 My name is James Pepper. I'm the chair of the Vermont Cams Control Board. Today is Monday, April 24th, 2023, it's 1 p.m. and I call this meeting in order. A few administrative details for return to the agenda. Inventory tracking. Most people are familiar with our decision to avoid the larger inventory tracking platforms and build our own system. For the state of Vermont's market, we believe that this is a much more rational approach. In the long run, we'll save state and our licensees time and money. The downside is that we had to implement a temporary inventory tracking solution while we waited for the permanent platform to be built. It is built now and we're going to be rolling it out in the easy-to-use case on your license site. We're starting with Cultivators, which is live right now since it is their inventory that populates the supply chain. There's going to be some growth in double-entering of data as we transition to this new platform. I apologize in advance for that, but please keep in mind the long-term benefit of this system. The team here has drafted up some guidance documents specific to Cultivators that is up on our website, and we will be conducting a training on inventory tracking for Cultivators in the near future. I'll just be sure to make sure we send out a link to participate in that training, and of course we'll record it and post it to our website or to our YouTube page. We have a peer networking event coming up this Thursday, five o'clock. The topic is insurance. We have some great speakers lined up to talk about what is required when it comes to insurance, why you need it, what to be thinking about when you're shopping for a policy, and everything else insurance-related. So the link to join that event is on our website under the event calendar page. I wanted to remind everyone that we are in the process of updating portions of our administrative rules, specifically rules one, two, and four. And quickly note that we're holding off on updating rule three, which covers the medical program because there is pending legislation that might significantly change the program, and we thought we should wait to see if that passes before we start making amendments to that rule. The part of the process is to receive and consider comments from the public. Anything that you submit to us in writing will be considered, but we also will be holding two public hearings dedicated exclusively to receiving comments, advice, criticism, your thoughts, really anything about our rules. The dates of those are Wednesday, May 10th at 10 a.m., and Monday, May 15th at 6 p.m. Both will be virtual. The links to join are available on our website. And these public hearings are all about the CCB listening to comments. We will hold a subsequent meeting to discuss those comments and consider amending our proposed rules based on what we've heard. So it's very helpful for us when you comment to pay, know the difference between what we can change, things like security or sampling requirements, and things that we can't change, like any sort of statutory definition or for things like advertisement or canopy or things along that. Also B, it's very helpful for you to, for us, if you get specific with your comments, things like your regulations are too expensive, don't give us much to work with, whereas something like your requirement for a cessation of operation escrow make it too expensive for me as a tier two cultivator to participate. They will, things that are more specific allow us to focus on areas that we actually can change. I wanted to also remind folks about the seasonal closure for outdoor and mixed tier licenses. I should say new outdoor and mixed tier licenses. And that closure begins this Friday, April 28th at 4.30 PM and it will reopen Friday morning on December 1st. This closure does not impact cultivators. But if you sat out last year and are thinking about getting an outdoor or mixed tier cultivation license this year, please get your application in by Friday at 4.30 PM. Your application does not have to be fully complete by Friday. If it's submitted by Friday, our licensing team will work with you to get you licensed. However, we've set an internal deadline of July 1st when we will not issue any more licenses for applications that have been submitted prior to this Friday. As a reminder, a reminder as to the reasoning behind this decision, it really starts from the premise that you're not allowed to grow cannabis for the adult use market without a license. Our internal metrics show that it takes roughly three months from submission to approval for us to process a new cultivation application. So if we were to receive an application for outdoor cultivation late May or June, that person would likely not receive a license to grow, which by the way, is their legal protection against criminal enforcement until August or September. And this would not give that hypothetical grower enough time to legitimately operate this year. We were in the position last year where some of our outdoor cultivators got started while they had a pending application where they were using a hemp license as their protection against criminal enforcement. The CCB did a lot of outreach to law enforcement agencies around the state during that summer and fall to explain to them about the backlog and applications and the fact that the people that were growing had a pending application and they were operating within the scope of that and they weren't otherwise breaking the law. And that those folks that fell into that narrow category shouldn't be harmed just because of a backlog at the CCB. Added rationales does not hold true this year. We are appropriately staffed. We don't have a backlog and everyone has had at least a year to apply. So we can't count on that same leniency from law enforcement this year. The decision to close the licensing window to new outdoor and mixed-tier cultivators was made by the board to hopefully avoid putting people in this sort of legal jeopardy. So once again, if you have plans to jump into this market this year as a new outdoor cultivator or mixed-tier cultivator please get your applications in by Friday and then work with the team here to make sure it's complete. Kyle, did you wanna mention something about packaging? Labelings? Public Health Warnings. Yeah, so I know people have started to look at our proposed rules. There is some language that could update and shorten the requirements for the warnings that would need to be present on label. I know a lot of folks are trying to order packaging now in anticipation of what may become rule but I just wanted to remind folks that that proposed rule has not been finalized even if we tweak one or two words you could put yourself in a position where you're ordering a number of units with the wrong label. So please hold off on using that proposed label it is still proposed. We need to keep using the warning label that is currently in rule until the time comes to where that proposal is finalized which could be another month or two at the earliest. And it could change. And it could change. It's again, it's a proposal. We're gonna take feedback from everybody if they think it should be adding even one word can throw off what you're trying to accomplish by getting ahead of the curve. And we don't wanna put you in a position where you've spent a considerable amount of money on labeling only to find out that you're one word off. So hang tight. All right. Anything else you wanna add before we move to the agenda? Nope. Okay. Well done. I will say that we recognize that folks do right now have most likely a lot of packaging ordered and we'll figure out a way for you to exhaust those current packages if that label requirement does change, but for now, that's, you know, we need to follow what's in rule. All right. We have two sets of minutes to approve. One from our regular board meeting on March 27th, 2023 and one from our special meeting on March 29th, 2023. I guess I had a chance to review those minutes. Yes. Yep. Is there a motion to approve? I move that the board approve the minutes from March 27th and March 29th. Second. All in favor? Aye. Aye. Okay. Let's move down our agenda. Next on our list is a discussion of a temporary closure of cultivation tiers. I just have a few opening remarks to this. We don't mind. I'm just gonna have a more open conversation. So from the very first conversations I can remember around cannabis legalization, there's always been intense debate about what the appropriate size and scale of cannabis cultivation should be in Vermont. A lot of the early discussions were about community gardens. They were built around co-locating 25 by 25 square foot plots. You know, when there was a real possibility of Vermont being the lone legal state on the East Coast and needing to supply the demand for potentially millions of visitors, there was discussion around having 30,000 square foot canopies as the maximum size. The legislature of course landed on a thousand square feet as being the smallest tier and then directed the board to come up with arrest based upon the anticipated demand in the state. You know, we took the RAND report estimates from 2013. We updated them with much more comprehensive tourism data and consumption data. And then we reverse engineered a cultivation licensing structure that attended to thread the needle between keeping this market unattractive to larger corporations, but also meeting the demand for cannabis in the state. Until we actually started running this experiment, we had no way of knowing how many people were gonna apply for our licenses or that they'd be indoor versus outdoor or what tiers were gonna be popular. And there are still plenty of unknowns about this market. Is there gonna be a failure rate for tier one cultivators? Are smaller operators gonna reapply at a higher tier in year two or three? What's the delta between canopy license versus Q2 be utilized? What's the yield per plant? And also just given the interest in outdoor cultivation, will this supply chain hold and can we have reasonable prices until we have our next outdoor harvest? That being said, to me, there is some logic to the notion that a tier five indoor cultivator is probably inaccessible to most small Vermont farmers and the people who've been most harmed to my cannabis prohibition. And those are the exact people we're supposed to prioritize. We also have a sustainability mandate. We're all familiar with the environmental impacts of large scale indoor cultivation. And I certainly don't want us to put us in the position of pushing people indoors who would have otherwise been growing outdoors but for the seasonal closure of outdoor cultivation licenses. So when you put all that together, I think we should absolutely have the conversation about whether we should temporarily close the indoor tier five licenses. Yeah, no, I think, you know, I know we've heard from some in, you know, through public comments and I'm sure the three of us have enough conversations that we have with various different facets and parts of the cannabis community here in Vermont. You know, I think after hearing those comments, I know the three of us have gone to our own research, you know, talked with, you know, the folks that helped us model how much canopy we actually need, you know, from the get go and where we are now. And, you know, I think it's certainly a good time to have that conversation. And, you know, with an eye to, you know, closely examining other tiers and whether they make sense in the future. But I think right now, tier five is a good place to start. I agree. It's consistent with our guiding principles, which we set out for ourselves at the very beginning. And I think I did the same math that you did. You came up with roughly the same conclusion. My only concern is creating a secondary value for these two current tier fives because they're not gonna be actually available if that's a decision we want to move. But I think that's something that we just need to make sure we're cognizant of moving forward should things change on, you know, the licensee side of that equation. And a closure is not necessarily permanent, right? We can close licenses and we can then open them also. Right. It's necessary. You know, I just want us to make sure we're thinking. Absolutely. In a way, it's like look to undercut what we're trying to accomplish. So I think it sounds like we could probably vote on a motion. And I think because as a Friday our outdoor tier fives and mixed tiers will already be closed, I think the motion should be specific to indoor. And I think it should be temporary as we move forward. You know, collect data around these things around utilization, canopy yields, and just the overall strength of the supply chain. And we can reevaluate at a future date as to whether or not we need these tier fives at all. So Julie, do you have a motion for that? Yes, the only thing I, so when we close, when we give notice that we're closing, it's 30 days. So it's June 24th or May 24th, exactly 30 days from today. The only thing I did not go back and look at. I think you could probably say 30 days from today. It is. Close that. Close that. You're gonna make me do math on 30 days versus 31 days a month. I moved at the board temporarily closed tier five indoor cultivation license effective May 24th. All right, per second. I'll second. Any further discussion about this? Nope. All right, all in favor? Aye. Aye. Okay. I do think it would make sense for us to continue looking at tier four and others as well as we move forward and kind of see the impacts of closing this specific tier and have on our market overall. Absolutely. All right, let's see what's next. It's discussion of our emergency rule. That's right. You want me to put it up? All right. I've got a few words to say about this too. If you don't mind why you guys are getting situated. So, you know, no topic gets quite as much attention among cannabis regulators as the conversation around hemder eye products and synthetic cannabinoids. We're seeing just a wide ranging approach among the various states. On the one hand, we have outright bands of Delta A, Delta 10. On the other, you kind of other side of the spectrum, we have just free for 2022, our legislature heard testimony about this and then punted the issue to the cannabis control board and gave us the authority to figure this out. Our plan, much like when we created our initial set of regulations for the adult use system is to engage with the public, with hemp producers and manufacturers and whomever else wants to be involved to create a common sense approach to hemder eye products. We plan to do this in the coming months, but in the meantime, we need to have a rule in place that's aimed at unregulated intoxicating hemder eye products. We're seeing hemp derider products with just as much THC as the ones in the regulated cannabis market. They don't meet any of our testing protocols or packaging labeling or advertisement requirements. They're being sold without any sort of age verification. So not only is this unfair to the people that went through the trouble of getting a CCB license, it also contravenes the very intent of creating a regulated market for cannabis. So we have an emergency rule drafted here that's aimed at intoxicating hemder eye products. It's a stopgap measure that will be in place while we do the work of developing a permanent rule. And things over to walk through the substance. All right, thank you, Mr. Chair. I can walk you through the emergency rule. The goal here is to sweep in the synthetic and potentially intoxicating products without sweeping anything that we don't intend to. The way the rule would work is by announcing under the board's authority granted to it in section 862A, announcing that the production, manufacturer, marketing, et cetera of hemp-derived intoxicating cannabinoids and synthetic cannabinoids are prohibited except it's set out further in the rule. The main targets of prohibition here are the isomers, variants, analogs, mimetics of Delta 9THC. So this takes in the familiar Delta 8 and Delta 10 that are seen on the market in Vermont right now illicitly and also takes in chemically manipulated intoxicating cannabinoids regardless of where they came from. So it is of no moment that they're derived from hemp. What we care about is what comes out the other end. Also included is Delta 9THC itself that has been chemically or mechanically concentrated or otherwise derived from hemp and then sprayed or otherwise reapplied to any product including spray back onto hemp flowers. Also seen in our market by folks that are not subject to regulation or have not subjected themselves to regulation. In order to operationalize that prohibition, the rule makes four simple presumptions. Presumes that we have a prohibited product if it contains THC in a concentration exceeding the familiar 310s of 1% on a dry weight basis and notably it's total THC to include all forms. And in the alternative, a product is presumptively prohibited if it contains more than one and a half milligrams of THC per serving and the board reserves authority to determine what is a reasonable serving but most of us understand what that means, the amount somebody might reasonably intake in one sitting. Also presumptively prohibited products with more than 10 milligrams of THC per package except if the ratio of CBD to THC is greater than 20 to one. So that's there to protect full spectrum products that are not the target of concern here. And finally, the board will make a presumption looking to the manner in which a product is marketed. The product has the dominant market appeal of mimicking or appearing to mimic the intoxicating effects of THC than is presumptively prohibited as well. The exemptions operate to make sure that we're not taking in anything that we don't want. The first and most obvious one is that a product that is properly registered with the board as a cannabis product is exempt from the rule not affected by it. Also for medical patients, it may be appropriate for the board to approve under 7VSA 971B6 as it has authority to do specific products that it finds appropriate for use by a patient, even though they would otherwise be prohibited by this rule. And finally, FDA approved legend drugs are not intended to be prohibited by this rule. The most familiar of those, of course, is Epidiolex and they're handful of others that are not included in the rule. So that's the walkthrough. Happy to answer any questions that you may have about this. So you've all seen this and had an opportunity to talk to you. Is there any questions lingering about this? No, it's here, thank you. No, I'm good. Thank you. Great, well, Gabe, before we vote on this or Bryn, can you just remind us the scope of an emergency rule? Obviously we haven't taken any public comment on this. We need it as quickly as possible and can you just kind of lay out some of the broad strokes of what an emergency rule is and how long it is in effect? Sure, thank you, Mr. Chair. So an emergency rule is for the APA, the Administrative Procedure Act that governs how and when agencies may adopt rules. The APA allows that an emergency rule can be adopted if the board finds that there's an imminent threat to the public health safety and welfare, such as the kind that you were discussing earlier. The rule would be in effect for only 120 days. It is filed with legislative committee that can't object if it disagrees that there's a genuine urgent need to act. But as you said in your introduction, this is an interim measure. That 180 days of effect will take us, fortunately, right into public notice and comment for the three rules that are now pending adoption. And it is proven that the agency move its emergency rule as soon as possible into the conventional rule where everybody has had an opportunity to offer comments, raise objections and concerns, et cetera. So what that means is that anybody with an interest in this topic should participate with us in the rulemaking hearing scheduled on the three rules now under revision because we will move this content into an appropriate place in those rules in order that it can be subjected to the proper notice and comment period that a conventional rule receives. So again, just kind of a stop gap here to protect the public while we sort out through conventional rulemaking what the final rule will be. Thank you. So how do we go about making a finding that this rule is imminent or it needs to be an emergency rule? You would make that finding by declaration. And I had suggested a motion that contains both that finding and the request to adopt. And after that motion, it would be appropriate to have discussion if people are interested in whether there's a real emergency here and the proprietary rule. Great, as well, do we have that motion? We do. I move that the board find the unregulated products containing synthetic cannabinoids as well as unregulated high THC hump derived products and parallel the public health, safety and welfare. And based upon that finding, I further move that the board adopt the emergency rule discussed for the immediate effect pursuant to three VSA 844. I will second. So as far as discussion, I mean, we know of a few cases, of course, both actual cases that we're aware of and anecdotally about these products being in Vermont, that they have just as much THC potentially more than cannabis products that are being sold at adult retail outlets. They're not being age verified. They have Delta 8 and Delta 10. And it seems to me like unless we have something like this in place, we don't have the legal authority to just start pushing those through our product registration process and some instances or just stopping the sales on the numbers. Agreed and some of these products are coming to Vermont from out of state, which I think only sharpens your point that this is undercutting all of the hard work that all of our cultivators and all of our retailers have gone through to kind of get to this point to showcase Vermont grown products in our adult use marketplace. I do want to be clear with everybody listening that this does not include CBD, CBG, CBN. We made some accommodations to make sure sure full spectrum tinctures are not swept into this. This is only the psycho active hemp derived products. So, before there's any confusion, those products would not be subject to this emergency rule. I did have one question and I'm sorry I hadn't thought of this sooner, but does the staff have a plan to communicate this out to like grocery associations or, I mean, I know the products that are coming out of state are tend to be at places like gas stations and not within our regulated system. So those are folks who are probably not paying attention necessarily to what we're doing. So it'll be important to communicate that out to other associations. Yes, we have a plan to make reasonable efforts to ensure that the rule is widely known and understood. Thank you. And I think we'll be making reasonable efforts to just do the public engagement side, with this in place while we do that. And none of this, as you mentioned, Gabe is etched in stone. It's in place for, is it 120 or 180, 180 days? And if we need to make changes to it, we can do so in kind of a more traditional little making process. Yep. There will be plenty of opportunities to have your voice heard if you're not in favor of this emergency rule. All right. All in favor of the motion? Aye. Aye. Okay. Great. Let's keep going then. Next, Brandon, I'll turn it over to you for our executive director report. You should go on licensure and social equity. Nellie, is that showing up? Okay. So starting as we always do with our public engagement since our last board meeting and what's coming up since staff are always very busy in between board meetings. On March 30th, we had a navigating local licensing session after hours. April 13th, we had a human resources 101. Oh, we did not have the human resources 101. Actually, that one was rescheduled. Rescheduling date is to be announced. That will show up on our website when it's been rescheduled. This Thursday, we are holding another after-hour session on ensuring your cannabis business. And then coming up in May, we've got the inventory tracking training for our cultivators on May 4th. And then our public hearings on the rule amendment that the chair mentioned on May 10th and May 15th. So all of these sessions that have already been hosted are found on our YouTube page. And once we do host the forward-looking sessions, those will also be on our YouTube page and you can get there through our website. And not much of an update here on our hiring activity. We are still an active recruitment for a medical program technician. We do have some updates to our guidance documents, which can all be found on our website. First, we've got inventory tracking guidance for cultivators, as I mentioned earlier. We are, there are a couple of documents there that will help cultivators enter their first round of reporting on inventory tracking. And those are linked here in the report and this report will be posted to the webpage. But they can also be found on our guidance page. We've also made some amendments to our application status flow chart to add more information about what applicants can expect when their application is in various stages of the process. And we've also expanded our bulk flower guidance to provide some additional information for cultivators and some more clarity about who needs to register bulk flower. So all updated, all on our guidance page. Just a little update for the board on where we're at with our excise tax revenue predictions, the consensus revenue forecast for FY23 predicted 4.7 million in excise tax revenue for the first nine months of fiscal year 23 that the market was open. And as of March 31st, the total intake of excise tax revenue is a little bit over 3.4. So that's actually tracking quite closely. So interesting, that's a... Interesting, but that's tracking so closely. Okay, I'm gonna move on next to our licensing data. So as always, we start these data sets with our average days from submission to approval. So we've got a variety of slides here that sort of track how quickly the licensing team is processing these applications and also just generally how long it takes for an application to make it through to approval. And so this compares our social equity applicants to our standard applicants. So you can see we're hovering around, takes about half the time for social equity to make it through as opposed to standard. So I think our next slide here is same data. So average days from submission to approval, but across the license types. So you can see that the number of days is holding pretty steady over time. This is kind of a quarterly report. So I think we can say with some certainty that it does take the least amount of time to process the employee ID cards and the most amount of time to process the cultivation applications and the other license types fall somewhere in the middle. So our average days total, I mean, if you look at these numbers, our average days total from submission to approval is about 89 days. And I just wanted to remind the board of this information, which I showed you, I think in February, these are some statutory timelines from other states that have adult use regulatory agencies. So these are periods of time that the regulatory agency has mandated to complete their review of a complete application. So 90 days for Alaska, Maine, Michigan, Montana has 120 days. But significantly, this is the amount of time that the agency has with the complete application. So once the application is complete from the applicant's end, then that's the amount of time that the agency has to conduct its review, its analysis, and then either approve or deny that applicant for a license. And the numbers on the previous slide were from submission, right? Not from... These are submission, right? So our numbers are around the same, around 90 days, but they are from the time that the applicant hit submit to the time that they are pushed for approval. And that, as you know, because we've talked about this quite a bit, involves a lot of shuffling between statuses and significantly a lot of time with the applicant. So this is some new data for the board to review. Of that average 89 days to approval for all license types, the board is really only has that application in our hands for 31 days. And the rest of the time, the application is an incomplete status, which means that the applicant is working to finalize their application. So just a highlight on how efficiently and rapidly our staff is processing all of our applicants through to licensure. So next we'll move on to our new submissions. This month we've got 49 new applicants for a Canvas establishment license. These numbers are increasing steadily over time, over the first four months of the new year. So this is according to their status, 61% this month are standard applicants, 23% are economic empowerment and 16% are social equity. This is by license type. So our new submissions, those 49 submissions across the different license types. So most of them are cultivation applications. We've got about eight manufacturing applications and then four retail applications in the last month. And this is a quarterly picture of what our new license application submissions looks like. So you can see there's been steadily increasing since January. And this is the new submissions broken out by their status. So at the bottom that sort of bright green are social equity status. The middle green is standard applicants and the top kind of tealish green are economic empowerment applicants. Another way of looking at this. And then here is the same data, but broken out by license type. So you can see that the largest growing category of new submissions are cultivators. That middle green are retailers and the top green are manufacturers. Okay. So these are our numbers of issued licenses as our standard sort of chart of the licenses that the board has issued so far. So we're up to 399 as of April 19th. So here are our numbers of issued license amendments. We're up to 22 amendments that staff has completed. And reminder that license amendments are not coming to the board for approval. Those are the sort of technical changes in an application or in a license that staff is able to complete without board approval for a rule. And we have also issued 413 employee ID cards. So this chart is gives you a picture of where all of the renewals are by status. So we are up to 16 renewals that are in process right now. And this is our wall of numbers that we were trying to move away from, but since there are only 16 in process right now, I thought it would make sense to break it out by status so you can see where we are for all of our renewals. So we started licensing folks in May. So we should see this increase over time. When would you suggest that folks start their renewal process? Probably as soon as it's available. Our subject, I think that we start notifying an applicant that they are ready for renewal. One week, all right. 120 days, thank you, 120 days prior to the renewal being due is when we start notifying applicants and given the amount of time that it takes to make it through the licensing process, I would recommend getting started as quickly as possible after you've received that notification. Soon we'll have more information about how long it takes us to process renewals. We're anticipating that it won't take as long as it takes for a new application. But once we have data about that, we can share that as well. So don't wait until the last. Don't wait until the day before your license is due to expire now. Please don't. Okay, so this slide demonstrates our canopy or the canopy that we have licensed and it accounts for this is actually a projected or anticipated change in the amount of licensed canopy based on the renewal tier changes that we have in the queue. So as of March, you can see like on the left side of that wall, that's our licensed square footage of canopy, the dark green is outdoor canopy, light green is indoor canopy. And then the higher number on the right that's represented by April accounts for the increase in canopy size given the number of renewals that are in the queue. And this also is adjusted for our mixed and outdoor. So the outdoor square footage reflects the outdoor portion of the mixed license and the indoor square footage accounts for the indoor portion of the mixed license. And then this slide is an overview of kind of the total submissions the licensing team has received in the last month. So 65 new licensing applications or renewal applications, 421 product registration submissions and 107 employee ID card applications in the door in the last 30 days or so. Here's our retail locations map, which is updated. Reminder that the blue pins are licensed retail establishments and the red pins are proposed. So still in the queue retail applications. Here is our areas of density chart with respect to retailers. So we are up to nine licensed retail establishments in Burlington and that does include the integrated licensee in Burlington and four in the queue. And then every other town on the list has three or a potential of three. No one has exceeded three except for Burlington. Moving on to product registration. So we've got a total of 2,398 product registration submissions of those, a little more than 1,300 have been registered and we've got 256 applications currently awaiting review and 302 are incomplete. So this is the pie chart that kind of shows the same thing. The majority of products that are in the door have already been registered. Certain 10% have been withdrawn and then we've got 3% that are sort of under review and then the remainder are either incomplete or awaiting review. Here's our product registration by product type. So this accounts for all products that are all product registration submissions. So those that have been registered and those that are awaiting registration. So the majority is still flower but that concentrate part of the pie is growing rapidly. So we can do a comparison of that. And we've got a little bit more data from product registration. Okay, moving on to compliance data. So starting with advertising. So since we've been started reviewing advertising submissions in November, we've had 72 submissions in the door and our approval and denial rate is about half. So we are denying just a little bit less than half of the advertising submissions that we've received. And the majority of those have been denied because they don't meet the 15% threshold for youth audience composition. Staff is really doing a lot of training and education of our licensees to help them understand what is required to demonstrate that no more than 15% of the proposed audience would be under 21. And then failure to include the health warnings is the second biggest reason why those are failing. And then some of them have included prizes or giveaways which is prohibited through the advertising statute. Three lacks of vision information and two staff considered to be appealing to children. So those are the rationale that the staff has for denying advertising submissions. Those are ones that were denied because they didn't meet the audience composition is that partly because the data isn't available or just was insufficient or that there was data and that it didn't meet the audience composition. First two, so nobody has yet submitted data that shows that the audience composition threshold is not net. Primarily people who are hoping that sort of a narrative description of who the audience would be is sufficient. Okay, so this nifty little map is a representation of the distribution geographic distribution of our compliance agents which I thought was very interesting. So you can see the upper like the Northwestern quadrant of the state is split pretty evenly between Andy and Denise. And then the Northeast Kingdom area is covered by Chris. And then we've got the Middlebury, Bridgens kind of Rutland area is covered by Mike. Orange County area is covered by Dwayne and it's territories for all of the staff and that's where they wound up. So it's territories for all of the staff and that's where they wound up. It's impressive how many inspections they can do given the base that they're covering. Now there isn't a direct route for a lot of those dots. A lot of miles, right? A lot of miles. Okay, so yes, on that note, they are, this is a kind of summary of the last four months of inspection numbers. So you can see that in the first couple in January that we were around 75 inspections, February around 80 and then in March, we hit almost 90 and in April, we're down to 87. So I'm guessing we're probably gonna hover around that 85 to 90 per month inspections per month. And that will likely increase in the summer months as the cultivators are hitting their stride. We've issued 399 licenses. Yes. So we're hitting people multiple times. It's like, these are scheduled and unscheduled inspections. Yes, this accounts for both scheduled and unscheduled. They are primarily scheduled, but includes both. So here's just a breakdown of who we've inspected in the last month, primarily cultivation sites and retail sites. And then the average amount of time that's spent in these inspections, about three and a half hours for cultivation sites and around two hours for most of your license types. So a summary of other compliance actions taken in the last month, we've got eight new investigations since the last board meeting. That's a breakdown of what those investigations are about. We've issued two notices of violation in the last board meeting. And we've finalized one corrective action plan. Okay, moving on to medical program data. So this is the slide I always start with to demonstrate the numbers of patients and caregivers over time. And then our last 12 month slide shows that we are continuing on this kind of decline. Our total number of active patients is 33,570. So we've lost 18 since the last board meeting. We have gained about 35 since the prior board meeting. So we're going up and down a little bit with the number of patients. Have our active caregiver number right now is 196. So that does represent a drop off of, I think 13, the last one. Okay, that takes us for our recommendations. Ross, are there any questions on any of the data? No, I know we don't have unlimited resources. I know this is a project that our director of licensing wants to engage with, but do we know, are we getting a sense of people? Why they want to drop from the registry? I mean, I can guess, but I just wonder if we're collecting any sort of... So typically, when patients drop from the registry, they expire and they don't notice on us about their dropping from the registry. So you'll remember that the, I think that we conducted a survey of our patients for caregivers probably around a year ago. So we are hoping to undertake that process again as soon as we acquired our new medical program staff. So hopefully we'll have more information about those reasons for the board to review soon. It'll be really interesting if language at the legislature involved in the medical program does cross the finish line, how our ability is to kind of pump some life into that program. And one way or another might change those numbers. Yeah, I think whether it passes or not, I think we have to spend some time this summer really thinking about the structural issues with it. Absolutely, there's a couple of things in there that might help us along the way in doing so. So our staff recommendations starting with social equity status, there is one recommendation for social equity status denial for submission number 3643. Rational for that denial recommendation is that the applicant doesn't meet the criteria for a social equity applicant as defined in board rule. Staff is recommending two applicants for social equity status approval. And that is submission number 2745 and submission number 2851. Both of these applicants do meet the criteria for social equity business applicant as defined in board rule. And then we're moving on to staff recommendations for licensure. So all of the following applicants on the next three slides have demonstrated their compliance with both board rule and statute. So we are starting with CloudWatch applying for an outdoor tier one cultivation license, return to our roots farm applying for a tier one outdoor cultivation license, TMM dispensary applying for retail license, pow labs applying for an indoor tier two cultivation license, sweet green supply applying for a mixed tier one cultivation license, big bugs applying for a tier one manufacturing license, green river cannabis company edibles applying for a tier two manufacturing license, JMS farms applying for a tier one small indoor cultivator license, Valley Organics applying for a tier two manufacturing license, Grandma Mams Hill Farm applying for a tier one small mixed cultivation license, Bell Solace Farm applying for a tier one indoor cultivation license, Sun Grows LLC applying for a tier one outdoor cultivation license, The Farm at Bolton Dome applying for a mixed tier one cultivation license, Cabbage Collective applying for a tier one outdoor cultivation license, Darksboro Sativa and Seed Company applying for a tier one outdoor cultivation license, Pine Blue, applying for an outdoor Tier 1 cultivation license. Cold Hollow Cannabis, applying for an out mixed Tier 1 cultivation license. Bud Butter, applying for an outdoor Tier 2 cultivation license. Prospect Farm, applying for an outdoor Tier 1 cultivation license. Sweetly Farm, applying for a Tier 1 outdoor cultivation license. LGH, LLC, applying for a mixed Tier 1 cultivation license. FWR Inc. Applying for an Integrated License, Orangebeam Hill Farm, applying for a Tier 1 Outdoor Cultivation license, Hyand Rock LLC, applying for Tier 1 Indoor Cultivation license, Green Flash, applying for a Tier 1 Outdoor Cultivation license, Lavishly Sweet LLC, applying for a Wholesale license, Coach Grown Farms, applying for a Tier 1 Outdoor Cultivation license, Green Acres-Ramont, Cannabis, applying for a Tier 1 Outdoor cultivation license for 20 craft cannabis applying for an outdoor tier one small cultivation license. The remaining are renewal submissions. So these four businesses are being recommended for approval of their renewal application for full circle farm outdoor tier three cultivation armature of Wilcox tier one mixed cultivation Oho Roho wholesale and Sweet Rhapsody LLC mixed tier five cultivation license. And that's your list for this week or this month. Right. Any questions for Bryn? No thank you Bryn. You're welcome. So I noticed an integrated license on there. That's not a renewal. That's their first time applying. That's right. That was on the list of new applicants being recommended for approval. So because they missed that kind of head start window they don't make a contribution to the cannabis business development fund. They are not statutorily obligated to make that contribution given when they are applying which is along after the October 15th requirement. Any other questions for Bryn? All right. Is there a motion to approve? I move that the board accept each of the recommendations as presented to us by staff in this meeting. I will second. All in favor. Aye. Okay. We are slightly ahead of schedule but let's move through the agenda. Last thing is public comment and we'll just handle this the same way as always. If you join via the link, raise your virtual hand if you have a public comment. We'll try and call on you in the order that you raise your hands and then we'll move to the folks that joined by the phone. Hello. I'm an applicant for mixed cultivation and tier two manufacturing currently. I'm just waiting for my occupancy to submit my final application. We lost. Can you guys hear me? Sorry. Yeah. Sorry. We got you're waiting for your certificate of occupancy before your application is complete. Right. So with the deadline looming on the 27th, I guess I'm just curious and I'm asking for a lot of people here. We can submit anything. I can essentially have everything submitted with a narrative of what I'm waiting for on my town. Right. I've submitted all my applications for the town permitting and everything. They've been accepted but there's a 30 day waiting period. I'm just curious how the CCB is going to navigate all of these individual narratives that people are going to submit trying to come in under the licensing time. Do you guys have a plan for that? Is there anything that you want to tell us over as these licenses just kind of the applications just stream in over the next two or three days as people are trying to get in with the deadline? I'm just curious. It's something I've been working on for two months. And you know, when you guys hit us with a deadline at the end of last month, they kind of like, I don't know, put a lot of pressure on people, not just the applicants, but their attorneys and town zoning offices, contractors and everyone else. And I'm just hoping for some guidance on what that process will be if the application is complete, but there's still something pending that's beyond the applicant's control. Gotcha. Thanks, Bernardo. So we don't generally answer questions during this session. When the session's over, it looks like Brand may have a comment for you. Cool. Yeah. For the record, we announced this in February, not in March. Okay. That's two months ago. All right. We do recognize that there's issues outside of everyone's control that start impacting your ability to get in. Anyone else who are public comment? I don't see any other hands raised. Can you hear me? Yes. My question is, when will that document for the emergency rules be up so we can print it off? All right. My strong hunch is this afternoon, we have to do a formal filing of those and simultaneous to that. It will be posted on the Laws and Rules page and the board's website. Perfect. Thank you. Thank you. Good afternoon, CCB. How are you all today? Fine. Thanks. Great. Thank you. My question is going towards the medical program once again because I am a medical patient and I see that there's lack of progress here in the medical program. I did reach out to speak with, said Mr. Pepper an email a while ago requesting what protections medical patients have in the state of Vermont compared to other states and did not receive a response. I'm also very concerned that the medical program is dwindling down slowly and that when you guys have meetings, like I know Britain is going to be the state house tomorrow for the H270 meeting, that there's nobody being invited to these meetings from the medical program being represented when you're speaking about medical changes to the medical program. Like increasing this, there shouldn't be a medical program working group that you guys should start or fundamentally fund that would help all of us work with you guys and the legislature because we have currently no say and currently you have no staff as a medical program since you've taken it over that Meredith Burdick quit and Lindsay Wells quit as well. So currently we have nobody working there for us to represent us at the state house. I have written Scott Moore which is the person for the Senate and Economic Committee who possibly invited tomorrow. I did see that David Silverman is being invited but he is not a, he's a business owner and an attorney for several business in the state of Vermont but he's not part of the medical cannabis program at all. So we have no representation as medical patients whatsoever when you guys are discussing medical anything. Even when you guys are there at the CC board meetings that you are today and if you discuss anything medical during after meetings during your meetings like not this public meeting you should always have a medical patient available or a medical patient representative available because this is our program it's not just your program it's our program it's the longest program in the state of Vermont and it's been hindered by not making progress. This is one reason why you guys are not making, more people aren't registering to the program. We have zero protections. My medical card Yarl and Garrett and tease me basically tax-free cannabis. I sent you something from the legislative review from the Americans for Safe Access which I'm a member of as well that gives you a legislative panel of how do we represent to get legislative work done at the Capitol through you guys. You're, for me, you're my leading connection. I don't have another connection. I can't go to the medical community here and say what I want to say because they can't. I'm not invited to the legislature because they don't recognize medical patients. There's no counsel at the legislature body that says these are medical patients and these are what our requests are to improve the medical program here. There's numerous changes that need to be made to the medical program and it says stagnant from 2012 to 2023 with very limited changes. The only current changes you guys are having are increased bank accounts and I think that's great but if that gets passed it's wonderful but doesn't, I don't know what we're going to do but something really needs to step up to the plate here and really work on the medical program. The adult program is taking over and this is why a lot of people are frustrated and I understand they're frustrated because I'm one of those frustrated. I've been in this program for quite some time and I've been at the state house. I've been there when the hemp things have been done there. I've been there prizly. I've spoken to Virginia Ranfrew. I've spoken to Shane Lynn when he was a representative, an owner of a business. I've spoken to some other patients down here in the southern part of the state where we don't have much representation at all because I am way down the southern part of the state besides the wind up county here. I'm in Bennington County and there's there is a medical dispensary down here but because now we have two other dispensaries and we're 20 minutes from the Massachusetts border a lot of people go across the border to get their cannabis because the prices are cheaper and the quality is better and there's issues there. So I mean within a half hour drive I can go to four different dispensaries and that's that including the two that are in my own local community and one that's being established in Manchester that hasn't been established yet because it's still waiting for some permits. What were you willing to do and there's nothing on your social schedule for after hours about for medical patients whatsoever. Tomorrow there's no representation. Oh discussing H270 you know and I've written Matt Boring, I've written Michael McCarthy, I've written Mr. Sears, I've written spoken to Julie over the phone via the Microsoft Teams message. What is it going to take to have the CCB here get serious about the medical program? There are things that need to be done and they need to be addressed. I'm willing to come to Montpelier and sit down with you guys and discuss this. If you have an invitation for all of us I'm willing to do it. That would be a three and a half hour drive for me. Neglecting my special needs that is a medical patient in Vermont that gets cannabis that has no protections. She has no protections in schools, no protections in hospitals, no protections in nursing homes. I cannot use my medical cannabis cannabis in public if I having a PTSD episode or my anxiety is through the roof. I cannot, that's unfair to me and I know that's something that needs to be brought up. It needs to be brought up. I should not be isolated in prohibition to stay in my house to use cannabis or at a friend's house. If I'm having an anxiety attack in a store I should be able to go outside and take something. I should be able to use a cannabis inhaler which they make now, feed a gummy or take a couple hits off of my one-hater to make sure that I'm getting my medicine. No medical program is regulated like this one in the state of Vermont. None of them, zero. You guys have neglected us for two years since you've been in here. What do you plan on doing? Can you put out some works for us? Because I know you're going to dwindle in the medical program and that's just going to be non-existent and then I'm going to have to go to the adult use market and that's not going to be fair to me as a lower-income person in the state of Vermont that also has disabilities and gets medical cannabis. And there's 3,000 to 4,000 of us here in Vermont. We will never see another fifth dispenser because of adult use. So there needs to be changes and there needs to be protections and some other things and if you could write me Mr. Pepper that would be great or Kyle or Julie or even Bryn. I will send you information. I've done this repeatedly with you guys and I've sent you information from American Safe Access. Please look at appendix one. The state of Vermont last year was reported a D for the medical program. The year before Maine was ready to be. The ASA sent you a form and I know they did because Debbie Turing which is the executive for the ASA sent you the paperwork about you're upgrading the medical program what you're going to do. Their recommendation is to follow Maine's medical program currently again. And this is a national organization that represents patients for the last 22 years, 21 years. They just had their birthday the other day. I'd also like to make a shout out to a love scientist that passed away recently that's been a part of the Vermont medical cannabis community and the Colorado chemistry. Dr. Bob, no me passed away recently on August 19th April 19th. He was a great member of the medical chemistry, a great science researcher and he was right up there with Dr. Ralph Mockel. So if you have anything to say, Dr. Bob passed away and we blessed his service to our community, especially medical patients and he's no longer with us. So thank you and I'd like to see some progress on the medical program. Thanks, Keith. Hey, bridge, are you there? Hi, can you hear me? Yes. Hey, thank you. This is Eli Harrington. I was going to say something about the Vermont Tourism Summit coming up on Thursday, but you know, I think I think Keith's comments are pretty good for for refocusing and and thinking about kind of what we can do structurally to get medical some attention because a lot of these issues that he's bringing up have been discussed for years and years. So rather than sort of more talking about tourism in commerce, I guess I just want to stand in solidarity with Keith and also appreciate him sharing that update about Dr. Bob, who was definitely a huge figure in the scene. So best of luck and I hope there's something that we can do and something more that licensees can do to help separate things because you guys are trying to do a lot of different things right now. And I don't know if the solution is legislative or structural or what we can do. But thank you to Keith and shout out to the patients there. Anything else that we can do, please please feel free to contact and anything we can do as producers to help medical patients in the meantime. You know, if this is a shortcut, allowing donations, I know there are organizations that are semi formal running out there. I think it'd be super, super important. So thank you very much. Yeah, thank you, Eli. Thank you. This is Marielle Matthews. She heard from when you ski partnership for prevention. I just wanted to thank the board for passing the emergency role today. It's a big relief and we just appreciate your protection of public health in that regard. Thank you. Thanks for the comment, Marielle. Hey, everybody. I was calling and say thank you for voting on the closure of the indoor tier five. I think it's a really big deal that you did that. And thanks for listening. And I know early shows that you have the small Vermont cultivator and small Vermont business in mind by by taking that vote today. I just wanted to say thank you very much. That was it. Thanks, Nick. Hi, thanks for taking public comment. I have a lot to say, but I'll try to keep it as succinct and quick as possible. I wasn't going to speak to you, but of course I will. So I want to thank both Keith and Eli for speaking to the medical program. The one thing I wanted to just mention is that Bryn brought up the fact you're still looking for a medical program tech. I'm hoping to encourage you guys and to encourage adult youth business owners here in the state of Vermont to ask the same thing to ask you guys to include medical professionals in the medical program to ask legislators for money to fund that position, just like you asked them for money to fund other positions. And Keith is actually 100 percent right. We don't have any medical voices right now in the program or being allowed to testify to legislators. We have other people who are testifying against the medical needs of patients, but we don't have any patient representation. And I want to remind all the adult youth business owners out there that there is supposed to be a specific committee that has patient voices. And someone from that committee is supposed to be sitting on the advisory board, but we don't have that. So there is things in place, but unfortunately they're not in place to the point of actually getting those medical medical patients in program voices heard. What I wanted to actually comment on is the fact that we're really not discussing education very much in these meetings. I'd love it to ask you guys to host a round table. Maybe one for the medical program would be fabulous, as well as one specific to education. I'm one of the six Vermont vendor trainers for the state of Vermont. And most of the people I talk to don't know what education they need. Once they get education, they don't know what they do with that certificate, which is simply to have the retailer keep that on hand. People who are not working for a retailer like a cultivator and manufacturer and wholesalers don't necessarily even know the rules that they also need to be to take an education course. So I think we're really lacking information to help Vermont businesses remain compliant because they don't know that they actually need to have education. So if we could maybe do a round table or some kind of more information at some point to that, I think that would be really helpful. Also part of the rules is to have continuing education on health and safety, but there's no specifics around that. So we I believe are the only vendor trainer that have started that we are offering monthly health and safety continuing ed workshops to help people remain compliant in because we're seeing since October the issues that are coming up like cultivators not understanding their own COAs or retailers doing deli style, but not understanding they should wear a hair nut and have gloves and switch the gloves in between one strain to another. So I really hope we can at some point soon help Vermonters and cannabis employees understand the education that they actually do need and how important that would be. And then lastly just to comment on something someone else said, I would ask you guys to consider closing the tier five outdoor cultivation. We don't have a lot of that here in the state of Vermont. My understanding is one of the few that we have is someone that came from out of state and isn't a small cultivator in Vermont. So just as you're questioning the tier five indoor, I'd ask you to question the tier five outdoor. And lastly, I Marielle, I really appreciate you speaking up. I second your appreciation for putting consumer safety first. And I also just want to throw out there to Marielle and anyone else in the prevention industry that as a vendor trainer, I'm trying hard to get access for Narcan to all retailers and have that kind of education for our bud tenders. But we are hitting every roadblock in the world. So I also want to throw that out there to retailers who have come to me and asked for that education that I need them to also speak up and say to you guys and say to the Vermont Department of Health and other places like Marielle's place for prevention that you guys do support that work and want to be part of it and want the education. But because we are in cannabis, we are hitting roadblocks basically around stigma and fear that has been unfortunately kind of barring us from doing so much with this plant over the years. So I was trying to be succinct and quick. I'm sorry, I wasn't quick enough. But again, medical support anyway, we can do that and actually have medical professionals involved. If you guys would consider a round table for that, as well as a round table or one of these after hour events, I might not be wording it right to really include educators. So people understand the education that is needed, as well as looking at closing that tier five outdoor and somehow supporting retailers who are interested in but tenders to have the education around opioids and Narcan as well. So thank you guys so much for listening. Thank you, Jesse. Hey, am I coming through? I just wanted to, I guess, third or fourth now saying thank you to the CCB for being somewhat craft-minded and taking back the tier five. We've learned a lot for the first few months. And I remember when scale was getting discussed back before legalization passed, there was a lot of debate over whether craft or small scale cultivators would be able to supply the Vermont market. And I hope it's really clear at this point six months in that the craft community here has done a really excellent job and can more than fill the demand and market today and moving forward. So I would just encourage continuing down that path, taking a look at tier four, even as being slightly too big for really what the size of the Vermont market will be, maintaining competition in the market through having a small business, small grower focus and dissuading more predator business practices in other states that result in, at the end of the day, worse outcomes for us in our local communities. So I guess thanks. I hope you guys continue with that approach. And I don't think the job is done with that stuff. And I also wanted to underscore some of the medical issues and also offer up that maybe there's some ways the some some tax revenue with some existing adult use facilities can be empowered to serve medical patients better, whether that's rebates, coupons, things, discounts, tax exemptions, things that can help medical patients access high quality craft products from adult use dispensaries as well. And that's it. Thanks. Thanks, Josh. Hi, thank you. I was a little technical difficulty there. Yeah, I just want to thank you guys for everything you're doing. And I really appreciate you putting a pause on the tier five indoor. I think that's a really huge step to doing it the Vermont way. I think we're going to be doing this for a while until we get to a point where cultivators are allowed to take their product to a farmer's market and represent it just the way craft wine producers are or other people that are producing their products. So we have a little ways to go for sure. But I do think that's a good step in the right direction. One thing I think I thought was a step backwards was the packaging, the allowing humidity lids, the compostable plastic. I thought that that was a really good solution to the problem of plastics. And taking that off the ability for us to use that jar lid stuck me with the option of having to use a metal lid, which is definitely going to be thrown into the garbage. And it's kind of a bummer that you guys have taken that step. I thought that being that it was compostable was a good alternative. And at least it was recyclable. And it also had a child safety closure on the top there. Maybe not to prevent kids from getting into the buds, because that's not a danger, but it definitely prevents the buds from being spilled onto the carpet. So just for protecting the buds, that would be a helpful thing. But as I say, we got a long way to go. I think some of the things you guys could think about in streamlining your solutions to some of these problems is we're registering products. And when we go to register a product a second time, it's already registered in your system. So what's the problem with having a pre-registration of products? Why can't we get things pre-registered as soon as we get our COA? Just like a second time, we're done. We're ready to go. And why not register products for two years instead of one and have a reduced fee? Why not have a license for two years and reduced fee for licensing for two years instead of one? I think that those kinds of things could really help to get away this bottleneck that's happening. Increasing the quantity allowed in manufacturing products. If you take it from 10, milligram edibles to 20, you've just decreased the amount of packaging by half. There's different ways of streamlining. And I think we still have a little ways to go with all of that. And obviously, there's just so many questions that people have that when we have these round table events and they're an hour long, they're really just not long enough. I think there's just so many questions that people have that are just not getting answered. And they're just little things. Like when you re-register a product and you're getting your second COA, do you need to update your terpene profiles? Or is that good for a year also? A lot of different little things. So I think a lot of people have a lot of questions. And I thought maybe those things might help you. Hope they do. Hope you guys are all having a great day. Thanks. Bye. Thanks, Chris. Hello. My name is Riley Amarosa. I'm a state vendor trainer. I work with the Kenris Nurse Association where I do the clean green vendor training. Thank you again for having the public comment. I appreciate everybody speaking and advocating. But I did have one or two things I wanted to say. I wanted to thank Keith and the other people that spoke about the medical standards. I'm also a medical patient. I'm a young medical patient. I've been a medical patient for a few years. And definitely seeing the lack of standards and testing in the medical program is something that has always been very, you know, not, hasn't given me a lot of confidence in the cannabis that does come out of those places. And then with the regulated market coming out was fantastic, because we have a lot of other regulations that do ensure a little bit more quality and safety for consumers. But also it doesn't make it any easier for medical patients to get higher quality cleaner stuff, stuff that they know has been tested for pesticides and stuff like that. And again, I did want to speak to that and not only to that, but also that even in the recreational space, I still see people touching cannabis without gloves on and and opening packages and selling them back to customers and like, you know, things that really we should know better as a community, because there's a lot of cleanliness stuff that goes into this. And there's a lot of people that use it as, you know, as medicine. And there's a lot of people who use it with compromised immune systems and stuff like that. So we definitely always have to keep in mind. And it's it's it is something that as an educator as someone who would love to see the market grow, because we did start in a fantastic space and we're doing really well. I would love to see it grow in a way that I stop seeing examples of of not the cleanest practices. Another thing is is I think again, we do need a little bit more guidelines, a little bit more specificity on on the continuing education side of things. Also, again, I work in dispensaries and I see things and a lot of people leave their kids in cars. And it's it kind of adds to the education piece a little bit, because we don't want to continue and raise more stigma as, you know, my my to leave my kid in my car and my kid doesn't know what I'm doing. And, you know, we have child locks on all of our cannabis things, but you can walk into a liquor store right down the street and there's not a child lock on a thing of odd. And you can bring your kid into that liquor store while, you know, with cannabis at consuming THCA. Again, the odds of a child getting two cannabis somehow in the store are obscenely low because we are so careful about, you know, protecting everything. But also, the THCA doesn't do anything to you like fun like, you know, eating it like if you eat weed, but you can walk into a liquor store again and the kid can get a hold of something. It's just something that we see, especially as the hotter days are coming up, we're going to see people leaving their kids in cars. And it's definitely something that I think about a lot as a working in dispensary, along with the fact that we need to do more for public education and help people kind of navigate the market more and there needs to be overall more, a little bit more education. But thank you. I'll get off my soapbox. I appreciate everybody for speaking and advocating. Thank you again. Hello, board. For the record, Jeffrey Pizzatello, executive director, co-founder of Rock Growers Association. I hope everyone in the agency had a good holiday last week. I want to say congratulations to the licensees that were announced today and the renewals. Got some familiar names in there. Appreciate all of the work that the board does. I'll be brief. This has been a long public comment period and I appreciate the board's allowance of such. I just want to extend gratitude from our organization for today voting to close temporarily Sunset Indoor Tier Five. As you know, we haven't been supporters of that for a while and we look forward to this agency revisiting in the future, possibly closing Tier Four Indoor as well. We believe both of them should be Sunset and the Indoor production cap should be 5,000. So thank you again expressing gratitude. And lastly, I just want to stand in solidarity and support a lot of the medical commentary that you guys have heard today. Being mostly an adult youth organization, we just want to emphasize that we are aware of the legislative environment as you guys know, but we would like to emphasize the prioritization of medical. Even if that means restoring the qualifying conditions that we lost in 270 this year, even if that means revisiting the program with a more sweeping piece of legislation next year, we look forward to working with you on these issues. And thanks to everybody that raised them today. That's it. Have a good day. Take care. Thanks, Jeffrey. I don't see any other hands raised. If you joined by a phone, you can like and would like to make a public comment. You can unmute yourself by hitting star six. All right. Last call for public comment. I will close the public comment window. Thank you all for your engagement, for paying attention to what's going on, for letting us know what's going on. I just wanted to address the question very quickly that we heard at the outset about people that have a pending mixed or outdoor application that might not have all their the application might not be fully complete because the things that are outside of their control. What we've said is that you need to get your application in by this Friday. The team here will work with you to make sure that it's complete. If you kind of through your own just negligence or not trying to move the process along are not substantially complete by July 1st. We will dismiss those applications. Bernardo, just work with us. We know there are things outside of your control, whether it's fire safety or local approvals. Just get your application in by Friday and then just work with your licensing agent. Let them know what's going on and we'll make sure as long as we can kind of get everything squared away by July 1st that we'll get a license to you. On the medical program we are in full agreement that it needs some serious overhaul, a structural overhaul. We have very little control over it. The statutes have not been revisited since I think 2017 and even then there's a very minor adjustments that were made. We put in a bill based upon a tremendous amount of public input last year and it didn't even get a hearing and we don't control that. This year you'll see that there's some modest changes that may have some big impacts that are being considered most substantially is the legislature which at multiple times when I was testifying questioned the need for the medical program at all now that we have an adult regulated system and I think there is a report that was put in to the H270 that is going to ask the cannabis board to propose a fundamental restructuring of the medical program and we're going to do that by the end of the year based upon the feedback that we get from patients and caregivers and through these meetings and through round tables and we haven't done a medical program round table or rule rewrite yet because until H270 pass our hands are tied with respect to what we can actually do to change the rules and I think it's our goal to make some substantial changes this year and then recommend that the legislature makes some substantial changes next year to make sure that there is continuity of services and continuous improvement to the program with respect to some of the sanitation complaints you know please just email us you can do it anonymously you can kind of just drop a line on our website but be specific so we actually can follow up on them you know if you're seeing people that are violating basic sanitation at a kind of adult use dispensary just let us know about it and we'll go check it out and on that just very very quickly if you see that our regulations are not clear or lacking in sanitation we do have our proposed rules open right now please submit comments officially or or email them to us or general counsel or brand so we can discuss them and figure out ways to to make sure that that bright line is you know up to everybody's standards through the portal is probably the most effective way sure I think that's what you're trying to guess you're right yeah yeah because I I know that our team is keeping track of the comments that come through there right all right um anything else before we adjourn yep thank you everybody all right um well I'll adjourn the meeting for today and see y'all next month