 All right, so we'll call the meeting to order at 12.01 p.m. In attendance, we have Kyle Harris and Nellie Marvel from the Cannabis Control Board, Billy Costa, Jigapolitor, and Stephanie Smith on the Sustainability Subcommittee with Tom Nalasko and Gina Cranweigel from NACP and technical expert John Wakefield also. And then, do we have any members of the public? We've got three members of the public. Three members of the public. Sweet. Okay. So first order of business, approve last Wednesday's meeting minutes. Stephanie, Billy, we had a chance to review and any feedback or changes? I guess I'll motion to approve the meeting minutes. I'll second. All right. All in favor of approving the meeting minutes. Say hi. Hi. Hi. Meeting minutes are approved. Okay. Next order of business, wanted to confirm the schedules. I realized that we had discussed the meeting times in a couple of meetings ago. I had tried to edit, change the calendars, realized that was only happening on my side. So I wanted to, now that it's like next week, confirm with both everyone on this call. For October 20th meeting, we'll be discussing social equity. It's just 12 to 1 p.m. still work for everyone. Looks like Billy's yes, Kyle's yes. Stephanie. Yes. Perfect. Okay. I will work with Nellie to get that updated. And then the other two meetings that are on this calendar would be the 25th and the 28th. So I think we should be good with that. Yeah, and I will just add that, and I think everybody here knows this, that the subcommittees are in all in a different stage of kind of wrapping up the first iteration of their work. And I see value in continuing this committee for the next three meetings or so, because I still think we have some outstanding stuff to accomplish ahead of November. So like for instance, the Compliance and Enforcement Subcommittee will be wrapping up on Monday. I know that the Market Structure Committee is already kind of adjourned for the time being so on and so forth. But just want to make sure this committee is all on the same page that this meeting and then three more, I think we should have a good baseline understanding of recommendations. And then Jacob will help kind of provide me with the overview of work of the subcommittee. I'll present that work to my fellow board members. And if everybody feels like we're moving in a good direction, we'll turn all of those recommendations into proposed rules. And then engage the subcommittee back at that point in time to make sure we've, you know, where our rulemaking has captured to the extent that we're able the vision of the subcommittee. Yes, and on that point I have in the bottom of the agenda. So I am creating a progress report probably in a slide style for Kyle on where we are with energy, water, waste, and then after today, air quality. So can you share that with the rest of the board? And I'll share that with you, Billy and Stephanie. So it's going to be an overview of everything that we agreed upon on outstanding gray areas, etc. And then in the last two meetings, not next week, but the following week, we'll be using those to kind of find, figure out like what are the remaining issues or issues we haven't agreed upon to provide Kyle with kind of background information, justifications for things or other things to kind of consider, that we, you know, would need more information on being kind of like with the waste on how the state's deciding to categorize that and things like that. And then my understanding, Kyle, correct me if I'm wrong, that we're going to yet provide you with kind of recommendations. But yeah, you are kind of like what you just said, going to be turning that into actual like regulation wording. Yeah. And again, like some of our work, you know, I think last week was a good example of that, the water conversation. A lot of that is already built out at ANR. It's just understanding how and where we slide in and identifying those gray areas like taking subsections of section, certain sections of the RIPs and figuring out where they slide in to ANR. And so we're not planning to start from scratch, but just do so where it's appropriate to do so and then make sure our rules or proposed rules are pointing people to the right portions of other state code. That sound good, Billy? Yeah, that's great. I appreciate that approach. And I think everything you and Jacob have just explained makes sense. My only request would be that to get kind of the directional documents as soon as possible. Because as you all know, we've got a lot of different programs who've been involved in this conversation. I just want to make sure everyone has a chance to kind of get eyes on something before it gets too far ahead. So yeah, sounds good. And just, you know, the more time we can have with it, the better, but understand you're running hard on a number of different levels. Yeah. And Billy, you know, I think, I think as we have questions, even with those recommendations as we build out proposed regulations, we'll be in contact with you, whether it's me, Bryn, or David, to make sure we've characterized things in a consistent manner with, you know, with how your experts at ANR are doing so. Super. Thank you. Stephanie, any questions on that? All right. Awesome. All right. So then we'll just jump right in. Thank you, Billy, for sending over the kind of draft final regulations. It looks like that comes from your department, Stephanie. So I'm sure you're familiar with that. And we've got John on the call as well. So I kind of just started to review what was written there and kind of what we're seeing from other states. So we can just get it started with the open burning. And so I saw that it was mentioned that if it's an agricultural product exempt, so I was wondering where things stand since cannabis is classified as a commercial product. So does that also mean it's banned under the APCR? I guess that's probably a question for you, John. Yeah. It's not under our regs. It's not necessarily commercial versus residential. There's really no commercial component to it. Really, you are allowed to burn brush, things from property maintenance. If it's a residential situation, if you're in a landscaping situation where you're collecting that type of brush from a place, we do require a permit from that. We had this situation a couple years ago with a grower who was trying to burn their stocks and the other waste from it. And what we found was that we can't, because there's alternate means of disposal of it composting, we can't under our regulations issue a permit for it. And it's not listed as a permissible burn. Our open burning regulations are more complicated than you'd think, and we are actually working on clarifying them. But really, that's the basis for it is that it's not something that we're allowed to permit for, because there are alternate means of disposal and the main one being composting that we look at. So question on that, because we do see oxygen here and there, when there is like disease, like a lot of powdery mildew or something that shouldn't be on that grow, that'll become endemic and also should not go into composting or the organic waste stream. So I'm wondering if there is exemptions for that, rather than having that all go to landfill. There are certain provisions that I think we might be able to apply to that. I might want to get back to you with a more official answer on that. Aside from, I think the question that would come up for me would be, is there an onsite composting capability where it's not going to a certain area to be composting and mixed with composting, as something that's going to be sold to the public as a nutrient or a growing agent, is there a place on the property where you can just pile it and let it decompose? And that's kind of what we, and if there is that opportunity, then it's not something that we can issue a permit to burn. But we do have provisions that allow for burning when it comes to plant disease and certain things like that. So unfortunately, I don't know that I can give you an exact answer without a specific situation. Stephanie, do you have anything to add? I feel like that's in your purview. No. I mean, actually, John, hi, John. It's nice to meet you. We've had multiple conversations about this relative to the hemp world. And we understand the rule as it applies to the hemp world. And likewise, if it's not a commercial composting operation, it seems reasonable. And if there's space on the site for it to be composted on site or disposed of on site, I guess it's maybe a more appropriate term there, where it doesn't impact the operation. Of course, you have to find that location. And then the air quality and climate division needs to make determinations about what's appropriate and an application of their rules. And just as John pointed out, and for any regulatory program, the facts of the situation matter. So we would defer to them. Okay. Perfect. Okay. So it seems like that is covered. So I guess, moving on to the public nuisance odor issue. So I was wondering with the AQCD, it mentions there that it's done on like a complaint basis, was wondering if that is only how the AQCD works. And then wondering like how we should view it with recommendations or requirements as far as like preventative issues. Sure. I think it is complaint driven. It's 100% complaint driven. It's that and unfortunately, something slightly subjective as an odor, where a case has to be built for a violation, that can really, really strain our resources. So yes, we are relying on hearing complaints from the public. And additionally, as it being a public nuisance, we don't have a definition of public nuisance, but it's any considerable number of people, which we've always, I try and keep the bar low and try and keep it at two distinct residential properties or it could be businesses as well in some certain situations, but at least two, because we do have a lot of, you know, and we do have a lot of situations where it is just one complaint and I can't apply that rule at all. I guess the follow up question is how does this interact with like local permitting? Like if I'm going to put in an indoor row and I get approval from the city, you know, they know that there is going to be some odor and they've approved it and then I get all of these complaints. You know, is there an intersectionality between that of, well, the city is permitted to like, you know, some does or does your department just kind of take the view that if there's all of these complaints, like you're going to have the shutdown operations if you can't remediate it properly? You know, the local permit really doesn't play a part. I mean, I, you know, a couple years ago, I was in discussions with regional states about the cannabis industry where, you know, Massachusetts was, you know, a little bit ahead over the other states because of where they were. And, you know, they didn't, they tried to advise me that the best thing that I could do would be to get the word out to the local municipalities and make sure their understanding of what, you know, what the side effects could be of allowing these businesses in certain areas. You know, I haven't been able to unfortunately put, you know, put much time into that kind of effort. But really when it comes down to it, you know, whether it's approved locally on the municipal level really wouldn't play a factor for us. You know, and in general, if the equipment's not big enough, they're not going to have a permit from us, any of the drying equipment or extraction type equipment, which generally we haven't seen move into Vermont yet. So we would, we would investigate under our regulations. And at that point, we don't, you know, we don't necessarily shut anyone down immediately. You know, if there are steps that can be taken, as far as, you know, additional, if we're talking about an indoor grow, if we're talking about, you know, additional controls that haven't been explored yet, you know, we would, we would require them to look into that, you know, as timely as they could. I can breathe asking though, I think, you know, it's certainly possible that municipalities would have their own ordinances related to odor that could apply to these facilities that they could enforce independent of the state air quality regulations. Yeah. And on that, I know that 164 does give special attention to municipalities as it relates to odor. So I think, you know, one of the ways that we could handle that, and we're discussing kind of internally is once, and as we start to build an application for a prospective license holder, there's going to be a certain number of things that, you know, if you're going to have to go to your town and make sure that you've checked a lot of boxes at the local level, so that you don't come to us before you go to your local level, and then there's this back and forth and so on and so forth. So recognizing that they're given that kind of zoning capability in 164, it's something that we're hopeful, but will we go into the application so that Docks are in a row before a license application is submitted to the cannabis control board? Gotcha. Yeah. And I guess I probably should ask this question. So it sounds like, John, the AQCD is going to require some kind of odor mitigation. You know, I don't think we have the authority to require it until after we've proven there's a violation. We'd love to see it on there. You know, I would love to see anything you could, the local regulations allow for them to do before we need to get involved. You know, that'd be fantastic, because again, you know, an odor case for us is many, many site visits, many corroborations of the odor so that we can be witnesses should it, you know, should it actually progress that far. And like I said, just an absolute strain on the limited resources I have on my staff. So anything we can do on the front end to prevent it from happening. But again, our authority is slightly limited in that area until it's proven that there's been a violation. Okay. John, I will go through. I know I attended a bunch of meetings about it a few years ago. So Colorado implemented, I'm going to be in Colorado, Denver implemented like an odor ordinance and kind of the way they did. I know what I'd do with like smelling of it, like those machines, but it was if you essentially adequately sized odor remediation equipment, you were somewhat kind of exempt from these complaints. And they kind of, I think we're assessing kind of what that meant. So I can see if there are, yeah, information on X, I know like carbon filtration on the exhaust air stream is kind of the most common. And it looks like it does run 50 to 98% of it. I know there's also like fog machines and other technology. So I can try to get that information on what we're seeing is like effective odor remediation equipment that potentially we can offer guidance to application or licensees. I guess my other question I had kind of on there is, yeah, does your department have kind of approved remediation controls from other industries? Yes. I mean, there are, I mean, it's more technologies than individual suppliers or manufacturers. Yes. But it really depends on what the pollutant is. If it's, I'm sorry, VOCs. Yes. Yes. So in general, like burning off of the VOCs before they're admitted that that's a control technology. And yes, I mean, we can certainly advise people on the best control technology. And we have, I don't know if we have an official list. And if we do have an official list, it's certainly unfortunately not specific to hemp and marijuana cultivation. But we can certainly offer guidance. Gotcha. Yeah. And I guess like a follow up is like is your department kind of ready for an additional 200 to 300, you know, people asking questions? You know, we'll do our best. We are a little bit behind it. And forgive me, I am a little bit behind. I was under the impression this meeting was next week. And so I did get a chance to skim through that Colorado material. But I haven't done and we haven't done a lot of research on this yet. We knew we knew it was coming. And we've tried to think about it and be proactive. But it's it's been difficult to be honest. Yeah. No, no worries on like reviewing that material. And I'll actually put you in touch with Caitlin Urso. So she's in the Colorado Department of Public Health and Environment and their air quality control division. She's been doing this, I guess now for like six years. And her job does advising consulting for other regulators. So she can be able to kind of easily give you the download on it. I was hoping to get her at the meeting, which was unavailable. But she was saying essentially most states have everything already in place and stuff. So I can do that to help give you a like up on this. So yeah, no worries. That would be fantastic. One thing I would like to mention on nuisance odor is that, you know, you know, we did run into a situation that was a process situation. And in that situation, it was it was apparent they didn't have controls at all. And it was apparent everywhere in the neighborhood. And the amount of complaints were so numerous that, you know, it was easier for us to prove. But one thing that is slowly creeping up that I'm concerned about is the actual crops and the growing of crops and the harvesting season and those odors affecting nearby neighbors. We have an active situation right now that we're in the middle of. And, you know, to be honest, I, you know, I know what ag stance is on it. And, you know, and like I said, the bar is high for a public nuisance for us, but it can tax our resources. And I just want to make sure that the board is aware of that situation as well, because there really are no controls for that. So it's that's when we get to a point where it's, it's, I think, going to be a little bit more difficult to find a solution. I will make an introduction to you with Bayer Scientific. I work with them in a couple of my sustainability working groups. And I know they do have technology out there for outdoor cultivation odor mitigation. What that is, I don't even know if it, you know, works or but yeah. Let me just jump in here though. I don't even know if our regs would apply to cultivation. Do you have a sense of they would, John? I have not known any situation that our nuisance odor regulation does not apply to. I don't know of any exceptions. You know, one thing to think about when in terms of cultivation is I'm trying to prove as a violation. I'm trying to prove it as a public nuisance. Now, our public nuisance is not, we've not presented it as a violation that's gone in front of the courts many times. So I'm not sure how the courts feel about it. And to me personally, you know, when it comes to something like manure spreading, it's seasonal, it's limited in nature, you know, and this can also be, you know, is I'm getting varying reports from neighbors on how long the odor is actually lasting during the growing season. And I think that depends on how adamant they are about the situation. But, you know, I think it's actually personally a fairly high bar for me to prove that something that's occurring in a month to a month and a half, you know, timeframe is really a public nuisance when the rest of the year it is not impacting the neighboring properties. So that's something to consider. And again, we unfortunately don't have a lot of experience in front of the courts with something as limited as that, you know, in a public nuisance situation. So perhaps, you know, perhaps it's an area that we would not tread, but we're still figuring that out at this point. And I will say on that point for like the seasonality of it, I think for like greenhouses out or like full season, it'll just be at one specific time. They're doing kind of like a light depth system or greenhouses, maybe three times a year. But if they're doing kind of a perpetual harvest indoor, they could potentially be harvesting flower every week. And so that way it would be a year around potential. Sure. Sure. But that indoor situation, I think provides a situation easier for controls to be added to the, you know, to be able to mitigate it. So. Absolutely. And so I just wanted to confirm, Billy, when you were saying, since this is our closure, that it would be exempt. Was that what you were? No, no, I just, I was getting confused with our various air quality regulations, some of which are focused on like stationary emitters of different, of actual air, regular air emissions. I was forgetting this is just a nuisance odor provision, which is different from those things, which is more broadly applicable. So that's my own confusion. Yep. And now that's what I think about. So we're going to be talking about right now, because we're going into the air pollution control permit to construct. And so just a thousand figures, like they talked to Caitlin, they're coming out with an actual study in the next month or two, where they went in and actually measured the VOCs within gross. And she was saying that their average is about five pounds of VOCs per ton of harvested cannabis. And that's total plant mass. And that I think the range was like two to 11. But that is well below, she's saying five to 10 times below what like any kind of federal air quality would come into play. So she was saying that it's not really a concern. For mitigating like the VOCs from cultivation. That sound great, John? No, not exactly. Because we do have a state operating permits and state construction permits where on the federal level, we're a major source for a federal level is 100 tons a year of annual pollutants or over 50 tons of VOCs. Our state permitting, our operating permit is down to 10 tons a year. And I'm sorry, I can't do that math per bushel per pound to determine where I'd love to see her study to see how our rules would apply to what she's seeing as actual emissions. But in a construction permit down to five tons. Okay, that's good to know. I remember she was saying it was a lot. It's like 50, at least 50,000 square feet, if not more to get to that point. But I just made a note that it's 10 to yeah, confirm that 10 tons for a state operating permit from us. Okay. And then for so it looks like in the document that we had, it's you estimate about 1500 gallons of ethanol solvent lost or emitted per year for requiring a permit? Yes. And forgive me that came from my permitting expert. So if there's any unanswered questions here that I can't handle, Doug would be able to use out of the office today so he couldn't join me. But I can get them back to you. I can get two answers in the permitting realm if I'm unclear on it immediately tomorrow morning. But yes, I think that's the that's what they calculated the the VOC trigger to be for our permitting threshold. Gotcha. Is there anything else in there or that you your department is concerned about? Or you think that I guess with permitting control would also need to apply for I guess any other like manufacturing besides kind of this 1500 gallons we're thinking about. So it's like the emissions bar, but is there other specific requirements that would apply for either cultivation or manufacturing? Not that I know of unless they bring in, you know, either larger scale boilers or engines as I mean, and, you know, we didn't see and perhaps, you know, and maybe hopefully Vermont will get there, but we didn't see facilities on the rise that quickly that would get to that size that would be requiring that equipment that would, you know, would require a permit solely for that equipment. If that makes sense. That doesn't make sense. Yeah. And so I did a review of some general, I guess, like requirements or regulations that we're seeing in other states that have required use of like closed loop extraction for, except for alcohol-based systems. I'm not quite sure why that's an exception there. The prohibit disposal of solvents by evaporation or spillage and then having essentially an improved solvent list. Are those covered in current Vermont kind of regs with other industries or things that we should consider adding to the CCB regulations? That might be one that I might want to confer with Doug Elliott, our permitting chief on. Okay. Yeah, sounds good. And I have what those Colorado regs are, so I can send those to you so you can look at how they're actually written. Yeah. Yeah. I think, Jacob, if you can kind of queue up any of these questions that remain after today for John and I, then that will make it easy for us to follow up on that stuff for you. Perfect. And then, Jacob, I just have a comment regarding approved solvents for the purposes of botanical extraction. Within the HEMP program, we do have a list of approved, well, generally a list of approved technology, which includes solvents in our role. And then as if somebody wanted to use a different solvent or technology, we ask that they get approval and writing from the agency so that we have a record of what we're approving and what we're allowing. But it's not related to air quality, it's just related to health and safety primarily. And then I want to say that the health department rules might have something, but I'm not, or Title 18 might have something relative to extraction. But again, it's a public health and safety rather than a air quality kind of issue. And I mean, to clarify, if we had a, if it was a closed loop system and it's not admitted to the atmosphere, you know, we actually don't have any jurisdiction over it. So, you know, and I think it would really depend on the solvent, the specific solvent being used. The reason I think that that was added to the fact sheet that we worked on with Ag was that we had, we did a little bit of exploration about after hearing something that someone was using an HFC, I think 134A, in a closed loop system as an extraction method. And that was obviously, that was that was news news to us. And we didn't know when we started to look into our HFC rule, which is reasonably new, which was copied from basically copied from a federal rule. And it was a little bit questionable as to how that rule would apply and whether the purpose would exempt that. And after some analysis and some talking to some of our federal counterparts, we determined that it's fine to use that HFC and an extraction method like that. So that's why that was on the, I think that's what spurred the bottom discussion on our, on the fact sheet that we handed you. Gotcha. Yeah. And so I had a question on that. And so it sounds like you had a case where they were actually using it for extractive purposes. Because I was like looking at kind of, yeah, the hydrochloric carbon stuff, and it seemed like commonly it's used to like clean equipment and stuff. And so I just had a question on, are there restrictions currently on the use of the equipment that they use HFCs right now? Yes. I can forward your HFC rule. It definitely lists all the exemptions and the specific HFCs that are regulated by it. If that helps. And again, we weren't, I think that was just a proposed extraction system. And I don't know that we ever actually officially talked to that person. But when it was mentioned, we started to do some research into it. And I found online, I found the actual extraction equipment that does use that. So we just kind of looked at that and compared it to our rule. But we found that in the end, we found our rule doesn't wouldn't apply to it because of the way it's used there. Gotcha. That makes sense. And then, yeah, I think what we get just to get at that, what that regulation is, so we can just pass it along to the CCB, so we can get noted. My understanding also is that even if it's a closed-loop system, there are still going to be emissions of sorts, specifically, like even when it's closed-loop, when they open it up to get it, it does off gas. And then I do believe with the way OSHA and fire code, etc., with the amount of gas exchanges for employee health, that's like directed straight into the atmosphere. But most of the time when it's closed-loop system, I think it's very low, you know, via the emissions. So it'll be definitely under the 10 ton environment. We actually found in that advertising for that extraction equipment that they were, let's just say, vague on it being closed-loop or what was actually admitted. And it contradicted itself in a couple places. But so that's something we only look through. But I definitely think it's probably like how it's used, operations, SOP's treating, you know, all of that. So, um, perfect. Then kind of on a higher level, which I'd love to get your perspective is Billy and Stephanie. You know, there was a report that came out from Haley Summer. So I had a chance to like review it with the greenhouse gas emissions. And wondering where Vermont stands currently on their goals if we should be requiring, encouraging kind of carbon reductions or offsets when looking at this new industry, since there is like an opportunity to kind of set a basis, you know, as this industry is rolling out. And wondering if, yeah, we're kind of Vermont stands right now, I guess, with their climate change goals versus like, I guess, like the compliance burden of doing this. Billy's going to have more than me on this. Sorry, I was just trying to be here for a second. It's a good question. The state is actively developing its first climate action plan right now. That plan is due on December 1st. We, the state passed what's known as the Global Warming Solutions Act last year that set into statute certain emissions reduction targets for 2025, 2030 and 2050. Those are applied kind of proportionally across sectors. So there is a reduction target for kind of the manufacturing and commercial sector. I think those are gross reductions. So I don't know that kind of an offset or carbon credit approach would be one that would help the industry achieve or contribute to that emissions reduction targets set forth in the act. But that's certainly something that I can follow up with folks on a little bit more. You know, my sense is that, you know, just encouraging efficiency best practices, really trying to get people the right information and resources to do the right thing to the extent factible, you know, from the offset is probably the best approach and then let the work of the climate council and others help direct more specific, you know, actions around emissions reduction. So that's my kind of initial reaction, but I am happy to. I have it on time too, but I will check in with the folks on that task group of the climate council to see if they have any additional guidance. Okay. So it seems like in line with what the PSD recommended for like, you know, kind of the high bar on equipment efficiencies for age by et cetera, could be applied to maybe like requiring like a closed loop system for manufacturing. So they were reducing as much emissions as possible. And if there's, you know, I think if there's certain technologies that have very high greenhouse gas emitters associated with them, where there's alternates that are less emitting, you know, I think either requiring or encouraging those alternates may be a way to go, you know, there may be ways to process and extract that have, you know, just really outsize greenhouse gas emission numbers versus others. And, you know, it may make sense to strongly discourage or, you know, prevent the use of those if it still allows for reasonable alternatives. I just don't know well enough whether those are part of the process or not. Gotcha. I have a question on kind of I guess how Vermont is looking at greenhouse gas emissions and responsibility. Is it a kind of cradle to gate approach like our producers somewhat responsible like moving towards it for the like generation of energy that they're using? Or is it just in the manufacturing process? So currently we look at electric like electric as a separate sector from manufacturing and commercial. So if you're a manufacturer or a commercial enterprise, you're not responsible for the emissions associated with the power that you're purchasing from your electric utility. The distributed electric utilities are the ones that are on the hook to reduce the emissions associated with the electric power that is being used in the state. So there's a separation there. You're as a commercial or a manufacturing entity just responsible for your direct emissions. And that includes then transportation as well? Yes. Well, yes and no, because there's separate targets for the transportation sector. And I don't know how that would be managed, whether, I don't know. I don't know the answer to that. I don't know if they're taking into consideration kind of trucking their deliveries associated with a business as something that they're responsible for. Gotcha. Our emissions in return right now is very coarse and doesn't really make some kind of generalizations about these different sectors. And part of what the climate council is doing is issuing an RFI then eventually an RFP for a consultant to help the state kind of rejigger the emissions inventory to be more detailed and granular to help us track these sorts of data so that we can have more nuanced and specific actions to address those emissions. We're just not there yet. We're doing a much more coarse thing right now. Those scope three indirect greenhouse gas emissions can be very, very hard to quantify. That's for sure. But yeah, Billy, this is great and super important. I want to make sure what we're doing here is in line with what the climate action plan is really looking to achieve and intend and offset programs, carbon trading. There's good programs and bad programs around the country. I think if you look at it and I don't want to wander into those waters if it's something that the state hasn't done before necessarily. Jacob and I had kind of had a conversation about it and just wanted to see how the state felt generally. I don't want to say hard and fast that that's not a good option here. It's just my sense that it might not help the sector meet the gross emissions reduction targets that forth of the act. But let me take that question back to the folks who actually have expertise on the council and have them reach out directly to you all for that conversation because it may be an opportunity. Other state programs that run certain carbon offset trading programs like I always think to a California's low carbon fuel standard and stuff. The devil's always in the details and how that money that's being collected as kind of like a pay to play is used, represented and so on and so forth because if it's just like a slush fund, it can be open to legal challenges as well. Right. And I think that sort of offset program is what Vermont is considering more like sector-wide low carbon fuel standard transportation type program that's modeled on the Reggie kind of regional greenhouse gas emissions program. So more kind of sector-wide efforts where you as an individual business aren't making those sorts of investments or allocations of credit. You're just part of a broader system that kind of directs how you do your thing. That makes sense. Yeah, if you wouldn't mind just seeing where A&R stands generally speaking, that might be helpful for sure. Yeah, I will certainly do that. Perfect, yeah. And I didn't have a chance to, so I was just going through the back end of that research. Everybody looks like the range of CO2 equivalent emissions is around 2,500 to 3,500 kilograms per kilogram of dried flower. So I can do the calculations of what we're expecting from the sale of dried flower in Vermont and see kind of like where that on a macro level looks like in relation to other industries in Vermont. One follow-up question I had was, is there a lot of, I guess, geographic diversity of electricity production in Vermont? So if you're in one area, is this more from like coal-fired power plants versus natural gas, or is it all pretty universal? It's based on the contracts that the retail distribution utilities have with generators. So the way it works in Vermont is that there's three or four large distribution retail utilities. Then there's a number of smaller kind of local regional utilities. I think there's about a dozen or so in total, maybe more, but there's kind of four big ones that represent the vast majority of the state. And those individual distribution retail utilities either manage or have contracts with generators in Vermont, or with generators outside of Vermont within our iso-region, iso-regional region, including power that comes in from Hydro-Quebac in Canada. So there's diversity amongst the utilities of how they procure their power. It's not necessarily tied to geography. It's just kind of how each utility does their thing in their most cost-effective manner. The real small municipal utilities often have existing hydro facilities or other assets that they've managed for a century or so that is producing a lot of their power. We do have a renewable portfolio standard for electricity in Vermont, so all those utilities have a statutory framework through which they need to reduce the emissions associated with the electric supply on an incremental basis going forward. That's how kind of electric side emissions are being handled. We already have a fairly low emission profile nationally and for the region, so the electric sector is in relatively good shape and there's good controls in place to clean them up even further. There's a handful of utilities that are already 100% renewable, Burlington Electric being one of them. Okay. No, that sounds good. I bring this up because I was looking at the research paper and other things coming out of different states. It looks like from a greenhouse gas perspective, greenhouses kind of reduce your overall CO2 emissions by 42%, outdoor by 96%, but that's really contingent on the source. Looking at it was like looking at a bunch of different areas like in Colorado when they bury 19% you ever take. They're looking at from a policy perspective doesn't make sense to try to encourage outdoor greenhouses in an area where it's sourcing from like a more of a dirty energy generation and not. I don't have an affirmative, but there's certainly data of all the different distribution utilities and what their current emissions are from their existing contracts. I think they're all within a fairly tight enough spectrum that there's no outliers or really dirty power geographically in Vermont that we need to be concerned with. I can understand in the West how you would see really drastic differences of where they're getting the bulk of their power. I don't think that's the case in Vermont, so I don't know that level of work would be necessary. We have one utility, Green Mountain Power that I think covers about 80% of the state. They're the vast majority of the power supply and they're very aggressive and they're kind of emissions reduction goals already and then you would be having to deal with a number of smaller utilities and the cost benefit there I just don't think is there. No, perfect. Stefan, do you have anything to add and also realize any put on here really like pesticide fertilizer emissions? I'm wondering if there is any gaps within the current regulations of your department that we should be thinking about. I can't think of any, but I can certainly ask that question. Yeah, I will ask the powers that be. Sounds good. Yeah, my understanding is like it's not going to be too much of a concern. I mean it also kind of depends on and we'll probably talk about this in a later meeting, but do we want to make recommendations on material use in the cannabis sector as far as soil fertility and pesticides and moving towards organic, requiring organic, that kind of thing? I don't know. I think that's up to the Cannabis Control Board specifically and obviously there needs to be third-party certification that's willing to certify cannabis organic and I know that there are, like I don't think there's a gap there. We do have guidance generally with respect to use of pesticides on cannabis just due to safety, public health, and I can share that list with you. And then relative to inputs, I don't believe we have a recommended list for cannabis specifically. So, yeah. Oh, perfect, yeah. John, I think there was a follow-up question I was looking at. Oh, with how you guys do the error permitting, it is like standard I guess would be like estimate of the annual error emissions by like a mass balance calculation. Is that correct? As far as the initial permitting or on an annual basis? I would say the initial permitting. So, when we're getting these licensees that are doing the application that I talk to your department when you require, I mean, we did talk about it at the beginning or I guess like before the meeting in that, you do have the capacity for guidance and to help do the calculations. So, I want to ensure that the calculations that you guys are doing is mostly like a mass balance kind of system or is it you guys are trying to test the hazardous waste content? I would think it might be on that, and that's what I really, because I'd like to get you a better answer that I can provide, but I can email you, like I said, I just need to talk to my permitting chief about that. I'm not sure how his engineers, I mean, oftentimes we're using established emission factors from the EPA, and which I doubt there are many for this industry yet. But, let me look into that one and I'll get back to you. I apologize. No, no, no, that's fine. This was more of just, we had a couple of minutes and, you know, whatever we can make recommendations to the CCB that helps you, you know, we're more than happy to do. I have been told that most of the states kind of oversee compliance of this issue, similar to like, auto body shops, and that's kind of what they're seeing on that level of indoor emissions of solvents is very similar to auto body paint shops. So that helps you at all. Yeah, I mean, usually that is, I think, a mass balance for us, you know, when we're looking at that type of situation, but let me confirm that and I'll get you a more detailed answer. All right, sounds good. And then we already talked about the progress report, the thing I'm going to try to get to everyone on Monday. Do we have any public commenting, Kyle? Not today. Okay. That sounds good. We'll have a few more minutes. I don't know, Billy, Stephanie, any thoughts on anything we've done so far to date or anything else? So I guess we can With this meeting went very fast and lots and lots of information, but did we talk about drying and using propane dryers and how that might come into play? No, we did not. Well, again, I mean, for in our shop, it's the size of the fuel burning equipment and how much fuel is used to do that drying. And I don't know that bar off the top of my head. But I think our permitting folks are under the impression that like I said earlier that that's going to be a significant amount of equipment. And we're not, you know, maybe Vermont will get to that stage, but we weren't expecting it with initial, you know, initial licensees. But we could be wrong on that. So, but yes, there would be implications to permitting in our world, depending on how big the equipment is that's used for that. Gotcha. And is that level for propane done on a propane used or a BTU level? I guess so the size of the equipment or how much it would be both. You know, if they were looking to stay under a permitting size, you know, or permitting threshold rather, you know, we would, we would, we would set a cap on the field that they could use to keep them under that, you know, under that permitting threshold. Gotcha. Okay. Yeah. And I was reviewing some regulatory guidance, kind of like on a macro level. And there's a lot of kind of notes that getting a state air quality permit process takes a lot longer than the standard kind of cannabis application permitting process. I was wondering what your thoughts are on that because they're saying encouraging potential cultivators and manufacturers to start the air permitting process early is very useful so that they don't get awarded an application in a specific area that then requires extensive, you know, remediation or would not be, you know, the best place kind of thing. Well, I mean, we don't, we don't necessarily, we don't have any non attainment areas in the United States. I mean, I'm sorry, in Vermont that would affect it on that level. You know, we don't, we, we aren't really involved in the siting of the facilities, you know, and that's, you know, that comes up often with hot mix asphalt plants for us, where there are orders involved and it's an industry that's can be controversial. You know, I wish we could have more say in where they're cited because oftentimes, you know, we have state bodies or local bodies that'll push something in because they think it'll help, you know, grow the municipality without a thought of those, you know, actual impacts on the surrounding area. So I would love to have more of a say because then often it, you know, everybody points to us when the problem, you know, actually arises. But we wouldn't have much of a say in that, in that instance. Can I ask one more question, Jacob? Absolutely. I was actually just chatting with someone like the climate council, who's working on these issues to kind of line up someone to respond to your questions. And just to be specific, the greenhouse gas emissions associated with the sector are primarily from drying and potentially transportation, or are there other kind of main greenhouse gas emitting elements of production? So what I've been able to glean, so for cultivation, the greenhouse gas emissions is from like equipment use and process. So it's actually from what they were saying in this report, like 80% of the greenhouse gas emissions from cannabis cultivation is from like non-traditional ag practices. So it's more like the indoor side. Whereas most of the greenhouse gases from agriculture come from land management, field prep, and then fertilization. And the sourcing of that, this is kind of the opposite. So it's mostly from like the electricity being used to run the lights. Is there anything that's non-electric or non-transportation that is a significant source that you can think of? So terpene production, the plant itself actually produces VOCs, but that is apparently below issues. That's kind of like the five kilograms threshold, something like that. And I think that's an annual thing. But I'll have to go through and clarify that. But yes, the plant itself actually off gases VOCs. And then in the manufacturing side of things, it's the solvents, mainly, that are a big contributor, a potential contributor for it. That's helpful. Yeah. And as I said earlier, I think the transportation electrical pieces will probably be dealt with kind of sectorally and won't have applications on specific enterprises, but the manufacturing piece may. So I'll try to get some follow-up on that for you. Oh, and also it's like, I think it's a minor impact, but we also on-site generators could be a significant source. I don't think it's necessarily significant source, but depending on how they were used, most of the time it's for emergency power, but sometimes also like supplemental power. I know like there's a lot of kind of outdoor grows that are either run on solar or have a very low kind of like lighting, water pump process, but then when they're harvesting, they might need generators to power kind of the drying equipment, like humidity control all of that. And so it's like a really usually small timeframe. Is it fair to say that many of the activities involved in cannabis cultivation, either in a greenhouse or otherwise or in a field, as you mentioned, are similar to existing industry? I mean, I know scale can be a little different, but like we have indoor, you know, wood-fired boilers that heat greenhouses in Vermont currently for production of food. We have, you know, I just like it's similar to some extent, but it is a new industry that we don't have, so it's an add-on, but similar, right? Yes. I believe so, from like a greenhouse outdoor, yeah, there's nothing new. That's not all right. I mean, even botanical extraction. I mean, we do have some, we have hemp, obviously, but I'm sure there are other botanical extraction operations in the state of Vermont that are, you know, doing other sources of botanical. Yeah. Yeah. I don't think there's anything new, you know, and I would imagine for the most part, without, you know, a limitation on just the capital cost, you know, you'd want the most efficient system because, you know, you're saving resources, and this is also, you know, a very pretty valuable product once it gets to that point. So recapturing in and having, you know, is, there's already that built in, I think, you know, business case for it. I think really the newest thing would be like larger scale indoor cultivation, you know, could be on par with like data centers, you know, big point mining, that kind of thing. So I don't know if that's a big, you know, industry in Vermont, but you know, be comparable to that. And then I said another question I guess for John is, is there issues with ozone, ground level ozone in Vermont right now, I guess currently, and looking at like really required mitigation of that? Yet again, you're a little bit outside, as from compliance and enforcement, you know, it's generally not a place because it's not from a specific source. It's not a place I'm deeply involved in. But yet again, when I'm, I mean, I can certainly find that out for you quickly and add it to the list of answers. Oh yeah. It just, it's a big deal here in Denver. I mean, we have the most red days, I think we've ever had kind of this year. And so there's just been a lot of news about, you know, mitigating it when I saw that like the VOCs with, I guess, the introduction of sunlight, the UV rays turned into ground level ozone. Just wondering if that, you know, if Vermont is a state was like, you know, really looking at that from like the, I guess, national air pollution like laws or whatever. Off the cuff, I don't think it's as large of a problem in Vermont. I don't think we're eyeing up anything to better control. But again, I'd like to confer with a couple other people outside of the permitting folks actually on that one that would have a better idea. Oh, perfect. Kyle, anything to add or we get to adjourn? I think we're good to adjourn. John, thank you so much for joining us today. And you're undertaking of helping get us some outstanding questions answered. And thank you, Billy. And you, Stephanie. Yeah, it was my pleasure. In fact, you know, obviously this spurred a lot of thoughts in my brain on being a little bit underprepared for this coming. So I appreciate the opportunity to think a little bit outside the box of where we were thinking and kind of look at how it's being handled nationally and make some comparisons there. So I do appreciate it. It's going to spur some work from us and that I think is a little overdue. So I appreciate it. You're not too far behind, John. We're all figuring this out day by day. And I'm the reason he's underprepared because I thought I told him we were doing this next week. So yeah, I'll take it. Yeah. So responsibility for that as well, especially sending you all this 30 minutes point this meeting. So I think we did great for, you know, what we have to do. Awesome. Well, I will at the meeting in June. Thank you guys. And we'll have a meeting on Monday. Oh, no, I have a meeting on Wednesday next week, Wednesday. Yeah. And I will get that calendar. Oh, perfect. Awesome. Thank you so much, Nellie. Amazing. Thank you guys. All right, have a good rest.