 I see a quorum. So I'm going to, my name is James Pepper, I'm the chair of the Cannabis Control Board. Today is September 29th. It's 2.03 p.m. This is a meeting of the Cannabis Control Board Advisory Committee and I'm calling it to order. We have a lot to cover today and so I'm going to just ask for the advisory committee members to, if you've had a chance to review the minutes from our meeting on August 18th, 2021 if I could have a motion to approve those minutes. Motion to approve. It's Chris Walsh. And is there a second? Second. Okay. All in favor. Any discussion? Sorry. All in favor. Okay. Well, with that, I really appreciate all the work you've been doing. I just can't believe the amount of time you all have volunteered given to us, given to the board. The conversation, I think, is moving in a very positive direction. I announced at our last Cannabis Board meeting that our October 1st report is likely about two weeks, I think, behind schedule. That doesn't really take the pressure off you all that much. I think the more we can get through today, the better. So I'm just going to turn things over to Gina to pick up with the agenda under kind of social equity in the criteria there. Okay. Thank you. Is it possible to just share the agenda? I sort of had sort of what we had gone over for a social equity that wasn't in there, which was the potential of creating a DEI program too. I don't know if you want me to review that as well. Sure. Please. Yeah, we have, yeah, I think we have your presentation, which can include all of that going until about 2.30. Okay. Great. Thanks. Is it possible to share the slides, or do you want me to just verbally tell everybody? Nellie will give you kind of co-host permission. Great. Thank you. I always think it's helpful when people can follow along with something visual. Sorry, Teams is disagreeing with me. I know how it happens. Well, I'm just going to start out with, I'm sort of explaining the responsibility of the social equity committee was to determine what a social equity candidate was going to be. And I know that there was potential legislation out there to help women along with people with disabilities. And so from a social equity perspective for people who have been impacted by the cannabis prohibition, we needed to show that. For example, people minorities, those social economic communities. So the committee has made a decision with the board's approval to make both a social equity program and a DEI program. So diversity, equity, and exclusion program. And that DEI would have to be on the scrutiny test of was a personal applicant historically underrepresented in society, which would bring in the woman aspect and people with disability as well. Which then after deciding, okay, we're first going to focus on social equity, we were able to come up with what a social equity candidate is, what are the qualifications for that program. So social equity applicant needed to meet at least one of the three criterias. The first one being living in an opportunity zone, which is low social economic communities. There are 25 in the state of Vermont, which has been determined previously along with the IRS of those most in need. This also carries a high rate of BIPOC community as well. This second was being a member of BIPOC minority race. After reading quite a lot of reports about pullover rates on the side of the roads and also incarceration rates for the people who for cannabis, we've made a determination that there was enough proof to show that they were highly impacted on the war on cannabis in Vermont. And then the third is if you were convicted of a cannabis related offense. So have you personally been arrested, convicted or incarcerated for a cannabis offense and or a family member who was impacted by someone being incarcerated, arrested, convicted of a cannabis offense. We've also made a determination that no previous residential city in Vermont was required, but you must currently live in the state. Now the residents, there's no residency requirements. Previous residents see requirements was made due to some new litigation that was popping up in different areas due to residency requirements towards their social equity program. There were some states that were debating what this interfered with interstate commerce. So in response to that, the subcommittee is making a recommendation that no previous residency is required. We then went on to what impacted family was. That's as we said, as a qualifying candidate, you needed if you had a family member that was convicted or arrested of cannabis conviction, the family members include a parent, a legal guardian, a sibling, a spouse, a child, a minority in one's guardianship, a grandparent or grand child. And then we've also spoken about supporting documents for social equity candidates. So proof of conviction, what did you have, do you have a document showing the court dates? Do you have a document, probation documents? Also what is the proof of residency? Silvermont driver's license, registration cards, recent tax bills, bank statements, notarized affidavit, school district requirements, utility bills, all of these to prove that you are currently residing in the state of Vermont. We've also discussed that anyone who applies for a social equity licensee business and receives an application, then it has to be at least 51% owned by one or more social equity candidates. Social equity candidates must be involved with the daily operations and must be able to make decisions regarding the business. So we actually want the person participating in the business. This was put into prevent people who start up businesses and other people's names in order to receive those benefits. And also any social equity candidate must meet state requirements to open a business. So it is not just the social equity, it's not the social equity job to say that they can open a business or not. They still have to comply with state statutes and any statutes that the Vermont cannabis control board may make on having and being a licensee holder for the state of Vermont. And so those are the permanent decisions that we have made so far. We're currently up for vote on Thursday. We'll be starting the benefits that social equity candidates would receive first in regards to applications and licensing fees. Right now I'm not sure Pepper would you like me to go into that or shall we stop here since a full decision hasn't been made about that. Pepper and Pepper? Yeah I think so. At this point it's good to get everything out there and then let the full advisory committee ask questions and kind of bring their concerns and input forward. So yes. Okay great. So one of our recommendation with that application fees should be waived and then the licensing fee for the first year should be waived and then there's a tier system which is in the second third and fourth year there be at different fees increasing by 25% each year. So the first year you would have it waived the second year would be a 25% of whatever the licensee fee is. The third year 50% fourth year is 75% and the fifth year would be free full price so that we feel that within five years a social equity licensee should be able to pay full price and be fully sustainable on their own. There is a caveat which is if you are not able to afford the licensing fee in the first or second year you are able to apply for a waiver so that will give you either a reduced or full waiver of the fee for that year but you also have to come with a business plan of how you are remedying the situation so we want to make sure that you're fully aware of it and how it's going to be changed not that there's just a financial need so both financial need and plans to remedy the situation must be given with that application and then up and coming discussions that we will have is a reduction program benefits for social equity applicants licensing special licensing fees and special licensee for them which is co-ops will be discussing delivery possible delivery licenses also transfer of ownership of social equity licensees for their businesses cannabis social equity board application approval expungement automatic expungement with social justice re-investment into disproportionately impacted areas and then finally coming back to diversity equity and inclusion program and having protocol of who would be qualified for that program and how would we run and what would those benefits be as well and the DEI program is just to ensure that we can be as inclusive and help everyone who is at the greatest need in Vermont but to do it in the most constitutional way so I know that was a lot to take in and there's still a lot that we need to go but does anyone have questions comments how does everybody feel about the criteria of a social equity candidate I can't see the person who has the hand raised it's Stephanie Smith but you are a presenter now if you want to pull them up I know you've been through them and thank you for doing that but if people need to see it as a visual aid it might help the conversation Stephanie first and then Siobhan Hi Stephanie Smith with the Agency of Agriculture I had a question with respect to the I think it was bullet three under qualifications or it's a bullet on my notes number three regarding convicted of a cannabis related offense and or a family member impacted by incarceration and you said that this would be submitted by an applicant or would this be a search with VCIC and I was wondering whether or not there have been conversations with the Vermont VCIC I can't remember what it stands for but it's Vermont's criminal records checked group what information they can actually provide and whether or not it would be provided directly to the CCB or it would be provided by the applicant through an application that the applicant would obtain their criminal record and then submit that to the CCB and I know that's really detail oriented but I think they have there may be limitations and or you might not be able to get the information you need so I just wanted to check in on that and that you know you can research that on your own so maybe it's more of a comment than it is a question thanks No as Stephanie that's a great point are you able to see my screen right now Stephanie because it is the third bullet point on mine as well Okay great we would have people submit along with their application proof of an arrest or conviction we have spoken to general counsel David Shearer who said they would be able to provide that information by going down to court I'm not sure how the Vermont cannabis control board would verify that information. Chairperson Pepper would you like to add anything to that about verification on your end? You know we have the courts will have records including of expunge convictions that are available to the person who was the who has the conviction dating back I think to the 70s that's where the kind of transition between paper and digital records happened in court histories so there might be an open question about some expunge criminal convictions juvenile criminal convictions or criminal adjudications and potentially pre-1979 or 1978 I forget exactly when the date transition but there might be a question about those or we might be allowed some sort of attestation or affidavit or something Thank you. Okay great. Does anyone else have any questions about the social equity candidate qualifications? I see. Saban. Saban you're muted. Sorry I lowered my hand but didn't unmute. Thank you. I think those are some great criteria it sounds impressive the level of discussion that you folks have had on the subcommittee similar to Stephanie not a concern per se but a comment to take back and think about and maybe this ends up leading to something that you folks want to tweak or maybe not but opportunity zones have taken a lot of negative commentary in the other uses that they've been used for in the investment context of how they were created by the IRS A they're a little random in how they're drawn and what they represent and are much broader than just the groups you mentioned that they do happen to have a high correlation to folks who live inside them so I wish I'd heard it in the opposite order but you're presenting it in the logical order which is here but I think you said that one of the rationale for opportunity zones is that there are a lot of residents who are BIPOC or other minorities or marginalized groups and if that already is criteria number two then criteria number one might be a little duplicative or overlapping but my concern is that there's also just so many more people who live in opportunity zones since some of them are really broad swaths of Vermont that we may be capturing a lot of people who aren't necessarily what was intended here and then part two of that is that a related critique of opportunity zones is that a lot of the opportunity zone development money that's being invested in opportunity zone projects are projects that are essentially justification and the worst type of justification so even if we decide that my first concern is maybe not big enough to warrant but rather we should be reevaluating this over the ensuing years because by five years from now we may have what were meant to be opportunity zones and this weird IRS funding scheme that gave a lot of tax breaks to help people gentrify and then we could have a lot of folks who are the gentrifiers who are applying for those benefits and that would clearly not be what was intended so again just to take back for consideration it may still be worth it to include opportunity zones because it just gives a very easy factor to measure at least each stage so that's for you folks to consider. Thank you Siobhan, that was a great point about opportunity zones what we did was also look at tax reports as well so we contacted the tax department and they said about 17% of people do not file for taxes because they do not meet the sufficient requirements so we also included high minority impacted areas and with the opportunity zones over the 25 census tracts that they do have it really helped to identify who was the most social, economical, the lowest means of that and then also included minorities which we were trying to target as well so we felt that it included both of those that were really important to include in a social equity program and also all of these programs we will be talking about later should be reviewed every two or three years. There will be a number of years that we say once we discuss what a social equity cannabis board should look like so that we're constantly reviewing the information because at this time opportunity zones will be the best area in five years that may not be the case but I do understand your concerns with opportunity zones but we tried to just make a disproportionately impacted area the best that we can right now to find it for Vermont. Yes, Chairperson Pepper? Well I was going to say Jim I see your hand raised I'm wondering Jeffrey if your raised hand is in direct response to Siobhan concern. It is yes if you don't if Jim if you don't mind if I take just a moment. Thank you so the reason the reason the opportunity zones came in and Siobhan I appreciate you bringing up the gentrification point I have the same concern. The reason we brought that up is because as of right now the state of Vermont has not conducted a disproportionate impact area study and so without that information we're trying to kind of capture the same idea without the presence of that data so one thing if the board could consider is creating a DIA report that would be more accurate so that's just that's why the opportunity zone is there but thank you for raising that Siobhan. I think those are all fair and just to put a final point on it either now or in the future if the one part that opportunity zones captures that isn't captured at number two you know Bapak minorities other marginalized groups, ethnicities if the one part it's not capturing as measured as mentioned by Gina you know 17% of folks don't even qualify to file IRS reports. In theory we could replace number one with you are in the lowest tax bracket or don't even qualify to file taxes so there are other factors we could think about to try to get to that whether now or in the future just to put that out for discussion but again that it might be that opportunity zones makes perfect sense for now and those are things worth reviewing in the future. Thank you. Thank you. Jim do you have a comment? Yeah I just have a quick clarification question maybe I missed something on cannabis related offenses and the mention of the Vermont crime information center made me think of this are there a list of excluded offenses like intoxicated obviously something public engagement is not included right like driving intoxicated. Jim what I would I guess I defer to Gina on that if that came up in the subcommittee. Yeah I'm just curious. Well right now we were going to talk about social justice reform later so we didn't want to indicate violent or not violent at this time and I know that there is criteria saying that if there would be that the person would be public harm that they wouldn't be able to get a license so therefore then they would not qualify but violent versus non-violent if someone was drinking under the influence right now would not they would still be able to participate unless there were a much larger harm to society and they also are able to apply for expungement on those levels as well so we're just coinciding with what is currently on the books. Okay thanks. Just sorry I know you're seeing my screen of all the people just trying to see if there were any more questions about this slide. Chairperson Pepper do we need to have people vote on this right now? I don't believe so I think really what the board needs just because of the pace that we're working at is everyone's input and comment and see if there's any major concerns that need to be raised at this point because this criteria really impacts our market structure and fee structure and so you know that report as I mentioned was due October 1st and we're probably going to be a little bit late so please if advisory committee members have serious concerns about this criteria or have ways that they want to provide input please do that now but I don't think a formal vote is needed. Okay and one of the things that I want to state for a candidate it is not just someone who will get a licensee so we don't want them just to be just a license holder and nowhere else included in the cannabis industry so this will also be for someone who's getting additional educational benefits that the program will have which we will be discussing probably a little bit on Thursday but most of that discussion will probably be on Monday so we will talk about things like certification programs educational workshops because we want to ensure that at every level of the cannabis industry that we are having it as diverse and inclusive as possible. I'm just going to go to the social equity and DEI programs does anyone have any concerns about having two programs or two potential programs in order to have the most inclusivity for the state of Vermont? Questions, comments? Okay moving on this is our impacted family parent legal guardian sibling spouse child minor in a guardianship grandparent grandchild any questions comments on that from the board? I might add a domestic partner there are many folks who consider themselves similar to spouses but aren't legally married and broadened out a bit. Okay I will bring that back to our subcommittee I think that's a good point anyone else I'm sorry I'm just I can't see if people's hands are raised as I'm screen sharing okay thank you for your input about that. Gina this is Ingrid sorry I just wanted to chime in I know that you had mentioned earlier about the verification of these categories does the board or does anyone feel like it will be a challenge to ensure that folks qualify I guess maybe just hearing from the board whether you feel this will be things that you can verify easily I don't know the answer to that Ingrid I think that people are kind of attesting or swearing that this is accurate information then it really puts their license in jeopardy if they're not being truthful and so I think at some point there's going to be a level of trust and we'll figure out the verified piece as it comes up. Thank you. Thank you for that question Ingrid and just supporting documentation to make sure that everybody okay with ensuring that people be able to provide their own conviction records and addresses of residence. I would throw in one nuanced one there Gina this is Yvonne again sorry for piping it a lot. Record of a prior conviction or things like that successfully navigated what has been a very burdensome system to get the record expunged. It's almost ironically comedic situation in which they got that record expunged and maybe they shredded or threw out anything from the earlier phases because they wanted to forget it and now how do they prove it. I don't have a suggestion because I don't know the system well enough but it's a scenario we should try to consider. I have a little bit of familiarity with the expungement process I think in 20 a few years back we did create a registry of all kind of metadata on all expungements that is accessible by the expungee the person that received the expungement so there is going to be a gap of about I would say around potentially up to like a few thousand convictions where there will be no record of them but at least from a few years back when we really started accelerating expungement and automating it as well there will be records of those but it's that kind of there is a universe out there a known universe of records that are just permanently deleted with no record at all and not even the kind of spreadsheet that VCIC keeps and we might want to ask someone with more expertise to help us consider what about people who were not Vermont residents at the time but now are right there may be many people in different scenarios from other states or other areas so again I don't have the expertise for that but that might be one worth looking into. Thank you so much and it's really helpful so as many questions or comments it always helps but I know that the Vermont Cannabis Control Board is aware of those issues and looking at ways how they can navigate around that and then our last point decisions on for the social equity subcommittee is that a licensed business for social equity is at least 51% owned by one or more social equity candidates a social equity candidate must be involved with the daily operations and be able to make decisions for the business and that the social equity candidate must meet state requirements to open a business any comments or questions about this okay wonderful I mean that is as far as we've gotten so far I will bring back any recommendations that were made by the board to the subcommittee group on Thursday thank you. Kyle I think you're going to give us an update on compliance enforcement and some of the decision points that were made there. Sure happy to I don't have a visual aid as Gina did but she really needs me to repeat anything and I don't hesitate to raise your hand or speak up. So the compliance enforcement subcommittee has a lot on its plate as a laundry list of priorities to dig its teeth into and really starting and start to make recommendations to the board on how to proceed on certain things what we did at the beginning is we looked at that and we also looked at various language in at 164 especially as it has us to prioritize working with our sister or partner agencies so a good place for us to start from that perspective I thought and NACB thought as well was to talk about indoor and outdoor cultivation, inspection, compliance and enforcement and what we did was we brought in some agency partners. Carrie Shagair and David Huber from the Vermont Agency of Agriculture Food and Markets came and spoke to the subcommittee a number of times. Carrie is the director of the farm division at the Agency of Agriculture which is the public health and agricultural resource management division. David Huber is the director of enforcement at the Agency of Agriculture and so we asked them to present to us how they typically handle everything when it comes from an inspection all the way through administrative civil and criminal penalties as it relates to issues that happen under their jurisdiction. The hemp program is housed at the Agency of Agriculture. They've got an extensive experience with licensing, inspecting and enforcing any violation as it relates to the hemp program. Carrie and Dave have a team of inspectors already in and around the state in multiple areas of the state. I think they have six inspectors in different regions of the state and a lot of them are cross trained to do everything from pesticide inspection and enforcement, hemp inspection and enforcement, so on and so forth. They look at what if they see a potential violation they'll relay it back to the Agency of Agriculture whether it's Carrie, Stephanie who is on the call. So Stephanie if I'm butchering this don't hesitate to raise your hand. And also today if it reaches an enforcement perspective, over the course of talking with the subcommittee and Dave and Carrie everybody seemed to be in agreement that the Agency of Agriculture could potentially be well positioned to partner with the Cannabis Control Board as it relates to inspection, compliance and enforcement. And we got to the point within that subcommittee where the subcommittee voted unanimously to charge the board with looking to enter into a memorandum of understanding with the Agency of Agriculture to act as its designate when it comes to inspection, compliance and enforcement. And talking with Carrie and Dave further about this I think everybody really wants to see what our market analysis is going to look like, how much resources are actually going to be necessary from a human man or human hour perspective in taking on this additional work and also a financial relationship between the Cannabis Control Board and the Agency of Agriculture and what that is really going to look like, how many licenses are we expecting to start with, how many folks are going to be participating here and this goes for indoor and outdoor cultivation. So I can stop there and answer any questions but as of right now that's kind of where things are. I want to also just briefly mention because it's come up multiple times in the committee and this is technically not an agricultural product. It's a commercial product and I did ask Carrie do you have any experience in doing inspection, compliance and enforcement on anything that would technically not be an agricultural product and he said that the Agency does have that experience. One thing he pointed to was farm worker housing conditions for migrant workers and how they look to inspect houses on farm where these migrants or other farm workers might be working and there's a couple other examples that I don't have directly in front of me but there's some things, some kinks that we're going to have to work out with respect to that but from the Agency partner relationship utilizing expertise that exists with our sister agencies we thought this was the most prudent way for the Board to proceed at this time. So I'd love to open that question up to that decision up to the full advisory committee about the cannabis board kind of using the expertise in the cannabis quality program and Agency value culture more broadly to kind of be in charge of or run the enforcement and compliance for the cultivation side of the cannabis industry. I'll take silence as a good thing and we can keep progressing. I want to just quickly talk about retail compliance and enforcement because that's kind of what has been the focus of the last couple meetings. We've heard again Kerry and his team have some expertise from a retail enforcement perspective as it relates to the quality of a product the shelf life of a product, how it looks and they've got some they've got expertise at the general retail establishments as well with how they do pesticide enforcement so on and so forth. We've also received a presentation from the Department of Liquor and Lottery on how they do tobacco and alcohol enforcement and what their programs look like from an ID check perspective, a sting operation perspective, so on and so forth both were great presentations. I've asked the Department of Liquor and Lottery to kind of take what they do from an alcohol and tobacco enforcement perspective and how that look in this industry specifically. We're going to have less examples of a minor walking into a dispensary because that will not be possible like they would in a general store so on and so forth and might try and purchase alcohol. So I'm hopeful that the Department of Liquor and Lottery can go back to us with how they would perceive this to look. Again the linchpin to this conversation just like the indoor versus outdoor cultivation perspective is really what the size of the market is going to look like and how much resources would be required of these partner agencies to help facilitate compliance and enforcement from a Canvas control board perspective. Billy? Just a quick question going back to the cultivation enforcement was there any conversation in the subcommittee about the distinction between kind of being a non-agricultural product being grown in an agricultural setting where there's two different standards that may apply to similar crops and just ensuring that the full conveying agency feel like they could walk that line given their broader enforcement role in the agricultural community? I don't think Billy that we got that deep within that distinction but what I would say is if the what I would imagine is if the Canvas control board did enter into an MOU with the Agency of Agriculture Food and Markets there would be a lot of training that would necessitate being able to draw that distinction and understanding and unpacking the implications of this not technically being an agricultural product. Great thanks and I'm totally confident that they can and will do that. I was just curious if you got into that point of the conversation so thank you. Thanks Billy. We're grappling with that in the sustainability committee but once we kind of have our heads above water I think it'll start to trickle down. Does anyone want to kind of weigh in on the question about ag enforcement or DLL enforcement on the retail side? Steve on I can weigh in a bit just have the long long history of an alcohol side of Vermont. I would think that if you're going to pursue the DLL option more seriously it might be worth speaking to some of the industries that they have regulated. Obviously if you take any commentary you get with the way it's all but I would imagine I would imagine that there is not high satisfaction rate with the people who have been regulated by DLL when it comes to enforcement and the approach they've taken to enforcement. Again it must be taken with a grain of salt but I would think that is worth looking into out of seriously. Thank you Siobhan. Anyone else on that question? This is Stephanie and I work at the agency of agriculture and I do currently manage the hemp program for the agency of agriculture and on the heels of what Siobhan said I think it might be worth also asking the hemp growers and others in the agricultural industry how they feel about being regulated by the agency of agriculture. Justice again another perspective but similarly situated. Thank you Stephanie. Okay do you want to talk about Sea to Sail? Sure. So the Subcommittee did talk about Sea to Sail tracking. We did get a review of what this technology kind of does and looks like from one vendor but we you know this subcommittee was not a charge from my perspective as a board member to the subcommittee to help have the subcommittee necessarily help us decide on a specific vendor. It was more about a charge of what technology we should look for in a vendor moving forward and I think it might just be best for me to read the charge that the subcommittee unanimously voted out of committee on what the board should be looking for when it comes to Sea to Sail tracking. Again Sea to Sail tracking language was explicitly in Act 164 as something that the board needed to implement as we as we moved through this process. So the language coming from the board or from the subcommittee was the board should seek a vendor for open API tracking software and that stands for application programming interface software that is maintained by the cannabis control board and is login accessible by cultivators to self report inventory. Software should have the capacity to track data based on both lot size and plan count. So what this means is the cannabis control board will seek a vendor that has the ability to link up with a software of a licensed applicant or licensed holders choosing. So we're not forcing any licensed holder to pursue a specific software company or brand but do something that makes sense for their size and scale of operation. We thought it was also important to look at both lot size and plan count recognizing that that difference may help alleviate some costs or burdens on small cultivators. So essentially what this will do from my perspective is empower the board and our executive director to go out and start speaking with vendors whether it's through an existing state contractor through an RFP on software that we can implement here and start getting some traction on. Chris do you want to weigh in? Yeah, I'm sorry I have sort of a strange connection going on with my Wi-Fi but were you saying that the licensed holder gets to choose what seek to sell software they want to use? So long as it syncs up with what the cannabis control board and I'm not a tech or software guy full disclosure so sorry Chris you're ahead of me here. It's my understanding that we can pick a software vendor and a licensed holder can pick a software vendor so long as it syncs up with our vendors API. I dealt with multiple seek to sales freeway biotrack and a couple others and my personal experience is from the regulatory side having five or six different options the learning curve is going to be excruciating and because the enforcement or regulators that want to come to a site inspection needs to be very well versed in all of those softwares my recommendation is to limit it to like one or two. Okay, thank you Chris that's good for us to know as we look for vendors to work with. Appreciate it. I don't necessarily think the language of the charge the subcommittee has given the board needs to be adjusted even if that were, if we were to kind of limit it to a couple accepted software vendors on the licensed holder side. I mean when I just anecdotally when I was running grassroots in Brandon and we switched our seek to sell DPS had a huge problem with trying to figure it out and we weren't much help as we were trying to figure it out too. And it really threw a hurdle into the regulatory process. I mean they would come in and out in an hour usually when we were using biotrack and then we switched to cannabis 360 and you know it just it caused many issues for months. Compliance issues. Well thank you for that heads up Chris. Appreciate it. Meg I'm wondering, I know your hand's not up, but I'm wondering as you know your experience with C2 sale tracking whether you want to weigh in at all on this question. I will second a little bit of what Chris is saying, we actually at series med he's in the process of switching their seek to sale and it is no small feat for sure. I can't speak to whether or not the DPS had any issues learning the new software but I can certainly ask the director of retail at series med. This might be you know a day late and a dollar short but have there been any discussions about the need for C2 sale? Like are there been any consideration of sort of side stepping it is explicitly mentioned in 164 that the board needs a system for C2 sale tracking you could take that interpretation as like more of the lo-fi self reporting and inspection kind of you know more old school model where hopefully our inspection backs up what you know that self reporting would take into consideration. I think you know with the focus on consumer protection, consumer safety, the risk of diverting this into the illicit market I think the subcommittee felt a little bit more confident in not doing that super lo-fi kind of process but to have the board go out and seek a vendor that would actually be able to do this give the board data in real time so on and so forth. Yeah in my personal experience and there are states considering trying to phase out of it but it's extreme overkill and it can be very cost prohibitive with updates getting people into just the it's very similar to like POS and the restaurant business where the companies that make these softwares make all their money on upgrades and you know issue based people flying out and upgrading your systems but it's I have not had a good experience in multiple versions of seat to sale in any of the locations that I've worked with them. It's going to be one of those things we've got to figure out. I know states like Oklahoma don't have seat to sale tracking as part of their program and I believe like products from Oklahoma is diverted as one of the major sources of the east coast elicit market that's crossing state lines. So in from certain perspectives it's something that we've got to go and just figure out the best way forward from a tech perspective. Jim do you have a comment? Yes I do a quick one. Not to beat it at horse on the seat but having worked in the food industry on the consumer side where in supermarkets field to market information is pretty much standard now and yet as a consumer and a former editor I can tell you that every single one you looked at it had to be left up to the distributor or to the produce wholesaler or meat wholesaler to interpret what the labels meant. Often if you asked a question to a store they would have no idea. So they are very complicated but also that being said I think we have a big medical program in our state seat to sales essential for that. Initially the license holders, the dispensaries are going to be doing a big part of our product so I can't see how it would make sense to not have it. It seems essential and pretty basic. Consumers expect it for a safe and reliable product. I know a lot of lending services and banks and credit unions want to see it as part of a program as well and complicated is what we do best here. So I think I would just as we before we move to public comment and then adjournment I just want to give an update the market structure committee is zeroing in on their recommendations which we can share. If you haven't seen it already there is a spreadsheet that was prepared by via strategies with a basic market structure and with tiers of cultivation, tiers of retail tiers of product manufacturers and associated fees for all of the license types and it's a little bit more complicated than that to navigate but I think it's up on our website at this point. That's worth reviewing even if you're not on that subcommittee. I know the lab standards subcommittee is kind of zeroing in on lab standard recommendation that we can send out to this crew and I think we're going to try our best to kind of get a draft of our October 15 report in on time on that new timeline and certainly it will incorporate the input and comment we received from the advisory committee. Other than that, thank you all for the work you've done for bringing your expertise to us and it's just been an incredibly valuable learning experience for the board and thank you to our consultants for guiding us through this process. Any last comments from the advisory committee or questions before we turn to public comment? Ingrid? Just a clarifying question. I'm just trying to know whether we have an idea of license numbers that are like is there you've probably already talked about it but I know that you mentioned with regard to agency of AG or DLL doing different types of compliance and enforcement a lot of that will be dependent on how many licenses are issued, correct? Yes, so the market analysis that's done by VS Strategy anticipates that we will need somewhere in the realm of 400,000 to 500,000 square feet of canopy and you know if we are going to follow the directive of the legislature in Act 164 we really need to focus on small cultivators, the legacy market and to achieve that canopy so there is an open question about whether there actually are 400,000 to 500,000 small cultivators in Vermont that want to participate in this but that determination will help that kind of issue and we're going to, our best approach to answering that question is to have a provisional, a robust provisional license process where people can kind of submit a short form application with a non-nominal, non-refundable fee that could help us gauge how much entrepreneurial interest there is going to be in the interregulated cannabis industry and hopefully you know we'll try and set up a structure that does prioritize and favor small cultivators and if we need to open up larger license types then based on that interest then hopefully that provisional licensing process will help answer that question and then based on that we can kind of get a sense of how many product manufacturers, how many testing capacity we're going to need, how much retail capacity we're going to need and hopefully kind of make adjustments along the way. So the short answer is no, except we do have a basic framework that we're working with and you can see that kind of basic framework reflected in both the market structure analysis and the kind of fee structure analysis or recommendations if you want to kind of wrap around just kind of rough numbers. Thank you. I just had a question about the provisional process while the full advisory committee is here and the social equity sub-committee is here, is that something, is that nominal fee something they should be considering or is that, in your mind is that separate than the application fee or should they also include that in their considerations for benefits for social equity applicants? I think that that should be brought to this in the sub-committee so that the... And when I say, I meant non-nominal as in it's a real fee to actually gauge interest, it's not like the $25 or kind of permit for him. All right, well, I'm sorry we're running a little bit over. We do need to open up to public comment. Jean, did you have any concluding thoughts? I was just going to make a comment that we will be discussing that fee tomorrow with this social equity sub-committee. Thank you, yeah. So we don't have anyone in the room with us, but if anyone who joined via the link would like to make a public comment, please raise your virtual hand. Join by phone, I don't see anyone. Star six to unmute. Okay, well thank you again everyone. I know this was kind of a whirlwind of a meeting, but please, you know, you've been doing so much great work for us. You know, keep it up. Thank you very much. And I would entertain a motion to adjourn. Second. All in favor? Bye. Okay, thank you very much.