 Okay, we are recording and we're streaming. Great. My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is January 30th, 2023. It's one o'clock and I call this meeting to order. Very quick update to the agenda. The staff are recommending a social equity status denial. And an approval of an employee ID card applicant with a criminal history record that has a presumptively disqualifying offense. So I'd like to add an executive session to the agenda to discuss the specifics of those two recommendations. I think we should do that between the executive director report. And then before the board votes on the full recommendations. It's so nice to be back in 2023. We certainly have a lot on the agenda today. So my remarks will be brief, but I just wanted to touch on an issue we've received quite a few public comments recently about our decision to shift to a monthly board meeting from a weekly board meeting. So I figured I'd start out by addressing that. The board's early work was heavily dictated by some very aggressive statutory timelines that were even further compressed by the pandemic related delays that we saw. And we had to seek a lot of public input. We had to draft regulations. We had to build an IT infrastructure and get licenses in the hands of applicants at a breakneck pace. However, as this market develops, our mission at the CCB is starting to shift. In addition to issuing licenses, we now have to focus on supporting licensees, which includes a heavy emphasis on education. And we also have to do the basic regulatory function of enforcing our rules. Staff time is a finite resource. And when new responsibilities are added to our plate, it means we need to cut some cut back someplace else. In this case, we can be internally more efficient and expand the reach of our limited resources by shifting to a monthly board meeting. And I think that last phrase monthly board meeting is important. Now that we have licensees and we're seeing that there are specific areas of our rules and the underlying cannabis laws that need more attention and education. While the board is only meeting once a month, we have on our event calendar, only three to four events a month. So we are having events continuously. You know, those are not board meetings, but they are Q&A sessions and issue specific education and networking events. We have one this Thursday, for instance, from 5 to 6pm, where we will be discussing how to stay in compliance with the Vermont Department of Taxes and how to navigate some of the complexities of filing taxes when you're a cannabis business. For what it's worth, I did look through the meeting schedules of every other adult youth state, every other adult youth cannabis board or commission and save one they all meet either monthly, once every two months or once every three months. So I know it's not satisfying to hear but this is the decision we've made and we're going to stick through it at least through June. The best thing you can do if you're thinking about getting a license is to start your application early. Pay close attention to the communications you're receiving from the board about the areas of your application that are incomplete. And please, I can't stress this enough, start the process with fire safety as soon as possible. Later in the meeting, Brynn is going to walk through some of the internal performance measures that we've collected about how quickly our staff can review applications or conduct a site visit. But we don't control fire safety. On the same token, we're not going to approve an application until they've signed off on it. In my experience, they actually have a pretty impressive clearance rate generally, but they operate in a first come, first serve fashion, and they also have a lot on their plates. You can't expect fire safety to expedite a site visit, just because your cannabis application is otherwise complete. In other news, the agency of administration released their year end tax data for Vermont, which now includes a line item about the cannabis excise tax. And it looks like the state is reporting a little over 6 million in sales between October and December. I think this is a very healthy start to this market. And to me, it shows that the kind of over 21 population in Vermont and our Vermont tourists and border residents are embracing the idea of purchasing regulated cannabis over the counter. And the more that the board can do to improve market access, expand testing and manufacturing capacity, and increase the diversity of products that are available, I think, you know, we'll see this industry really kind of reach its full potential. A quick note to retailers that are selling pipes, tongs, rolling papers, or any other device that could be used for smoking cannabis, but also could be used for smoking tobacco. DLL, the Department of Liquor Control, their reading of the current laws is that you are required to get a tobacco license and you are subject to their jurisdiction with respect to those products, even if you're not selling cigarettes or tobacco products. We got word last week that a DLL enforcement officer conducted a compliance check on a cannabis retailer that was selling glass pipes. Just like the CCB, DLL takes an education first approach to enforcement of its rules. But I think it's important for anyone who might be considering selling glass pipes or any sort of tobacco paraphernalia to know that this co-jurisdiction exists. I wanted to say a quick word about hemp and hemp derived products. We're very much aware of the FDA's recent comments about CBD. We don't know the full implications of this decision other than to say that the sands are shifting under everyone's feet. Prior to the FDA statement, we submitted a legislative report on the regulation of hemp derived products in Vermont. However, this issue plays out federally. At the state level, we will be seeking public input and legislative input when it comes to regulating hemp derived products in Vermont. Julie, I know you wanted to touch on an issue. Before we do that, I just wanted to do a very brief introduction and put a face to the names of our two newest members of our compliance team. I'll start with Dwayne Tomlin if you could just wave at the camera. He brings an extensive background in security as well as a deep knowledge about the cannabis plant. Andy Chevrifields, if you wouldn't mind just waving, comes to us from the Department of Health where at least part of your job was serving as a public health inspector and manager for the food and lodging program. Given the breadth of the job, our compliance team has to achieve, including regulating, overseeing every piece of the supply chain. I think your experiences and expertise will really help round out the compliance team. So we're thrilled to have you on board. Happy to be here. I look forward to meeting everybody. Julie, do you want to? Yeah, I wanted to call attention to something that I'm noticing and I see it more and more as our staff builds and grows and I think it's time to address it now. We're seeing a pretty distinct difference in the treatment from members of the public and people in the cannabis industry towards members of our team. And it's pretty clearly based on gender bias. It's not always blatant or overt aggression. Sometimes it is kind of subvert, like attempting to skip a typical process or procedure and go to a man on the staff with the intent of undermining a woman on the staff. I want to give people the benefit of the doubt. I think that a lot of this happens unconsciously and perceptions of power and gender are definitely deeply rooted in our culture. People often have, we thought of women as the weaker sex, right? For how many decades have we thought that? But that's shifting and it's an evolving and changing item in our culture. And so not calling out anyone in particular, not blaming any particular group or organization. So today my ask of the cannabis industry and members of the public is to do some thinking about bias, where they show up and why we have them and then to please treat our staff, all of them with the dignity and respect they deserve. We see the disrespect happening and we'd like it to stop. Thanks Julie. Thank you Julie. And I don't think have anything further to add. Then why don't we approve our minutes from our last meeting? That was on December 21st, 2022. Is there a motion? So moved. Seconded. All in favor? Aye. Aye. Aye. Okay. And we will then now shift to our agenda. Bryn, we have a statement, or Kristi? Well again. Is it the statement? I will do that. So the board is going to be releasing an update to its hemp industry bulletin that we released a couple of months ago that articulates the board's stance on products containing manufactured Delta 8, Delta 10 and other synthetic cannabinoids for which there's really insufficient research to demonstrate the safety of those of those products. Delta 8 and Delta 10 are psychoactive compounds that occur naturally in only very small amounts in the hemp plant. The natural concentration is so low that they're unlikely to have any psychoactive effects on the consumer. But Delta 8 and Delta 10 and these other cannabinoids that can be synthetically made from hemp. So we're using a chemical process to convert sometimes CBD into these cannabinoids and create Delta 8 and Delta 10 products. Manufacturing Delta 8 and Delta 10 from CBD has become a way for manufacturers to create a psychoactive substance under the guise of being derived from legally produced hemp, which by definition does not have high concentration of any psychoactive cannabinoid. These products are not going to be registered by the CCB and therefore are not going to be eligible for sale in our retail establishments. As we've said repeatedly, we have not yet drafted our rule on hemp yet. But the goal here is to give the public really abundant notice that the policy position of the board is to prohibit the use of synthetic cannabinoids and the production of any hemp derived products. And that doesn't mean that any naturally occurring Delta 8 or Delta 10 is barred from hemp or hemp derived products, but that Vermont producers can't be manufacturing the Delta 8 or Delta 10 cannabinoids from hemp. And the bulletin is going to contain further detail and it will be published in the coming days. Any questions for learning about that. No, thank you. Thank you. Okay. Moving down the agenda, we're going to review the Vermont Agency of Agriculture's new pesticide rule that was just approved by Elkar. Is that you or is that Christine? That's the pesticide rule. I am not reviewing the new pesticide rule. Maybe talking a little bit about what a couple of the aspects of the new rule regarding pesticides. That's great. This is what I'm going to do is do just to underscore a few points of our current pesticide guidance that are important just to keep in everyone's front and center and everyone's understanding. So as the point about the new rule that's good to underscore is that we've proposed mandatory lab reporting on pathogens and pesticides. So that's something that should really help us to in our bid to really create trust with the consumer and our markets. And coupled with our own just on the ground look at everyone's pesticide cabinets. It's going to be a really good combination. So I just wanted to reiterate that the licensee is responsible for knowing what is on these pesticide allowable lists as well as what's on the not allowed list, which is handily on your COA, your pesticide COA. So I would just suggest that everyone get familiar with the allowed list that's on the pesticide guidance on the website. Printed out would be a really good idea and have it handy as well as check your COA for those pesticides that we're testing for. Those are active ingredients, very popular active ingredients in a lot of black market cultivation. And with those two lists, the allowable lists and your residual list from the COA, you're well equipped to vet new products to go into a grow store and to speak with people about exploring new possibilities for management. I also wanted to mention on our allowed list that that list is based on active ingredients. Unlike Massachusetts list, which is restricted to 25 B pesticides, which are minimum risk pesticides. Our list is not so restricted. We actually encourage you to choose EPA registered products that have those allowed active ingredients when they're available. Also a huge misunderstanding is our allowed list is not based on whether or not products are organically certified. And this has been kind of a fairly large misunderstanding. Just because it's organically certified does not mean it wouldn't fail a pesticide test. So a very common example of this is the product pyganic. It has an active ingredient pyrethrin that's on the restricted pesticide list. Just look on your pesticide COA and you'll see it down there. Even though the product is certified organic. But just wanted to make this distinction for everyone and that just because it's organic doesn't mean it's necessarily safe in our market. The other thing I wanted to mention. Those pesticides on the COAs are residual pesticides, meaning they stay with the plant either on the tissues or systemically in the tissues. For long enough that it is very likely that the consumer will come into contact with them as well as those chemistries then being subjected to all the things we do in our interest industry like burning, concentrating, extracting. So because of their very residual nature, they stick around. They also stick around in spray equipment. So be very, very careful. And I would I would say do not ever borrow used spray equipment. There's no way to clean spray equipment of residual pesticides. So just a note to be cautious there. So be cautious with the spray equipment be cautious when you're ordering that you have the good and the bad list. Don't rely on other people like grow stores to do to know these things for you. It's your responsibility. And one final thing, our tracking system that we're developing will ask you for your application app data so all of your foliar applications and nutrients by weekly. So if you're not already keeping an application log. It's this is a good time to start doing that. And you can find, I think just by Googling pesticide application log, you can find templates of logs that you could use or you can create your own. And that's about it. I just wanted to say we're really developing a lot more pesticide pest and disease management education and training. So, just be looking for that to to be coming. Thank you. Any questions for Chris. This is just my own lack of awareness, but I know some folks will rent some types of farm equipment. Are these sprayers something that people also rent so I know folks maybe are borrowing them but is it something that they might rent from somewhere else as well. They should know they they shouldn't rent spray equipment. Yeah, I would say that would be something that I would really look to buying new on and and I think the definition of pesticides by spray equipment is a common issue nationally. So it's, it's not just our market. Definitely something to be cautious. Yeah, it's a good point. Yeah. All right. Next on the agenda is a presentation from Project WorkSafe about workplace safety. Julie, do we know if our presenters. I think that Luke is here. Hello, everyone. Hi, Luke is Sean on also, or did he have to go? He might still be floating around. I think he had to call it on the phone today though. So hopefully he's broken around the background here somewhere. But yeah. So, good afternoon everybody and thanks for giving us the opportunity to talk to you today. Again, my name is Luke McCarthy and we just wanted to make you aware of a free state resource that's available to you as hopefully you begin to stand up your your businesses. So hopefully everyone's heard of OSHA occupational safety rules regulations. I'm sure you've heard of the fines. There's a service in Vermont to help small businesses learn about and comply with all those OSHA rules. And in Vermont, we call ourselves Project WorkSafe. So we're not OSHA. The use of the program is completely voluntary and it's completely confidential. And I'm required whenever I give this pitch to tell you that it's funded mostly by your federal tax dollars. So that's how we are able to keep it a free service. So the program operates in a couple of different ways. Folks use us however they want. They'll either call us up or email us with a question or we go all the way up to going out onto their job sites to look at their operation or propose operation if you're not entirely in business yet. And then we can point out safety and health issues and help you resolve those issues. And through that on-site visit gives us a good feel for where you're at with your safety and health efforts, maybe where you should be, and what you need to do to get there. So we can provide resources like written programs or training templates. In a lot of cases we can actually provide you with training that's needed from OSHA. And we can provide air monitoring and industrial hygiene work. That's all free as well. You know, just anything that you need to help meet or comply with those OSHA standards. So that's, you know, that's who we are. That's a two-minute explanation of who we are. And I just wanted to put in a plug for the program for maybe those of you who, you know, don't have it on the top of your head. So OSHA laws do apply to any company that has one or more employee at any time in a calendar year. And hopefully your businesses will be successful and you will grow. And once you've hit a threshold of 10 employees, there's a whole other slew of record-keeping requirements that will apply to you. So, you know, when I say the OSHA rules apply to you, you know, maybe not so much on the retail side, but on the production side, you have a whole bunch of hazards that your employees are exposed to. That OSHA also has regulations for. You know, you could have air quality issues, including, you know, maybe exposure to mold or even ozone carbon monoxide, carbon dioxide. There's a whole slew of things. So you might be looking at, you know, ventilation issues, respiratory protection issues. You've got potentially high levels of noise from fans or the very ventilation systems that are there to keep you safe. You know, OSHA does require a hazard communication program and training for any employee that's exposed to chemicals. And this would be separate from whatever regulations the pesticide program makes you do. You know, for your indoor growers, you've got electrical issues. For your outdoor growers, OSHA does have an emphasis on heat. I know it's kind of hard to think about when it's 20 degrees of snowing out, but it is coming. You know, and you definitely have ergonomic issues between processing and lifting and everything else. And just an FYI, ergonomic issues are incredibly expensive workers compensation claims. So, you know, we always kind of keep an eye out for those things when we go onto a site. So, you know, there's just that's not that's some things that maybe are specific to your industry, but there's also things like fire prevention rules, fire safety, egress. And, you know, and obviously all the stairs that are around personal protective equipment, like, you know, goggles and gloves and aprons. If you use chemicals, that's where it's like. So, you know, I don't want to go too far deep into each one of these topics that could be here all day. But, you know, like I said, as you start to get your business up off the ground, please keep some of these employees safety issues in the back of your minds. And just know that there are, you know, not only are your employees exposed to them, but there are those regulations that you have to comply with. If any of these situations are in your facilities. But, you know, please, if you have any questions, you know, it's or need clarification on what your requirements are as an employer. Feel free to give us a call. Don't hesitate to contact us. Our numbers, it's pretty easy. It's 1-888-SAFE-YES. That's S-A-F-E-Y-E-S. And if you can't remember that, just Google Project WorkSafe or the 1st one that comes up and all of our phone numbers and emails are right there. You know, again, it's a free service. We're here to help small businesses comply with the rules. And so, you know, your tax dollars are funding it, so please feel free to take advantage of it. And that's my 10-minute pitch of Project WorkSafe. Great. Any questions for Luke while we have him? Luke, if somebody wanted to go do a little research on their own to start before Project WorkSafe came in and to figure out, like, what applies to them or what safety standards they should be looking at, where would they go? So, I mean, there are no safety standards right now specific to this industry. OSHA kind of pulls in standards that are already written, you know, as you may or may not know, we haven't written anything new in decades. So, you know, if you're not too familiar with the actual OSHA standards, there are actually, there's a bunch of new research being done by states that have already had this industry up and running. There are a couple of, if you just go on the internet and start cruising for, you know, safety issues in the cannabis industry. There are a bunch of great documents and publications out there. And we can compile all that and send anybody who wants a nice little packet that's easier to read and digest. We're happy to put that information together. That would be really great. And just to put a finer point on that, even though there aren't specific industry standards, is this right, Luke? All employers have sort of a general duty to provide a safe workspace, right? Absolutely, yeah. I mean, OSHA is really good at applying standards to situations that they haven't really thought of. But also there's what's called a general duty clause where, you know, if they walk in and see something that is typically accepted industry practice, even though they don't have a standard specific standard for it, they can still cite what's called a general duty clause and, you know, seek compliance that way. Yeah, on that. So, you know, while there might not be a cannabis specific OSHA regulation with respect to kind of cannabis edibles, there might be an OSHA regulation with respect to a product like a food processor that would apply. Or some of the equipment that might be at a cannabis edible producers. Yeah, exactly. So, you know, there aren't rules for a specific machinery associated with production in the cannabis world, but there are general rules for, you know, machine guarding and, you know, compressed gases and, you know, all the systems that are involved with the process. Just bouncing off that, I know at least currently cannabis isn't considered an agricultural product, but OSHA does have agricultural operation standards that might be a good starting point for folks to think about and look at as it relates to. The cultivation or production side of this, even as it relates to contractual employees, seasonal employees, et cetera, et cetera. And if Project WorkSafe, remind me if this is right, because I've had Project WorkSafe walkthroughs in my past lives, right? So, you can provide advice and walkthroughs and there's time for an employer to remedy things or change things. It doesn't necessarily mean they're going to get fined, right? Like the idea is to teach safety not to find people right away, right? Exactly, yeah. So our program is different from OSHA in that we seek voluntary compliance. You know, people contact us because they want to do better. And so we're not going to go out and, you know, issue a citation or a penalty. There is a caveat to having us out onto your site and that is we cannot, in good conscience, walk away from a serious violation. So if there is a violation that OSHA would cite you for if they walked in, like electrical hanging out of the wall or something, we would work with a company to get that fixed. You know, we're flexible with our time ranges. We know everyone's on a tight budget, but we do need to get that issue fixed. So that's kind of the catch to using the program is that we do kind of force you to fix the things that we find. So no penalties, no citations, no fines, but there might be some money involved with fixing issues. Luke, for a lot of the businesses that are entering this regulated market, they've largely existed in an unregulated area in the past. So this interplay between organizations that have code jurisdiction, like I think the cannabis board has jurisdiction, fire safety has jurisdiction, the tax department has jurisdiction, OSHA has jurisdiction is what I'm hearing. And then OSHA, whether you knew that or not, you're subject to OSHA's regulations by it by being a kind of legitimate business. And I hear that there's kind of an enhanced set of regulations that you're subject to if you have 10 or more employees. And what I'm hearing is that you, or Project WorkSafe specifically, is there to provide technical assistance to help people understand those and to come into compliance with them. Absolutely. No, there's very little downside to giving you a call to just review what things you might not have ever known about, but you're subject to kind of a regulatory authority. I'm a little biased, but yes, I think there's no downside to calling us. Like I said, it's confidential. So whatever we discussed with the client, we always send a report out that reports stays between us and the client. It doesn't go to any other regulatory body. So it's just a friendly conversation to help small businesses comply with what they need to comply with. And that includes the record keeping that you're talking about, right? I know that that can trip up some business owners, especially new business owners in the beginning. Yeah, so if you have less than 10 employees, you don't necessarily need to keep things like injury logs and written programs. But once you hit that threshold, you do have some record keeping requirements such as keeping injury logs and making sure you document all your, you know, let's say you have a big vessel that holds something that somebody needs to go in and clean. So that's what's called a confined space. So you would need a confined space program, train and all that stuff. If you have less than 10 employees, the actual written policies are a little more relaxed. Once you hit 10 employees, you're going to start having all those files and documents and everything else. You know, to say that this is our policy. This is what we do. This is how we train our employees. And most of that information is right on the OSHA website, right? Like what people are required to keep track of. Yeah, it is. It takes some digging, but yes, it's there. All right. Anything else for Luke? OSHA can be complex depending on your business. So please reach out to Luke and his colleagues if you have questions. Yeah, I don't, I don't think we can emphasize the employee safety pieces enough. Quite frankly, I mean, a lot of the biggest injuries come from very simple. Like it slips trips and falls quite frankly, right? Luke, like that's like the number 1 industry injury and small actions can result in lifelong problems. So it's important to keep folks safe. Absolutely. And I appreciate your time allowing us to spread the word. Thank you. Thank you. We'll get your, we'll get work saves contact information up on our website. So people have quick access to that as well. Very much appreciate it. Thank you so much. Thank you. Thank you. All right. Next on the agenda is the presentation of the CC and social equity report. I weigh a background. This is a report that the cannabis board is submits the legislative every year. And this is the first year where I think we actually have licensees. So there's some good information in there. Okay. Yes, this report is going to detail the background of why we, why we had to submit this. But as the chair mentioned, this is the first year that we submitted social equity report to the legislature. And I'm going to go through it for everybody now. We'll start with some background on the social equity program. That's the part that I might move through a little bit more quickly. Because I think everybody has a good sense of what the program entails. And then it talks about the data on social equity within the industry. And I think that we'll take a little bit of a closer look at the numbers of social equity licensees and applicants that are in the queue. And then will the report details the cannabis development fund beneficiary payments that the agency of commerce and community development is administering. And then the end of the report kind of articulate some of the barriers or what the board sees as the biggest barrier to accessing the cannabis industry, and then some additional recommendations for the legislature. And then a little background on the program. We start with the requirements of the report. This is a statutory requirement that the board in consultation with a CCD and the executive director of racial equity report each year in January. This was the first year. And by annual by annually afterwards on the implementation of the social equity program that's required by the statute. I'm going to include some data on the number of the number of social equity applicants and some details and data on the amount of funding that is is provided through that cannabis business development fund, which we'll talk about a little bit later. This is the board's mission statement on social equity and a little bit of just a kind of a general statement on the board's approach to social equity. I think the board is familiar with this. I'm going to get that one. So this slide details some of the work that the board has done so far to reduce disparities in participation in the cannabis market. It's kind of an attempt to demonstrate that the board has really considered social equity in every aspect of its work. So for example, the board proposed comparatively low licensing and application fees to ensure that the barriers to entry were relatively low. We've avoided imposing caps on the number of licenses to prevent creating an industry that reflects only those businesses that are the most well capitalized. The board's staff has prioritized social equity applicants for licensure and for technical support. The board has adopted rules that don't impose broad restrictions on whether or not you can get licensed based on your criminal history record. So the board considers applicants with criminal history records individually and limits licensure only to those individuals that would pose a threat to the safety or proper functioning of the cannabis market. The board is also prohibited considering prior cannabis convictions as a sole justification for denial of a license. And we've also imposed employment and subcontracting requirements on larger cannabis licensees. And that is done in an effort to help ensure that the ancillary business activity that's generated by the cannabis industry benefits BIPOC people. So a little summary of the work that's been done so far. This slide has links to the former legislative reports that we've submitted that have information about the social equity program and the development of the program. So, you know, this is kind of a summary that we've received really an extraordinary amount of public feedback when we were developing the social equity program and that's detailed in the January 1st report. And then the Jane October 15th report detailed the social equity criteria that the board developed that allows access to the program, which includes the waived or reduced application and licensing fees access to technical assistance and also eligibility for disbursements from the business development fund through ACCD. And we've also sorry we've also adopted economic empowerment policy and I'll talk about this a little bit in the report as well. And the idea behind the economic empowerment was to support and encourage the participation of women veterans and minorities in the cannabis industry. So here is our social equity criteria. I know that the board is quite familiar with these. If you are black or Hispanic have served a sentence of incarceration in a correctional facility as a result of the cannabis related conviction, or have a family member who has. Or if you can demonstrate that you're from community that's historically been disproportionately impacted by cannabis prohibition, and you personally have been harmed by that impact. Those are the four different criteria that can make a person eligible for the social equity program. This is a summary of what the program offers. So applicants that meet social equity criteria are prioritized for by the licensing staff and the compliance staff. So they are prioritized for application review site visits and technical support. And as I mentioned earlier, they also receive fee waivers and fee reductions so a fee waiver in the first year and then reductions for the following three years. The board hosts entrepreneurial outreach education and networking sessions for social equity applicants and licensees and that is to encourage both participation participation in the market. And also, you know, cultivate success among the existing licensees by fostering connections among them. And also, as I mentioned, social equity applicants and license holders are eligible from those disbursements from the cannabis business development fund that ACCD administers. Economic empowerment benefits somewhat more limited because these folks don't have access to the cannabis business development fund they are not eligible from for disbursements from the fund. So again, the board hosts outreach and education sessions that are targeted towards these folks to foster networking and support and we've had quite good attendance at these sessions. And we also prioritize them for review after social equity applicants. So I'll get into the data now on our social equity licensees. So we're starting off by a little trip down memory lane when we did pre qualification. The board implemented a pre qualification process early on when we were prior to opening the first application window. And this process allowed applicants who intended to get a cannabis establishment license to get kind of official state approval for their team and their initial plans before they had to go out and secure real estate and do other kind of financially burdensome activities that would lead to them being able to open their business. So we had 222 applicants that were approved for pre qualification and of those 202 applied for a license and of those 202 pre qualified applicants that applied for a license 51 were social equity applicants. So those are some early numbers on our social equity program. This slide details what our current population of licensees looks like from a kind of status perspective. So you can see the gray 61% that is our standard applicants. The blue 17% is our social equity licensees and the orange 22% are our economic empowerment licensees. So I said applicants I think at first but I meant licensees. These are numbers of just people who've had their licenses issued. This slide details the categories for the social equity criteria when I went through those four categories of qualifying criteria. This is a breakdown of our current social equity applicants and licensees. So everyone that has been confirmed by the board to have social equity status is reflected on the slide. So black or Hispanic applicants and licensees constitute 50% of that group. 27% are qualified because they were formerly incarcerated in a correctional facility as a result of a cannabis related offense. And then orange the 23% are folks that had a family member who are incarcerated in a correctional facility as a result of a cannabis related offense. And then the next several slides do this breakdown between social equity economic empowerment and standard by license type. So you'll see on the next several slides that the majority of our social equity licensees have applied for sort of the smallest of our cultivation tiers. So you can see 10 applied for tier one indoor 10 applied for a tier one mixed. And we've got six that applied and received a license for a tier one outdoor. And we get to the manufacturing licenses so that tier one tier two and tier three are reflected in the bars across the bottom of the graph there. So you can see our tier two manufacturing licensees. The majority of them are actually economic empowerment licensees. Just great. And then this is our other license types so we can see wholesale retail testing lab and integrated down there at the bottom. Happy to slow down if you like. So moving away from that data, we're going to go look at some data on our demographics. And this really kind of implicates the economic empowerment program but there's this slide just provides a note on the data, which is that on the following slides we were really looking at licensees. And all of those numbers reflected the not each individual person who owns a cannabis establishment but just the status of the cannabis establishment itself. And these next few slides really are designed to provide like a picture of economic empowerment in the industry, but the data is on an individual level as opposed to on a business level. So, and all data is of as of the end of the year. So here is data on gender of individuals who owner control cannabis establishment business so this includes applicants and licensees both. And you can see that the orange there 14% are female. The yellow 24% identify as male. Only one individual who identifies as non bear non binary and one who identifies as gender queer, but you can see the vast majority there I can't really see the number I think it's 62%. They just left it blank. So, the, the state is collected on our application form. It is not this is in the demographic section and there is no requirement that applicants complete the section of the application so it's an important note on the data also in our gender queer and non non binary those options to select or is that something that people write in their options. Okay, the slide reflects the identified race of applicants individual applicants. So again this includes applicants and licensees and all of the individuals all the data and all the individuals that we collect from those businesses. So, you can see the vast majority 494 are white. The brown column all the way to the right there. That's a smaller column of who chooses not to disclose so it's only 30 that chose not to disclose their race. Interesting data to look at. So now I'm going to move on to the slide about the business development funds. So the statutory requirement is here seven BSA 97 or no this I think this might be a 32 anyway. Okay, yeah, that's entitled 32. Okay, anyway, there is a fund that's set forth in statute and it comprises an initial appropriation of $500,000 and then it also comprises contributions $50,000 per $50,000 per integrated license. And that is only for licensees that had an integrated license on or before October 15 of last year, and then any other funds that are appropriated to it from the General Assembly. And the purpose of the fund you can see there is under subsection C to provide low interest loans and grants, social equity applicants outreach targeted to attract and support social equity applicants to Vermont's industry. And assistance with job training and technical support and and that's it. Here's the language that puts a CCD in charge of administering this program. So as I mentioned earlier, the fund is in the hands of a CCD and that agency is making the disbursements from the fund. So this is a summary of the technical support that has been provided to social equity applicants and licensees. So the ACCD contracted with Rhodes Consulting Group to provide technical support to social equity applicants and licensees. And so far Rhodes has conducted intake assessments with about a quarter of our social equity applicants and licensees. And there's some details about where those businesses are located. And they've provided technical support for eight of those businesses. And you can see there the bullets are kind of a detail of what kind of technical support Rhodes is providing. From marketing and bookkeeping to website development, branding, some financial management support. And this outreach and technical support are ongoing. So although only a quarter have started the process, it's going forward. So social equity applicants and licensees are entitled to this support. So all those areas where they provided technical support kind of, to me, look like they go, there's just general business needs like whether you're a cannabis business or not. But Rhodes does have some cannabis specific technical experience, right? They do, yes. This organization was used by both Rhode Island and Massachusetts to provide technical assistance specifically to the cannabis industry. So they do have that expertise. So I remember that, but I wasn't sure. And on those intake assessments, you kind of indicate where you need the most help. I think it would make sense how a lot of people feel like they have good knowledge of the plan and just need help for keeping and doing the things that every regular business needs to do. Yep. Okay. So this slide details the beneficiary payment plan. So $350,000 of that original $500,000 was reserved to provide the financial support to social equity businesses. So that $350,000 covered one $5,000 payment to each business that's currently confirmed as having social equity status. So that may be an applicant or a licensee. And the second bullet here is really a note that this decision by ACCD to provide a equal flat amount to all of the applicants and licensees really doesn't account at all. Obviously account for the really different needs of these businesses. And the agency decided to treat these businesses equally rather than equitably because of the limited amount available in the fund. And that had had ACCD instead offered these beneficiary payments based on the business's need. We would have, they would have run through that fund very quickly. And certainly before every social equity business had the opportunity to seek some financial support. So are there some reporting by roads or ACCD after the fact of like, are we going to survey folks to see whether or not this was impactful and how impactful and yes that part of the roads charge. It is part of it is part of what roads is doing is doing initial data collection and then I believe it's six month out data collection and then 12 month out. So some facts about the timeline for these payments. ACCD is still developing their application to receive the payments from the fund. And that should be ready to go on February 1. And they have reserved about $50,000 to support future needs. So there is some reservation of funds for additional support in the future. And as I noted there, there isn't an additional $50,000 that is anticipated to be deposited into that fund. So that would leave $100,000 in the fund to support some future needs of future businesses or existing businesses. Okay, so now we're getting into the barriers to accessing the cannabis industry and our recommendations of the legislature. This slide really the synopsis here is that it's the board's position that the biggest barrier to the having success in the cannabis industry is lack of access to capital. We talk a little bit about the startup costs can be very high and how cannabis businesses are really limited and their options for securing financing. And that limited available lending means that most cannabis businesses have to fund themselves from the beginning. Disproportionate enforcement of cannabis prohibition has really left a legacy of racial injustice in the now legal cannabis industry. When we've got several links here that support these statements that black and Hispanic people have been historically targeted by criminal legal enforcement and sentencing practices and that has resulted in really profound generational impacts that include longstanding economic harm. These racial disparities persist in Vermont and given that businesses that are owned by people of color are less likely to have their financing needs met than that of white owned businesses. The limited access to financing as described on the previous slide is in all likelihood going to disproportionately impact people of color who are looking to have access to the cannabis industry. And then this is a slide that talks about barriers to sustain sustaining success in the industry. So not only are those financial impacts going to affect people's ability to enter the industry but also their ability to achieve some success in the industry once they are licensed. So the slide details some of the kind of unique costs that cannabis businesses face that businesses in other industries don't face. And that includes the banking and insurance services both of which are very expensive and some of the municipal barriers that we are seeing happening. Municipalities are imposing local local like control barriers on cannabis businesses and those sometimes are resulting in litigation costs. And then also testing cannabis is required to ensure quality and as we know testing is very costly increases as a business sort of expands its product line. Okay. So here we're getting into our recommendations. So new applicants for cannabis establishment licenses are slowing down as we know. But the proportion of social equity applicants that are applying now as opposed to in the when we first start opening application windows is is higher. So there is some sustained interest in the industry by social equity applicants. So as a result we the board is indicating that access to additional funding is necessary both to ensure that we continue to provide economic opportunities to social equity applicants that would like to join the industry but also are existing licensees that are trying to achieve some measure of success in the industry. So here is our specific recommendation that a portion of the excise tax be set aside as a financial resource for social equity applicants. Or specifically that a portion of the excise tax be be allocated to the cannabis business development fund and that that fund should be available to both existing licensees and also applicants to ensure that these economic applications are being provided to individuals from communities that were harmed by prohibition. You know how many other states do that. Have a portion of the tax. Yeah. Community reinvestment or specifically to support social equity. Yes. It's not high. I don't have the exact. Yes. I think that sounds right. Yep. It is a small number. Certainly. As you mentioned another one of our recommendations is that the board is or that the legislature create a reinvestment fund to funnel some of the revenue from the cannabis industry to communities that were disproportionately harmed by cannabis prohibition. And reinvesting that revenue into these communities would be a much further reaching approach to mitigating some of the harms given that not everybody who has been harmed by prohibition wants to be a part of the cannabis industry. Okay. And last slide. Our final recommendation is to allow for some additional license types including a delivery license which would create another point of entry to the market with low economic barriers. And also creating an onsite consumption pilot program. And the recommendation here would be to address kind of the ongoing racial disparities in drug enforcement that persists in Vermont. And just a note that you know current law prohibits consuming cannabis and basically everywhere. All places of public accommodation and public spaces federal housing and having a location for onsite consumption would offer all people a safe place to consume and reduce the possibility of criminal legal enforcement. And there you have it. That is your social equity equity report to the legislature. Any questions about that. Congratulations. I just want to recognize hundreds of hours of work between you and the board and everyone at ACCD and Susanna and everyone. Thanks for putting that together. So concisely. Yes, thank you. Great. All right, are you ready for your next agenda item? jump into my report is just to back up something that Julie mentioned earlier in the opening remarks and I would just like to emphasize that all of our staff are really dedicated to public servants and one of the benefits to having such a small organization to being such a small organization small agency is that our work is really collaborative basically at every level and as a result all of our staff have a really firm grasp of the rules and the guidance so I would really encourage that applicants and licensees and their representatives treat all of our staff with the respect that they deserve and that really includes refraining from escalating your issue or making a special request of certain staff or of the board if the staff member that you heard from if you don't like the answer that they provided you I think that just to really foster that respect between the regulatory body and and our regulated community I would encourage respectful treatment of all of our staff so with that I will move on okay so here we have our our new this is going to look different from our register that we've presented in prior board meetings new look so I'm just going to jump right in I think we're a little bit behind schedule so I'm gonna I'm gonna jump right in we're starting out as the chair mentioned at the beginning with some performance measures so the following the the next several slides detail some average timeframes for licensure based on license type so that's where we're going to get started today um so again this is we're we're talking about the adult use program right now um this slide shows the average days from submission to approval for all um cannabis establishment applicants and I know that the text there on the right is really tricky to to see and um there's kind of a lot of information here but on average um the number of days between submission and approval of an application for a cannabis establishment license is 83.6 so we're going to jump in and break out those numbers by a license type in a moment but the first piece of data that we have here is the average days from submission to approval compared between all applicants and social equity applicants so you can see 83.6 reflects the average number of days for all applications but when you um when you pull out just those applicants that have been approved for social equity status that number of days drops to 37.2 so I think that's a great reflection of the work that staff is doing to prioritize our social equity applicants so now we're going to pull apart these numbers by license type so here you can see that for cultivation applicants the average number of days from submission to approval is just barely under 90 and I'd note that this number is higher than every other license type except for integrated licensees and this is likely for a number of reasons first I would just point out that cultivators really made up the bulk of our early applications when we first opened the window for applying for a cannabis establishment license the vast majority of those applicants were cultivators and during that really intensive phase of licensing over the summer we did not have a full team of licensing staff and the other important thing to note is that the very first these applicants many of these applicants were applying under the very first version of our of our application and that version of the application had no logic it had no conditioning and then essentially allowed applicants to submit something that needed a lot of corrections so there was quite a bit of support that our staff was needing to do especially in that early early version of our application and by logic we mean it didn't it wasn't intuitive right it didn't skip to the next page automatically that's correct yes yes thank you okay so the average days from submission to approval for manufacturer applications is 67.4 and it looks like it's about the same based on no difference among the three different tiers of manufacturing license average days for wholesale applications was 73.7 and testing labs was 20 on average 20.3 days and I would just note here that we waived all of the licensing requirements for applicants that were seeking a testing lab license if they were already certified if they had a current certification under the cannabis quality control program established by the agency of agriculture so all that those labs really needed to do was to to submit proof of their current certification and current certification number and the scope of their certified testing areas in order to get their license and here's the number 166 days from submission to approval for our integrated applicants so the only note I would make about that number is that those applications are really quite complex and intensive given that they are licensed to do a whole shebang and then here is the number 56.2 average days from submission to approval for a retail license and about the same 53.2 days for an employee ID card I ask a question about the ID card when someone submits an application they get a temporary card almost right away is that right or pretty soon they're not waiting 53 days before they can begin working that's correct you they can get as long as they do not disclose any presumptively disqualifying offenses on their application but they can get a temporary card while we await the results of their criminal history record they also have to attest they don't have them right not just they're not disclosing them that's correct they have to attest that they don't have any presumptively disqualifying offenses yes okay so now the next couple of slides detail the new license application submissions what they look like so this is from the date of the last the day after the last board meeting to um January 23rd so it's not up until today but you can see that um we've got a pretty good division of um applicants among the three statuses standard social equity and economic empowerment so it was 17 percent at the end of December and the for and the social equity report that we just went through was like 14 or 17 percent for social equity of licensees yes and these are our new application submissions which is yes 27 percent yeah okay and then this is a breakdown among social equity economic economic empowerment and standard among the different license types you can see that our we've got you know the big ones are indoor um tier two manufacturing and retail for the last 30 days this slide is just an overview of our the number of issued licenses by license type and tier so these numbers are current as of today so we've got um 547 and that but that is inclusive of employee ID cards so as of today we've got 326 issued cannabis establishment licenses okay and then these numbers based on the numbers um on the prior slide of license cultivators this is a little bit of a picture of our licensed the amount of canopy that we currently have licensed versus the amount of canopy that is licensed and utilized right now so I think you know the board has been doing a lot of talking about the amount of canopy that is currently being utilized by our cultivators given that it's the first year of cultivation there is a there I would say that this year our cultivators are probably using less space than they will in future years so licensed indoor canopy is 117 thousand square feet um outdoors 450 thousand outdoor and mixed and then utilized and and I want to emphasize that these are really rough estimates um based on what our field agents are seeing during their inspections so the estimate is that approximately 75 percent of our indoor licensed canopy is being utilized um while closer to half of our outdoor licensed canopy is being utilized so it's likely that that utilized number is going to change significantly um as our outdoor cultivators enter their second year of growing any questions about that yeah I mean what it what it kind of tells me is even current licensees even if they were utilizing 100 of their capacity we're not necessarily to the point where supply will outweigh demand in our model estimates that would force us to think a little bit more critically and strategically on how we want to oversaturate things and by not utilize there's like no part of the canopy like no seedlings no it's just not used at all right with the benchmark that's right that's correct yes so the next slide is our retail location map um and this map is going to be available on our website later this week um I just wanted to note that the blue pens are um licensees actual licensed retail establishments and the red pens are retail applicants um and I also wanted to note that those red pens um are they do not reflect the precise location of these proposed retailers they are just randomly dropped within the borders of the municipality to give a visual representation of the potential density of our retailers so um nothing precise about those red pens very quickly yep with a couple concentrations yep and those concentrations are where you would expect them given how commerce works in our savings right for sure yep and to and to address that a little bit here's um some breakdown of where we've got some areas of density in the state for retail locations um and this is just a little bit of a picture of what what we currently have licensed in burlington and what is coming um so retail applications in the queue we've got six of them for burlington um and then brotland is probably the second highest area of density um given the two new applications that are in the queue and then brattle borough morrisville and derby I don't know if you would really call that an area of density but um those are the the three the three other municipalities where we have um potentially have three cannabis concentrations I wonder how that density would change if we had a default provision of opts in versus the default being opt out it might not change like morrisville and derby but it would probably change burlington to and we've talked about this south burlington will listen right now we're going to get into our product registration slides um so this is product registration by the numbers so as of the 23rd of this month um we had a 1,057 total product registration applications submitted to the board um and of those 493 are awaiting review 248 are in are an incomplete status so we have um reached back out to the applicant to let them know that they need to provide us with more information before we can register their product um and 282 products are registered and then the rest are either um denied or withdrawn so this slide provides a little bit just a visual of what that looks like we've got um nearly half are in submitted status um and then about a quarter a little more than a quarter are registered so we do have um I think that we've talked about this at a prior board meeting we do have additional staff um that are addressing sort of the backlog of product registration applications that have come in the door um and we are developing a plan to um to keep on top of those applications as they come in peace is also just picked up due to this kind of migration to sales force I feel like it's my yes understanding yes which is review I should say right there's a backlog and we'll get it clear it'll be a smoother process for internal folks and external folks moving forward next slide is just a picture of what types of products are licensees are seeking to have registered the vast majority as you can see is flour and then we've got smaller proportions of edibles tinctures and concentrates you might not know off the top of your head but I presume we don't have any solid concentrates that are 60 percent thc or less um there is I believe an application for a just under 60 concentrate yes next couple of slides are provide some detail on our inspections so here's some numbers about our inspections um that are reflecting just that period of time that we've had compliance agents on staff which is just um we've I think we some of our staff joined us in August but we really started doing inspections in September so total full-time compliance agents during this reporting period was four we have we do have a couple more now which is great news and in that time the staff conducted 422 inspections and I would note that these are total inspections includes um our new inspections um any investigations any routine like revisits and any unscheduled inspections are all included in these numbers um average inspections per week is 22 or five and a half per uh compliance agent and that average hours per inspection is the average number of hours that our agents are spending with the license or the applicant or the licensee so it does is not inclusive of drive time which is I think on average an hour there and an hour home and report writing I assume that there's some after action that has to happen that's right yes and so we'll likely have some additional detail on um data about kind of the the what our compliance agents are spending their time doing but this is really intended to reflect like how much time is actually being spent with our applicants and licensees I mean I know some people might look at this and say well five and a half per week three hours per like that's not a four-hour work week but uh you know you think about all the resources we're dedicating to product registration from these folks and all the time they've spent building our inventory tracking platform as well it really is an impressive amount of work yep and as I mentioned earlier you know because we're such a small staff we we collaborate on all of it so our guidance documents um our development of all of our programs really heavily involves the compliance agents also yeah it requires a report yeah eating weeks unfortunately we have we have to have those two okay um this is a picture of our enforcement actions uh so far from september through january so i've just broken them out by the category the category of violations that they fall under um and really under the 10 closed enforcement actions we're really considering an action to be closed um once the letter of warning has been issued since um the the majority of these are are lower um severity categories uh these have primarily been addressed through a letter of warning so once the letter of warning or the notice violation has been issued and the licensee has remedied their non-compliance that is when a matter is considered closed any questions about that okay and then the last couple of slides before we get on to the staff recommendations are just a general picture of our um medical program so this is the patient and caregiver numbers um and this looks all the way back to 2009 so this really shows the the steep um the joining of patients to the registry and then the gradual drop-off that we're seeing um since really 2017 but more more sharp decline um since in just in the last year and to kind of get a put a finer point on that decline over the last year here is um the number of patients and caregivers just over the last 12 months so you can see we've dropped um from our numbers at the beginning of the year which were over 4,500 to um I think we're just around uh hovering around 3,700 now in January is 23 okay I'm gonna I'm gonna go to the recommendations if everyone's ready for that so um here are staff recommendations on social equity status um and then we also have one recommendation for overcoming presumptive disqualification for an applicant for an employee ID card so we have submission um 25.99 staff is appro is recommending approval of social equity status submission 23.48 set staff is recommending approval of social equity status um submission 24.96 also recommending approval of social equity status uh submission 26.03 recommending approval of social equity status and then one um submission 24.92 the submission staff is recommending denial of social equity status um and submission number 2602 is an applicant for an employee ID card whose criminal history record reflects presumptively disqualifying offense and staff is recommending approval of this employee ID card um because the applicant meets the criteria for overcoming presumptive disqualification is set out in a rule um and these last two submissions are um will be the topic of conversation during executive session okay and then the following slide is the list of applicants that have demonstrated compliance with all requirements for their cannabis establishment license that's contained in the rule and in statute see if I can see them um so we have I hopes applying for a mixed tier one cultivation license Vermont cultivars applying for mixed tier one cultivation license medley farms applying for an indoor tier three cultivation license palm trees applying for an indoor tier one cultivation license giving tree hemp farm applying for a tier two cultivation indoor cultivation license drink tonic applying for a tier three manufacturing license somewhere on the mountain applying for a tier two manufacturing license don't leave process applying for a tier two manufacturing license um some sunset light cannabis applying for a tier two manufacturing license Bt Skunkworks applying for a tier 2 manufacturing license Vermont Select applying for a tier 2 manufacturing license Freedom flower tier 2 manufacturing license flour first tier 2 manufacturing license an Max applying for a retail license big Intelligence Group applying for retail license Formulation, Station Vermont, applying for a Tier 2 Manufacturing License. Mr. Tree, applying for a Tier 1 Indoor Cultivation License. BB Can, applying for a Retail License. The Higher Collective, applying for an Indoor Tier 1 Cultivation License. Matterhorn Apothecary, applying for a Retail License. River Valley Group, applying for an Outdoor Tier 1 Cultivation License. Emerald Roots, applying for a Tier 1 Indoor Cultivation License, and Burn Legacy Cannabis, applying for a Retail License. So we have 23 applicants up for board approval today. Great. That is it. So the board would like to enter executive session. Yeah. Just to just a little bit of context in that, we're dealing with an executive session, two applicants, they're very personal details about their application, including criminal history records that we need to discuss. Anything that we decide could be the subject of litigation, and so the board needs to enter into executive session in order to protect both the applicant and the board's decision in case this were to lead to litigation. So is there a motion to enter into executive session for purposes of reviewing staff recommendations around the social equity denial? And the employee ID card approval? Yes. I move the CCB going to executive session to consider confidential attorney-client communications made for the purposes of providing professional legal services to the body. And that executive session is required because premature general public knowledge regarding such communications would clearly place the board at substantial disadvantage. I further move that the board include Susanna Davis, Executive Director, Jay Green, Racial Equity Research and Policy Analyst, both from the Office of Racial Equity for the State of Vermont into executive session. Second. Hold a second. All right. I'll call in favor. All right. So it's roughly 12.30 right now. I've read the memos. I think we can do this in 20 minutes. So why don't we come back at 10-2.50? It looks like we've scared everybody away. All right. We're back. We're still recording. Okay. All right. I'm going to resume the meeting. We got to finish with executive session a little bit early. The current time is 2.43 p.m. on January 30th, 2023. We are out of executive session. We discussed the kind of specific facts that underlie the staff recommendations around a social equity denial recommendation and a overcoming presumptive disqualification for an employee ID card. And I think we are ready to vote on all of the staff recommendations as a package. Is there a motion for that? I move that the board accept each of the recommendations as presented to us by staff in this meeting. I'll second. All in favor. Aye. Aye. Okay. Great. So last thing on our agenda today is public comment. And so we do this the same way we always do. If you join via the video link and would like to make a public comment, please raise your virtual hands. Do our best to call on you in the order that you've raised your hands and then we'll shift to people to join via the phone. For a second. For the only second. Keto. Hi, can y'all hear me okay? So just thank y'all so much. James, Julie and Kyle and Bryn and Denise and Chris and Mike and even Ray, you all have personally helped us at one time or another and what a journey it's been. Thank you all so much. Brand openings on Valentine's Day. Everyone's invited. Thanks, Keto. Hey, I just wanted to take a moment to thank y'all, you know, really appreciate this update and looking forward to working closer with y'all beyond that. It's just super disheartening to hear everything you said at the beginning of this meeting and in regards to, you know, being berated in low key sexism or not so low key apparently. So I'm sorry y'all have to endure that. And, you know, someone wants to slot me some names under the table. I'll have some words with people. Have a good one. Thanks, Bobby. Again, we're in the public comment portion of the meeting and so if you join via the link and would like to comment, please raise your virtual hand. If you join via the phone, you can unmute yourself by hitting star six if you'd like to make a public comment. Bridget. Hi, just glad to see the delivery and pilot program recommendations for onsite consumption and just would recommend if it's not already being considered that the health department be brought in on the onsite consumption because I'm assuming that food and beverage is going to be an important part of that program. That's all. Thank you so much. Thanks, Bridget. Anyone else for a public comment? Dave. Hi, guys. So at the start of the meeting, you mentioned DLL and licensure for selling tobacco paraphernalia. And I see Carrie back there. I hope you can hear me. In 2018, we changed the law in Vermont to legalize possession and growing your own but in that same piece of legislation, we also legalized possession and sale of cannabis paraphernalia. Cannabis paraphernalia was previously illegal to possess and sell. And that's why prior to 2018, it was very common for all the tobacco paraphernalia shops, well, all the head shops, to call themselves tobacco use only. They would have the signs up for tobacco use only. People would giggle about it and people would think like, oh, I'm gonna get kicked out if I mentioned this is a bong for weed. And we changed that. And when we changed that, we did not give DLL any kind of regulatory authority over cannabis paraphernalia. And in 2017, 2018, 2019 or 2020, we went through a lot of different iterations in the legislature over cannabis regulation. And the legislature considered giving DLC at the time, now DLL, some jurisdiction over the cannabis industry and ultimately decided not to. And the reasons for that, there's a couple of reasons for that, but one of the reasons is that DLC, DLL, they're cops and we don't want cops involved in the regulation of cannabis. They've done a pretty awful job of dealing with cannabis so far. And so this board was created as an independent agency to deal with cannabis. And you have taken a, in my opinion, fantastic education-first approach to compliance. And your compliance agents from Carrie on down all the way through have been partners to my licensed business, to all of my clients who are licensees, a true education-first approach that is not in the DNA of DLL. I don't believe that their interpretation of the statute is correct. I believe that cannabis stores are selling cannabis paraphernalia, not tobacco paraphernalia, and should be allowed to continue to do this without any DLL oversight. I believe that applying for getting a DLL tobacco license exposes cannabis retailers to a level of regulatory risk that is unnecessary and uncalled for by law. And I cannot recommend to my clients that they go that route, even though not going that route exposes them to a risk that DLL will issue them a citation for failing to have a license. This is a very difficult problem for the cannabis industry right now. As you said, there was a raid on one just last week and it wasn't just come in, check out whether we're selling the pipes and have the right license. They also did an undercover purchase, an underage person trying to get in. This is squarely the CCB's jurisdiction. You are the agency that's supposed to be sending people in with underaged fake IDs trying to get into our stores, not DLL. This is a big problem. I was surprised by the tone of your remarks at the start of the session, indicating that the CCB perhaps is okay with this position by DLL. It should not be. They are encroaching upon your turf for one, but two, they are endangering the cannabis industry in its infancy. I have reached out to key players in the legislature about this already. I will be pressing this very hard in the weeks ahead and I really want the CCB to join me in that effort, to support efforts to make a clear delineation between cannabis sales and tobacco sales. If that means making a change in the law to more explicitly prohibit cannabis stores from selling tobacco, I believe you would find support for that from the cannabis industry. And so that, yeah, that's it. I really want you to think about this and join us in pushing back against this overreach by DLL. And if a commissioner night or anyone else from DLL is listening, I will tell you, I for one am ready to challenge this determination by DLL in court and I believe that we will prevail if it came to that. Thank you. Thanks, Dave. Liz. Hi, yes, thank you for creating this space. I just wanted to spend a moment here to talk about another facet of equity that I would love some guidance and support from the board on. I am the director of the Vermont State Labor Council, AFL-CIO, which is our state's Federation of Labor unions. And we have unions that have worked with tennis workers in other states and are really trying to find ways to create a healthy environment for workers and employers by incentivizing labor peace when there are potential organizing campaigns coming up or just establishing labor neutrality. From the beginning, so workers feel comfortable in exercising their fundamental right to form a union. And some other states have done this through incentivizing licensure by employers agreeing to licensees and employers agreeing to labor peace agreements, which basically just a state what the law is in terms of respecting workers' rights. But unfortunately, we are in a state in this country where we have to remind employers of those laws. And so these agreements are very important. And so I would just love to discuss or just figure out how we can go about having a discussion and serious consideration of amending rule one to incentivize affecting workers' rights and labor peace. Essentially, a licensee would be able to agree to having a labor peace agreement as one of the four choices in section D. And I did submit this officially as well through the board's website. So I'm happy to answer any questions with respect to this, but I would love to just hear from others about how we can get this discussion going. Great, thanks, Liz. Anyone else for a public comment? Raise your virtual hand if you joined by the link or hit star six to unmute your phone if you'd like to make a comment. Yareem. Hi guys, how are you again? I hope you're doing well. One question, well, question I guess I had and I don't know if you can clarify, how many of those product registrations not being final are based on awaiting COAs from the labs? That's all I have. Thanks, Yareem. I don't have the answer to that on the top of my head, but we can see if someone from licensing can get back in touch. At least make a note to cover that point specifically. And our next meeting. Anyone else for a public comment? I think I'm gonna close the public comment window then. And thank everyone for joining. Happy New Year. The legislature is in session now and a lot of the constrictions that apply to the board and our rules are statutory. And so if you have kind of advice about things that really intersect with the cannabis laws in the state, please do reach out to your legislators. With that, I will adjourn the meeting.