 My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is May 16th, 2022. And I call this meeting to order. Just a quick update on licensing. I won't bury the lead today. We're going to be issuing our first operating license. It's a social equity applicant in a small outdoor cultivator. I know many people out there were hoping we'd issue more by now. And we share that concern, that feeling, but it's, I think, at least relevant to put me, put this moment into a little bit of context. When I started down the road of tax and regulate back in 2015, the goal was to get up and running by issuing licenses exclusively to dispensaries. This was the model at the time around the country and it still largely is. Vermont really has charted a different path forward. You know, when we were appointed a little over a year ago, issuing licenses in 2022, let alone May of 2022 felt like an impossibility. You know, the Cannabis Board is a new independent agency. It's not under the umbrella of a larger agency. They could give us things like computers or a place to work or any of the kind of basic IT or HR support. You know, we really had to build this agency from the ground up. And I know I'm a broken record on this point, but you know, the legislature was supposed to give us our staff and approve our basic market structure last year. We were supposed to hire these people and build our regulatory structure with them last year and essentially have the entirety of the table set for May 1st. But the early delays and passing Act 164 snowballed into delays and appointing the board members, appointing our advisory committee, missing the 2021 legislative session and hiring our executive director. And of course, there's always a tension in government between doing things in the open with public support and doing things quickly. From the beginning, the board really recognized that the only way we were going to build trust and the rules that we needed was to embrace the open meeting laws to have an open and honest dialogue with the public. Since our first meeting last May, we've held over 150 public meetings. I think we set the record with respect to adopting our rules. And yet we did so with the tremendous amount of public input and advice. We now have a functional licensing portal that's getting better every day. We've pre qualified I think over 100 applicants and today we're going to be issuing the first Vermont legal cannabis business. So this is not a victory lap, but I would like to take a brief moment to acknowledge the incredible work of our staff. You know, making up for these delays has always been a top priority of the board, but it's come at a real personal cost to our staff. Who've ignored their families, postponed taking time off, spent many sleepless nights thinking about canopy sizes and insurance requirements. Certainly cash in all their favors with our partners and government with the legislature and with family members. And really a lot of the problems that we face as a cannabis board are unsolvable. And at times intractable because of the federal status and the enduring stigma associated with cannabis. And working here at the board just means you have to embrace that and wake up every day attitude that we're going to give it our best shot. So thank you to the original cannabis team. Nellie David Kimberly. Thank you to the medical team Meredith Melissa and Lindsay. Thank you to our new recruits, Carolyn Alexis and Dominique. And Julie Kyle, thank you. You've all really shown a lot of persistence and patience, resilience and conviction. And you're all a lot of fun to work with. And I know, Julie, you keep looking over at Bryn. Bryn, all I can say is where would we be without you? You really are the heart and soul of the cannabis board. You're a leader, a strategist, our therapist, our spiritual advisor and our best friend. If you go back and watch the debate around Act 164, the legislature didn't want to spend any money on the board before it started generating revenue. So they combined about six positions into one into the executive director. And when I was appointed, I created a list of people that I thought could pull it off. It was a short list, an extremely short list of Bryn, you are at the very top. So, you know, I'm very grateful for you that you said yes. I'm grateful for all the sacrifices you made. I'm grateful that you've never keyed my car when you pass it. But then again, you're always here before me and I always leave before you. So maybe it's just a coincidence. Anyway, we are, you know, just taking a brief moment to acknowledge the staff, but we are getting back to work to approve more licenses. You know, in issuing licenses, the board needs to balance the urgency that we all feel with the need for transparency. So our plan is to approve licenses during our regular meetings. However, if we get to a critical mass at any given time, we may decide to call a special meeting to approve those licenses. We will do so in compliance with the open meeting laws and give 24 hours notice. And when we do approve an application, we will notify the applicant by email, the instructions on how to download your license and your establishment ID card will be contained in the email. We will also update our website with the business name, the license type, the tier, the general location, and the priority status of the licensee. We've been feeling a lot of questions about where in the pipeline each individual applicant is. And I recognize there's a lot of anxiety about getting your license, but and do feel free to call or email us with your questions. But please just keep in mind that each inquiry slows down our team and issuing licenses. We have guidance on our website on how we're reviewing applications. We are prioritizing social equity and economic empowerment candidates and the current dispensaries as the statute requires us to do. And then we will turn towards general applications in the order they were submitted. If you call us and ask where you stand in the queue, we can't give you any greater detail than that. And we will be in touch directly with you, either when your application is complete. If it is incomplete, what information we need from you and when it's appropriate for you to reach out to CSI. So that's it on licensing. I'll just give a very brief legislative update. You know, our two kind of policy priority bills did pass both chambers of the house. They didn't pass in the exact form that we asked. But they were combined kind of in a legislative maneuver in the waning days into a single bill. It's S 188. You can find it on the legislative website. It's an important bill does some really critical things for leveling the playing field between small cultivators and, you know, larger companies. There's a lot of issues around consumer safety and public safety that are addressed. And it does things, you know, that increase the functionality of the market. But it didn't do concentrates, you know, they didn't lift the cap on the high THC solid concentrates. They did ask for a report back from the cannabis control board about the impact of leaving that place. And so this issue is still alive and will be debated next year. Fire safety. I mentioned a few times fire safety needs to talk to every perspective licensee, whether you're kind of a retailer or product manufacturer or you're an outdoor cultivator. They've done some internal reorganization at fire safety and now all cannabis inquiry should run through just land and wheeler, whether you're north or south, it's land and wheeler. Landon dot wheeler at Vermont dot gov or his cell phone is 802 216 0501 inventory tracking. I know that this is an issue that people are focused on. So it's a very important part of the regulated market. It protects the industry from federal enforcement protects licensees from being undercut by illegal inversion. And it helps the board prioritize our compliance resources. And I know I mentioned it a few times, but the three major companies that have occupied the space and almost every adult use state. Have some serious downsides to them. And the last thing that the board wants to do is to enter into a long term contract. And force the industry to kind of learn the system and devote the human capital to to kind of mastering it and then have to change. You know, Washington state, for instance, has had to change three different times because they were unsatisfied with their inventory tracking systems. And every time it caused major disruptions the supply chain for trying to avoid some of those mistakes. With respect to an update though, you know, any big project requires that we follow some strict rules around procurement. We have our scope of work drafted for inventory tracking. It's being reviewed and approved by all of the right people currently. And will subsequently be put out to bid until we have a contract. I can't get too much specificities to the exact parameters of what will be required. However, conceptually, you will be required to keep records of your inventory, including all sources of seeds and clones, acquisitions, sales, transfers, harvests, applicators, testing, disposals. You can do this on your own or you can do it using a third party inventory tracking platform. You'll have to share these records with the board on a regular basis and we will be analyzing them internally and conducting regular site visits based on our analysis. This is the model that's being used in a growing number of states as the industry starts to move away from the kind of big three heritage systems. I'll continue to provide updates where possible, but please know that every licensee is required by law and by rule to track your inventory and we will be requesting those records. Other than that, I just need to approve the minutes from our last meeting on May 9. You guys had a chance to review them? Is there a motion to approve? So moved. Seconded. All in favor? Aye. Okay. The next on our agenda is to review staff recommendations on pre-qualification and licensure. Okay, so we have our pre-qualification and license register for today. I will go through it, but as a reminder, as I mentioned last week, all of these numbers that you'll see in the charts are current as of last Friday. So some of these numbers may have changed like today. So you'll see that the board has before it today 36 pre-qualification applications up for review and approval. We have really plowed through the cultivator pre-qualification applications. You've already approved a little bit over 100 of them. So today we are primarily going to be looking at retail, manufacturing and wholesale pre-qualification applications. So I'm going to jump in to our list for today. So again, all of these applicants have demonstrated compliance. They've been reviewed by staff. Their applications have been deemed sufficient to meet the requirements of rules 1.41 and 1.42. And therefore have been found to be suitable for pre-qualification. We'll jump right in. By submission number, we've got 106B applicant for tier two manufacturing license. Submission 106C retail license, submission 149B tier two manufacturing, submission 149C retail, submission 156B, tier three manufacturing, submission 156C wholesale, submission 6B retail, submission 155 tier two manufacturing, submission 39 retail, submission 538 retail, submission 55 retail, submission 74 tier two manufacturing, submission 142 wholesale, submission 142B retail, submission 238 retail, submission 469 tier two manufacturing, submission 290 retail, submission 169B tier two manufacturing, submission 1B tier two manufacturing, submission 269 retail, submission 302 wholesale, submission 319 tier two manufacturing, submission 320 retail, submission 322 retail, submission 26B retail, submission 291 tier three manufacturing, submission 291B retail, submission 490 tier two manufacturing, submission 505 retail, submission 35 retail, submission 75 retail, submission 312 tier two tier one mixed use cultivator, submission number 350 tier one outdoor cultivator, submission 369 retail and submission number 253 retail. And a reminder when there's a, when the submission number is followed by a letter, that's because applicant has submitted a pre qualification application for another license type. So those 36 applicants are recommended by staff or board approval for pre qualification. And I will keep going so if you'd like because we've got something else we have two other things to approve on the register today so if you'd like to approve everything as a package we can go through everything first. So as the chair mentioned here, we do have one license application for review today recommended by staff or licensure, but we'll take a look first at the application numbers. You can see that we have sent out about 25 incomplete letters to outdoor and indoor small cultivators. So that means that those applications have been reviewed by staff seem to be incomplete and staff has prepared a letter indicating to the applicant what they need to what they need to submit in order to have a complete application for the board to review. So we have one staff recommendation for a cannabis establishment license. So that's our that is our first applicant up for review by the board. So this business. Rutland craft cannabis limited is has demonstrated compliance with our application requirements for all license types and also those specific requirements for cultivators subject to the waiver provisions that are set out in rule 1.18. So they've that what that means is they've demonstrated compliance with rules 1.4 and 1.5 and they have been deemed suitable for licensure by staff. So you can see here the business name this is all information that the chair indicated would be public on the website business name it's a indoor tier one small cultivator. The location is Brandon Vermont and they are. They have been deemed to be a social equity applicant by the board. And lastly we have another submission number for up for review for social equity status. And then also you can see our social equity numbers up here got 10 and submitted and received status we have three social equity license applications currently under review. 29 have been deemed incomplete and we have one pending board review which is right here. So this applicant has met the criteria for social equity individual applicant is set out in rule as they need the definition of a socially disadvantaged individual as defined in rule 1.1.3 Q. The staff is recommending that this submission number be approved for social equity status. Right. Well, David you want to help us with a motion or have you done that. I think you can reuse the motion that you've been using for each of these. Yes. Do you want me to read the motion. Sure. Okay. I move that the board accept the recommendations for pre qualification social equity status and licensing approval as presented to us by staff. Second. Any discussion. I'll tell him if I'm here. Hopefully. All right. Well, all in favor. Hi. Hi. All right. And so these folks will be notified the person with the operating license and Brandon will be able to download his license and his ID card and begin operating. I feel like parliamentary procedure doesn't give you an opportunity to like celebrate small moments of joy. Like we were talking about work like this is a heavy lift like we had all these policy ideas and then our staff made them operational reality and that's just that and we had a number of people who spent a lot of time with us. And that's a gift like the fact that the public was willing to spend that amount of time and be that vulnerable and share that much personal information is a huge gift. So I just want to appreciate all of that. No, I totally agree. I've said it a few times now, but I know very little about cultivating cannabis. And, you know, there's, we could have gone down one of 100 different ways to get to where we are. And this, this one feels like the right one. We wouldn't have found this path without the support of the public. Yeah. Looking back a year ago, I think at this time a year ago, we were still trying to get cell phones or I was trying to figure out how to create a website because I don't think people realize that all of that work was done by us for the most part. So, a year big moment. We'll turn out more hopefully full application licenses in the coming weeks to other states started with small amounts and then it gets, you know, that becomes more of a routine. But it's a lot of work and there's more to do. So it's, you know. All right. Well, why don't we turn to public comment. If you have joined by the link, please raise your virtual hand. We'll try and call on you in the order you raise your hands and then we'll move to people that joined by the phone. So if you have a comment, feel free to go ahead and raise your hand. Dave. Hey, congratulations on the big first step. Very proud of all the work you guys have done. You should be proud of it. It was a lot. I was wondering whether it might be possible for the board to act as a clearinghouse or provide contacts between different parts of the supply chain as folks are pre qualified. For example, I find our retailers who would love to start conversations with pre qualified growers. So to the extent that the board can can help the market with that sort of connectivity. I think it would be much appreciated. Thank you very much. Thanks, Dave. Next, we have a red clover. I think analytics red clover, regardless. Yes, red clover analytics. Previously, we were THC analytics. But we don't change start names banking. They're really finicky about names. But nonetheless, can you hear me? Oh, yeah. Nonetheless, I want to thank you for all the work you have been doing. This is great. And I used to do group development before I started doing this. And one of the things I used to say is celebrate even small victories because celebrating small victories gives your team that that to keep going and desire to to see the goal. But anyhow, the other thing I was asking is, are we going to see any type of updates on the side of medical? It just since you guys merged, I personally haven't heard much from that end of things. And no curiosity. Thank you very much. Thank you. Okay, organics. Can you do you have a comment? So unmute yourself. Now, why don't we keep going and we'll move back if okay. Just like a spider web right here. All I can see. That is all for folks. Wait, we have one more and good morning. I am calling you from beautiful Arizona. And I just wanted to congratulate your team. I worked in 15 state processes. And I've never seen one with such transparency and truly appreciate what you have all put together there. So thank you for being such leaders in the industry. Thanks, Anne. So if you've joined by a phone, you can unmute yourself by hitting star six and we'll try and And we have a couple more folks. Okay, organics did manage to unmute themselves. Okay, thanks. Hi, sorry. It was not working with me. This is Greta with okay organics. I have applied to be a door cultivator. And I'm just getting a little concerned at the pace of things. Given that we really need to be able to get plants in the ground. So I would like a little guidance on on how to move forward, not having a license yet when really it's time to plant. I've invested a lot of money and now I'm concerned that I'm not even going to be able to grow this year. And then to about the whole background check thing. I never received a response to my email from three weeks ago. I would just like clarification as to why you can't accept the FBI check if I have already had it done and it's in my possession, and I am willing to give that to you as a background check. I understand that that you couldn't contract with them. But back in March, that was the guidance it was to go through the FBI and the state which I've done both of. I really don't understand why those cannot be accepted. That's all. Thank you. Thanks Greta. Next we have Sean Iraq. Hey, good afternoon. Thank you for taking the time out to hear the comments. As much as you all can just impress upon the legislature that the solid THC caps are going to do nothing other than perpetuate the black market, and even cause, you know, essentially another vape crisis as manufacturers potentially look to add terpenes other cannabinoids or any other item that could be dissolved into that concentrate to produce a product that now comes under the 60%. And I don't really understand why liquid manufacturers are getting a pass on it when that was a large part of the crisis of, you know, additives. There's a high potency THC that seems to be a mental health crisis or at least what other folks are chiming back in on the caps about. And maybe there could be a workaround that if you're producing concentrates above 60% that there should be a minimal amount of CBD as part of that test result rather than just an entirely THC based product. That would be a compromise that the legislature would be willing to go for. Thank you very much. Hi everybody, I hope you're all having a great day. I just wanted to express my disappointment that the THC caps didn't get removed coming as a legislature and I just want to emphasize the importance of getting this changed as soon as possible to, you know, if it has to wait now to the next legislative session, then we just got to make sure that this stays in the conversation because it really is devastating. It's really like just eliminating 50% of the revenue for retailers it feels like. But that's that. Thank you all. Thanks to you. Jared. Yes, I'd like to second the comment from the caller that said she was concerned about getting plants in the ground. I'd like you to consider prioritizing growers. For up for approval, because if you don't get the growers approved. The dispensaries won't have much to dispense. I'm October. Thanks, Jared. Can you guys hear me. Yeah. I just wanted to commend you guys on your work. I've seen this process roll out in other states and I have to say the transparency provided to the public is like unmatched, especially with regard to pushing for small cultivators and small producers in general. I will not be joining the market because of the THC cap. And so far spoken to six people who I think they want to pull their license applications but I'm curious. I just have a suggestion curiosity I know this might be written in the legislature or not. Does the board have is the board allowed to decide what products are disposed in cartridges to my understanding solid concentrates have a cap on them liquid concentrates do not but they have to be dispensed in cartridges. Is there a workaway work around for that. The cartridges themselves because of the product being put inside the cartridge. It's essentially a hundred twenty two percent tax right that's 30% cannabis tax 92% vape tax. So as a producer I sell a $25 vape cart to a store the store wants to sell it for 50 the consumer pays 110 $111. So if liquid concentrates. We're not susceptible to THC caps but we're eligible to be sold in jars as opposed to cartridges. And I just want to second the speaker who discussed the vape crisis. That was a vape crisis of cartridges cartridges being imported from China containing lead and all sorts of metals in them. People just putting whatever they wanted in those cartridges because taxes for them were so high in the white market. So you know this is this is a real problem for this market. I myself as a producer was ready to do manufacturing for over 15 different hopeful producers coming into the market. And now aside from trimming packaging edibles making they're not able to turn over a majority of their harvest to a small production lab. In order to have faster turnaround when you consider the home occupancy growers only being allowed to hire one employee. That's a lot of work for them to maximize their value and they're not able to offset that work to anyone. I mean they are but I don't know who's going to open a trimming facility because it's not really worth it. Anyways, I know it's not your fault. I think you guys are doing a great job. I just want to give you some bullets to take to the legislature. Thank you. Thanks for narrow. Hi, everybody. Thank you for everything you guys are doing. I had one comment that I was hoping. We are deep in our packaging and we want to make sure that somehow we know that they're all the packaging requirements are done and completed on your documentation that you guys have versus starting and, you know, it's very costly to change packaging. So I'm wondering if there's some way of knowing that from you guys. Also, if it's possible to get visual examples. So there's no misunderstanding of your copy that you've written. If you'll be adding any visual examples of of how things are supposed to be presented on packaging. That's it. Thank you so much. Thanks there. Jason. Hi, thank you. I just wanted some clarification on the application process about whether the applicants listed on like a tier one small cultivator application need to apply for employee ID cards or if that's kind of happens automatically with the application because for one of the two applicants, it wouldn't let me put in an employee ID card application. But the other one. It's saying it was redundant that it was already in the system. One of two of us. Okay, thanks Jason. I'm Ezra. I don't know if there's more than one Ezra, but I'm happy to share a comment. Thanks. So I am a licensing consultant in Massachusetts and a social equity applicant down here and I too have been just so relieved to see Vermont approach this from a more realistic perspective in terms of entry into the market. You know, a tier one of 1000 square feet is really going to keep local operators participating. And, you know, for example, in Connecticut, a tier one is 10,000 square feet. So it just and they also are trying to do social equity, but to make the industry more clearly kind of resemble what it already is a lot of individual growers have about 1000 square feet. And so to make that tier one I just think is a really excellent idea to keep the industry local in in Vermont so that's fantastic. And I just look forward to it coming online. Thank you. Thanks Ezra. Anyone else either by video or by phone. Jesse just raised their hand. Hello. Hey. Hey, how's it going actually this is a this is Shane McFarlane with old growth organics. I just wanted to touch base and first, we lost you. I don't know if you turn off your video might might help the connection. Is there a bad connection. Yeah. I apologize. Yeah, is this better. Okay, yeah. Okay, I posted a public comment the other day online. And I just wanted to reinforce it a little bit I had and I know we're far, far past this at this point but it's worth noting for the future. Just the the outdoor plant canopy, and then the correlating plant cow. You know, I was doing my research a couple weeks back and looking into the plant count aspect because I've been growing large outdoor plants for some time I don't do small and rose I don't do light deprivation any of that sort. And then when I read in the laws or the led regulations or what not that it has to be under eight square feet in order to be considered for a plant count right so I was excited to be able to do tier 125 plant plant counter what not but I feel like keeping it to an eight square foot per plant kind of negates the idea of a plant count at all being that, you know, square footage suggests that it can be unlimited plants, you know so then having the ability to choose that I choose 125 plants instead but it needs to be eight square feet. I would have to plant a plant in, you know, the end of June, and then you know let it go right into flower and it would still be. It would still be bigger than eight feet so there's that and then you know, obviously to piggyback on some of the other people obviously you know there's nothing we can do now but the, you know, the illegality in the black market is going to flourish with the illegal concentrate debacle. You guys all know this not trying to beat a dead horse just figured out throw it in there and you know just joining with everyone else and the obvious concern of the amount of money invested the properties purchased and all the things and needing to get licenses, you know and obviously you guys are doing absolutely everything in your power I applaud you I just, you know I don't join in very often so I figured out throwing my two cents. Thanks a lot. Yeah, thank you. I'll close the public comment. You're on the phone you can hit star six. All right, well I'll close the public comment window just a few comments in response. The things we can answer. The board will share whatever contact information about licensees that they kind of agreed to other than what we've done already so we can look into maybe sharing contact information if someone gives us approval to do so. Medical, you know there was a medical bill this year didn't get a hearing. We, you know, the new rules are up. People can apply for medical licenses if they'd like to. And if there's suggestions about the future of the program the board, you know, we'll probably be looking into that issue and creating a new legislative proposal on that. The federal ID check. The kind of you go to the post office of the sheriff's office and get your own fingerprints that specifically is not permitted to issue a license using those federal ID checks. The process that was spelled out in our statute is slightly different. And that is through the Vermont Center for crime information or crime information center. So we can't issue a license based upon that federal ID check solid concentrates. Yeah, I mean, we hear you. The legislature I think actually started to come around the idea that regulate a product is better than having the black market or the illicit market supply that demand. They want alternatives to just list lifting the cap. They want to see what can we do to kind of protect youth to protect low information consumers. And then we educate them about high THC concentrates before they lift the cap. So, you know, the Senate voted twice unanimously to lift the cap, the house. They didn't feel comfortable with just lifting the cap they wanted something else. So they've given us the task of creating a report about the impact of leaving that cap in place. December 1st of this year. So we'll be holding a series of kind of public meetings about that where people can weigh in. But really, if you weigh in, feel free to, you know, focus on what the alternative can be to lifting the cap because I think, you know, people have caught on that the illicit market will continue to supply those and do so using dangerous products. We do have a packaging approval process. You know, I would like to see a system similar to Oregon where they do have pictures of approved packaging. I've got the model numbers they have the place where you can order from. So, you know, our goal is to have a running list of approved packages. If you don't want to go out and order, you know, bulk packaging before you know whether it's going to be approved. You know, you can send the board a request to approve the packaging in advance. So I think that's, I would just say hold those requests right now we're kind of working on some processes on how to do that in a more formal way so that your request doesn't kind of get lost in the hundreds and hundreds of emails that our team gets throughout the week. So I think we've been waiting as a board until some of the packaging language that's been moving through the legislature was a little bit. You know, further towards the finish line, but we are working on guidance and a waiver process if you do have to minimize amounts of plastic and a package material that you want to use. We have a packaging and labeling because the other part of that question was about labeling so we look that's on its way. Yeah, and there is those high depth pictures of everything needed on our website from a warning perspective. And then with respect to the employee ID card friend you want to just explain that a little bit. Sure. So the employee ID cards. They were there will be a separate application for employee ID cards that separate from the cannabis establishment ID card that you get once you've been licensed. So if you do have employees or are anticipating having employees, you will have to fill out a separate application for those individuals. We set it up that way for a number of reasons, but one of which is that we are going to allow for employees to apply for their own employee ID card in addition to allowing an employer to apply for that employee ID card for their employees. So it will be a separate process. And we will have the details of that process available to everybody as they as all the licenses are issued we will make the information about how to apply for an employee ID card available. But if you are licensed to operate and your sole proprietorship if you've been screened. Does that individual need a separate employee ID card. No, so the way that our rules are structured you have to have a cannabis establishment ID card if you are principal or an owner of a cannabis establishment. And that essentially fulfills the same function as an employee ID cards if you're a sole proprietor, and you are licensed and you have your cannabis establishment ID card you do not need to also have an employee ID card. Okay, we're at the end of our agenda any other just want to clarify something that you said about the FBI that that's the FBI's role and not right of Vermont rule or a CCB rule so it's not one that we have control on their website. Yeah, the employee ID check the kind of go to your post office or share his office and get your own fingerprints for background check is not sufficient for licensure as a federal rule. Yeah, we can't wait that. So that's why we're going through the process that we are. All right, any other comments for you. I think I think just very quickly on on the response to I believe it was Shane, or Jesse Jesse Jane, all growth organics, you know certainly recognize how different grow methodologies might make that box that's outlined for you know, tough to which to prevent mold and stuff like that we we get that I think we had to put some parameters around that to make sure that those folks could still be tied to the definition of small cultivator in our authorizing legislation but got a bunch of well qualified candidates for our compliance director position and a bunch of well qualified candidates for our compliance enforcement staff. And I think they're going to help us figure out what's the right way to interpret some of that language to accommodate folks depending on how they like to grow outside. So, bear with us. One thing to what you were saying everything you said was correct but I think one helpful way to think about it is that everybody has to get cannabis establishment identification cards. The difference is that if you are a principal or owner or controller, you will get that upon gaining your cannabis establishment license employees also need cannabis establishment identification cards, and there will be a separate process for getting that after, you know, after licensing that happened. So it's sort of all the same thing. It's just that if you're one of those people who is part of the application, you just get it when you get your license. So that clarification. Any other comments before we adjourn. We're working as quickly as we can appreciate everybody for bearing with us. Great. Well then, we will adjourn. Thank you all. And we'll see you next week.