 I'm James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is Wednesday, December 14th. It's one o'clock and I call this meeting to order. The very sad news will wrap past away this week. He was a true pioneer in cooperative agriculture and the giant in Vermont's agricultural economy for the past four decades. No one has had more of an influence on the way that I approach cannabis regulation than will. I first met him in 2015 in the governor's office when he was pitching then Governor Shumlin on legalizing cannabis. We had just received the ran report that showed what demand for cannabis might look like in Vermont if we were the only state on the east coast with legal adult illegal adult use program. None of the kind of policy wants new quite how best to approach the problem of supply in the entire east coast or at least New England with cannabis other than we needed big indoor grow operations and we needed them quickly. Will very shrewdly new then what seems obvious now that unless we do something special here and build Vermont values into the very DNA of our cannabis industry we not only risk doing irreparable harm to the Vermont brand we also would not have a sustainable market once other east coast states came online. He told us to keep the plot small to embrace craft cultivation to encourage the formation of cooperatives to force larger operators to use sustainable growing practices and pay their employees a livable wage to create rigorous testing standards and to lead the way on genetics and research. These are the very principles that we're trying to place at the core of our mission at the CCB. We're not there yet and just like a good garden our laws and our rules and our regulations need constant tending but this is the vision and I just thank Will for articulating it so eloquently for me back in 2015 for living his values and all of his endeavors and for the ongoing legacy of the intervail and the employee-owned gardener supply you will be missed. All right so in other news our product registration process our new process is going to go live later this week. We're finally leaving the Stone Age of Microsoft forms and incorporating product registration into our licensing portal so now when you log into your CCB account there will be a tab that will allow you to register products. If you've already submitted a product registration through the Microsoft form you do not need to resubmit through this new process. You do not need to resubmit. We're going to be doing another Q&A session on product registration. I think the date is Tuesday December 27th at 6 p.m. Just a reminder that in the new year we will be shifting around our meeting schedule a bit. At our next meeting we'll approve our regular meeting schedule for the new year but the gist is that we're going to be moving to one board meeting per month. In between board meetings we'll be reviving our subject matter specific networking events. We've been brainstorming some topics that seem to need some attention things like insurance requirements, tax compliance, cultivation best practices, licensing renewal but please email the board or tell us during public comment about other topics that might be helpful. On a somewhat related note these events are part of our education first approach to compliance with a system that's understandably new to everyone. We know that we didn't contemplate every scenario in our rules and that there are ambiguities or gaps in the rules that we created. We actively are trying to close those gaps with guidance documents. We always anticipated that there would be there would need to be a fair amount of hand holding at the outset of this market to make sure people are in compliance with our rules but we're very quickly getting to a point where we can no longer chalk up some of the issues that we're seeing to good faith mistakes. Everyone with a cannabis license should have an intimate familiarity with our rules or guidance and the FAQ section of our website. We should not be fielding questions like can I buy cannabis from an unlicensed cultivator? There is no excuse for not collecting taxes properly or fudging the number of employees you have in order to avoid fire safety jurisdiction. It's the fundamental responsibility of any business owner to know the rules of the market that they're participating in and the CCB at its core is an enforcement agency. We drafted our rules with a tremendous amount of public input and we're committed to listening to the industry and amending them as needed but we're not going to turn a blind eye to violations that result from either intentional ignorance or bad faith. And again we know we didn't think of everything so if there is confusion or ambiguity please let us know. We will draft guidance. We will continue to hold Q&A sessions. We will continue to host these networking events to help kind of guide this industry. We have quite a bit to get through today so why don't we approve the minutes from our last meeting. I don't think Nellie did a sufficient job kind of talking about the emotional impact that you know David's leaving you know add on me in the minutes but I think that they're an accurate reflection of the meeting. I mean I can I can always amend them if the board feels strongly. That's all right. Is there a motion? Seconded. All in favor? Okay we have a concentrates report that's due to legislature and it's currently out to comment for our with our advisory committee but we figure we'd walk through it today and it might change a little bit but might as well just kind of get it on the record. That makes me think something happened. My job is to open teams and just share it from your computer. Nellie might need to give you a presentation. For the technical difficulties folks and she was going for this report. I don't know. I'm like an FMA card duties strip. Nellie does Brynn have a presenter status? She does but she's not in the meeting I don't think. Okay. Also not working. Brynn if you email me the the report I can bring it up on the screen. Okay let's try that. I think it was actually here try now I should I heard it was like excellent thank you. I guess it was much fun. Okay we did drop that thing a couple times this morning. Thanks everybody for your patience. Okay so as the chair mentioned this is our draft report to the legislature with respect to the solid concentrates the cap on solid concentrates and it's an 82 page report. I'm not going to go through every single page in detail but I will review it for the board. This is the draft as the chair mentioned it's gone out to our advisory committee and we're waiting for comment from them and we will submit it to the legislature within the month. So we will get this draft posted to the website and indicate clearly that it's a draft and we will also once we have finalized it and sent it to the legislature we will replace it with the final version. So we've had an overview here I'm just going to skip through the first few slides. These are the requirements of the report so the legislation specifically asked the board to provide a summary of the regular market share for solid concentrates above 60% THC and the status of the illicit market for these products in other states that have a regular still use cannabis market. Here is the section of legislation that imposes a cap on cannabis flower and solid concentrate products. So prohibited products in the state of Vermont include cannabis flower with greater than 30% THC and solid concentrates with greater than 60% THC. So this is kind of a specific portion of the legislation that we're dealing with. So we jump into the key findings portion of the report and this slide provides some high level takeaways from a summary of the research which comes a little bit later in the in the report. But high level is that few states impose percentage based THC limits. Specifically it's only two. Vermont and Connecticut impose a THC limit on solid concentrate products. There's really a dearth of research for regulators to rely upon because of federal prohibition and there's really no scientific consensus that has emerged on the potential mental health effects of using these types of high potency solid concentrate products. The report also summarizes the work that Massachusetts and Colorado have done on looking into this issue. Both of those states have done a pretty deep dive into solid concentrates issue and both have concluded that there's insufficient research, insufficient literature on the use of these products such that regulators can really draw a conclusion on the best course of action. So I'll just continue with these kind of top takeaways because this offers a good synopsis of what's to come. These creating low potency solid concentrate products are essentially what what producers would have to do to create low potency solid concentrate products is to incorporate some sort of additive or excipient into the product which could conceivably have a negative health impact and that can be seen with the E-Valley crisis. Consumer education is really critical to ensuring that user use products are using safe. And later in the report we go into how the estimated users are in Vermont and the takeaway is that solid concentrates really make up a pretty small portion of the existing illicit market and the estimate is somewhere between four and eight percent of cannabis consumers use solid concentrate products. And finally a prohibition these solid concentrates with greater than 60 percent concentration of THC is really likely to keep these types of products in the illicit market as opposed to having a regulated market for them. So the main recommendation main takeaway from the report is that the board is recommending that the legislature remove the concentration limit for solid concentrate products and authorize a consumer education and use prevention campaign. The recommendation is that a portion of the revenue that is directed to the Department of Health from the excise taxes from cannabis products be used to fund these education programs. And lastly a recommendation that the board makes this information available including state dosage information and other public health information relevant to these types of products. So the next portion of the report is some educational materials for the legislature about what these types of products are and how they're made. So I will kind of review these pretty quickly this is just a description of what what are solid concentrated products and how are they used and how are they made. Just going to skip through some of these about the common production techniques for making these types of products. This slide talks about how to produce a low potency concentrate. There have been some suggestions to the legislature that that manufacturers could create low potency THC products or solid concentrate products. And this slide kind of describes that the way that these products are manufactured really necessarily creates a product with a high concentration of THC really at the outset. And as such really the only way to lower that concentration level of THC would be to dilute the product or add an exception or some kind of that kind of additive that would dilute the concentration after the extraction process is already complete. So a good example of this is adding oil and vape cartridges and for solid concentrate really the only reason to add any kind of filler to that product is to meet the potency threshold that is provided for in statute. So a little bit more discussion about the types of fillers that would be used. There's really no the board really doesn't have a way of knowing what manufacturers would use for filler product if they were required to add filler to their products to meet that concentration limit. And the board is not really in a great position to evaluate the safety of these types of additives. So the next couple of slides are address the danger of using filler to dilute concentrates. So we've got some information here about how adding filler really disrupts the natural composition of a cannabis product and using fillers and excipients could lead to unintended negative health consequences. And we reference the Valley crisis as a good example of the dangers that can arise when you're using filler for products that are inhaled and there's additional information about the Valley crisis later in the report. But the conclusion really here is that consumers are likely in a better position if they consume a full spectrum product that reflects the natural composition of the plant in its natural state. So the next set of slides are about how some other states are handling their high concentration products. So as we mentioned in the beginning only it's really only Vermont and Connecticut are imposing these policy limits on concentrates. Data market is difficult to come by and when we're looking at the the number of consumers in other states of concentrated products sometimes it's difficult to have a have a really good understanding of who's using the solid concentrate products like what percentage of users are using solid concentrate products versus other types of concentrates because most states don't break down their sales data between liquid concentrates and solid concentrate. So this is the map of the states that have legalized adult use and you can see that the two states in purple, Vermont and Connecticut are the only states that have imposed a concentration limit on concentrate products. Montana has imposed a potency limit on flour only but we are the only two states that impose that concentration limit on solid concentrate than flour. So here's the chart of the other states and you can see Connecticut flour percentage limit and concentrate percentage limit is the famous Vermont. How our concentrate limit is for solid concentrates only. This slide discusses how most other states really don't take the approach of limiting the concentration of THC but instead adopt the per milligram of THC limits on edibles and that's the way that most states handle this. Only Vermont and Connecticut other states are taking some other approaches to encourage responsible cannabis consumption and there will be some more information about this later in the report about states that are taking a consumer education approach and this final bullet indicates that there have been lessons learned about the ineffectiveness of prohibition and this can kind of be extrapolated to the limitation on the types of products that you can purchase from the regulated market. Prohibiting certain types of products isn't going to prevent consumers from finding those products either on the illicit market or online or in other states and having consumers use these unregulated tested products from the illicit market pose pretty significant health risks to them. So this is a chart on the state potency limits for edibles. The majority of states have the 10 milligram THC limit per serving and the 100 milligram percentage. Vermont is the minority of states that have the lower THC limits per serving and per package at five milligrams per serving and 50 per package and then we have a couple of slides that detail how Canada handles this issue. So there are no percentage base potency limits at the federal level in Canada. There is an exception for Quebec which we discussed on the follow-up. So Canada abides by that 10 milligram per package limit for THC and their concentrates per package are limited to a thousand milligrams. So Quebec is the exception. They essentially ban concentrated products because they've got a 30% concentration limit on those products which amounts to an effective ban. There is some data on solid concentrate usage in Quebec which shows that about 9% of cannabis users there report using solid concentrates. So this does indicate that because there's an effective ban on these products in the regulated market what Quebec has done is essentially push consumers to the illicit market for using these types of products. So the next set of slides discusses state efforts to regulate these products and includes Colorado's consumer handout that they have recently developed that gets handed out to consumers who are buying these types of high concentrate products. We've got some information about some legislation that passed in California and Colorado. Colorado was mandated to come up with a four-page educational handout and provide that handout to everybody who is purchasing a concentrate in their retail market. And this is what that handout looks like. So it has quite a bit of information in this four-pager including the appropriate concentrate serving size which is down on the bottom on the left which is that little dot is the recommended serving size for concentrates also includes information about the risks and precautions for using these types of products how concentrated THC products have a different effect on the body than other types of cannabis products and also provides information about the labeling requirements the penalties imposed for violating the Colorado statute and some additional resources including the poison control hotline suicide prevention hotline some other crisis hotlines that are available to consumers in Colorado and then some links to public health resources. So this is the handout that Colorado was mandated to come up with and hand out to anybody who's purchasing these concentrated products. So then the next several slides deal with cannabis equivalency numbers and other regulated states. Colorado is the one that Vermont is following for equivalency. These are some excerpts from the marijuana equivalency and portion and dosage report that the Colorado Department of Revenue developed in 2015 of those slides on these equivalency numbers and then here's a slide on the alcohol product equivalency and I think that this people are generally pretty familiar with the alcohol products equivalency chart and Colorado did start out in their work to develop their consumer handout with the goal of coming up with something similar to this but given the kind of scope of different types of cannabis products they found that difficult instead wound up with the handout that we just reviewed. So the next batch of slides is about the research that has been done on cannabis potency different cannabis potency products and general takeaways from the literature covering use of these types of products. Essentially the takeaway is that there is really insufficient data to make any really informed decisions about prohibiting these products. So we've got limitations on the data. The Massachusetts cannabis control commission did a report or did a survey of all of the existing data to come up with some conclusions and here are some highlights of from that report that indicate the barriers to doing adequate research on this really leave regulators in the position of not having much to go on. Cannabis Massachusetts in Colorado both have legislatively mandated report to evaluate the existing research to determine whether or not they should impose potency restrictions in those states. Both states determined that there was just insufficient research on the use of these products to be able to draw any reliable conclusions. So here is a summary for some takeaways from the Massachusetts report. Inclusion from that report with the evidence was insufficient to recommend a potency cap and that there was more work that was needed to understand the potential unintended consequences of imposing a limit including how other components of the cannabis plant work to enhance or reduce the effects of THP and there's a link to the report there. So the Colorado report completed in 2021. The key takeaway there was that once again the federal prohibition results in really inadequate research to determine whether or not these high concentrate products and the use of these products is safe. So there was not a full conclusion here either and Colorado is working on a follow-up report which should be out by the end of this year. So we've got some more research summaries here. I'm not going to go through all of these. Here's the slide on the general takeaways on the summary of all of the existing research and that really boils down to a significant need for additional research into the effects of high potency cannabis products and that really public policy should evolve as the scientific research develops. There is some studies that have found a correlation between high potency cannabis product use and increased risk of negative health effects especially in young people. The studies have shown that that this correlation could be the results of individuals having underlying mental health issues and those individuals being more likely to use high potency products but high potency products have not been causally linked to the genesis of significant health problems but it's possible that they exacerbate or trigger a pre-existing mental health problem. So this slide kind of articulates the concern of the board when it comes to prohibiting these types of products. Prohibiting high concentrate THC products in the legal market isn't going to eliminate the demand for them. People will turn to the unregulated illicit market or purchase these products in other states or potentially create their own by using extraction processes in their home which can also be dangerous. Using exipients, additives to create a low potency version of these products could potentially have other health effects unintended health consequences and also the types of the way that these products are manufactured can often result in residual solvents existing in these products. So the idea is really that these high concentrate products are especially prone to having contaminants or other types of impurity. So forcing users of these products to the unregulated illicit market could also create pretty significant health impacts that would outweigh the benefit that could result from prohibiting them. And lastly the Massachusetts experience with Evali really illustrates the potential dangers of removing these types of products from the regulated market and forcing users of them to purchase on illicit markets. So the next couple of slides are the Massachusetts detail, the Massachusetts experience with the Evali crisis. I think that the board is really pretty familiar with this by now. We've done quite a bit of discussion of the Evali crisis and we'll do that. So the estimate of the market. So these next several slides attempt to get our arms around the number of Canvas users that would be interested in using these types of products from the regulated market. It's difficult for us to assess what the illicit market really looks like. Difficult for us to get data from the illicit market. However we did, the report does look to the data from our medical market to see how how many of our medical patients are using these types of products. Also looking at sales data from other states and looking at some survey data to try and understand what the market for these products looks like. So this was kind of a general disclaimer slide about how this kind of data is difficult to gather. Other states don't always separate their concentrated products into solid concentrate and liquid concentrated products. So it's difficult to get a really accurate representation of what's going on in every state. So this is a summary of some data from the Vermont Canvas market. So 2019 survey found that 2% of adults and 8% of high school students indicated that dabbing was their primary consumption method and a year later a survey found that 4% of adult consumers in Vermont, adult Canvas consumers, indicated that they dabbed or used Canvas in some other way. So later slides talk about the Vermont medical market but the prediction based on these surveys, this data is that around 4% to 8% of the market would be for these solid concentrate products. So we've got data here but this is more information about our estimates on the size of the market which we're estimated to be around 318,000. The slide indicates that this is kind of anecdotal information about how pretty easy it is to find these products on the illicit market for sale online and also to point out that consumers near the border are likely to be driving over the border to Massachusetts to purchase these types of products and also an emphasis on members of people who are operating on the illicit market and also consumers could be producing these products in their home or in other areas that are not regulated by the board so that could be a potential public health hazard. So here's a chart about medical sales by product type. You can see that the percent of the medical market for concentrates is around 4%. Here is that translated into numbers, prediction of the numbers over the next four years. So here is just a summary of where we are anticipating the Vermont market to be when it comes to the solid concentrate products. So here we go into some data from other states that shows approximately what portion of the market in those other states. It goes to the solid concentrate product. So it looks like about 23.2% of retail sales in Maine from last year were for concentrate products. But this is likely a much larger number because they do not separate out their solid concentrate products from the liquid concentrate products. There's a chart of those Maine numbers. So concentrate sales amount of the concentrates is in blue on the right side as compared to other types of cannabis products. Again, this does not break out solid concentrates. So not a perfect comparison. Massachusetts does break down their sales information between solid and liquid concentrate. So the number here is so year-to-date sales for concentrated products accounts for about almost 6% of their retail sales. And that is for solid concentrates. Here's a chart from Massachusetts. So let's read this chart. A lot of information here. So Michigan is another state that allows for these products. They also don't separate out their solid concentrate from their liquid concentrate. But it's the yellow inhalable compound concentrate is the portion of their market that's taken up by those types of products. Here you can see the portion of their market that's taken up with concentrates about 7.6% in June of 2020. And it's dropped to about 6.17% two years later. Oregon data, same here. They're concentrated in extracts. They don't separate them out, but they accounted for about 23% of the market five years ago and today roughly the same, about 24%. So let's see a little rise in June of 2018, but essentially leveled off in 2020 and it's been the same three years, two years. So Colorado surveys are on the next couple of sides and they show the prevalence of different consumption methods over time. So you can see dabbing accounted for about 17.7% of the types of use in 2015. And that did increase to 23.5% in 2018, but has dropped leveled off a bit since 2019. So it's currently almost 21% of the methods of use among consumers in Colorado. And you can see at the bottom of the page indicates students who are, so young people who are using cannabis, that comes from the Healthy Kids Colorado survey data that does show an increase over time from 2015, starting at 28% and in 2021, going up to 49%. So the next set of the kind of, we'll wrap up the report with our recommendations. And that we go back to that initial slide that talks about our four part plan to promote public safety regarding concentrates. So the first is to remove the potency cap for solid concentrates to authorize consumer education campaigns and youth prevention programs by using a portion of the revenue allocated to the Department of Health for substance misuse prevention programs. And also to make public health information, including safe dosage information readily available to the public. So we've got guiding principles here that education really works better than prohibition. Prohibition isn't going to eliminate the demand or the supply of these types of high potency products and could actually be counterproductive when it comes to promoting public safety, because these products are readily available in the illicit market. And prohibiting them is going to drive production and sales into the underground market where there will undoubtedly be additional safety risks, both for the public and for the people who are using these products. And we've got a reminder here to ourselves that we have a specific mandate from the General Assembly to move as much of the illicit market as possible into the regulated market in order to protect consumer safety and public safety. And because the current scientific evidence really does not justify a prohibition, it's the recommendation of the Board to remove that prohibition. So further information about the rationale behind this recommendation, this is sort of a reminder to the legislature that they recognize that prohibition of cannabis was really a failed policy, and they chose to replace it with assistance that allows consumers access to regulated and tested products that comes with education about their safety. And that should really be extended to the high potency selling concentrate products, since there are a percentage of remotors who are using them and might be unaware of their risks. So this is a proposal to launch two different types of educational campaigns along with removing that potency cap. And the first is the consumer education program for adults, which should focus on safe consumption methods and general information about how these products differ from other types of cannabis products. And separately, youth prevention efforts, which should focus on reducing access for youth to these types of products. And this is a reminder to the legislature that the Department of Health is entitled to up to 30% of the cannabis exercise tax revenue to fund substance misuse prevention programs. And this would be an appropriate use of that funding. And then the last couple of slides are on how to make this public health information readily available to the public. So the recommendation is to develop educational materials around high potency cannabis products so that users of those products really understand what they are, how their effects differ from that of other cannabis products and what safe consumption really looks like. So it's the recommendation that we provide this information on our website, that all retail establishments have this information available for customers, and that every solid concentrate product include a QR code that gives the consumer access to this public health information quickly and easily. And this kind of describes the recommendation to not mandate handout with a solid concentrate product. So there is quite a bit of information that the board could provide. It's not necessarily our recommendation that everything, all that information be included on the label because that can really reduce the readability and understandability of that information. So it's the recommendation that the label include a QR code so that consumers can access it and to make sure the retailers have the information available to consumers if they want it, but also to more specifically provide just that safe dosage amount on the label. And then some final other recommendations, which is to really advocate for additional research, especially on the high potency products so that states and regulators are better able to regulate these types of products and also to clarify to the legislature that cannabis products aren't subject to the tobacco products. Because cannabis and tobacco are really two separate and distinct types of products, the taxation on them should reflect the different challenges that the state faces of regulating those products. And there we have it. Thank you. Thanks, Bryn. Thank you. So, you know, the reason we have to submit this report is because the legislature could not resolve this issue during the session earlier this year. They wanted some kind of more concrete information. And our recommendation has not changed. You know, we do believe that there will be a net benefit to consumer safety and public safety to have a regulated product, as opposed to an unregulated product. We'll see how it goes. We, you know, just to be clear, we don't have the authority to eliminate this cap on our own. This is a statutory prohibition. And it's going to require legislative action to get rid of it. So we'll see how it goes. Any comments on the report or move on? Nope. All right. Why don't we move on to the staff recommendations for licensure? Okay. No. No. All right. So here is the adult use and medical register for this week, starting out with our medical numbers. Our number of new applications and renewal applications dropped this week, but staff did issue 42 patient cards. And we are well within our 30 days staff are processing applications received on or after November 18th of this week. So moving on to the adult use license application. Here are the numbers from this week. So we've got 30 new, 34 new applications on the door this week. As usual, the majority of them are for employee ID cards. We've got about 25 new employee ID card applications, four new retail applications, two new manufacturing applications for both a tier one and a tier two, one new wholesale application, and two new cultivator applications, one for a tier two mixed and one for a tier one indoor. So moving on to this is our chart describing the location within the state of all retail applications both in the queue and also retailers that have been issued their license. So we now have 57 up for from last week. The new four applicants are in one is in Burlington, one is in Rutland, one is in Bennington, and one is in Plymouth. So that brings our total in the Burlington area up to nine. So that includes retailers that have been issued their license and those that are still in the process of applying. I think I've note that there's nine applications in Burlington, one in Winooski and one in Essex, but none in Williston, none in Colchester. I mean, the rest of Chittin County doesn't have other retail establishments. I was thinking about this this morning in terms of concentration and volume of retailers, you know, an age where most retail is not brick and mortar. I think more brick and mortar is going to be required in our most populated county in order for people to access products. So just thinking about that this morning. We'll move on to staff recommendations for their for our license. So this is your list of applicants that have demonstrated compliance with all the requirements for a license both in board rule and statute. We've got rainbows and cannabis applying for an indoor tier two cultivation license. Kingdom boys applying for a tier one indoor cultivation license. Verbio applying for a retail license. Dalen LTD applying for a retail license. Superkind farms applying for an outdoor tier one cultivation license. Stone and leaf cannabis applying for a retail license. Vermont craft edibles applying for a tier two manufacturing license. Etegrity farms applying for an indoor tier one cultivation license. And fat cat farm applying for a tier one next cultivation license. That's your group for this week. Our license amendments chart here indicates that we have one new license amendment in queue. And then we have our social equity numbers here, which indicate that we have four new applicants that are claiming social equity status. And then lastly we have one recommendation for social equity status approval and that's for submission number 1715. And staff is recommending social equity status approval for this applicant because they need the criteria for social equity business applicants to find a board rule. One recommendation for denial of social equity status and that's for submission number of an 81. This applicant does not meet the criteria for social equity business applicant but to find the board rule. And then lastly the staff is recommending issuance of an employee ID card for an applicant who has met the criteria for overcoming presumptive disqualification. As set out in the board rule. That's your list for this week. And on that last one the overcoming presumptive disqualification. Generally speaking we go into executive session to discuss the specifics of the case. The staff did present us a memo and after reading the memo you know Brynn talked to all of us and none of us decided we needed to further discussion. We will not be doing any executive session. We'll talk about that. So any questions for Brynn? Nope. All right. Is there a motion to approve the staff recommendations? I move that the board accept each of the recommendations as presented to us by staff in this meeting. A second. All in favor. Hi. Hi. So why don't we move to public comment? Same as always please if you join via the link raise your virtual hand if you'd like to comment. We'll call on you in the order that you raise your hand and then we'll move to people to join via the phone. Nellie if you could help us with the order. Absolutely. We have Dolan Dolan first I think is Jesse Lynn. So yes this is Jesse Lynn. Thank you guys as always for taking public comment. A few things I want to quickly so I'll be as quick as I can comment on is your report now in the hands of the advisory committee. I'm hoping that there is some kind of consideration for the seat on the advisory committee that is meant to be a patient representative for the symptom relief oversight committee. My understanding is as of right now that C remains empty. They're just mentioning that we are missing a big you know member of the advisory board that would be representing patients and patients thought so if that can just be you know known and see what we can do about that. I also wanted to throw out there that with the new federal regulations changing on research and you guys have mentioned multiple times how beneficial research would be and I think we all know that if you guys could consider in 2023 looking at a specific licensing structure for research which would include on-site consumption. A great example is right now I just launched my own research study which is specifically working to help people feel they have over consumed cannabis so I think this would be a consumer safety support mechanism and if we had an on-site consumption site I could get my research done in about two days instead of probably three to four months so if Vermont could consider as Massachusetts has put my research license in place allowing on-site consumption I think that would be fabulous moving forward. I also quickly wanted to mention that as you guys know I'm always a big proponent for education and appreciate that you are as well. Working with the Vermont Department of Health I would ask that you guys consider including again not only patient voices but also to work with the Department of Health some industry cannabis industry professionals to bring in their insight and experience. When working with the Vermont Department of Health we know we have some great educated medical professionals but we do not necessarily have medical professionals who are educated specifically in cannabis and I think that is something we are missing. An example of that is the pamphlet that retailers need to have available for consumers that the Department of Health put together with you guys. There is one or two things in there that I think you need to look at being updated that was missed. We talk about vaping in that pamphlet and it does not in any way differentiate vaping flour versus vaping concentrates. So I think that is an example of if you have some industry professionals or medical professionals specializing in cannabis that might be great to update and look at that to really differentiate that from the educational standpoint. And when we do speak of concentrates Bryn had mentioned how you guys mentioned full spectrum concentrates in there. I'm hoping and I think my understanding is correct that there is a differentiation between full spectrum and distillate products on labeling because if we do have concerns of either over consumption or cannabis hyperemesis syndrome or anything like that we really do for from the education standpoint need to very you know very specifically differentiate between a full spectrum product and a distillate product if we are moving towards hopefully getting rid of our concentrate cap. So that's something that I also think with the Department of Health and you guys could use you know a little bit of tweaking from the medical perspective. And lastly I just want to thank you guys for your advocacy on this concentrate cap. And as James had mentioned and I appreciate you mentioning it and want to remind people who are listening you guys cannot make these changes and most changes that have happened in Vermont have happened because people have stood up and reached out to their legislators and reached out to their reps and use their voices. So I think you guys have done a great job putting the info together but everybody on this call and everybody in the cannabis community also needs to rally behind you and do their part and speak up as well individually and reach out again to legislators and reps because that is how we will make change because that's how we've made change here in Vermont thus far. So I think that's it. Try to be quick and concise. Thank you guys for your time. Thanks Jesse Lynn. Bernardo. Hi sorry Bernie again. I just I want to commend you guys on this report. I think it's really well written kind of covers a lot of bases. My input would be to not forget about California, Colorado, Maine these states that don't have concentrate caps specifically they have robust medical programs where patients have lots of access to different products and I think it would be a missed opportunity to not factor in sales of concentrate products from those markets you know comparing it to Vermont where I think it's pretty well known people don't shop at the dispensaries here because of price and lack of availability of products but in those other states for example Colorado Springs when I lived there it had a hundred different medical stores. As a patient myself I will say when living in a state that had a robust medical program my preference was to join that program because of the cost of concentrates and the taxes making them kind of much less affordable on the adult years side. So considering you know Maine, Colorado these states that do have large you know medical programs a lot of people who consume cannabis opt to become patients in order to attain those concentrate products at a lower price and so some of those adult use numbers might be skewed because they're missing a lot of users. Other than that you know I think just continuously hammering home the difference between solvent and distillation processes versus solvent less you know there is no distillation occurring during solvent less extraction so ice water extracts that's always a full spectrum product when thinking about the nature of this THC cap it kind of becomes clear to me that someone along the line thought liquid concentrates distillate that's why we're putting it in pens so that we can control it solid concentrates not in pens and I mean I mean vape cartridges and so you know going back to what you guys said and what Jesalyn spoke about I think that consideration of a full spectrum single pass product versus a product that's refined several times in order to increase its THC potency there needs to be some sort of distinction between those two types of products not between and not just lump them all together I mean so again I really appreciate you guys and all the work that you put in you're here for the people I think everyone sees that you know and so thank you very much thanks Bernardo Keith hi this is Keith can you hear me yes hi so I'm a local hemp grower just keeping an eye ID or an eye on this market but I noticed that you guys attended the the USDA meeting they had over here a little while ago last month and they made a claim that if anybody got licensed with you for growing in particular that they would pull our USDA hemp licenses for next year and so what concerns me is I I see in the the rule one rewrite that you have the 2023 rewrite draft that you've got posted online that you're pulling in hemp derived products into the rule which I believe rule one if they have more than one milligram of THC in any serving and I'm just wondering are you aware of that conflict that you know that one milligram it's pretty easy to get there most most of the tinctures that are sold on the market now that are hemp derived can hit that one milligram very quickly and some of the flowers can as well so I'm just I'm looking at that thinking how is this going to work out if you guys start pulling us under your purview for hemp and the USDA is telling us if we ever have to get a license with you we lose Keith we did lose him he's in the waiting room now I'm readmitting him Keith I think you uh if you're back in the meeting you dropped out are you here now I am good old Vermont internet infrastructure you dropped off right right where you're talking about the conflict between USDA requiring a hemp license in this one milligram this year right so what I'm worried about is in this rewrite it basically says if we have one milligram or more of any serving size of THC in them that this rule applies and so I I don't know what it means yet but what I've been told by the USDA is that if we have to get license with you guys particularly for growing that they're going to pull our hemp license which is a federal license under the farm bill so it just feels like a freight train of conflict coming and I'm not looking to get overseen by any more regulatory agencies that I have to so I'm just wondering if you if you are aware of that number one and is that the intent that if we had for example an oil that has exactly one milligram of THC in the end are we going to have to follow the full rule and have to be licensed for all parts of that because if it does it shuts us down at the federal level yeah yeah thanks thanks for that comment and honestly we're in the process of developing our hemp report um the legislature gave us jurisdiction shifted it from the agency of agriculture to the cannabis control board starting January 1st of 2023 and um we're going to have to develop rules and guidance and clearly this is an area where we're going to need to do you know one of these kind of Q&A sessions networking events um and uh we do have a report that's due I think in January 15th we're going to kind of lay out how we intend to regulate hemp derived products we'll review that we'll review that probably later this year or very early next year so will there be a comment period on that before it comes out in January yeah absolutely thank you that was it yep thanks Keith Heland hello can you guys hear me there again cool um I just want to say uh some good recommendations in here guys especially I think as it pertains to the the THC caps and the vape tax as well um that one's really killing the the vape market out here um 90 grand distillate carts are just not something that anybody I know is going to want to buy so good stuff there I'd also I don't know if I if you talked about the edible packaging at all um I feel like there was something in there I was kind of being dragged in two directions but that's another thing I think that could really help this mark I mean again 30 for 50 milligrams of cannabis edibles is really really pushing it you know and I can go to my guy on the black market and get 500 milligrams for 10 bucks you know that's you know 10 times as much for a third of the price so I I feel like some adjustment there would really help the edible market um flourish a little bit here um I do want to also echo a couple of things that Jesse Lynn said because I've also been hearing from people that this seat on the advisory committee has been vacated and the symptom relief oversight committee has been disbanded or dissolved and I I agree with Jesse Lynn if if the advisory committee is meeting again I understand a number of people worked pretty hard to lobby the legislature to get those seats added so that patients could have some representation at the table and if Jim is no longer in that seat I think it would be a great time to get somebody in that seat who is an actual patient who is not connected to one of these MSOs um you know I don't know who that would be but it would be great to just have you know someone like Jesse Lynn for example I'm sure she's way too busy for that but or Amelia or someone like that in that seat um who really cares about this and knows this knows the legislation and cares about patients I think someone like that would be great um Jim also during one of the advisory committee meetings last year or the subcommittee meetings he issued a report in the medical subcommittee meeting I believe which was submitted as some supplemental material that I have been trying to get a hold of and I have not been able to track down and if you guys know where I could find that that would be great um and the last thing is about the education piece I really um again I gotta agree with Jesse Lynn here um I feel like throwing money at the Department of Health is just kind of um you know you might as well light it on fire with what I've seen from some of their executives in terms of their what they consider education you know it's still very very fear based a lot of it lacks scientific justification um so and even some of these rules the THC caps and so forth were something the Vermont Medical Society was sort of pushing without any justification really and honestly I think you could get a better education from going to talk to industry professionals I've learned more from talking to people in the last year than I have ever learned from any state agency in my entire life um in terms of cannabis education those are the real people I think we should be talking to and it would save millions of dollars um anyway that's all I got guys uh thank you very much if I could find that report that would be really great thanks Caleb Tito hi everybody um so I apologize I had to step away from the meeting for business for a short time but when I was listening I didn't hear anything about the vape tax and this definitely seems like the place that it should be um and and this is it if we don't get something changed in you know in this next session um a lot of retailers aren't going to want to sell these products for nothing or even add a loft because uh the margins on the flower vapes are not great and uh but look these are these are this is the healthiest way to to inhale cannabis and and the fact is Vermonters won't have a way or at least it'll be a lot harder for them to get these products uh if we don't get some change um so that's all hopefully everybody's having a great day thank you thanks to you Bobby thanks for having me I wanted to echo uh some of these people uh encouraging you to push for more robust uh reform efforts uh particularly particularly sorry particularly in reforms uh the edible packaging restrictions uh especially with these 40 dollar gummies it's just really not fair to patients when you know we're talking all of five dollars in ingredient costing packaging even uh with these packaging restrictions um it's really just going to push people to the traditional market I can tell you that firsthand uh you know uh I also would be remiss if I didn't take another moment to uh lament the inconsistencies in communicating with y'all uh time and time again in these meetings you encourage people to reach out directly over the past six months I've made dozens of emails and phone calls to central ccb contact points with all of one response uh I do have a tentative meeting with one of you next week via phone which I'm very thrilled about but uh you know that took a long time coming other than that the only person we've been able to interact with is the individual processing our application and that's been shaky at best so I understand y'all are dealing with a lot but uh wanted to encourage y'all to attempt to tweak some of these communication issues in the new year uh thank you very much have a great day thanks Bobby Keith can you hear me hello we can hear you Keith thank you for taking your time today once again to hold this meeting I look forward to your changing your meeting platform to once a month because it'll be longer and more uh informational the comments say are the ccb commissioners going out to the communities to develop equity in the cannabis industry is the cc building any educational cohorts for social equity participants development of information informational videos is there any effort to simplify the process se e process with in-depth overview of the benefits of being an scp participant are you producing any awareness or equity in educational mission participants to work on some of these things are there any cohorts coming up to work with incubators to help people learn on the technology that doesn't have the technology such as using duchy or your new ncs analyticals um tracking tray system can you please post a overview for social equity applicants a historical overview of cannabis and the racial disparities from the marijuana tax acts of 1937 onto your website please that would be wonderful to have um also what specific areas are the three of you as chair people specifically working on in your tenure during your time here at the ccb to increase the cannabis industry here in Vermont what specific areas does james pepper kyle harris and julie hobert working on and burn hair to increases i know y'all work as a team but do you have specific areas you want to work on individually to make a robust thing there also are two educators i just whipped out two emails to you all three just recently if you could view those i also want to know why there's a comment why the ccb is not writing rule three for patients i also do want to know why the ccb has not allowed lindsay welles to be a member of the chairboard as the former director of the medical cannabis program because there's no longer a director of medical cannabis program and she oversaw it for 10 years and she's not normally included on some of these meetings it should be because there's a lot of patients on here today that don't have any representation she knows the thing she could fill that advisory board seat as the oversight committee that has been disbanded there's no longer an oversight committee in the state of Vermont overseeing the medical cannabis program at all currently has no leadership it has two administrators but no leadership in the program at all is there any chance that you guys could list all other pro or possibly somebody here could pro list of all the pro senators and house representatives that are pro cannabis in the state of Vermont and if anybody's willing to make a Vermont medical marijuana community website that would be a better way for all of us to get together and enforce the state legislatures to hear us and maybe we can get a committee to sit on the board at the state house i'd be willing to do that as well i have plenty of free time other than taking care of my child there's things there that i'm looking forward to seeing like that and other than that um you guys are doing pretty well right now i know you need to add some more staff to your thing um other states have about 50 to 200 people working in their staff and i know you guys are a little short-handed so you're doing what you can and i get that i appreciate it it takes time to reach back out and i do thank you for reaching back out when you have thank you thanks Keith press hi guys can you hear me yes yes all good i just wanted to thank you guys for all your efforts that you guys are doing for uh taking care of the thc caps um i think it's uh it's a long process i know you guys have your hands tied with a lot of it and i i feel like you're you're done an amazing job of putting that uh research together for everyone um one thing that i didn't see mentioned and i didn't feel like was represented well was the use of concentrates really allows people to not have to inhale all the smoke that's often used i mean it's it's a way of using cannabis without having to use much and i believe that you know that for medical patients it's really great to be able to not have to consume as much to get the same effect and i think a lot of that a lot of the fear that's around it all is that it's going to be abused on the level of you know overusing but i think it really does give the the patients and the users the ability to use less and i think that that really wasn't represented in your in your findings there and i um i just wanted to put that out there you know the vape tax um taking away the ability for people to use different vaporization techniques um you know such as a volcano uh having that be something that just costs prohibitive in this state um you know being able to dab having um proper temperature dabs not just in a pen but a really proper temperature dab is vaporizing those oils and it's uh it's much less harmful than other ways of consuming i just thought that that information should be brought to light thank you i appreciate the ability yeah no thank you that's a good point h m h h m h are you with us if you join via the phone and would like to make a public comment you can hit star six to unmute yourself and of course if you join via the video link um just raise your virtual hands we have no one who is joined via phone currently and h m h is presumably not unmuted no they are still unmuted that is correct well i'll just give it one one more minute then hello i think i got it yeah there you are all right great thank you guys sorry about that i was calling to lobby the board on what cultivators are allowed to possess because these days with all of our big trimming machines keef is kind of a an unavoidable byproduct after you're running flour through these machines that tumble them around and trim them so i'm wondering if there's some provision where the growers can sell our keef directly to the extractors or i'm just trying not to get stuck with a product here that i'm not allowed to have and it seems like pouring it back into your trim batch or whatever is just really counterproductive and going backwards in my opinion when you've got a big jar of nice separated keef and nothing to do with it it presents some challenges and other than that i appreciate everything you guys have done and uh having a great time with all this thank you so much great thank you um why don't you submit that question i'm trying to thank to our compliance team it's ccb.compliance at vermont.gov and they'll get you an answer on that specifically i think it's on the what can i do with yeah or it's on the what can i do with my license there's a one-pager guidance on what can i do with my license also i think has the answer to that question yeah okay and i guess the other caveat to that is i'm having the same issues with sending you guys emails and never never ever getting a response i understand you're busy and all that but it's challenging on my end all right about that we'll um if you can you might share in your name yeah my name is jennings i'm with high mountain homegrown and i know okay you're one outdoor yeah thank you all right thank you dave is next hey guys um on kief uh just that was mentioned it reminded me uh i was surprised to see that that your your guidance that doesn't allow cultivators uh to to have the kief you know it's just it literally falls off the plant um and it just kind of seems like a thing that if it's restricted to manufacturers it just i think it's just going to get people in trouble for no reason at all and and and raise prices ultimately because you know now you have to go through yet another hand in the supply chain um you know there's not a huge mark from what i'm seeing there's not a huge demand for kief at retail um but you know there's some um and uh you know the more you kind of artificially increase that price um through well intention but perhaps unnecessary uh regulatory intervention um you know the less um that that demand is going to be met in in stores uh and the more it'll be met on those you know quote unquote street um so i think that's one that you know i would urge you guys to reconsider um um anyway thanks have a great day thanks dave anyone else for a public comment well um close the public comment window um always you know feel free to get reach out to us in between meetings um and thanks for joining today and we'll see you all next week during the meeting