 You still in touch with John Boat? Yeah, we still chat every once in a while. He's a good colleague, good friend, good mentor. I really enjoy working with him for him in DC. Yeah, it's a good organization. Yeah, he's a good guy. Savannah and I? Here you go, I don't see you. I can still load in once in a while. Hi Ashley. Hey guys. Hey Ashley. Hello. Hi. Hi everyone. All right see, Savannah just wanted to let you know, we revisited the definition of social, of family for the social equity subcommittee and we added domestic partner. Nice, glad you're there. And then obviously we're just the other issue we're talking about when that issue comes up later on during our social equity group. Sure. So I know Tim can be with us today. I'm going to give Ingrid another manager too and Saban is here today. The market structure subcommittee is wrapping up and he has continued to volunteer this time to help this committee and provide his perspectives and I'm so thankful for that Saban. And Chris Walsh I think should, you know, be doing something so large as Saban. I don't know if he's planning or can attend today but I'll give him another minute or two. Hi Ashley. I was just having some technical difficulties with my ear buds so it's okay. If I looked for flag. I'm not worried at all. And some really good news are Megan Howe who, you know, takes a lot of the notes for our subcommittee groups in labor right now. So we'll have this soon. Nice. Yeah we have no idea if it's a boy or a girl but I don't think it's a boy. All right well I see Ingrid's here. I'm going to go ahead and start the recording and we can get rolling down. Okay. I'm calling the compliance and enforcement subcommittee to order October 4th. I'll just do a quick roll call of those who I see present. We've got Mark Gorman, Jeannie Cranway I'll call from the NACB. Carrie, do you get here? You got it right. Ashley Reynolds, I also want to say that G always throws me off. Kyle Harris, Kyle do we have anyone else from the board in the room? We have Brent here. Thank you Director Grant. We've got Brent Knight from the Department of Labor and Lottery. We've got four members of the public. Great. And then we also have David Huber joining us and Siobhan Tritchell. Okay I think we're all set. You're great. Thank you everybody. Again for those that... I'm sorry Ingrid, I missed you tonight. Ingrid is present as well. Alright everybody, thank you so much. What I want to do is continue our conversation from last Thursday. Siobhan I'm going to send you a document quickly. First, I believe nobody has seen events from last meeting yet. I don't think that's my fault. They were sent to me on Friday. They gave me when I was sending out stuff earlier this morning. So, comment would help remind me. I don't think I sent them out right before this meeting. I doubt anybody's had time to do a good mullence over. But we can just put that on the agenda for Thursday to serve a good image of my Thursday. And today is coming Thursday. Keep myself straight. So Siobhan just to bring you up to speed. Last Thursday we started talking about conversation security. And I'm going to send you a document we heard from Jen from BS on how Massachusetts approached outdoor security. And we're talking fencing, cameras, lights, security systems. I'm going to send you that right now. I wanted to, you know, I know Bates here. I know we had a lot of questions. I know Jen's not with us anymore. But I want to continue that conversation in an indoor cultivation security and retail security. Does anybody have any thoughts? You know, from my perspective it seems as if everything's kind of pretty similar across all other jurisdictions with a legalized values market. You know, from my perspective I'm curious about alternatives. Again, like, you know, folks that are cultivating their own interest in securing their cultivation site. At what point or how overly prescriptive or prescriptive does the board need to be from requiring fencing, lights, cameras, security systems, or is there an opportunity for us to kind of recommend some stuff and require a combination of those, not all of them, looking for alternatives. Again, my thought is not being overly burdensome from a cost perspective on some of our smaller cultivator peers but recognizing that, you know, consumer safety, theft protection, so on and so forth are already the other end of the conversation. So Ashley, I see you raise your hand. I was just curious if we can look at this from a standpoint of, or the smaller cultivators talking about them specifically, possibly not requiring fencing. I know that we're having sort of different tiers for rolling out licenses and delayed so we have really the option if we want it. I wanted to also get Carrie's perspective on folks who are choosing to fence. I know he brought up last week how, you know, there kind of runs the gamut as far as like how the hemp program is working versus how people are fencing. Some are not. Some are, you know, doing much larger grows without any fencing at all. Some are using armed guards. I think you said Carrie, and, you know, from my perspective, I don't really feel that there needs to be fencing, especially for the smaller folks and I just wanted to kind of test the temperature of the rest of the committee here and see is there a will be, and if we're not going to do the test. I'll weigh in when you're ready, Ashley, I'll just have a chance to... Any other thoughts? This is Tom, Carrie, and you all can correct me if you've got a different impression, but at least from what you've seen from the research memo that we disseminated from Ashley and from what Jeff was saying, I mean, I think fencing's probably the most critical component for security. If you're going to do away with that, then I guess everything else becomes optional. I mean, it still is. I know everyone wants to equate it with him. It's still different. It's different legally. But it seems like if we're talking about security and you're making fencing optional, then I don't know if that might be... I would think it's probably a departure from what other states are doing, and my impression from what Jen was saying was in Massachusetts, we require that because you don't want people just stealing away with product in the middle of the night and there's also need some protection from wildlife as well. So I'm not saying, Ashley, that it doesn't make sense. And again, intellectually, what Kyle is raising is an issue across all the subcommittees of more regulations are giving more costs, especially for the regulators. That's the nature of what we're doing. But ultimately, it's up to the board to decide how much direction they want to give, especially small cultivators in the town. So those are the issues that we're facing. Saban, I know you needed a conversation, but I would love your perspective. Brand new, so take everything I say with a grain of salt. But, you know, certainly, we've touched on security a little bit intentionally in the Mark's Doctorate Committee and just kind of made reference to what we assume this committee is working on and or where you might end up or might not end up. But we've multiple times really mentioned when we're talking about allowing potential permitting for local farmers, who are going to be small cultivators, to also potentially have storefronts at the farm, at some sort of farm sales, and it being kind of the cannabis equivalent of when you see maple syrup available here everywhere all around Vermont, that one of the big concerns was not inviting risk to those farmers. And, you know, I'm not necessarily a big regulation guy. I don't want to be paternalistic and, you know, tell people, we're going to protect you from yourselves. But I think in the other committee, we've been on a working assumption that there would at least be a bare minimum of security because we are a little afraid of just kind of rampant issues that could come for all these folks who are, you know, it seems like the Vermont impression is that small cultivators were going to get into this or really get into this for an opportunity to do something very different from how their farms have been, etc. So, intentionally, systemically invite a large amount of risk on to them, we may not be to our fiduciary responsibility. So, I think we've been on a working assumption that fencing was a given, you know, other things like lights or cameras that all those things are, there's some balance in all of those. But it does seem to me that some sort of fencing would be a bare minimum. It's not just like, you could make a choice when you have an in-ground pool or you've got a fence that are not completely right, like you don't want the neighbor's kids to run in, unsupervised and swim, but that's your choice, what risk you're taking or not. I think this is a more serious level above that, that we, at least in the other community, were probably working under an assumption that they would at least be stopped similar to fencing or other limits like that. I mean, with the pool you're fencing in because you're worried about death. With this, you're worrying about death. You're actually less of a concern. You're not protecting somebody. You're protecting your own commodity whether that's from deer or fat. But the swimming pool you're preventing a drowning from happening on your property. So I think equating it to is doesn't happen, right? I accept that, Carrie. And that was me making up that comparison right now. You know, it's not a subject we've had before. But I think we're all worried that people besides they're not just taking the blends. They're going to show up and bring whatever. They're shotguns. I'm not actually talking about organized gangs, but other people are going to come rob your little storefront and thinking about it as a big cash box cow. We don't want to, in the same way when you go camping, you have a bear bag or maybe any of those things. Again, this is due to me at this level of doubt. Just for the sake of clarity, I guess we started this conversation on Thursday and we weren't even thinking about it from the farm gate sale perspective, but from more of the just growing site perspective, you bring in another wrinkle, though that I know you're curious about. And we haven't gotten that far. I'm not sure I want to get ahead of myself. We could do specific recommendations or regulations around having that farm gate sale farm stand business along with your outdoor cultivation site. Maybe that's treated a little bit differently versus somebody who's strictly cultivating. I don't know. I'm trying to get a temperature read on everybody and where everybody's at. Tina, I see your hand up. Thank you. I just want to remind everybody that this is not like an agricultural product. That if anyone consumes it, it'll be fine. You know, this is a schedule one job that's federally prohibited and it consumes can have an impact on the person. So I think we have to take that into consideration as well. Where if we would lock up alcohol and have fencing around that to prevent someone to come in. So, you know, this is really how hemp and can visit different and why additional restrictions and regulations need to be put on this job. Thank you. Mark. My question is if you don't have fencing which is your first level of security are you going to get any sympathy at all from the police if you report a theft for your insurance company if you report a theft. Now, maybe that's just part of the risk you're taking with not having a theft. But those resources will be drawn on people we'll call the cops to try to get them in case they're in their problem. Thanks Mark. Ashley, is your hand still up or do you have a we'll carry it. I know that it has to your perspective and I'm thankful everybody's speaking of it. I'd like to hear your perspective, Carrie, and then Dave I would like to hear your perspective working under the assumption that we will, the board will have a formal agreement with the agency of agriculture. I want to make sure that any concerns, thoughts or perspectives you would share foods on the ground actually going to these sites I think would be extremely helpful for this committee here. Sure, and in terms of actually reiterating sort of what I spoke of last meeting and it runs again it's either out in the field or it's behind fences and really the only concern of direct theft is for two or three weeks at the end of the season. I haven't heard of any theft so far this year but certainly two or three years ago there was some reported and behind the fence are not the folks who called the police received the same level of response and sympathy same as stealing apples or some corn off off a farmer and sort of my perspective on this I read the California model that you shared last week and that was sort of outside it needs to not be seen and then I feel like it's up to the producer to decide what level of security they want. I've read your sort of different versions of licenses and the outdoor growth was averaged to be 20% of the market most of the quality cannabis is going to be grown indoor sounds like that's 80% it sounds like some there's an opportunity or an appetite to have small cultivation plots outdoors and as far as new businesses that want to get into the business I think what happens to that particular business is going to dictate what sort of security that they want or need if you're in sort of a more populist area, Chittenden County most of the hemp theft that occurred were within distance, a walking distance of a fairly large college and the stuff out among the world communities where work was not targeted and I think it really depends on where you choose to put your growth and who can see it all those options should be available fencing cameras and lighting but I also feel like it shouldn't necessarily be something that the board has to dictate we'll get to where we get to as the market evolves Ashley maybe this is a little bit too much of a drill down but for anybody who is getting a cultivation license is there going to be any sort of site like through is anybody sort of thinking about is it going to need to be some approval or is it really just going to be an application online and people can just fill it in because I think you have brought up a really good point, Carrie even just looking by county by town in Elmleur, Morseville hard way close to the left of the kingdom I mean there's so much there that seems a little bit silly I think about the grows that are happening all around Stowe or even just right down you know over in hardwood there like I mean they're massive and I don't ever hear about anybody messing in the beginning yeah you know when crops some of them are hot some of them weren't hemp at all I think there was a lot more of that I don't think that fence is a necessary answer I think that if somebody wants to get cannabis they're going to regardless of if it's an event or not regardless if it's grown in the ground or not I do think having it be sort of a way and not playing music is a really great idea but I mean like I'm a mom you guys like I'm not looking at this from a perspective it's just like this really heavy I do think safety is huge I just don't know that it's a one size fits all for what we're thinking for these smaller cultivators angry I'm just it's more of a question I'm wondering I don't know anything about insurance regulations for this type of product but wouldn't that be would that be a requirement in order to be assured does everyone have to be insured for this where does that factor in actually signal so I don't really I don't know Tom are you going to yeah okay I'm just going to say that crop insurance is not really applicable for this particular crop at this time maybe Tom you know something that I don't I would say probably the majority across the country are not insured for cultivation and you know for any other passive cannabis it's very expensive and it's hard to get you know Ashley probably talk about that more firsthand but if you can get it and you can afford it like any other business you probably should and you could and if you go through those groups then yeah I would guess that fencing your crop would be a requirement in order to obtain the insurance Mark if you're standing or yeah some by the look on your face your hand is still up okay Gary question for you just trying to respond to one of Ashley's questions or comments and yeah I think your instinct is spot on we're getting a little bit far ahead of where we currently are but when it comes I'm trying to remember the hemp program process and I know folks need to whether it's through Google Maps or some other service they need to actually show the agency of agriculture specifically where a cultivation site is as part of their application is that correct that is correct and that's a that is a USDA that's a federal requirement and we need to share that list with law enforcement so if somebody does report it they check with the agency to make sure that that is a registered hemp but yes you know if that that's now I don't know what will happen in years to come I don't know growing cannabis outdoors are going to be registered somewhere so you'll either be on the hemp list or with the control board in the future it will sort of figure out what that looks like if a cannabis outdoor road did have to be situated a certain setback from a road or from you know the eyes of the public I don't want to pull a number of thin air when it comes to trying to establish that, recognizing the farms and parcels of land look different depending where you are even in the state of Vermont I know a lot of farms situate themselves pretty close to the road or at least they did historically for the winter months because it was easy to get trucks in off those properties but I don't know where Kerry, Tom where do you think we would start in trying to if that were going to be part of you know this conversation where are we going to start in trying to pull a number you know Kyle I like this standard of not being able to see it out of sight so if you know you can see it from the road then you're putting up a fence that so folks can't see it but if you've got a spot that nobody has access to unless it's you know cross country through the woods that's a completely different scenario I guess there are those public reasons throughout the state so we would have to be careful about Ashley here I think that I agree with Kerry first of all and then I also you know we're not going to require this but here we are thinking about these cultivators the talent perhaps some of the folks from the illicit market now transitioning into this regulated market there's things that we all do those last two three weeks of before harvest occurs that is part of our own if you want to call it insurance people sleeping out in their patches people doing their own foot traffic I mean again I know these are things we're not going to be able to require but I mean these are things that we're going to be doing anyway and I think again you know really looking at it from the lens of what it takes to grow and not from a lens of this is what has worked in other states like I don't want to stand on the soapbox I do think fencing is going to be needed for certain areas of growing but I think if we could figure out a way to sort of decipher the size maybe a little bit more about this thing site I like the out of site and obviously access if it's close to being grown to a school all of that needs to be put into consideration but I just want to share just anecdotally like we're all used to that time of year and we're all used to being a little bit more diligent about our own personal surveillance and so yeah just wanted to put that out to the universe Thanks Ashley, Simone? Just saying I also support Kerry's idea of you know thinking about different circumstances you're comment earlier Kyle that maybe the way the final legs are written are yeah it's different if the field is visible from the road or not it's different if you have farm gate sales directly or you're just a cultivator I think all those are part of our smart Thanks Yvonne Dave, any thoughts from your perspective on a pretty place to start and then I'm going to try and pivot us to more of an indoor based conversation Sure Thanks for letting me comment on that I agree with whatever you're saying as well I think that I kind of want to talk about two different things now the safety for all of the staff and the talent that Ashley is mentioning but then also Kyle who had mentioned boots on the ground probably the safety of the regular as well and potential pitfalls there with certain situations I think it's probably something that Anchorage would also be thinking about with her past career so you know there are a couple things that are inherently dangerous out there dogs inherently dangerous animals, agency of agriculture definitely the inspectors do run into dogs they run into bulls they run into other very dangerous animals that do have to to be fenced off or at least made known to the regulator make sure that nobody is going to get maimed, harmed, killed those are really real problems in Vermont especially in an agricultural sort of setting another thing is the Vermont federal laws potentially armed registrants so all this sort of ties into different trainings that need to be offered to the regulator de-escalation technique trainings, we do already provide that we can have work with the Vermont State Police to provide our staff with de-escalation techniques as well as EPA officials regulators in rural agricultural states to make sure that everyone has that most up to date training when it comes to protecting the staff for the regulating entity just to make sure but the one thing I wanted to add for the other conversation was you know there probably are many many techniques to deter that and to maintain security and perhaps we think that in a best management practice there's a lot of work going on so fencing would be maybe a baseline and this is all hypothetical but maybe you have 10 other ways to keep track of everything cameras, lighting maybe some other type of perimeter security perhaps it's you know you have a policy of fencing plus 2 out of 10 of prunes other types of security and then maybe something that the team chooses on their own or works in conjunction with the pound or works in conjunction with the regulator and that may be a good smattering to see exactly what works and what doesn't work for different geographical areas different types of growing operations different types of areas and the last thing I wanted to talk about was the out of sight part of this would keep the public away from seeing what is going on at the operation and eventually could have its own pitfalls in that if someone were in trouble and this is completely out of sight there may not be somebody to come to the rescue in instances where a regulator is trapped or you know there is something dangerous going on if the public were to see or at least have some sort of light of sight and they were driving by and they said oh wow this is really something a little strange they could make that phone call I'm sure that's happened with Vermont State Police as well other local precincts where somebody has said you know something is out right I would like to make a call completely screen off an operation while maybe a fence may also may also directly relate to harming certain individuals I just wanted to say that as far as the safety boots on the ground kind of realistic statement thanks Dave we had a lot of good perspectives here with different experience I think it's a good conversation Harriet I saw your circle light up yeah I was Dave knows this first hand actually I brought him to a site that was alleged to be not growing him and when we showed up there were pitfalls on chains so good call Dave well this is what I this is what I'm hoping that we can do and I'm looking to you Tom Mark and Gina I'm trying to pull from the way Gina tries to facilitate some stuff in the social equity committee and giving people options with words on a slide every piece of paper because I think if we can kind of be presented with some options this committee can be presented with some options and see those words on those papers and I'm thinking about options meaning most prescriptive to more of I don't want to say least prescriptive but you're providing more options a suite of best practices as Dave kind of alluded to the out of site no fencing, in-site fencing model but just getting like maybe three options that we could talk about on Thursday might be helpful for folks to kind of conceptualize what we're talking about here not even necessarily thinking that we need the full regulatory type text but just bullet points on paper key takeaways, key buckets of different types of security that is typically found at an outdoor cultivation site is that something Tom and Gina you think you might be able to help me out with yeah I mean I think the concepts are there and the reference materials we disseminated last week you want that just kind of narrowed the bullet point format I think everyone would know I mean we're talking about fencing we're talking about lighting we're talking about video surveillance I'm trying to get recommendations and trying to bring this into something at the board or the subcommittee might feel comfortable you know voting on or passing to the board as a recommendation we can put that together for you David if it would be possible to speak to you from an agricultural perspective just what your regulations are for Hampton and some other so we can make it very remote-focused as well Thanks Gina, Tom I know you put together you and actually and Martin put together a lot of awesome stuff for us I didn't want to in any way that you have it but just something that is easily digestible in this type of setting for us to move on that would be very much appreciated Sure David and Kerry my understanding is that there aren't any right for ag or Hampton there aren't any security rights that exist right now right? I think Kerry would answer no but there are security requirements for the staff for the regulator I understand that side of it but I don't think we need a separate call to talk about what's already existing because it doesn't at least for Hampton Right Correct Okay, alright thank you Thanks everybody So I want to start the conversation on indoor security and cultivation security and even I think it was included in their Tom retail security too and again these resources have been fantastic as they're launching off point and hopefully you might be able to give your key takeaways to kind of engage conversation here Yeah and I just included that beginning section which does include retail as a summary because a lot of the indoor cultivations are combined with the retail stores at least here in Arizona, Nevada and out west and they're fairly similar so I mean the buckets that we're talking about mainly are again video surveillance what Jim's planning and stressed last time is limited it's access control to make sure that there's only a limited number of people that have access to the indoor cultivations so building access control systems and alarm systems again so those are the three main buckets and places like California and this is more for retail but there's actually regs about physical security or arm guards needing to be present at the facilities as well and I think that's what you're going to find when you look through those materials it's going to fall into one of those buckets Any opening questions for Tom or for the group Tom it doesn't seem like again just when we're talking about this we're not trying to reenact the wheel here it seems like other jurisdictions pretty much do things standard across the board for the most part but is that your takeaway as well? Yeah but I mean some are definitely more prescriptive in your terms in the beginning than others not everyone is going to require physical security guards like California does so it's the level to which you want to describe the regulations that you're going to impose Any thoughts I mean we can start with security guards anybody have any thoughts there I know that I just had to see you this morning so maybe we can get a better conversation on Thursday but actually I see your hands up I mean I follow a lot of cannabis news I'm pretty nerdy about it and I just don't hear about this type of thefts I don't hear about you know that level of force being needed optics or culturally you know necessary you know are those armed guards there in response to something happened again I know we try to look really hard at data we try to look at patterns but again I'm only one person in this industry but I just don't hear about any of the needs for that stuff so if anybody has heard otherwise I'd love to hear it yeah and to be clear the California regulations for physical security that's for retail that's not just if you have indoor grow oh I mean as well like in Arizona they all have security guards as well for the retail I think it's less advanced hand up first and then Dave I'd say overall no different direction but I'd agree with Abbey's with Abbey's perspective there I think that if you interpret what's the intent of the two acts that give rise to all of this it's quite clear that we're trying to create opportunity for small Vermont operations that you know it really is a unique approach to the very Vermont approach and in the market structure subcommittee we spent a lot of time trying to think about what that means from a cost perspective and that's really how we our decision of how we recommend tiering pricing for licenses for different sizes because we don't want to be overly burdensome financially on the smallest growers when it seems what's the intent is to empower all these new call whatever you want small businesses small organizations small whatever X, Y, or Z so I'd agree that especially from a cultivation side if you started talking about security guards that's such a cost prohibitive factor that almost out undone everything else that's going on the other levels it makes more conceptual sense to me on a retail sense but I would still think that that should be optional not required you know I think that Vermont envisions a lot of small main street on a small town small shops not just a shop in Burlington it's going to be a mega XYZ and so you know I think again that same cost burden perspective is going to be cost prohibitive for a small organization and they also need to have security guards on hand and you know I personally come from the alcohol industry especially from a regulatory side I would think of this more like bouncers at a bar you know the bar when they build themselves to set up and they know the area they're in and the client are catering to and they're going to choose whether they have a bouncer or not and maybe a bar that caters to the college kids is going to have a bouncer or maybe they'll only have it on Friday or Saturday nights and you know a bar that's a wine bar is probably not going to have a bouncer and or in a location or XYZ I think all of those are fair considerations to allow the business to decide what's appropriate for them Thanks a lot David I just wanted to clarify the record real quick Carrie had mentioned earlier about that of hemp plants the agency has not been made aware of any thefts by a complaints this past week and there were two plants that were stolen from a preschool teacher personal garden I think in downtown Montpelier that made just a local front page form which is a local news source essentially for Vermonthers and that was the first that I had heard about it as well so this entire year of the owing plants that I'm aware of not through a complaints agency is this and that might potentially be because it's gearing up for harvest time I just wanted to clarify the record there Thanks David I did see that on the front page form this morning yeah so I think we're kind of getting great between the indoor cultivation and the retail and I know in some states it might happen here where somebody's cultivating at the same spot that they're retailing I'm not allowed to say that that's going to be something that's going to happen or not at this point in time but I want to try to focus on just the cultivation side Carrie at this time just so we can kind of keep track of what we're talking about and have that kind of logical flow into more of a retail space and those comments are extremely helpful for kind of featuring you know how you envision this and how the legislature is likely to envision this kind of market taking shape you know it's one of those things again where I'm going to sound like a broken record folks are going to have their own their own vested interest in making sure that these are secure so I don't know any thoughts Carrie I might be able to put a spin on this from a cost perspective for the board so when I talk about the buck I was talking about so access control limiting the number of people that have access that's obviously something that any grower or licensed owner can take care of with their own internal policies and that's not cost prohibitive at all where you are going to find you know higher costs are for the video surveillance and the alarm and notification systems right and then you know you kind of run the gamut on what that looks like there too so how much video surveillance do you need you're looking at that here's some of the factors are you going to regulate the visibility of the cannabis that's out there are you going to regulate the quality of the video I mean Oregon does that are you going to regulate how long you have to store footage Ohio does that for 30 days right are you going to regulate you know how much your fee needs to be monitored because you kind of run the gamut with different alarm systems as well so that's where you can kind of tinker with costs on the video surveillance and alarm and then you can you can maybe have more freedom to regulate the building access control system without worrying about maybe overburdening the small grower if that makes some sense that's super helpful and I think it will help spur some more conversation I know we focused a lot on fencing and the outdoor cultivation context but I think a fence and an indoor grower was inherently there of the building from a certain perspective anyway so understanding how deep we want to get into requiring specific alarm systems pixels from a camera perspective 24-7 monitoring does that 24-7 monitoring need to be remotely accessible by the board or law enforcement or just making things up but yeah it's fun I'd say philosophically you know I think good regulation is clear and good regulation is the minimal amount necessary to achieve the stated goals so I think that's an important one to consider where it's always better if you have the opportunity of regulation to be more specific and more broad of what you're allowing it's better to be more broad of what you're allowing you have the opportunity to decide to be more specific or more broad of what you're forbidding it's better to be more specific about what you're forbidding so that you're clear and also so that you're the least burdensome you need to be to achieve your goals so that doesn't mean zero regulation at all far from it but it means that when you're considering how much regulation or how many things to regulate that you try to be on the minimal edge of what is still effective so when Tom was enumerating all those various things that we could or couldn't be specifying I would strongly recommend that we stay on the lightest touch of that that we think achieves goals thanks a lot do we have any thoughts so my thoughts are just and I mentioned them last time keeping in mind sort of the downstream effect I agree with you know I can see this from all different sides but I think just not forgetting that when it comes to reporting theft or people wanting responses to those types of reports that we don't tie the hands of the folks who are left to respond or we give them we give them you know some useful tools to help with their job Ashley I want to be conscious of the public comment time as well but just one other sort of thread to pull on is that you are trying to normalize the use of cannabis we are trying to normalize the health effects and I just want to make sure that we are creating a really nice normal destigmatized shopping experience you know I don't want to go somewhere where I can't see the windows I don't want to go somewhere where there are not people in there I don't want to go somewhere where I have to go down this long road to access it I also know that Vermonters care so deeply about where and how and why it's being made they want to tour they want to look at the plants they want into all the different facets of how the plant is getting into the little charts and then they take home and consume so just before we really go down these rabbit holes I mean I do see Tom your points for sure you know there are I'm not interested in rewriting or reinventing appeal but I really we have to keep our lenses on of what it is like in Vermont and what we are trying to do of making this product accessible easily accessible for folks who are of age and can consume it safely that's it you know Kyle a lot of what I said with regard to outdoor grown where you've got a three week window where that crop has any value is not true for indoor the indoor however you set up your square foot you could potentially be harvesting every week or every two weeks and you will have that value product the product will have value at any given point of time in that facility I'm this one is more of a conundrum for me it needs to be protected but I don't know what level is appropriate thank you Terry go ahead Tom I just want to respond to what what Ashley said because it's important and that's another big issue out there I think everyone on the industry side of it wants to have this more memorialized experience and I appreciate what you said Ashley because that's probably exacerbated in Vermont where I can see where a lot of your farms and a lot of your retail you are set up so how things are processed how things are made because it's probably more national it's coming from Vermont but boy that's a real challenge in cannabis right now and just to give you a perspective from Arizona and California and out west where we're getting to be in Arizona it's somewhat more of a mature market now but even with my clients it's become more restrictive to do those tours in the beginning they would invite me as the attorney and I'd bring some folks from my law firm what I was trying to convince listen this isn't the devil's work this is a commodity like anything else look how much care they take and how much security is surrounding the product and I do those we do those tours pretty freely as more regulations came about it's harder to access that more limited access you have to put on all this PPE to even do the tours so that's going to be a real that's a real conflict from what you're saying and to normalize it and to get where you want to be with other products that's not where the industry is right now so it's going to be a little wild before you get there I think any final thoughts before we open it up anybody have a comment there is no comment what I would ask is thank you NACB for getting some words recommendations from a bullet point perspective on a piece of paper that we can move on from an outdoor cultivation perspective I will caveat that with we haven't discussed how farm gate sales might be impacted in separate and supplemental to those so I think we can hold off on that for right now just because I know we've got to think hard about how to do that there's less practical examples that we can go from I know there are some licenses in Canada and they've been debating out west on how to do farm gate sales but I want to make sure we take the time to think about that and the next meeting I'd like to get something on the screen so that we can all review kind of see where everybody is and then thinking and then if folks have time between now and Thursday to kind of dig into some of these indoor regulations think about it from a you know philosophical even perspective as Yvonne said how do we want these regulations to actually look from how specific we want to be with requiring certain types of certain systems and so on and so forth and I'd like to move in that space and then expand into the more retail focus and I know Wendy and I will be back with us on Thursday as deputy commissioner who might be able to share some perspectives on that too with that I think we can enter in a couple minutes early thank you everybody have a good rest of your Monday too