 Last week's call. So, yeah, again, Chris, you want to run a motion over one minute. Second. Perfect. All right. So, I think that is done. And so, the, as I just sent in an email, the vast majority of today's call is going to be going over basically the culmination of what we've been talking about so far, the license types, and then the fees that we, you know, I guess our draft proposal fees to put before the subcommittee for feedback. And we put it, as we've talked about a few times, two different fee proposals, one of which meets the statutory requirements of, or estimate, could meet the statutory requirements of covering costs. And then the other, which is maybe slightly lower fees to try to increase the amount of folks who can access the market. So, Andrew, if you want to start getting ready to share that screen, I can kind of start running through like what we've done. So, we're just going to operate right off the PowerPoint, I mean, right off of the spreadsheet that's all, that's all right with everyone. The first thing I just want to say is that while this is a, you know, our proposal on fees, it's not the only proposal on fees that's coming from the advisory committee overall. What we haven't done here is take into account for the social equity subgroup and some of the other subgroups that are working on issues of fairness and market access. And I know that they are working on reduced fees or eliminated fees for certain applicants. So, what we tried to do here was build a structure out that kind of meets the statutory requirements over the covering costs, but would also be compatible with your equity coming from that group because obviously that's an important part of this program and also another statutory requirement to make sure that there's reduced fees. So, as you look at this, I don't want you to say where is the social equity aspect of it or where is the discount that's required by the statute. That will be recommended by another subgroup and I'm not, I think they're talking this afternoon, but at some point we'll try to merge the two proposals together. But having said that, I guess, having said that, we did try because comments from this group and the public comments that we've received have tried to push for low fees generally and for a market that prioritizes incorporating smaller growers and smaller businesses. So, particularly our fee proposal A is the one that we have set slightly higher fees because we know we need to try to hit those cover those costs. But in our fee proposal B, which we'll get to later, we tried to have pretty low cost to make a market more accessible to all. So, before we get into the actual parts of this proposal, I just want to run through a few things that made this process a little difficult and that the subcommittee members should keep in mind as we start evaluating them and adjusting them if need be. The first is that there's a lot of variables and unknowns in this area. We've tried our best to project a whole bunch of things into the future, but if you give me a, I'll just kind of run through some of our assumptions and some of the things that we did to try to address that variability and uncertainty. The first thing being, obviously, don't have a perfect budget summation of what the CCB is going to have for a budget over the next 10 years, but the statutory requirement is to cover costs for 10 years and payback deficit. So, kind of we try to create like a little shorthand work around there where we took the budget data that we did have and projected out a like a 3% cost increase at least for the first couple years to try to estimate like a potential median point for what that budget could look like in out years. So, yeah, Andrew went over there so you can kind of see where we did that. And then, because we also don't know exactly where the deficit is going to be after, because obviously as we've talked about, it's going to cost a lot more money to start up this organization before there's any revenue coming in. So, there was a, the legislature had a fiscal note that said there was $1.8 million that they anticipated being a deficit as of after FY 2024. So, that's the figure that we used and then for our, to try to figure out the cost to payback, we spread that deficit out over those next seven years for payback purposes, if that makes sense. So, the two figures you see there is basically the cost that we think we would need to hit to cover costs for fees and then the cost that we think we would need to hit in order to both cover costs and payback that initial outlay of funds to the Cannabis Control Commission or Cannabis Control Board. So, that is, that's kind of our baseline. Again, there's a lot of guesswork there. And I imagine that that's not going to be the exact dollar amount that the budget will be, but we thought it gave an estimate to aim for and so that's kind of what we're using. And then also, as you see, it goes up, but to simplify the math, we basically have aimed to have to meet those figures in FY 25 for a couple of reasons. The first one being that in the early years, you're going to have a lot of businesses entering the market, so it's hard to tell which year they'll actually be in, but by FY 25, hopefully a good chunk of those businesses interested in joining the Adult Use Cannabis Market in Vermont will be up and paying annual license fees. And the second thing is that, as we've talked about in previous calls, there are other license types that we may want to look at in the future, like delivery, co-off, things along those lines that could provide additional revenue in the out years. So for the purposes of this, I think what our goal was was to aim that by 2025, fee revenue would be equal to cost or equal to cost plus payback of the deficit. So that was a long-winded explanation of the target that we're aiming for. The other major variable is that there are, it's hard to tell exactly how many, what the demand for opening up a business in Vermont is going to be. This is something that we've talked about a lot before as well. So how we tried to get around that was to, we created three different dynamics based on how many businesses we thought might be enter, might want to enter. Dynamic one, and you can see them in this column, the first column is Dynamic One. This is a market that would have very robust interest in starting cannabis businesses in Vermont. If this is the sort of interest that we have, then we will be certainly fine hitting all of our fee and canopy requirements. So this is probably a very aggressive amount of interest. The middle dynamic is probably a more reasonable one based on our estimates. So that's been the one that we wanted to make sure hit the fee limits as best because I think that's probably, if we had a project, would be closest to what we think the projection would probably be. And then the final one is basically the, not doomsday scenario, but the not great scenario. There's not a lot of interest for various reasons. So this is kind of where it would end up. And in this situation like that, the board would probably be looking at bigger ways to get more people into the market, either through lower license fees or other incentives or things like that. So that is quite a bit of a rundown on background of how we built this model and how we tried to take out some of, or address the ambiguity. So I hope that makes sense to everyone. Are there any questions on that before we start going into what we did here? And I think first, because we never finished the license type discussion, I'll start by just going through the license types and then we'll go into the fees. But I'll stop for questions because that was probably a lot and I probably need to catch my breath. All right. Hearing none, we will go into the fees, I mean into the license types. So Andrew, if you want to just scroll up to the top, you'll see that on the left-hand column here is where we put all of the different license types that we think could be offered, or I mean there's obviously other options, but this is what we would, this is our draft proposal as of now. The goal here and Andrew Jen, feel free to jump in if you want to add anything, but the goal here was to try to create a market that was heavy on smaller cultivators and try to create a market that allowed for more opportunities rather than a couple of large companies entering and dominating the market. So we had both a hearing for outdoor cultivation and indoor cultivation. We started, I guess starting at outdoor, we envisioned three immediate tiers and a fourth tier that would be delayed a little bit. So tier one would be that under a thousand square foot cultivation tier, that's kind of the small cultivator from the statute. And then we had a under 3,000 and an under 6,000. We also put in this under 10,000 square foot, but in brackets there you can see it says delayed. We were thinking in this and for indoor that we would propose starting with small cultivation tiers to begin with overall, but provide the board opportunities to in the future expand to larger tiers. That could be for a couple of reasons. First one being one of the small tiers, one of the guys in the small tiers doing a great job developing a brand that needs to need to expand so they should have the opportunity to grow as their business grows. And the second one being a safety valve if the market for the small licenses doesn't develop the way that we hope and some people think that provides an opportunity to provide some larger cultivators if needed to meet the demand of the market. So those are the tiers for outdoor. Maybe I'll stop after each one and just pause for questions. So outdoor cultivation tiers, those four tiers, does that make sense, any thoughts? And again, we'll just go through the license types first and then we'll go back through the fees. Stephanie, I wanted to compare the fee proposal and I have to look at statute as compared to the hemp proposal because it may be cheaper to grow 3,000 square feet of cannabis than it is to grow. So let me just compare. I'll get back to you. I'm going to look. Yeah, that sounds good. Yeah, I did not. And again, we have like at most fees are the annual renewal license fees and annual renewal fees. There'd also be application fees as well, like one-time application fees. But the numbers that you see in that column are the annual fees. So we try to keep them low, but we'll make sure that we try to align it with the hemp fees or not create weird dichotomies in state statute and state fees. So check on that and let us know. And then for indoor cultivation, same concept, only more tiers and going higher up in total cultivation. In that, the tier four, the 10,000 square foot would be available right off the bat. And then in this model, and this is where some spot where we differ between fee proposal A and fee proposal B is that as we're starting to try to figure out how we make the numbers work for to meet the budget, it looks like we might need to add in this higher fee, higher tier in proposal A to hit the budget number. So we would allow up to the 25,000 square foot facility in the first round. In some of the other proposal B, we actually have that tier delayed. But for proposal A, we thought when we tried to make the revenue numbers and estimates accurate, I think we might need to have that larger tier available immediately. And then also we wanted to have that larger scale, 50,000 square foot facility again available for the board if needed. Or if any of these companies grow and exceed, we want to try to build in as much flexibility for future growth as possible. But that would be something that wouldn't be eligible for people to apply for off the bat would be available day one from the market. So I'll pause there again to talk about that for the actual, I guess do you have any questions about the tiering structure? Do those tiers seem to make sense to everyone? Do they have any questions about whether there needs to be higher or lower tiers? You'll notice that we've talked about before creating like tiers below that thousand square foot. Again, we thought that that probably wasn't necessary because we're trying to keep the fees low for a thousand and under. And it's not, there's not a minimum requirement. So if you get that license, you don't have to grow a thousand square feet. You can build your business however you want. But our goal is to not try to create too many small license just to try to keep all of those small licenses more affordable. But again, open to comments on that. Thanks Dan. I also wanted to jump in and just mention that in this case, I think it probably makes the most sense from a producer flexibility standpoint to have the cultivation square footage be on total cannabis road, which includes veg space and flowering space. So a good way to think about it is the flowering canopy is going to probably, it depends on indoor, outdoor type of growth and things like that. Probably about 50% of the cultivation square feet area. And that also accounts for, you know, not necessarily hallways in rooms but portions of rooms that you're not going to wall to wall with plants. And so with this sort of thing, you know, we end up with a total amount of about a little over 900,000 square feet. And this is a, we could probably bump this down a little bit. This is the upper edge of, you know, what I'm thinking might be needed as far as flowering canopy square foot. I'll let the other subcommittee know that I did a new revised version of the pro-former model, of the market analysis model back to the CPD yesterday, given some potential changes based on interpretation of product selection may actually increase total square footage needed, probably somewhere closer in that 400 to 450 range than in the 300 to 400 range. And just one more note about that, just a thing that we haven't added to this model yet, that cultivation figure that changes as you adjust these number of licenses and things along those lines in this model does not account for the existing businesses or what will be the integrated licenses. We just haven't added that dynamic to the model yet. So as you're looking at it, it should always be like, add some square footage, add some capacity there because it's just, it will be underestimated slightly because of that factor. And James and others, I know we've course gone back and forth and I've been course going with Lindsay Wells as well. But if it's possible to obtain exact information on the amount of cannabis cultivated by these decent operators or square footage, I obtained some of it directly from the cultivators, but not enough that I could provide it at the state level, then there's a limited number of cultivators that I didn't want to provide any potentially identifying information. But that is going to be paramount to truly understanding what the market may look like at transition and over those initial growth periods. Thanks Andrew. Any thoughts, any other thoughts on the cultivation hearing before we bounce to retail licenses? It's fine with the hemp indoor cultivation. The over 500 square feet is $2,000. So it seems to be aligned with the smallest size of indoor cannabis cultivation. So it seems fine. The other thing I wanted to ask is the, or bring up is that I understand that cannabis products may include some portion of hemp CBD I guess in the formulation of those products that are sold to the market. And whether or not these licenses or is there a potential for licenses to include canopy that is grown for CBD but might not, but might meet the definition of hemp. There's a fair bit of, I think under the USDA domestic production program it'll be difficult for a cannabis cultivator to also grow hemp in the same location. Maybe on a different property it would be okay only because inspectors in the hemp program have to have full access to all cannabis plants growing and or in storage for the purposes of sampling. And I think that in itself will limit the ability for cultivating both of the same plant, yet two different plants in the same location. Yeah, I mean, I was envisioning that being not done in the same cultivation facility for the reasons you mentioned and just because generally the costs of operating these facilities would normally lead to trying to reduce the higher value product inside of them. But like I was thinking that we would in the regulation just allow for kind of an input ingredient so that products from the hemp lane could enter at various points into the marijuana lane, I guess. But I don't know, Andrew, if you have any thoughts on that or Jen, do you think we would need to try to create some sort of like variable cultivation canopy limit? Like I would think that if a company wanted to do both they would probably have separate facilities for that property. Yeah, yeah, that's entirely possible. I was just thinking of a streamlined, because it is the same plant and if at some point in the future it becomes legal nationally then we're setting up a system of two different. But, you know, we have time, I guess, to address that in the future. I was just thinking outside the box for a streamlined process and less confusion and potentially even less money for growers generally. But that's okay. No, I mean I like thinking outside the box and I wonder if there's a way that we could, I mean you could obviously grow, because it's the same plant, you could grow hemp under these cultivation limits. So you think like you would want to be able to like, I don't know, actually a lot of it's probably going to depend on the exact definition of how we define this canopy, I would think. I don't want to, I'm kind of thinking, as you can tell from my positive, I'm just kind of thinking through it aloud. I'm not exactly sure how we would approach it. But that's a good point and we can, maybe we'll think more about it going forward and see if there's a way that we can try to make, basically build in and to anticipate future changes at the federal level so that the Vermont process can as quickly as possible streamline to kind of the new reality, pending federal legalization. But we'll try to think about that going forward. And Dan, Chris Walsh here, I mean this is really only applicable to the outdoor cultivation licenses. You know, you're really, you're probably not going to get people using kilowatts to be growing hemp indoors. Yeah, that makes a lot of sense. So maybe for the outdoor cultivation, we just have a separate, because you might be able to, that's an easier problem to solve if we have to. You can just say that your cultivation for adult use cannabis doesn't, your square footage is only that, or you can co-locate with a hemp facility and your square footage for both programs don't count against each other. Something along those lines. That's right. Yeah. So that's good. Any other questions just on the, basically the scale of the tiers? Like these are obviously much lower tiers than you see in a lot of other states. But we thought that that was one way to encourage more businesses to enter and also like more small businesses to enter and also just the market here is going to be smaller than the other states. So there's not a need for, you know, a bunch of 100,000 square foot facilities. So we think this should work. But again, it's a lot of, one of the things that I think is important that we have included thanks to the guidance from the board here is that what we've called either the very between calling in a provisional license or like an intent to apply basically early on provide some sort of, so here it's called a provisional license, but it's probably more like an intent to apply. It's basically a way for the board to get an early estimate of interest in cultivation. And if we don't see the, if we don't see the interest that we would want to see, you may want to kind of reevaluate like how we're going and probably see if there are, if there's a market for some larger facilities in order to maintain, to make sure that we hit demand. But so we thought that that's kind of our two-poor flexibility here was we wanted to build in other higher license sites that aren't authorized from the start, as we've already talked about and then have that provisional process so that you can get a real quick gauge of like, oh, there's a bunch of people who are interested in opening up, indoor facilities of 5,000 square feet or less. You might be all right for your demand. If only a few of those trickle in, you probably want to reevaluate how you envision the market and try to see if we can entice some other folks to enter the market, whether those are little guys or big guys, just anyone who can service the demand. So that's kind of the rundown for cultivation. I'll move on to retail, which we already talked about a couple of days ago, if there aren't any other questions. And then we'll jump back up to fees. All right, retail is pretty simple. We had retail storefront, which is what everyone has talked about before. That's the retail store that everyone's thinking of that sells adult use products to folks who have been ID'd entering and the sales go into the sales tracking system. The seed and clones, we also talked about this. I think it was a week ago today. That would be selling seeds and clones. That would be not selling finished products, not selling any adult use finished products or flower directly to consumers. Those are the only two license types that we factored into this spreadsheet, because as we talked about on the last, again, a week ago, there was two other license types that we think could be viable for this market and could be a real help to increase access to products, but they'll depend on the other security requirements, input from other subcommittees, things along those lines, and we're happy to keep trying to work these out, but didn't want to factor them in yet. One is that limited retail facility, which would be part of an existing business. The model here is to give a boost to the general store by letting them secure one area of the store while a limited number of adult use cannabis products. As we talked about, there's quite a few things left to figure out exactly how that would work, but we think it could be a really good model for Vermont's both culture and demographics. There's a lot of towns in Vermont that probably can't support a full storefront, but could probably support a limited sale from one of their existing stores. And then the second one is the retail, the farmer retail, which would allow farmers to sell a limited number of products directly to consumers, whether from their farm, like from their outdoor cultivation facility or from farmer's markets and the like. But again, a lot of security requirements and things to work out, so we didn't factor them into having licenses in this round to be safe for projecting caught, but I do think they're both viable and valuable license sites going forward. So probably in this subcommittee and probably with other subcommittees, we should further explore how that would look and how to go, but I included them here for fee setting purposes, but not for factoring into the overall cost. The other two license sites are ones that are future-contemplated and I didn't include in the spreadsheet, but it seems like we need more discussion about delivery and kind of like a bent and on-site consumption purposes. So we have a tab for potential future license sites. They're in there, they're just kind of, I guess, in the holding pattern for now while we figure out how to go forward with those, but kind of stuck to the core license sites for the job of projecting fee revenue. So does that make sense? Everyone, that's kind of, I think, what we talked about on the call the other day. Dan, Chris Walsh, just trying to get clarity. Why are we having the seed and clone license be exclusively or mutually exclusive with the regular retail instead of giving retail the option to bolt on that secondary license and what's the logic of keeping fine-finished flower separate from clones and seeds? I don't actually think we've decided whether or not, like I don't think we've actually talked about it, so I'm glad you brought up a good point here. Again, with all of these license sites, they haven't fully been defined in statute yet or I mean they're not defined in statute and they haven't been defined in the regulations yet, so it's kind of up to the board on how they would like to, which kind of what activities or retail license could have. So you could have a retail, you could allow retail facilities to do both. I recommend that because I don't think, and I know these metrics pretty well, I just do not think with the limitations that home growers have that there's that much money generated. I mean all you could really sell per customer is seven clones and seeds are very expensive. I just can't see a standalone brick-and-mortar sustaining any sort of success just selling seeds and clones, but if it was a secondary up-sale, if people are coming in to dispensary for finished product, you see in other states, and I think there's a reason why they combine it like that. Yeah, so to kind of elaborate on some of this, I think when Dan and I and Jen and others were thinking about this, a normal retail for a front would be able to sell seeds and clones, so the normal retail for a front license would be all inclusive of products and flower and seeds and clones, and the seeds and clones license would be a smaller license that probably would be either utilized by a, say, a garden store, wanting to sell seeds and clones. Or a grow store, yeah. Or a grow store, or maybe a locality wants to allow cultivators to sell seeds and clones, maybe not full-thought, and so they're able to sell seeds and clones from their pharmacies because of the lower security costs associated with not selling dried flower. So we kind of had a vision that seeds and clones, that would, I agree, would not be able to sustain a standalone brick-and-mortar store. It would probably be added on to either existing floral shop garden centers, existing grow centers, and maybe cultivators if that is permitted. The other thing we need to consider is, until we figure out this nursery license, there are going to be cultivators, especially year one, that want to hit the ground running. So if you're just a regular over 21-year-old that wants to buy seven clones and grow them in your basement or in your backyard, we should have some sort of way to distinguish a license holder because, theoretically, I think you could have people that are going to want to buy a thousand clones per purchase. Are you talking about other cultivation license to you? No, I'm trying to sort of figure out a way where, you know, the seed and clone license makes a lot of sense, but you have two different customers or clones. You have someone who's just 21-years-old who comes into a store and he wants to buy seven clones to grow in his backyard or in a tent or something, but you, you know, and this goes to that nursery license, which to me isn't really defined yet. You know, you may have somebody want to call the store and make an arrangement to buy an entire flat of clones because they have a tier one license and they want to grow 100 plants. Yeah, so typically that is done from the cultivation to cultivation. So, you know, I don't know whether or not there needs to be some stack store change to allow this and kind of what the dynamics are, but ordinarily in other states, essentially a cultivator could not go to a retail store, like let's say in Colorado, a cultivation facility owner could not go to a retail store, buy clones from retail, and then use those to populate their inventory. They would have to go directly, essentially, from a cultivation facility and do an inventory-to-inventory transfer in that regard. So, I mean, I actually think Chris, I think that makes sense, Andrew, but I think Chris brings up a good point and I think it's one that we can fix in through the regs though, because I think he's looking at, you know, even for somebody with that smallest outdoor license, you know, maybe we do let them go to these seed and clone stores, but there needs to be a way to differentiate between somebody who's actually already licensed to possess enough, like to grow a whole thousand square feet outdoors versus the, you know, just your normal home grower. But I think we can do that through the regulations later. You probably just have, you create like a purchase limit for the seed and clone stores where basically like if you are a registered employee of a licensee or like if the sale is to another licensed business, you have a higher purchase limit than if you're just a... Well, just to kind of follow up, if we don't figure out this nursery license for year one, then when you say you can buy a cultivator, cultivator, it's kind of like a chicken or the egg. Like year one, no one's going to be up and running before anybody else except for the vertically integrated and even if they could sell more than seven clones to a license holder, they're never going to be able to fulfill the demand. So you have, you know, a couple hundred licenses, everybody's dumping money into their infrastructure and they want to hit the ground running. They don't want to like pop seeds on day one. They want to like get plants growing. So, you know, there's going to be a huge demand for startup plants. And I just, you know, I'm thinking throughout this whole process like where is this all going to come from? Unless people are growing illegally, you know? I mean, you've got a 5,000 foot facility. Your license doesn't kick in for two months. You're building everything. Where are you creating your actual plants? Where are they coming from? Because no one's going to want to pop seeds. Yeah. I'm going to look up the law for a second because I'm pretty sure there is a potential allotment in there for the small cultivator dynamic as far as painting cannabis. But what I will tell you is that while this is a conceptual problem in every single state in the country, it is not actually a market implementation problem. To try to read between the lines there. Yeah, I'm reading between the lines. Yeah. It normally, you know, normally ends up working itself out without too many questions being asked. But the, I think, but Chris, I think you actually bring up a good point in that we could try to bring a good chunk of this or some of this above a board through if we do a good job of setting up the seeding clone licenses early and figure out how to structure their sales to other nursery licenses or other outdoor cultivators early in the process. So I think that's something that we should work on and that the board should look at, trying to figure out exactly how to design that so that that license can serve both kind of your hobby grower and also some of your small outdoor cultivators who will be looking for clones as they start out. And I think that's great. I agree with that. Just to add one last thing, I would also highly recommend that that license type is, you know, and the cadence of licenses that goes out early similar to the laboratory so you don't get bottlenecked. Like that should be, that license should come out before some of the other licenses. I think lab licenses is number one so you don't bottleneck the program. But large-scale clone sales should be right behind that, whether that's nursery or seeding clone. Yeah. I think today we have not seen large-scale seen in clone businesses as a standalone cultivation be prevalent in all that many states. And I think that is because of some of the dynamics that occurs both the profitability of the cultivation license as well as some of the issues we discussed, you know, right previously. There are some states that allow existing medical cannabis patients to transition over, you know, clones for a set amount of time as a period if you are really concerned about that. That may require statutory change rather than just regulatory, but there are examples of other states making this work for that kind of intervening period that is more complicated. So I took notes that we should work on that and of course I agree with the timing and the concept here. So we should add that to future conversations and remember to remember when we're drafting the regulation. I just want to move on for the sake of time to just at least run through these license sites. And again, most of Monday's call is also going to be reserved to kind of go over this because I figured we'd run. This is kind of the meat and potatoes of what we've been talking about for the last couple of weeks. I figured we'd reserve more time to keep the conversation going. But the next one with the manufacturing licenses, which I guess similar to the retail and fees and clones is basically two licenses. Tier one allows you to do everything. Tier two is limited, so you basically are allowed to... So it's not that you wouldn't have to get both if you wanted to do everything. It's just that Tier two is basically... doesn't allow the solvent-based extraction or the CO2 extraction, so you're able to basically make confused products but not have the full manufacturing capabilities that others do. And then the last three license types, just to get them on the board because I think this is where we ran out of time. What we could go to is the integrated license, which we I think everyone knows about, which is the existing businesses and the wholesale license, which could be an interesting license type, but in the statute it looks like most of the other businesses can wholesale as well, so there probably won't be a ton of demand for that just because most companies will want to just do... but there will be some demand. And then testing laboratories, which Chris already highlighted what those could be an issue that we probably need to work through further because we need to make sure that we have enough testing capability to not create bottlenecks at the beginning. So for our purposes here, I think the only reason to talk about it is just that we wanted to keep testing fees and application stuff below because we wouldn't want to scare off any potential testing labs from the state because we would obviously want to bring in as much testing capacity as we can. So those are the rest of the license types. Any questions on that or anything that you think we're missing? Stephanie, I see your hands raised. Yeah, I just wanted to mention that the HEMP program has a lab certification program and the cost to become a certified lab annually is $1,500. So I just wanted to clarify whether... And that is a Cannabis Quality Control Program, which includes we have set standards for contaminants and cannabis in addition to HEMP. And I just wanted to make sure I understood that this would be a cost over and above a certified lab or is it that we currently manage at the agency? And this might be an open question as well. Yeah, it might be one that we wanted to... We should probably coordinate on that. I don't know a ton about... It seems like if those labs are qualified and approved to do this, I wouldn't think that they... I guess it's up to the board and up to others. I wouldn't really want to just keep hitting more fees on testing labs. I think we want testing labs. So if we all feel comfortable that the accreditation needed for the HEMP program would be fine for testing adult use of medical cannabis. I think we could align the fees properly so that they aren't paying double fees. Does that make sense to everyone? Yeah, it definitely makes sense to me. Stephanie, just a quick question. What do you think the HEMP testing labs that exist in the state first, do you know how many there are? So we currently have two labs that are certified to do testing in the state. One for, well, three, actually. Two for potency and one for metals and other contaminants. And we suspect we'll probably get at least two more applications in for lab certification within the state of Vermont and potentially more. We have at least eight labs that we're interested in participating in an interlaboratory survey or study for their practices. So it could be up to eight. I mean, given, I've done quite a bit of research on lab testing and lab markets. I think that's that great paper for NCIA a few years ago. I do have serious concerns about whether or not Vermont's market is large enough to sustain a healthy lab testing market itself. Like you need a certain number of amount of throughput to sustain a lab and you need enough lab to be competitive. So I, as much as possible, would love to see the labs that exist in the state in any new labs be able to service both the HEMP and marijuana industry. And so I don't know what hesitancy those existing testing labs may have to work on both given as federal law progresses it may be additional scrutiny on testing laboratories. But kind of just one of your thoughts there, Stephanie, you know, it may require to a certain extent for the health of the market for those labs to be able to open their arms to all types of cannabis to see if regardless of its CHD content. I do believe that's possible that some of the existing or at least one of the existing labs may be interested in that that we have certified. I mean they will have to be DEA registered as well under federal law. But my understanding is that in the state of Oregon that the health department there certifies labs or credits labs and those labs both test HEMP and cannabis in that state. So I don't know that the I mean there's still potential a problem with DEA registration but I think my understanding is DEA is willing to work with those labs and with these industries understanding the same plan. Hey, this is Chris Walsh. I just wanted to add to seeing this in other states and I actually talked to Tom, the owner of BEA Diagnostics but you know part of the hesitation about you know too many labs not enough business is you know we really need to change the philosophy where we should make it available to everybody including home growers. I mean I think is the multi-panel test kick in because right now with the medical license holders you're only testing for cannabinoids. Once you start testing for yeast, mold, solvents, heavy metals I think that's going to rub off on even home growers and people want to know what they're inhaling. So like if we can have nurseries take samples it's like a kiosk for labs or growth stores. I mean I've seen this in Rhode Island and a couple other states on the East Coast and it definitely adds tremendous amount of business. I mean the market for home growers is potentially huge in Vermont. Absolutely. I think that's a good point. Yeah, definitely a good point. I have one other question. I'm just jumping all over the place because I have ADD. On the manufacturing licenses I just want to get clarity not to sound like I'm getting caught up in semantics but if I was a tier two manufacturer I could still make bubble hash and rosin, correct? Because those are solveness? I personally think so. This is all up to regs but I was thinking that the tier one would just be for essentially a higher risk. Right, yeah you're not going to blow yourself up making bubble hash. And so typically with this, there's another question too with this different state of data whether or not even making bubble hash is something that a cultivation license can do as part of processing similar to rolling joints. I think that is probably more of a reason to push that into a tier one or tier two manufacturing license but normally I was looking at this in a similar way that I think California does which is granted for other states that allow for hydrocarbon base extraction I also put that in that tier one but given that tier two requires such high pressures then it is still dangerous and so you're really dealing with the difference there whereas a tier two could make like topical lotions in which they're just using an alcohol like alcohol without pressure or I've seen people do where they're just using a prop pot not the same level of danger as a tier two license. So tier two would be manufacturing without the safe room. Yeah, yeah you probably would not need the same degree. I mean you need a fire inspection anyway but you probably wouldn't need a certified engineer or things like that. This is all to be determined in regulation where it gets a little more nitty gritty but I think we're on the same page. Yeah I think that was where we envisioned that line was basically like the the more danger extraction and then the less dangerous one. Stephanie? Dan. Stephanie. In the HEM program just to provide a perspective. Sorry Stephanie I think. Oh I'm sorry. Yeah I apologize we have we need to reserve about seven minutes for a public comment. Oh yeah sorry I lost track of the time here Let me just mention my idea about manufacturing and then we can part. I was just thinking that in the HEM program we base it on who's concentrating something regardless of the process. Just because then you can trade and concentrate it exceeds the 60% but you got to be I don't know that was how we put the line and it wasn't necessarily related to the to the danger associated with it. So if you are doing it in a cross-pot you're not concentrating it but anyway just a thought. And the good news is that again I think we're going to spend a good junk of Monday going back over this again and getting into the fees because we didn't get there. So we can pause for now take public comment and restart again on Monday. How's it going everyone? This is Ebo from Gaston. I just wanted to make a comment about some of the retail licenses. As someone planning to do a retail store in Burlington I get concerned about like the general store type licenses and the farmers market stuff just on a compliance level. I just hope that those will be held to the same standards that you'll hold us to as far as the distance from a school or a daycare. General stores my family actually owns one so it could benefit my family but you know there's a lot of kids going in there and without having a blacked out room like a pornography videos or something for your cannabis. I see it being a compliance nightmare on those type of licenses and again just hope that they're held to the same standards as everyone else in retail. And then another thing I wanted to echo what Chris said about the clones and seeds would love to have those in a dispensary I think that a lot of people are going to want to come in and buy those and then on the manufacturing end of things I just want to give one more shout out to hopefully you guys will see it see fit to do hydrocarbon extracts. And that's it. Thank you. Thank you. Thank you. Thank you for the time. My name is Ben Mervis. I am formerly a Vermont Department of Health employee actually and I went on to work with the FDA. I've been in cannabis for about five years. I'm working with Craig Mitchell who announced via public comment that we're exploring viable business options here in Vermont as potential social equity applicants. So we're still in that process and excited to see where this all goes. Most of what we have to say will be submitting to the social equity subcommittee for consideration but we do want to ask the subcommittee to really consider the potential future licenses in particular delivery and social consumption as they have direct ties to community direct ties to marginalized communities in terms of destigmatization of cannabis and providing safe spaces for consumption. I will also submit some things via online to speak to the reduction in arrests and summons as the New York has seen by providing just public consumption language but of course we're not looking at public consumption we're just looking at at least providing people a place to consume and then also by doing home delivery you encourage home consumption rather than walking out of a store walking five feet down the street and consuming there and that's it for now. Thank you very much. Thank you. I actually think that's it for public comment in the room. Great. So I think again Monday's call will be a lot of the same stuff we'll go through the fees we'll go through the two proposals. So until then I will let everyone contemplate over the spreadsheet here. So do I have a motion to adjourn for the day? Motion to adjourn. First adjourn 70 seconds. Second. Excellent. And the Market Structure Subcommittee is officially adjourned.