu of testing. We'll get there, but we haven't circled back to that specific process yet with the umpteen other processes we're trying to install right now. All right. Well, I think William will adjourn this meeting and we'll see folks back here hopefully at two o'clock, 15 minutes for our medical, first of our two medical roundtables. Thank you all.