 My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is January 31st, 2024, and I call this meeting to order. I just wanted to start. I needed to mention an issue that's been raised by our compliance and licensing teams. They've been fielding an inordinate number of calls, text messages and emails with the sole question of where is my application or renewal in the pipeline. I'm empathetic to the anxiety that applicants experience and the economic position that you all are in. But every time we are responding to an email or phone call, it's taking a staff person away from the work of actually reviewing the applications, and it really does slow things down for everyone. I can certainly appreciate the need for state government to be able to walk and chew gum at the same time. Which means that we certainly need to be able to communicate to applicants when they're in the pipeline. But there is a difference between emails with questions that are necessary for approval, like genuine questions about the application itself, versus status emails. We're happy to answer the former, but when it comes to the latter, we've set up and published communication processes that are meant to avoid you having to call with that question, when will my application be approved? So let me review the process quickly now. So within a day of an application being submitted, we will change the status in the portal to received. And then within three business days of your application, your application status will change to in review, and you should see an invitation from CSI to initiate your background check. Depending on your priority status, this initial review period may last up to 30 days, calendar days, from the original date of submission. So sometime within that 30 day calendar window, you should expect to receive an email from our licensing team through the portal that lays out any areas where your application is incomplete. And it will also include instructions on how to correct those areas of incompleteness. Once we've sent this notice, we will not pick up your application back up until you have updated all the areas of insufficiency, and then resubmitted the application. So this is an area where an applicant can really accelerate or delay the approval process, depending on how quickly they move. Once an application has been resubmitted, you'll see a change in the status in the portal to resubmitted, and we will begin to review the changes. It sounds like it's this stage where we're getting a lot of these status phone calls and emails. So let me just say what is published in our application guidance document. Reviewing a resubmittal takes us about 14 calendar days. Now your application is not the only one in the queue, and the team here isn't sitting around waiting for it to be resubmitted. We moved on to other applications in the meantime, and so we give ourselves a little bit of a grace period in order to finish whatever applications picked up in the interim, and then come back to a resubmittal. If everything looks good and you have all the other licensing free requisites satisfied prior to our published cutoff date for that month, we will change your status once again to pending CCU and add you to our agenda for the board meeting to approve at the next regular meeting. These agendas are of course published at least 48 hours in advance of the meeting, so you have some time to follow up with the staff here at that point if you think that you should have been on the list, but you're not. I know this is new for everyone, and that applicants are investing a lot of money into this endeavor, but that really doesn't justify the 20, 30, or in a very a 52 phone calls and emails that one applicant gave us merely checking on the status of their application. This slows things down for everyone, and it's really bordering on harassment. These timelines and statuses are clearly laid out in a guidance on the guidance page of our website that's ccb.fermont.com slash guidance under the link application status flow chart. So if we're outside those timeframes or you have a legitimate question about the substance of the application, go ahead and reach out to us. But if we're in these timeframes again, it's 30 days from the original submission and at 14 days from resubmission, please show some restraint and let the process play out. And this is not meant as a criticism of any of my colleagues around the country, but our licensing team processes applications in a lot less time, about a third of the time is most adult use states. And our new pre qualification process will hopefully reduce that time frame even further. So thank you to the licensing team, thank you to the compliance team and we're all in this together. So other than that, just need to approve the minutes from our regular meeting from December 20th 2023, and also our special meeting from January 5th 2024. You guys had a chance to look at those? Yes. Yes. All right, is there a motion to approve? So moved. Seconded. All in favor? Aye. All right, Bryn, I'm going to turn things over to you. Here is your executive director report for today's meeting. We're going to start out with a little bit of a reminder for everybody about what the very exciting thing that's coming in 2024, which is our new license type that was approved by the legislature during last year's session, which is the propagation cultivation license type. I just wanted to give a very brief update because I know there are folks out there that are looking forward to being able to apply for this license type. So this slide just has a, actually it pulls directly from the statute to list what this license, this type of licensee will be authorized to do under the statute, and that's to cultivate up to 3,500 square feet of immature cannabis plants, test, transport, and sell those cannabis clones and immature plants to other licensees, license cultivators specifically, and to test, transport, and sell cannabis seeds that meet the federal definition of hemp to license cultivators, retailers, or to the public. And what these licensees will not be able to do is to cultivate mature cannabis plants for the purpose of producing, harvesting, transferring, or selling cannabis to any person. So these license types will be available. The board is actually directed by the statute to begin issuing these licenses by July 1st of this year, and we are on track to do that. We've got our vendor that is supporting us in building out the licensing portal to accommodate these propagation cultivation applications. So we hope to be able to begin accepting these applications probably within the next three months. So stay tuned for more information on that. So with that, I'll jump into our adult use program licensing data, and we're going to start out just our first couple of slides, offer a little bit of a retrospective of 2023, just an overview, a picture of how many sort of submissions that the licensing team has received just in the 2023 calendar year. So 800 or 864 employee ID cards have been issued in 2023. 3,683 products were registered in 2023, and we've issued 303 license applications in last during the last year. So that's a little bit of an overview of our application numbers. And then the next slide is a retrospective on product registration submissions. So this is a little bit of a picture of what types of products are being submitted for registration. So this data will probably look familiar to everybody. We're still around 75% of those products that are submitted for registration are flower, and then it's broken down from there from I think the next most common is extracts and then edibles, then tinctures, and topicals. You can barely see it and it's not represented percentage. I think it's a less than 1% topicals we have there. And then that dark sliver 3% is other products, which I believe is primarily clones at this point. So that is your retrospective of the year, and unless there are any questions about that, I'm going to move into our regular reporting on starting with cultivation license. I'm just curious to see how that changes over the next year, recognizing that most markets start as a flower heavy market and move into products thereafter. We'll keep an eye on that as the time goes on. So starting with our cultivation license numbers, here's the picture of total issued cultivation licenses by their type and tier. So we continue to be primarily an outdoor and mixed market. That really hasn't changed. So this is a picture of our current active licenses that are issued for each type and tier cultivation. And a note here that if a licensee expires without renewing or renews with a change in their tier or their type of cultivation, the numbers here reflect the new currently active issued licenses. So this is intended to reflect up to the moment picture of where our licensees stand. And that this slide reflects cultivation renewals by type and tier. So you can see that we are chugging along with our first year cultivation renewals. We're looking at around half of our initial first year cultivation licensees being in the door for renewal. And actually this next slide gives you a little bit of a picture of what that renewal process looks like for our cultivation licensees. So that first column on the left, initial licenses issued, sort of reflects that all of the initial cultivation license that the board issued. The next column is renewals. So that number captures all cultivation renewals that have either been issued or in that pipeline. So we are right now around halfway through the renewals process for our outdoor and mixed cultivators. And that is we are sort of right on track since we were issuing these license types, I think all the way through August. We did close that window for applicants to apply for an outdoor mixed cultivation license at the end of April. But we continue to issue those licenses throughout the spring and the summer. So we're around halfway at this point of renewing our first sort of year of cultivation licensees. And then that column to the right shows how many of each type and tier of cultivation license has either relinquished their license or has let their license expire. And so far about 8% of our cultivation licensees are relinquishing their license. So overall picture of cultivation licensees. And I think the next slide, I'm doing the same thing with the manufacturers. So an overall picture of our manufacturer licenses. It number of issued in that first column, renewals in the middle, and then number of relinquishers expired off to the right. And here, obviously, we've got a little bit less just where we are in the cycle. We are not quite as far along as we are for the cultivators for the manufacturers since we started issuing those licenses late in the summer of 2022. So we're not quite up to, you know, the same the same rate that we are for cultivation, but still a little bit of an overview of what we are. And then here is the same overview summary for the rest of our license types. So the number of issued retailers, testing labs, wholesalers and integrated licensees, the number of those licensees that have either renewed already or in process of renewing, and then the number that have relinquished their license. And then this slide just takes at the relinquishment rate by the priority status. So rather than breaking it down by each individual license type, which the farmer slides do, this just takes a look at who is relinquishing based on their priority status. And this relinquishment rate reflects almost exactly the proportion of standard economic empowerment and social equity licenses. And I keep talking through. So looking at that relinquish, looking for the reasons for a relinquishment rate, you have seen this data before. This is just an update based on any additional licensees that have indicated they're letting their, they are relinquishing their license. So the numbers still continue to be primarily in that personal category. The reason given for relinquishing the license are personal reasons. And then the next slide dives in a little bit deeper and you can see that the costs are really, are growing. The factors given for relinquishment are primarily costs, if they're not something else, some other personal reason. Okay, so now we'll go into changes when cultivators and manufacturers are going in for their license renewal, what portion of them are changing, either their type of cultivation they're doing or what tier they are growing at or manufacturing at. So 78% are not changing. They're staying where they are as they go into the renewal process. 13% of all cultivators and manufacturers are changing a tier. So they're either moving up or down and we'll dive into that on the next, within the next couple of slides. 6% are changing the type of cultivation that they're doing. And then 3% of cultivators are changing both the type of cultivation they're doing and their tier. So we're looking at the whole picture of cultivators and manufacturers, but some of these categories only apply to cultivators. So just diving in a little bit more deeply here, we're looking at just cultivators now and their changes that they're making upon renewal. And you can see how people are affected. So almost an even mix here of people shifting, either from outdoor to mix cultivation, mixed to outdoor or indoor to mix. And so far there is nobody who has shifted from outdoor mixed to indoor. And now we're looking more closely at the license tier change. You can see the majority of folks that are making a change in their tier are increasing their tier, the percentage or decreasing. So this one applies to both cultivators and manufacturers. All right. I'm going to keep going unless I get interrupted in this question. So license canopy capacity, here's our chart that demonstrates how much licensed canopy we have capacity we are capable of growing here in Vermont. And this outdoor license canopy number continues to decline and the indoor license canopy number continues to rise pretty steadily since the end of the outdoor harvest, which is very natural. So we're up about 3500 square feet of indoor licensed canopy capacity since December. Those are the only license types that are open for you, right? That's correct. So next slide shows our comparison between capacity and utilization. And again, a reminder that the total number of licensees surveyed for this utilization percentage is still around 15% of our growth capacity. So we're making that utilized canopy percentage, it's a projection based on a subset of our licensees. And we're hovering around the same utilization rate for both indoor and outdoor since actually since November, we're just around the same percentage for both. That utilization rate is not changing much over time. Bryn, does the licensed canopy number include the the licensees that are shifting up? Because is it a point in time or is it current? So this number reflects our current, the amount of capacity for who we have currently licensed. So it reflects those changes in tier. I think yesterday at this data this was updated. Okay. If we're talking about tearing up, are we seeing a trend in like one two or one to three in terms of tier size? Yeah, we can we can dive in to that a little bit more deeply. I think the majority of our increases are tier ones up to a tier. My guess is that it's from tier one to tier two and not a double jump, but we can we can dive into that. I'm trying to think there's some obviously so many factors that go into it, right? We've got 25 people that haven't remunerated or relinquished their license so far. We're not, we're only getting a couple new licensees each month, it seems over the last couple weeks, but people are also jumping tier sizes. So I'm just trying to get a picture of are we losing total potential canopy that could be grown based off of how things are shifting on renewal, especially before we get to the outdoor reopening. Yeah, and I think that this is the slide that demonstrates that the most clearly is where we are actually with our current licensed canopy capacity, but we can we can certainly take a look more closely at how people are changing when they do change tier. Yeah, this is total canopy, a lot of canopy, just folks listening. This is the UDLS. Correct. Okay, I'm going to move on to our retail locations, our areas of density chart. There's no new additions from actually our November numbers. We've had no increase here, total increase here since I think October. So I have not included the map because essentially we're the same here. I think one has shifted from in the queue to licensed, but overall we are looking at the same numbers here. How long have you got a relinquished retail business? Not off the top of my head, but I bet we can get the answer by the end of the meeting. It was not in an area of density and I'm presuming that there's number 17. Okay, so as long as everybody's ready, if you can wait, hold on. Okay, I'll I think that our licensing team will be able to provide us an answer at some point. But I would say I move into the next few slides are just a summary of where we are with pre-qualification. So this process opened up at the beginning of December. I thought it would be useful to take a look at how many folks we've gotten in for the pre-qualification and interview and what the outcome of those conversations has been. So this slide just gives us the data here, the numbers of how many pre-qualification applications have been received by licensed type. So our tier one cultivation applications continue to be our most popular followed up by our tier one manufacturers currently. So a total of 40 in the last essentially two months since pre-qualification has been open. And then the next couple of slides is just I provide a little bit of narrative information about how these are going that specifically the pre-qualification conversations that are happening between applicants and staff. So since December 1st, we've had 28 pre-qualification meetings with pre-qualification applicants. And the board will remember that the whole process of pre-qualification was really designed to help applicants better understand what is required of them to both obtain full license, Canvas establishment license, and also maintain that license. So in that vein, we've seen some common themes in these conversations, which I've outlined here. The cost benefit analysis has been a big point of conversation. And what our staff are doing is really educating about the initial sort of upfront cost to obtain a license and the future regulatory costs of maintaining a Canvas business to just help applicants understand how viable their business model is. Also space limitations has been a big topic of conversation. Both licensing staff and compliance staff are participating in these conversations. So we've been doing education about space requirements so that applicants can either configure their space or reconfigure their space as they've gone that far in a way that's going to achieve compliance with their site visit and also maximize their potential production capacity. Business plan, I think that's been a topic of conversation quite a bit. Helping licensees better understand how the industry works so that they can craft a business plan as a part of their full application. Some educating about products and the requirements around products, so product registration, white labeling, manufacturing, full sale options, so that applicants have a better understanding about how they will get their product to market. And then timelines for licensure is another big topic of conversation so that applicants really understand what to expect for both the timing of their initial license, their full camp establishment license, and also what will be required for them upon renewal. And that will really help applicants be able to plan for both the startup of their operations so they know when they should really begin sort of paying their rent and getting their insurance in place and all that. And also helping them understand early on how they can remain operational a year from now. They're continuing to operate and they want to renew their license for educating people early on that you do have to we do have to get renewed each year. It's not a one-and-done kind of thing. This is great. I remember Massachusetts would do something very similar with their social equity app, Pennsylvania. It had the effect of a lot of prospective social equity applicants deciding not to get a license. Are you seeing any of them? As far as you can tell, it's a little too early for us to tell but because I don't think there have been any pre-qualification applicants that have withdrawn just yet. It did look like the most conversations have been around tier one though. Has there been any folks that maybe had big stars in their eyes that are like okay maybe I should start smaller? That makes sense. Well I don't know if I have an answer to that right now. I can point out what people have identified as being issues that maybe have interfered with their with their grand plan. I didn't mean to put you on the spot. No, no, that's a great question and I'm just not sure we have those details yet but maybe we will at the next. That's what's thought of it right now I guess. Yeah it really is anecdotal. You may not have gotten to any of the retail pre-quals yet but okay. Are you guys going through the areas of density with them as well? Just trying to like sort of understand the competition and market saturation. That is a part that's definitely part of what's talked about. So this slide just details some of the compliance issues that staff have identified in their conversations around pre-qual. So you know the other sort of point of the pre-qualification process is that it's designed to uncover potential problems with an application early on so that we have time, the applicant has time to correct that deficiency or to identify those or for us really to identify those circumstances where a license, an applicant might be inappropriate for licensure because for one reason or another and it helps us identify those issues early on before the applicant has invested significant resources into what is essentially sort of a non-compliant business model. So this is sort of a list of those compliance issues that have been identified so far just in those 28 pre-qual conversations that have happened so far so I think this is actually a really good demonstration of how well pre-qual is working even right out of gate. So multiple applicants, pre-qualification applicants have been identified as folks that would be out of compliance with the one license rule. They are proposing working with business partners or having other principles of controllers that either already have a license, a separate license of the same type or are simultaneously applying for a separate license of the same type. I think that there have been more than two of these. Co-location issue, there's been a proposal to operate two cultivation establishments in one location that would have exceeded the plant canopy limit for the largest open cultivation tier so we were able to identify that early on before the applicant invested significant resources into that business plan. Presumptive disqualification, so we've identified applicants with presumptively disqualifying criminal convictions that could either disqualify or delay their full application and staff is walking these applicants through the process of how to overcome a presumptive disqualification early on so that doesn't result in a delay later on when they're fully ready to operate. Retail space build-out specifications, we've had applicants who have retail plans that included non-compliant ID check and product placement locations so that plan could be corrected prior to investing all the money and building out a retail establishment that would not have been compliant upon inspection. And then testing and product registration and this is again I think goes really towards that cost-benefit analysis that we talked about earlier that some folks are coming in with a plan to cultivate multiple strains before they understand that there are testing requirements and product registration requirements that really would impact those plans. I have a quick question and you may have said it and I may have missed it so for folks who would qualify for social equity are we moving them or connecting them with the technical assistance in the grant application during this process or are we waiting until they're fully licensed for that? No we are not waiting until they're fully licensed we are anybody who's identified as a social equity applicant needs to go would go immediately to the to the board at the at the next board meeting to be confirmed as a social equity applicant and we're connecting those folks to ACCB immediately now we don't wait for their full license. Excellent excellent okay um I wanted what I was about to say was that I'm not going to do this every month but I thought it would be helpful to take to just have an overview of how they're going so far and I'm also happy to do it every month if you would like or give you any other information about pre-call that might be helpful okay I have heard from at least a handful of prospective cultivators that it's going great for them and they're very happy with the pre-qualification process so far. So I was going to move on to the compliance data um unless we want to policy it for any reason or were we able to find an answer to your question? You know I thought about it I think I know it was probably because of the acquisition of the supply-send bar and to give up their retail for the integrated license okay um that retailer is in branding okay so compliance data starting with the summary of the compliance work that's been done since December 16th um we've received a total of nine new complaints since then um compliance team has observed two product distractions uh as a result either of a compliance issue or um a wrap-up of operations compliance team has undertaken eight new investigations um the subject of which are listed below so scope of license activity advertising compliance on-site consumption and unlicensed establishment employee misconduct thefts of product and general compliance are all the new investigations as of mid-December um we've issued three oops sorry we've issued three notice of the violation um one was about a security violation and two were relevant to employee misconduct or product theft and we've issued four letters of warning um and those included um compliance issues around retail record keeping advertising violations and operating without finalizing the licensing process and actually having their license issued so next I'll go into a summary of our advertising review and I know that I mentioned I think I pulled this from the slide deck a lot last month but we decided to include it again because there has been a significant uptick in the number of advertising submissions that the team has received which is great because I think it reflects that licensees are understanding what they need to do before they um publish an advertisement so just in the month of January since January 1st we've received a total of 41 advertised proposed advertising submissions and then we've got a breakdown there on the left of what those submissions were all about standard submissions about half or standard submissions six or resubmissions 11 where requests for more information or sort of just a request for education around what the advertising requirements are and then we've received um four that were multiple advertisements in a single submission and you can see the breakdown there the review outcomes that were that we approved 20 um and that is our initial like after an initial review the outcome was an approval um six were initially denied um but you can see the asterisks there which notes that of those denials um all of them were cleared after recent being resubmitted to the board um and then let's be 10 we per of 10 of those of those 41 we provided education or clarification two were partial approvals and five were um are still outstanding as of today so that actually gives a good picture of what it looked like how quickly we're responding to these um I think that we've received five um submissions just since Monday so we are regularly replying to these within um I would say like 48 72 hours um and we're always replying to them within seven days and then finally at the bottom right hand corner there you can see the reasons for denial um which are staying pretty steady primarily uh lack of audience composition data or um that the advertisement contains false or misleading claims um and then there there were a couple that either the health warning was um miniscule or bad efforts and sort of prize your giveaway so that's the summary of our advertising review work and that is all I've got for you besides our staff recommendations for licensure and very quickly on a phone or semi-related topic what do you discover obviously we've seen a couple um advertisements in Vermont based newspapers for out-of-state dispensaries or cannabis businesses would you just for people listening explain how we kind of since we don't have jurisdiction over those licensees from the newspaper how we kind of talk with our um states around us that might uh yes have control over those licensees yep so just as a reminder we um the ccb has jurisdiction and authority over our own Vermont state licensed entities we do not have jurisdiction over either um you know our our newspapers in the state or licensees in other states so what we do when we when we do see uh an advertisement for cannabis establishment from another state is contact our partners in that state to inform them of the advertisement and we have some good relationships with regulators across the border in New York and in Massachusetts um that's how we handle it when we when we are made aware of those types of ads thank you um generally how quick does it take to get an advertisement reviewed and some sort of action taken oh we have um no it's not but i but i think i just said it it's not it's not listed here but we always get to those submissions within seven days um and i would say the majority of the time we get to them in 48 hours to 72 hours especially if they are submitted and they are compliant those like approvals um the approvals tend to be turned around pretty quickly if the submission is a request for information um those can sometimes take a little longer but always within seven days great we'll see you later did i did i see it a proposed change to the language around advertise i was just trying to look for the bill number but a proposed change to language around advertising and the legislature no this year okay i think we requested that the like authority for us to charge a fee for an advertisement review be struck just to make it clear to the industry that we're not intending to charge a fee and we never will okay just thank you we never had the authority to charge a fee there was just a reference in the statute to a fee okay but we never actually had that authority or had a fee in statute so if he was coming later at some point but okay okay um so if you are ready here are you ready um staff recommendations for and licensure so these applicants have met all of the requirements for their adult use canvas establishment license that are in statute and rule they have four this month um so we've got green star hill applying for an indoor tier one small cultivation cultivation license atlas cultivars also applying for a tier one indoor cultivation license um we've got to kind of chronic who are applying for a manufacturing tier one license and hey bud collected applying for a retail license um and then the next several slides are uh the the licensees that are up for renewal so we've got 67 renewals for you this month and i'm not going to read them but i will pause on each one and again this report will be posted to the website by the end of the day um for folks to go and take a look and is this posted to the agenda as well yet the agenda has all i don't think there was any change from the agenda to the the who you see here so if you were on the agenda then you were here in the report last year well done oh actually 67 recommended renewals great any questions for brand nope i'm not asking questions um for now all right well uh any discussion about any of those all right was there a motion to approve the uh recommendations i move that the board accept each of the recommendations as presented by staff in this meeting that was second all in favor hi hi great all right um well why don't we just turn to public comment um and uh we'll start with anyone who joined by uh the video link if you did just raise your virtual hand if you'd like to comment and then after we get through those we'll move to the people that joined by a phone okay looks like the first person is Grayson hey uh can you guys hear me all right yes yep thanks for renewing us for another year i'm my name is Grayson Glosser i'm the development director for extract from on great to be back for another year um i was calling in to comment about just the guidelines about plastic in packaging and just kind of uh maybe give my opinion just on you maybe some suggestions and some feedback that we have as a manufacturer um we make a lot of different um edible products in particular and something that's been it's been really difficult for us to have um to really identify some solid packaging especially because it needs to be child resistant and that paired with the milligram caps has made um finding packaging really difficult you know something that was working well with those safely locked pouches um and now with those going away and i'm not sure i i don't i'm not quite sure why um just kind of being able i i kind of want to just open the door for a little more conversation on what what drives the decision making on what's allowable as a plastic alternative and what isn't you know i i remember hearing you know something managing one of the previous meetings talking about how PLA is a common industrial compostable plastic whereas um pha which is what humidico offers is something that's home compostable and how you know PLA if it's put in a landfill won't break down in a reasonable amount of time and i think that's a good that's one good metric to measure by but i think there's a few more that we could discuss because something that i think you know that that's one that's really important to me i'm a synthetic chemist and looking at something like a polyolefin like polypropylene polyethylene it does bug me that those are just going to be persistent in the environment and as they break down they're going to generate micro plastics and that's kind of the other part of this as well is that you know something like polylactic acid or PLA while it won't necessarily degrade particularly quickly it will break down into just lactic acid which is a biocompatible you know pollutant i'll put in air quotes because lactic acid you know is in is very prevalent in as a biological um molecule um so you know having that consideration especially because you know a three ounce glass jar is 90 grams and you know we'll go through you know that shipping that from several thousand miles away the environmental effects of that plus you know any of the liners um a lot of pre-roll tubes come wrap you know the glass comes wrapped in plastic unfortunately um just trying to have a broader consideration of what goes into that because taking into consideration that you know how much how energy intensive it is to ship and recycle glass it might be outweigh you know that environmental impact might be greater than that of something like PLA which while it will take longer to break down it may not have that large environmental impact and kind of the last little you know so that's kind of the material choice and you know i'd be happy to talk to anybody about this i am pretty big nerd i tried to tone it down there as much as i could um that's so that's as much as i could but the other part is you know food safety there's a pretty stark lack of things that are able to be hermetically sealed and particularly with confections something like a caramel or chocolate where moisture is going to drastically diminish the quality of the product like a caramel is hygroscopic and it's going to pull moisture from the air um something really needs to be hermetically sealable and something like an aluminum tin they advertise that they're hermetically sealed but they fail pretty basic water tests um and you know things that are even watertight are not necessarily airtight um so that's kind of that's kind of just my little note on packaging and that's something that we're struggling with as a manufacturer that makes a lot of different products um and just kind of giving my input on what you know the different avenues of plastic that get input so thank you yeah thanks thanks grace and it's certainly something that we're trying to take very seriously and appreciate your input okay next up we have jessie lin hi thanks so much uh my name is jessie lin dolin i'm the founder of the vermont cannabis nurses association also the president of the american nurses association here in vermont i'm a ccb vendor trainer for bud tenders and i also run a free nurse hotline for consumers two things i want to quickly touch on is labeling and education um as i get more hotline calls educate more bud tenders and visit more dispensaries it's glaringly apparently we need more labeling directives transparency and enforcement what i'm seeing is packages that are dated over a year old i'm seeing thc listed on oral and edible products with zero information as far as whether that's a isolate distillate or full spectrum i believe you guys at the ccb are aware the drastic difference between product effects from both therapeutic and consumer safety perspectives and uh if you don't please help me provide some education for that to you i'm seeing added terpenes listed but not which terpenes they are terpenes can be serious allergens and need to be transparent let alone the differing levels of euphoria also known as intoxication that they can bring i'm seeing topicals with added essential oils but not listed what essential oils are out there my son for example is dangerously allergic to lavender and would end up in the emergency room if you were to touch that i had one caller take 10 mls instead of 10 milligrams of a thc product because of the labeling and i had another caller think they had to take all 25 milligram gummies as one dose so the lack of transparency is an absolute consumer safety issue and needs to be addressed not doing so will allow legislators and policy makers to not only question the program but add stigma and more prohibitive laws understandably so if we don't do better secondly we're almost a year and a half into the program and there's been zero attention and focus on education as an educator i get plenty of feedback including people who've taken other approved vendor trainings stating they have barely any education on consumer safety and practically no up-to-date compliance information i will continue to ask even beg you to prioritize education for consumer safety especially as we head into legislative session with policy changes on the line i would love to be able to testify that the adult use program is doing what's necessary for safety but to do so again i ask you to prioritize proper labeling and education please let me know who i can connect with in a timely manner as carry and nelly we're working on that but are no longer working with you guys let me know how we can expedite some of these serious concerns and needs i'm beginning to meet regularly with prevention works with the substance misuse prevention council with the agency of aging with the department of labor and i'd love to be able to say that consumer safety is up to par in a focus of the adult use program so please help that be a conversation we continue to have there are some serious concerns with the lack of labeling and education and lastly just to quickly mention i think some of the charts you guys put up were great the product wheel listing the top products cultivation wheel but on the one product wheel i would mention that there was not the percentages listed and for someone who's colorblind that makes it very challenging to understand the graph so i'm just to throw that out there as well so i'd love to touch base with someone if you guys let me know who's working on education and how we can look at labeling to make that much more consumer safety friendly thanks so much thanks jesse Lynn okay we have kirsten now hello just can you hear me yes okay great um so my name is kirsten and um i have a tier one license for my company called list point chocolates and i recently um applied for a waiver to get a waiver for um my really application fee um the argument i made was that you know women as an economic empowerment uh license should be getting a waiver also um uh one of the main reasons is that i saw that that called tier one cultivators were getting a waiver on their manufacturing license is that right did i get that right now we're only allowed to like because this affects state revenue we're only allowed to waive application fees when the legislature authorizes us to and they said only social equity applicants and then even then they've got a progressive waiver process they were they after five years pay the full amount of their fee okay um i thought was there something about the manufacturer or the cultivators getting a break on their manufacturing license no well this really isn't a q and a session but maybe we can connect a few offline about it but in general we're not allowed to this is one of the areas where we're not allowed to issue a waiver um you know this isn't about kind of compliance with the regulation this is a fee that's set by the state that you know we really don't have much control over okay all right i just thought i read i had read that somewhere that um met the cultivators were also getting an extra like added but i i must be wrong about that so sorry about that thank you okay yeah yeah thank you okay next up is teeto you hear me okay yep um so i just want to say that it is getting crowded in the grow community and it feels like it's time to cap those higher license tiers that hopefully everybody's having a great day thank you thanks teeto okay jesse spear hey how's it going can you guys hear me yes sorry i got on the meeting a little way this is the comment section right yes it is okay so i just had one comment regarding product registration so i'd just like to say um our compliance officer's awesome had a really good relationship with her she's been more than helpful i'm really happy with working with her and she's doing an amazing job but it seems like she maybe has a bigger workload and i might be wrong but talking to other uh companies and cultivators that are out of the chitney county area their compliance officers might not have this big of a workload and i know like she's gone out of her way and worked um on times where she wasn't getting paid for overtime just to help out the cultivators which is a big deal because we have a perishable product and if we can't get it out in a timely manner um it hurts us significantly and is there any way to either approve overtime or have different staffing or provide more staffing for product registration for the compliance officers that have a bigger workload or an area that has has more cultivators or stores yeah thank you for the comment and we are constantly evaluating those types of things asking our friends at the legislature for more support when it's needed okay we have bushy beard cultivation up next hello can you guys hear me okay yes hello okay um i just wanted to piggyback on what tito had said and was just curious if there was anything coming down the pipe with capping the larger licenses and if there was any plans because like tito said it does seem like you know the market is reaching a saturation point so i just kind of wanted to piggyback on what he said and see if there was any plans in the future for doing something like that all right thanks for the comment uh jane linda hi thanks this is jane from family tree we're mix tier three we do our sungrown on the larger side and the small tier one for the indoor is part of that mix and we manufacture and we have been um gratefully participating in the industry since the inauguration and adapting to all the changes one that i'm particularly noticing is the amount of retailers who get their own cultivation and manufacturing license and i'm just curious from a cultivator or manufacturer point of view myself if there is a direct avenue that you guys might see down the pipeline for direct to consumer from the farmer's point of view to catch up great thanks for the comment i would just pause right here and just know you know public comment sessions are not q and a sessions essentially we can't make policy on the fly or deal with everyone's specific concerns you can make questions to the board and we try to um am i opening comments and or else we're trying to address specific questions or common themes that come up over and over again and if you do have specific questions you can certainly just uh reach out to i think it's common at ccb.org info at ccb.org it's a portal almost like okay so ccb.org the email address there's also a public comment but those are also that that takes the legislature to kind of authorize that type of of license jane so i would encourage you to talk to your elected officials thank you i am in that process great that's they do they do listen i will say like they not you know it's 180 people not everyone has the same kind of ability to move legislation but they your legislature will listen to you if you're if you're struggling okay elie herrington elie you're muted if you're talking okay uh thank you very much sorry about that uh with the discussion of possible event permits or any off-site sales delivery or special events i'd like to float the idea that a portion of those sales must come from independent cultivators that if we are going to start doing off-site sales and off-site consumption that we build in a niche specifically for independent cultivators because i do see a lot of consolidation happening at the retailer level and it is easier for a lot of these larger folks to just get a retail license than for those of us who are smaller to to get one until something like a catering license maybe exists in the future so i just wanted to to float that idea that as we talk about opening up new markets with events and off-site consumption uh we in statute carve out some space for independent cultivators so that way we don't see every retailer working every wedding only selling their own products and that we've got a space there by statute because i know there's a lot of good intentions but capitalism going to catalyze and we're we're starting to see that so uh there will be an advocacy day at the state house next thursday the eighth i hope to see a lot of folks there people can email me or check our instagram for more details but uh we will be there the afternoon of next thursday the eighth so a good time to catch up with other folks in the industry thank you thanks you like okay kasey you're up next yeah good afternoon everybody so k my name is kasey carton i live in north hero island craft cannabis llc a tier one mixed that is uh just on the cusp of um going to market so to speak and i want to say thank you to everybody i really want to uh you know not only just with the state of vermont and putting this together but all the hard work from uh the entrepreneurs the growers everybody um i've been i was born and raised in vermont i would be considered very small um so we're on like month 14 of of being live here in this little state and very quickly we're saturated so i am going to sort of mirror that commentary about the larger scale licensures and ask for all consideration for the little guys whatever that can be and uh julie noted about reaching out to you know the legislation and so on but thank you to you guys um and that's the comment i had today thank you thank thank you kasey okay john you're up next okay yes hi so i have two things i'm just going to um mirror what was just spoken about the uh oversaturation of the market uh the amount of product out there succeeding the the demand um you know boots on the ground kind of information uh the other thing is i'm uh uh handicap in a wheelchair and um during my initial inspection i was informed by my compliance officer that a three-foot handicap pathway was included in my square foot canopy and um you know i and and one of the things that she had told me was that you know the plants are going to grow into the area and i said well no i can't have them grow in because i need to get through there with a three-foot wheelchair you know some people can turn sideways and walk through so i'm hoping that there's like maybe in the future some sort of waiver that um somebody can fill out or apply for if they're in uh you know an immobile situation where you know i'm going to take up more of a pathway or a square foot of my canopy you know like a three-foot aisle down the center that's not included um okay that's it yeah thanks john okay jody you are up next yes hi my name is jody horner i'm calling from vermont green castle reserve we are a tier one cultivator in johnson we had manufactured some product hush infused uh two harvest lots ago and we still have not found approved packaging for that harvest lot there is a waiver currently out there for glass or other non-plastic jars with metal wood bamboo lids that utilize the plastic or rubber gasket i wrote a waiver to have that expanded to hash infused and it was rejected currently that waiver only applies to cannabis flower and the real issue is child resistant so we need those plastic threads for child resistant we don't need them for regular cannabis flowers so this waiver doesn't seem to do anybody any good um furthermore and i'll end here the suggested websites on the packaging guidance page um i've contacted all of them and none of those were approved by the ccb so it's a real struggle to find child resistant without plastic threads and the waiver request being denied makes no sense because we really really need the plastic threads for child resistant thank you story nick you can go ahead and unmute yourself hey everybody this is nick with emerald visions thanks for for everything you all do and just wanted to kind of echo the the statement of what several other cultivators said about the crowded flooded market that we're experiencing right now um it's i don't know we all keep hoping that it's gonna get better but um i don't know we all thought that it was just like kind of a end of the year people didn't want to add any more to the inventory in december but this is all it just keeps getting pushed on week after week hearing the same thing from a lot of our partners just saying like i don't know they have way too much flower and most of them are saying even that 12 cultivators are going through their door every day and they're having to unfortunately turn them down and these are all there's quite a few people in desperate situations and i know i'm not the only person that really is feeling the pain right now of just how saturated the market is and just imagine if this would have been an outdoor year that was um not a complete disaster and probably would have seen twice as much saturation and even more people not renewing but yeah i know that this is probably not even within the guidelines of the ccb to do too much about it probably more of a legislature change but i don't know i just kind of wanted to let everyone know that they're not in this alone that everyone's struggling to keep your head up i guess thank you thanks nick looks like that was our last comment yeah okay sure how are you guys good um randy from doha here i just wanted to you know echo what nick said and a couple other people in the market is um very saturated at the moment um and i'm hoping that you guys will take into consideration licenses that are being issued going forward and canopy space that's allowed at the moment um try and find that like happy medium where everybody can survive that's in it right now um it's financially debilitating trying to pay you know ten thousand dollar power bill just for a tier one um i can imagine tier two people in fire that are having a hard time selling product right now um granted the tourism uh right now is bad because of the weather but like he said with the outdoor had we had a great year it'll be pretty crazy right now and uh nobody seems to know when product's gonna start moving again um we're just barely moving a quarter pound here and there normally we move you know two three four five pounds um every week every other week and just sales have been pretty stagnant right now so i hope that uh you guys take that into consideration with the available canopy and how many more licenses that you guys are going to issue going forward and that's all i gotta say thanks thanks randy hey you are up next thanks um this one i kind of throw in sort of like from from the other side of that equation you know like we love randy stuff by the way it's fantastic um next to um lots of ultimate great flower um you know this is gonna happen every year um we're gonna hit the the low point in the market right around now uh and that's gonna hit at the same time as the outdoor stuff is hitting the market and that's really dangerous uh but unavoidable uh just because of the way the calendar works uh and so you know just to urge everyone a not to panic uh and you know to the best you can uh you know hold on um but also you know there is actually a bill that's being considered now in the legislature uh it's a short form bill so there's no details it's just a discussion uh around uh sort of like a license moratorium potentially um and i think you know if folks are interested in that sort of thing and i'm i'm in very active listening mode on that um if folks are interested in that sort of thing um really urge them to reach out to uh to their reps in the house um and and talk with them about that um because it is you know it is actively being considered in the legislature and the ccb you know we can we can argue over their legal authority to impose caps on all sorts of license types or you know just what they've already done on certain tiers and closing and opening um but um you know i think certainly getting a um some direction from the legislature would help um and julie james and and kyle make the right decisions as well so um that's all thanks thanks dave okay up next is liz hi there i'm liz from green mountain gourmet cannabis company we make all sorts of unique edible products from olive oil to peanut butter and strawberry jam and we've noticed uh oh i'm so sorry my dog in the background um but the uh we've noticed that another company has had some products that have gone bad and there's the new intro batch testing for every three months for potency um and you know i'm not trying to be a business owner shooting myself in the foot of adding more cost um but i think that adding in some parameters for food safety would be really important as well we take it really seriously at my facility um but having intro batch testing for making sure that there's not any bacterial growth or anything going on in those batches is super important yeah thanks liz thank you um any other public comments if you join by video raise your virtual hand if you join by phone you can hit star six to unmute your phone uh yeah this is nate from uh pressure lab cultivation can you guys hear me okay we can okay um yeah i just wanted to uh you know make a couple points or comments um so what tito and nick was saying about the market saturation uh me and a buddy of mine were looking at some numbers um john who made a comment earlier and just with the tier ones uh with outdoor and indoor um 85 percent of the state's projected canopy needs are already met just with tier ones um so it is saturated i think that it's safe to say i think most cultivators would agree that cultivators in the states are sitting on um sorry uh cultivators right now are sitting on literally metric tons of process cannabis in vermont so they're literally thousands and thousands of pounds sitting that aren't moving right now so i think that considering capping in my opinion all licenses for the time being i think would be a great move uh and then the other comment i wanted to make uh is about the fact that um somebody else i think with a family tree brought up a point that you know small cultivators need you know every advantage we can get you know especially to be honest even tier threes um but the fact that we can't have teeth uh or dry sift or whatever you want to call it as cultivators is kind of crazy to me because it's actually a byproduct of trimming um so when we trim uh most companies use trim bends uh or some type of trim bend that has a screen on the bottom and it collects the key so you're not wasting product uh so we you know we're a small company we're a mixed tier two much like family tree we only got to tier two so we could grow more outdoor plants uh our indoor is only 480 square feet we're finishing up a second room which will be another 150 square foot so we're under a thousand square feet um but we are currently sitting on keef that we can't sell and we can't do anything with and we're just expected to i guess throw it away um and to me that just is a little crazy because you know like jane was saying like we need every every uh um advantage we can get in this market and being able to advertise infuse pre-rolls would give us the opportunity to you know charge twice the amount that we're charging for a normal flower pre-roll and um as i said it's it's a byproduct so i had a dispensary owner at our farm recently and and she saw a bunch of keef and said i would love to buy that from you and i said well i would love to sell it to you but i can't um so i just wanted to bring it yeah yeah you know i'm not going to give any sort of legal advice on the fly here but i would just look at act 65 from last year 2023 because we changed the legislature changed some of the allowances of what cultivators could do and it's not about making infuse pre-rolls but it is about you know certain products that they're allowed to possess and sell so you just want to probably look at that those changes that were made um and it might give you some guidance on this issue okay great thank you very much um well that's it those are the only two points i wanted to bring up and thank you guys for all your hard work and uh i will add just another thing about the compliance officer yeah our compliance officer is is very busy so i would just agree with what he said that maybe trying to get her some help or prove overtime would be awesome and that's it thank you guys great thank you all right we have chris vickers this is chris vickers rootland cannabis hickory hashing bud i'm a mixed tier one um and i'm also a tier one manufacturer and uh yeah it's been going pretty good um i totally agree with what a bunch of people are saying that the market has kind of has consideration and uh and uh you know i i got a manufacturing license because i needed to be able to process my trim into hash and that's just part of what we all do as cultivators and it really needs to be added as part of a cultivation license it can be a mixed plus or a tier one plus or something like that but um yeah we we all need to have the ability to to do what we do with our product instead of having to have you know a mixed license and a manufacturing license and and all this renewals that are re really aren't even renewals they're more like re applications that the process is no easier to do it a second time and uh you know at that at that point i think that having a license that's good for two years or three years would be a real advantage it would free up a lot of your staff there it would make things a lot easier for us having to redo this over and over i mean we didn't get into this to do it one year we're in it you know so having to do it every single year is it is a real pain for us um i just want to um you know just state that you know that's a cottage industry thing and and as a cottage industry business we you know we like doing all of it we like indoor we like outdoor we like making our hash we want to make infused products maybe some edibles um you know we kind of want to do it all so i you know maybe coming up with some kind of cottage industry uh grouping would be the way to go for tier one and tier two i am not bringing in material from other people just working with our own material thank you for your time appreciate it yeah thanks chris okay we have someone who's joined us guest you want to unmute yourself um okay so i'm doing that but um only kind of have this point would be that i wish you guys could do something who's responsible for looking at it but um flavor papers flavors are not for kids i mean it's i don't know it's no different than adding salt and pepper to your food people like flavors so outside of the cannabis having its own distinct flavor especially if you got a good grower you know it would be nice to open that door up for the creative mind and uh let them have some fun with it while they're trying to make a living um and people will like it i i can assure you a bet so i really wish you guys would would do something to help get the okay or the approval through to say yeah you can make you can use flavored papers i'm talking about like whether it be stigarello type papers or whether it be joint papers flavored you know it's good but tastes great but boy you can do a lot with it so i'll leave it that all right thank you anyone else for a public comment all right i will close the public comment window thank you for all the comments you know this is legislature meets for a very short amount of time each year and i think a lot of what you're hearing a lot of those repeat comments themes are things that we really don't have a lot of control over um but uh there's certain things that we do and so we always appreciate the comments and the advice and the kind of you know boots on the ground kind of vantage point that she provides so keep the comments coming thank you um certainly reach out to your legislature uh your legislators both house and senate um and um let them know how you feel um so with that i will uh adjourn the meeting thank you thanks