 Great. So my name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. It's 11 a.m. on January 14th, 2022 and I call this meeting of the board to order. Just a few comments before we get to our meeting today. Just wanted to remind everyone that the new day and time of our regular board meetings are going to be Mondays at 11 a.m. However this coming Monday is Martin Luther King Jr. Day so our meeting next week will be on Tuesday at 11 a.m. and while we encourage remote participation just because of kind of the you know current trends in COVID cases we will have a physical location and it's our offices here in Montpelier 89 Main Street. So today is our official public comment meeting on rules one and two. I think this deserves a little bit of elaboration before we get started. Pursuant to the Vermont Administrative Procedures Act the board has been and will continue to collect all public comments that it receives about our rules starting from the time that they were filed and running through at least the end of next week and then we're going to hold a series of meetings in the coming weeks to review all of these comments publicly and respond to each unique and substantive comment and we have the ability to amend our rules based upon these comments. So these public comments and our responses to them are not only helpful for the board to kind of identify and correct issues they also become very relevant to the next stage of the administrative rules process where we present our rules including all the public comments we received to the legislative committee on administrative rules. That committee is really trying to ensure that everything that we've proposed in our rules is consistent with the legislative intent of our enabling legislation but they also want to make sure this legislative committee wants to make sure that we've listened to and considered every public comment you know all the people that went out of their way to read our rules and make comments on them that the board has listened to those folks. Again when these rules make it through that process and they're formally adopted they do have the force of law and violations of them can result in civil penalties they can implicate people's ability to participate in this industry um so these comments really are instrumental to shaping you know they have been and continue to be very instrumental into how we developed these rules the shape of the market the proposed fee structure and all the regulations we created have really been influenced by the public. Today we're focused on rules one and two we're going to have a similar meeting to this about our remaining rules but the most helpful comments today for the board will be around rules one and two. So just a few ground rules to help facilitate this meeting we're going to be here for the next two hours regardless of whether people are commenting we are not going to be responding to comments today or having a discussion about comments today. You can ask us questions today if you'd like we try to collect all questions that are asked and post responses to them on our website we're just not going to be answering them today. If you have a comment please raise your hand and we'll call on you in the order as you raise your hand with a few caveats. We always try and start with people in the room first. All right can can everyone can anyone hear us? Now you'll let us know when we're back if you can hear us. That's a bummer because that was all really great explanation. I hope we're on to start over again. Apologies for the lack of audio folks. So the people in the cannabis control board office can you try maybe leaving the meeting and coming back in? I'm having difficulty unmuting you as well. I'm in here. Okay we're unmuted now. Nellie here we go. Wonderful. Thank you all for your patience. Nellie do you have any sense of how far back I should go in my comments? You are just getting into the ground rules of all of this. Okay well I'm going to start with the ground rules for the meeting and hopefully everyone heard the beginning my opening comments about the process the stage the stage that we're in now. So we are going to be here the board is going to be here for the next two hours regardless of whether people are commenting or not. We won't be responding to comments or having a discussion today. You may ask us questions we really do try to collect those questions and post responses to them on our website but we just won't be answering direct questions today. If you have a public comment please raise your hand we'll call on you in the order you raise your hand with a few caveats. We are going to start with the folks that have shown up to the physical location again that's 89 Main Street in Montpelier. Then we'll move to the people that joined via the link and raise their virtual hands and then we'll pause and ask people on the phone if they have comments and when we get to that stage if you join by phone you can hit star six unmute yourself and we'll try and manage that process. When commenting please start by stating your name and where you're from we will allow repeat comments at this meeting as in the same person can comment at multiple different times over the next two hours. However we will prioritize first time commenters over people who have already made a comment. I'm going to try my best not to impose any time limits on people's comments unless it's looking like we have more commenters than we have time for and I will as always try and maintain a certain level of decorum if comments start becoming either kind of disrespectful to other commenters or if the comments really start to veer too far away from what's relevant to the business of the board and finally just ask that people leave their videos and their microphones off when they're not commenting and Nellie can help with that as well. So with that I think any any other additional statements Kyle or Julie that you'd like to make for you sir? No I really appreciate folks time and energy towards this process. Yeah let's get going. Great well we have a few people in the room again if you'd like to make a comment and you join via the link please raise your virtual hand but we will start with the folks in the room so please the floor is yours. If you if you wouldn't mind coming up here so the camera and the microphone can take it. Based on what I understood am I am I able to voice the five comments that I have or do I voice one and then after no afterwards come back just cycle through them yeah okay yeah so start with my name and name where you're from you know okay if you're comfortable with it it's not a requirement. Sure my name is Michael and I'm from the Northeast Kingdom and the very first comment that I had was related to section 2.4.1 through 2.4.3 titled security and I am what you would call an eco-grower and what that means is I would utilize the entire ecosystem to to my advantage when growing and it's a part of how I avoid using pesticides and insecticides is allowing a free ranging of my chickens my ducks and my guinea fowl and there is a I don't know how to quantify it but there is an order between birds and the dogs that I have and the ability to free range and coming up to the plants you know for a little bit of time while then free ranging to other spaces in which I've developed a a balance in in that the birds act as pest control but at the certain level now to get past the very first tier of growing there's you require specific security features which I understand why they're in place however I would like to grow past the first tier and I'm having an issue with the fencing in that as soon as I put a fencing in I'm influencing the ecosystem and now as a result of putting a larger fencing in I would thus have to use pesticides and insecticides whereas right now I'm currently using the most environmentally sustainable model that I can imagine so I would ask for special consideration for outdoor growers utilizing this method and in addition the size of the property that I'm talking about I'm talking about cultivating in the center of it so I already have somewhat of it's not a real fence but somewhat of a barrier or or boundary or border so that was the very first point that I had and that I see the fencing being an issue in terms of what I do and and remaining environmentally sound the second the second thing comment that I had was 2.3.6 section D and this this talks about the state giving them giving themselves permission at any point in time to come in and take clones or take samples of the genetics that you're growing and the reality is I can understand why the state would like to do this if there's been a safety concern or a safety breach and the call the genetics that are being cultivated pose a risk to the public health but they've specifically written in there that they have the ability to take genetics to further the state's research into what works and the reality is is that some people will spend an entire lifetime 30 their entire lives breeding and growing these strains and that's what I would consider intellectual property and I don't know of any other professions where the state's allowed to come in and take someone's intellectual property so my major issue being that someone like myself would spend 30 to 40 years of my life you know working on these genetics and then ultimately the genetics will be taken and then you know redistributed to someone's someone else's family or somehow the genetics get out and you know it's no longer a secure project and why would I why would I breed my plants and why would I work towards creating genetics that ultimately you know could could just be taken away from me in an instant so that that was a that was a point that I had and and also that I'm not aware of any other professions that allow that so moving forward I didn't fully understand I this was 1.4.9 section C and it's talking about creating developmental development ladders and I'm just not I wasn't fully sure what that meant and and I would like to be given the freedom to hire the the best possible candidates irregardless of their nationalities or sexual preferences or chromosomes so I personally feel that I would like to hire whoever is the most qualified irregardless of of that and I feel that I would ultimately be limited if I were if if I would ultimately be limited in in the selection that I could make for potential candidates that could serve the role in the best possible way see here another issue that I'm having is at 2.3.3 and this is regarding testing it states that samples need to be sent in for testing within a within three weeks of harvest and as an artisan grower I've been experimenting with longer dry times and this last season for example within my legal plants I spent up to four to even six weeks to incredibly slow the dry time down and what I found is that the trichomes continued development to continue to develop during this and so if I were to take a sample from that at three weeks well it would still be wet and if I were to then send it into a lab it would mold in the process and it would be completely unreflective to the the product that I intend to give so I asked for I'd ask for some wiggle room associated with that maybe it would be a situation where you send the sample in right before you package it or after it's cured for example I think I think three weeks is a is a bit of a stretch in some situations for an indoor grower that would probably be perfect okay and then and the the final point that I had 4.5.3 is related to alcohol consumption and the way I currently operate in my in my vegetable gardens is which was in walking distance to where I live is that I will occasionally drink a beer or two at the end of the day while I'm still working and I could see the need to put this in here for people who are using tractors and are using vehicles it's against the law to use alcohol while you're operating heavy machinery and or vehicles but I would also ask for some situations especially when the individual was able to walk from the location of the grove directly to their home and had no intentions of driving or using these heavy machinery I would ask the that that be waived as well I'm unsure the extent the state's willing to work with that or not but those were the five points that I that I had and I really appreciate you all allowing me the opportunity to voice any concerns that I had about this proposal and in general I thought I really liked it and I thought everyone did a fantastic job so far thank you very much I think these are all valid concerns we're not going to of course address them directly today maybe the week after next we'll kind of have a meeting and talk about all of these thank you so much thank you and if you want to comment again you know you'll have an opportunity if someone says something you want to respond to later on you know well you'll have that opportunity over the next couple hours thank you hello and good morning I want to thank you all for the opportunity to be here and I want to commend you all and I think it was a wonderful job that I've done so far outlining all these rules my name is Matt I am from Wyndham County in southeast in Vermont um my questions are not quite as as pointed as the previous gentlemen's as far as referencing the numbers but I think they are general questions that do relate to rule to rule one as they are um my first question would just be on is the mixed use license considered small tier or not I didn't see any clarity about that and any of the rules that I've reviewed thus far my next comment would be about outdoor cultivators being allowed a small space indoors for starts of course we know we have a short growing season different strains respond differently may need different times to grow so I think even just 20 30 40 square feet to start something indoors could be could be a boon for a lot of outdoor growers um my next comment would just also be about outdoors and considering is a hoop house or a high tunnel is that considered outdoors I didn't see anything specific on that but that's something that can really help you know growers in this in this part of the world to achieve good results and then my next question to be is is a greenhouse outdoors and where is the line is it is it supplemental lighting is it multiple crafts per year should you be using auto flowering varieties is it climate control so where do we draw the line between indoors and outdoors um that was my question that um next would be about the requirement for retailers to source 25 percent of their flower from small tier growers I know I saw this referenced in multiple places and I just wondered if there's any chance of making that permanent I saw that there was maybe between August and October of 2022 was supposed to be the requirement and I feel that that doesn't even really give especially outdoor cultivators any chance I mean your the final product isn't even cured by October so this isn't really a boon to small tier cultivators I really appreciate the emphasis on keeping this small and local as much as possible and I think that if there's any way we can make this a permanent stable of the program that would be beneficial I guess my last quick comments would be about if there is any um excise tax I've seen in a lot of other states that there's a per pound excise tax and I just wonder this is something that would be good to know ahead of time so that growers when they're actually making their business plans can take that into account and my last comment would just be about a timeline for provisional licensing it seems at this point like we may even be going into a 2023 before um growers in the state can really be up and running if we're pushing it towards the spring and towards May and June the actual license is going to be you know issued to people I mean there's infrastructure that needs to be built there's genetics that need to be sourced and I mean this is something that takes a bit of time and planning so um if we could get any clarity on that I really appreciate it great thank you yeah thank you very much appreciate it appreciate you're driving up today I don't see anyone else you know a physical location so why don't we turn to people that join via the link um you join via the link please raise your virtual hands and we will call on you in the order that you raise your hand Ben trouble joining the link still I'm not sure that there's anything you can do on here but just did want to let you know in case you are taking your lack of raised hands personally um but I also just want to jump in and say I don't have any specific notes right now I just want to jump in and throw full work behind this board for anybody who's listening Eli Harrington of Vermont, Tawana did a live on Instagram last night and also gave you your flowers in that and made it clear to folks that this is the time to support the board going in front of legislature is going to be a massive undertaking and I hope you all feel very supported by the Vermont cannabis community in that because you really set us out on a strong foundation so thank you for that and if I have a specific comment on rules I will raise my hand again but thanks so much thank you Ben next we have TS hey folks my name is Tim um I just have a couple clarifications and um one comment um concerning rule one uh there is a nursery license that looks to be included in a retail license and I was wondering if there is growth that is associated with that or how these clones or mother plants are kept by a retail business or for source elsewhere um and a comment I've been reaching out to a variety of banks and really Vermont specifically and most of them are not lending for this purpose right now and I know it's been an excellent um perspective of you folks it gets to small folks in there first um but it will be very difficult for anybody without you know BT from somebody else to get in and still own their company without being able to raise capital from um local banks and that's all thank you Tim next we have Will Roberts hello uh I'm Will Roberts I'm the prevention coordinator at uh Central Vermont for Edge Mead right here in Montpelier and serve Washington County and I would just like to emphasize I know you all have talked a lot about this over the the months that I've been um I would like to address a couple just sort of emphasize a couple of really necessary components of the legislation one being buffer zones for uh for establishments this is this is kind of a pretty important point so it needs to include the buffer zone needs to include schools childcare centers libraries playgrounds sports facilities or rec fields um and even parks and the reason why is that you we don't we don't want to have uh establishments being closed by any of these other uh other places where youth congregate youth attend classes youth attend sporting events um just because if to have that normalized behavior sends the wrong message to youth right and and and that's something that we don't want because we we want to help kids be safe we want to help kids uh you know have responsible use when they are actually adults right the other piece that I want to talk about is the cap on THC levels so I know that it's been recommended that we cap that at 15 percent and I know that that was not initially taken up but I'm going to emphasize that that's actually pretty important uh because with higher levels more higher risks of psychosis especially if you have any um you know uh pre-existing conditions so you want to cap that uh at a lower amount 15 percent is a pretty uh high amount anyway so having it at a higher amount than that just leads to greater risks for uh for you church so again thank you for hearing me out and um I I think you all are doing a great job and I appreciate all of the work that you're putting thank you will next is Jill hi uh thank you for um for being here and thanks for your comments um I'm speaking today on behalf of the Vermont Medical Society the American Academy of Pediatrics and Vermont Psychiatric Association and um I won't go on I did put in about six pages of comments so we won't go through all of that today but I did want to highlight a couple of things that um we haven't um spoken about before and that's in proposed rule two on 2.2.9 on the packaging um we highly support all of the um regulations that you have suggested in this section uh we would just say that child resistant packaging is actually pretty difficult the U.S. Consumer Product Safety Commission has said that it should not be relied on and so um one of the things that just came out recently was a study out of Ontario um January 7th 2022 that just showed a ton of young kids under the age of 10 that had gotten into edible products so one of the things that the study suggests is really making sure that those edible products do not look attractive to kids do not look like candy and you know so going a little bit beyond the packaging of what the products look like and how um this can lead to cannabis poisoning in the under age 10 um so that's color shapes flavors and then just to clarify we've been in the press on this and we also have put in comments before about the warning labels including acute physical and mental health risks associated with a higher THC um potency and just cannabis use in general and just clarifying that we had suggested that it be a very small um warning that includes psychosis impaired driving addiction suicide attempt uncontrollable vomiting etc and we had some concern and maybe you looked at this closely maybe the department of health looked at this closely but it seems like with the longer sentences and the warning label that people won't be able to focus on that and so that's why our suggestion was really just those six things and keeping it short and tight and bold um uh and including the mental health risks especially right now the other thing that I wanted to talk about as in proposed rule to also um you had it in 2.2.11 and that's regarding age dating and what we've seen with vaping and tobacco um products age dating is that it has not been successful in keeping use from buying these products and so I think there needs to be a real focus on effective age dating um in our comments we did put it's a somewhat dated article for 2015 um but it was about um a North Carolina study in which kids um there was 98 orders for vaping products and 75 were successful out of that for underage kids that were trying to get through age dating so just flagging that for everyone that that that will take a little bit more work and I think that you need to dig deep on on effective strategies around that because what we hear is that kids can get anything they want online um and that that's just a it's also an area for advertising that were um highly concerned about how you would regulate and how you would keep that to only 15 percent of youth under the age of 21 there's so many different kinds of social media right now and you know kids are far more savvy and um so that's it's a big concern for us and then we also um put in the comments and we've said this before is you know what kind of data collection system I didn't see anything and the um proposed rules around that um in terms of advertising and um how that works with the density of retail shops and the youth youth rate so I think just having that data collection is very important for us and um you know possibly the you know that would be directed to the Department of Health um and uh I think that that's the bulk of our comments we did also reiterate the buffer zone that that we think that there should be a minimum of a thousand foot buffer zone between all cannabis retail outlets and any schools parks college campuses and child care facilities and um I think on my comments some of the references did not get on there so I will send in a corrected copy um to you all so thank you very much thank you Jill and we'll um we did receive the written comments as well so we'll take a look at those thanks all right next is Evo good morning um this is Evo with Gaston wheat company first of all I want to thank you guys for all your hard work very exciting point we're out and I hope you know getting these readings in um a couple one thing that's really kind of like keeps coming back to me as we talked about you know some of these potential like general store type licenses and or the event licenses I've heard a lot about you know like being out of the public eye you know for me you know as a state who wants this who wants an adult use for a recreational market um I think like making sure that it's like tucked away it's like it's taboo so like let's be like forward thinking like we're monitoring the state and like embrace this this space that we're bringing to the state right like it's recreational use I think if you like a lot of the um stuff I've heard is that states that do have recreational or adult use the the youth consumption numbers are down um but let's not make it sort of taboo like let's let's embrace it let's not like worry about being tucked away so people can't see it like it's you know it's a pretty awesome thing that we're doing and I just think you know the you know the thousands feet from schools churches colleges daycares I mean that for one that really limits your availability to put in a put in a store or a cultivation or whatever but like let's normalize this you know there's a liquor store on every corner um you could go out and buy in a pod get a kill yourself and your whole family with your child um and I just think it's important to like embrace it and normalize it like don't make it so it's like a you know like a dirty corner of the store or whatever like it's that's just my my two sons on that um that's it thanks you both next is Amelia hey guys happy Friday um so I just wanted to touch really quick on packaging um having read back through rule two um I just wanted to mention again that often child resistant packaging has a big overlap with packaging that is not friendly to people with certain disabilities um you know arthritis uh various mobility issues um so I would just really urge that when you talk about child resistant packaging you also factor in what is and is not easy for an adult perhaps to open as somebody who struggles with arthritis myself oftentimes I have to have other people open things for me um that is considered child resistant which is annoying um and then as far as as far as buffer zones go uh I think when you talk about a buffer zone in regard to a childcare facility Vermont has a really high number I think of at home child daycares so what you have is you have obviously people running daycares out of their home and out of their residence and so if you if you put in a buffer zone of x amount of b whether we do the 500 to a thousand of childcare facilities all of a sudden you're not regulating the amount of space from you know a school you're regulating the amount of space from anybody's home and so that really narrows the amount of available space for a retail location and just kind of echoing what Eva said Evo said um you know this is this is something to be normalized and I understand that we're not normalizing youth consumption I think you guys get that too uh we're just normalizing the plant and we're normalizing not stigmatizing people that use the plant that buy the plant that legally consume the plant and I just just want to point out um that it is not the cannabis controls word's job to uh to parent other people's children um it is not your job to make sure that you know individuals children are not thinking about trying cannabis or about getting into the cannabis that their parents fight like there is a certain level of parental responsibility that comes with being a cannabis consumer and there's only so much that I think you guys can prevent as an individual for it um so I just wouldn't yeah that was just point it was me appreciate everything you guys are doing hope you have a good weekend thank you Melia next is Mariah thank you um my name is Mariah Flynn I am um uh a parent in a six junction of high school or middle school or and also um I work in the substance misuse prevention field um and but also I care a lot about the environmental impact of cannabis grows so I think that this group has spent some time thinking about that and I really appreciated in um in the the first uh rule making the kind of acknowledgement um around looking at the water um and um and the water use and the capacity in a community to be able to manage that I think that's one of the things I would continue to explore um looking at both the energy use and the waters and the water supply that are used with um cannabis grows um is different than most other plants that we grow um and so the impact is different and I think I'm really concerned about the um long-term environmental impacts that some of the other states are seeing around um increasing cannabis grows and so I the one thing that I would say maybe I haven't seen reflected here yet is what our evaluation of that over time might be um and how we're looking at you know in this in this provision I saw the kind of looking at individual communities and what the impact might be but like as a state overall having some way to evaluate that and respond and make changes to roles as we need to to ensure that we're not having you know increasing our environmental impact um so that's kind of aside from my prevention um that my prevention focus um which I'll honestly as a as a parent of teens and um and someone who kind of looks at substance abuse rates in our state um we continue to have some of the highest substance use rates in the nation for alcohol in cannabis um and so um so that's the piece that I'm really interested in and I appreciate Jill from the Vermont Medical Society's all of those points that she made around packaging and um and the warning labels and I just wanted to reiterate that that I think that um it was I was disappointed with the warning labels that were chosen um because I think that they're not really um acknowledging current research around cannabis and I think that um while I appreciate some of what's on there um it it really is um missing some of what the current science says around the particularly mental health connection to um regular cannabis use that I think needs to be better reflected there um and um and the kind of the there to me there was a piece around um make sure I have it in front of me while I say it um around you know it may uh in the language it says it may cause harm to the developing brain but I think the science is pretty clear that it does cause harm to the developing brain so the the lack of really clear language there is a little bit concerning to me um if we're really trying to prevent youth use um and then the other thing I wanted to note um was the again the buffer zones I think you know I think some in some of this I've really appreciated I actually in all of this I really appreciated the board's attention to really trying to think through all of these pieces and I think the only thing I sometimes get concerned about in looking at this and how things have developed is that sometimes we choose the what seems manageable in terms of causing regulations or in terms of the regulations and not what is best practice so I think you know what I've looked at around the research is that best practice in terms of buffer zones would be a thousand foot barrier from youth serving organizations or schools um that most of the you know we don't have a ton of research around this but we do have this kind of based on a thousand feet is the better parameter so I would just note that that you know if we want to really create a science focused or research focused way that we're approaching this um to use best practice in some of this pieces and and I um and one of the things that I appreciate is because we have this opportunity you know we have two legal substances already and so we have the potential to do better so I would um I kind of just wanted to respond to the fact that I don't think that we are trying to normalize cannabis use in Vermont I don't think that the in general are a goal in any substance use should not be to normalize it because that is um not in the best interests of our state um you know what we want to normalize is healthy um is healthy behaviors for folks so what we're what I think people really are thinking that they are hoping for is a lack of not stigmatizing people which is different than not normalizing so I just wanted to kind of make that distinction that in for our state when it comes to any legal substances we it's more cost effective for us if people do not use substances um that we end up having a longer term impact from substance use particularly if people develop problematic use so um so just wanted to kind of acknowledge that and make sure we we all have a sense that um substance use in general doesn't have societal benefits for us thank you Mariah next is THC Alex folks thank you for hearing us out I just have a comment about who to and under your definitions under uh harvest law uh it's uh it says means that growers harvest harvest a cannabis product produced during a single girl season in a continuous era containing the same cultivar variety and the reason I bring that up is because on rule walk two two nine I believe when you start talking about uh testing requirements uh under uh testing requirements you have harvest law um for trim for THC compliance and that would mean that anybody who uh grows anything over a thousand it's over a thousand feet anything anything and oh but anything between one plant and 20 000 feet you only have to test once if you have the same cultivar and it's the same growing season whether it's one plant or 25 000 plants uh I'd just like to see a little bit more clearance on that um because uh again it's ambiguous I can I can fit in a thousand feet I can fit one plant or you know a thousand plants in there and if that means I only have to test a fraction of the of that plant of those a thousand plants then you know it kind of defeats the purpose of the of the test itself um but that's my only comment on that um thanks very much for your work you guys have a good day thanks thanks for flagging that for us next is Damien hi my name is Damien Evans from um Morrisville and um my comment is just in regard of the retail cannabis license from my understand how it's tied to the address and location and everything um just would like some consideration to being able to like move our license to another location if we want to move to a new area and everything like when I'm being in a strip mall at first but then I also plan on building my location with just like the move to there and everything so just like a relocation fee something to think about and everything since I didn't see anything like that just a comment I had thanks Damien so um I don't see any hands raised from people that joined via the link so why don't we move to oh there's one right Nellie yep we just had two more first up is Sean hi good afternoon thank you for taking the time to hear everybody's comments um I don't understand why there's such a clear delineation between cannabis and alcohol in terms of trying to destigmatize and also just bring some semblance of normalcy of a product in a market so uh the proposed tax rates should now become more in line with how we're currently taxing alcohol sales um also THC caps should be removed uh and not necessarily put even further back at a proposed 15 percent like some of the other commenters that would remove and negate the last 50 years of both scientific and agricultural work that a lot of folks have been doing um delivery and online sales need to be done in a way that is customer friendly as soon as a person hoping to purchase through an online or delivery fashion cannot have that easily done from a licensed retailer they will go back to the black market they will go on to whatever the easiest and secure social media platform is and find somebody that will deliver them whatever they're looking for in short order please please wherever you can be an advocate of not attaching the vape tax to cannabis related consumption products or devices um tier three manufacturing needs a little bit better definition uh maybe in like rules 1.6 it's just kind of open that that'll still be determined in some timeframe from the board uh vendor and employee sampling i noticed was pretty clearly defined that samples will not be consumed on a licensed premise where does that leave the social nature of the substance and product testing in general uh where where do these samples get consumed as the conversation get had um so perhaps removing or clearly defining that perhaps sampling could be done on a licensed premise as long as employees are clocked out where there is some form of security measure built in if you're trying to avoid having employees on the clock while potentially intoxicated i get that let's appreciate it certainly trying to prevent child use and as it relates to packaging but i also noticed that packaging says that it needs to be opaque uh opaque packaging does not translate to a very customer friendly experience of being able to look at and try and understand the product that they're purchasing and i noticed one other thing in security uh 2.5.1 section f that the board can request pretty much any and all parameters of the security system and operational functionality of an establishment that now means the board is responsible to keep the operational security of every licensed establishment that you request that information of and if for some reason the board's database is breached in that regard anybody now has free reign to a a retail establishment's security protocols systems uh so p and so on um thank you so much for your time thanks yawn thanks for the specificity um next is tito hi everybody happy friday um my name's tito i represent the burn collective and uh i will be submitting all of my um all of my analysis on on rules one through five this week but just today to focus on um again the the commercial building requirements um is somewhere in your recommendations you can recommend to relax the commercial building requirements for let's say two years i mean you know we're all we're all getting started in this a lot of us who have been growing cannabis for a long time have not run a commercial facility so i know for me we're we're only going to go with a tier two we're going to try small and we absolutely have plans on expanding let's say in about two years and i'm sure a lot of other people feel the same way so if there's a way to relax the commercial building requirements for two years um and uh things like um installation requirements you know bringing a building up to exactly r 40 when maybe it's r 33 or something and it's like i mean what tremendous cost that's going to add to have to uh re-insulate the entire commercial building when in two years we might just knock the whole thing down and start over and you know handicap bathrooms the requirements have to have um uh you know the 62 inch turnaround um and um you know these things that maybe at first are really not that important um you know and maybe we could relax it a little bit for two years let um you know the whole legacy market uh get in there and get started and and and and then and then require that let's say two two years down the road uh also uh i agree with evo um let's not talk this away uh and and on that note um the we have to not count inside of store visual things as outdoor advertising uh i think that could be really really terrible and uh that's gonna create like uh a really seedy feeling which is you know you're gonna see all these stores with these blocked out window fronts i mean nobody wants that i cannot imagine how they'll block out the front of the burn gallery because if you look through the window you could see something that said toward cannabis or something i mean i think you gotta listen to um but thank you all so much and hopefully everybody has a great day thank you to you all next is allison i'm allison link i live in morrisville and i'm parent of three kids i also work for our local substance prevention coalition healthy lamoille valley so i'm glad to be here and the opportunity um so the first thing i want to mention so last night we hosted an event teens and cannabis and just to reiterate um you know hear lots of um data out there that uh you know comes through public comment and elsewhere but i know you've done some thorough research we've also provided from the prevention community and others that really that huge impact on youth and teens that cannabis has and even that are we retail market um would have and that the one of the main things is looking at data longitudinally looking at data um you know not just at one point in time and to be able to look underneath what the data means like for example um just because you know the question is not why hasn't uh cannabis um youths and teens gone up with uh legislation and that's not necessarily the case but if that is a data point that someone does see it's the question might be why hasn't it gone down like the other substances had trended going down and why hasn't maintained the same so i think looking at the data with uh different lenses especially longitudinally is important and nuances are even related to potency and other pieces and happy to send a copy of the recording from last night's session that um with dr john seros uh two i would just want to mention um outlet density not just of the um of retail outlets but also of any other licenses uh and thinking about density we've heard a lot about buffer zones before and the buffer zones but i was also thinking about with respect to density um and considering even the connection between buffer zone and density i guess in distance between licenses um whether it's retail uh or other other licenses that um you know when working with local municipalities on what their potential regulations might be in addition to what your proposals are and what is passed in the legislature that seems to be coming up for some folks um and with respect to funding i know there's a set amount of tax that's been earmarked for prevention and just to reiterate the importance that that goes to vdh and that you know vdh already doing so much of the prevention work that the folks that that it really gets to the health department to be able to figure out okay now what do we do with that my last piece that i wanted to mention is something that's coming up with some of the towns that i'm working with um so so some folks are starting to um ask for that from their towns for permits to start building um facilities uh for manufacturing or growing or whatever they're doing and that some of that is not necessarily in alignment with what the recommendations from the ccb are so um and they surely don't have licenses yet for cultivation or because they haven't been issued yet so what may happen will be vacant buildings that don't align with uh you know either like those folks don't get licenses or those folks um you know not um you know in regulation with what winds up being the regulation of like let's say um the the amount of space so just to highlight that i don't know what that might mean for um you know your work moving forward but that's happening on the ground in local municipalities uh and is uh you know something that i guess folks who will be applying for licenses would be good to to know and and as the rulemaking becomes more set but knowing that the rulemaking will also evolve so thank you so much for the opportunity to comment have a good weekend thanks allison and i know uh i at least would like to watch that video so maybe nelly can get in touch with you about getting a link for us thanks next is ron hi uh so this is ron from mr z craft canvas um i just want to make two comments first of all completely agree with tito um i really really really really would like to request that you know the ccb please work to help relax commercial building apartments for two years i think that was a great suggestion on tito's part um you know this is really an owner's process and and you know we are doing everything we tend to comply with that but you know we were just quoted for 300 dollars per square foot which is i think an insane number everyone can say that uh you know without doing the math on hand um so yeah relaxing those requirements would be incredibly helpful for smaller growers such as ourselves to enter the market um second i would like to do with people um and we are trying to be safe with best cannabis consumption you know i'm speaking of a 29 year old man i'm friendly with the majority of people that i think have been on this call have been older people substantially older you know as is the makeup of the state uh you know i was a teenager not so long ago and let me say you gave this figure on a product that's gonna entice them they're gonna do what they want and they're gonna go for what they want you know so so let's make sure that we are creating these laws um you know trying to think about uh you know destigmatizing the product and ensuring that you know medical patients can obtain what they need to obtain um and that we're not you know we're being realistic about about consumption and how this should play out here um and those are my two comments that's it thank you thanks ron next is glenn yeah hi how y'all doing um so my name is glenn ederson i live out here in waterbury center in a few three decades and uh came up to the law to give you the end and stuck around my son recently just went to castleton uh he's now in chicago at this essay i see it's an art institute and while he was at castleton he um went through the cannabis program there that's actually a phenomenal program somebody that's been in the industry for a while you know i sort of listened in um and i think that the state's done some great stuff to you know actually encourage this industry um and as somebody that literally brought it in uh to an intern on a farm where we grew at the tier six uh level for hemp licensed through the agency of agriculture um you know we literally in the tier six proposed regulations obviously in these rules here but you know we were able to uh do some pretty phenomenal things from research and development and you know that translated into an internship that was actually ironically fully paid for by the state because that was his uh senior high school year um so that was a program the state offers to public schools that were actually to all schools um where students can go and um learn and he was actually um 17 at the time of completion of that program um and now he's off in chicago a licensed state where i cannot actually uh run over there and say hey you know he better you can't do that and so he's now 18 in a big city that has graduated on is over in college and he's done great things and we brought him um and really excited about the program at cast and it's normal things um then i've met some of the other graduates of that program right so i guess the thing that i'm trying to drive back here and try to truncate this and maybe supply some written this to you um on the full set of pools not just one two but as the packaging comes up um i am neurodiverse i am somebody that thinks that he typically i have been prescribed all sorts of medicines for that by the healthcare industry i really do find efficacy and how they're all for sure um but i find a great deal of efficacy in the cannabis specifically and so for that reason you know i pushed my doctors many many years ago to help get cannabis trials moving forward for bonds and specifically for neurodiversity for what i've been through they did not but they were very willing to don't to open up prescription for Vicodin from a back pain and that was just an open script so my point being that this drug that kills no one right in all time ever is being compared to alcohol a drug that kills 300 providers on average every single year and 80 000 americans every single year but we're having this excellent conversation for medical people proposing ideas of packaging to make a drug that kills absolutely no one look like it's a devil and i can't help but think of you're trapped in a warm charge and i do see the work the ccb is doing and i do appreciate it i want to just make that point very clear but there's a lot of us that speak about mobilization and we realize you're trapped in a set of rules that a legislature put together and at that very same level we see them manipulating these rules trying to push you know and whisper ideas into your space and you have the power to push that back and i do highly encourage you to because quite frankly i support my son's work i want to come back to Vermont and want him to be a vigorous uh human being that lives his true not necessarily in this industry per se but what i do want to see is a space here in Vermont where innovation can thrive where the youth aren't told they're bad because they harmed their brain on something that we know he has no one when there's wet bars in their parents home that keeps killing them from the toxicity of the alcohol poison so as people are advocating for increased packaging that as a very diverse individual is sort of seemingly offensive on every level you know that of medicine that literally in medicine that we find increasingly studies from israel that speaks to the autistic community uh other communities are canadian studies that speak to the add efficacy and treating add i mean so many pieces that are on the table proof and facts and yet we're hearing hearsay about how alcohol and tobacco are the exact same thing as cannabis where we know the data statistics of death alone are not even close to being parallel but the only reason we're having this conversation now is because it was regulated and legislated into title set now i suppose i mean i suppose that to be anything but i do support i had supported under title 26 which is occupations and professions and so while i can't go backwards and ask the legislature to rewrite those laws so that the titles actually make sense and how we do it and how we legislate it relative to potentially more like a vet tech or a tattoo parlor or something else that just doesn't kill people so i guess what i'm saying is you have the power i really do hope i do hope to come before you and get a license not just for the farm that we crop share at and not just for you know some friends of ours that are interconnected that want to put together a retail license here in water very but for all the reasons that i want to contribute to this economy and bring back my son and all these other people that want to be part of this community that will get pushed out and squeezed out because of all the technicalities that we can choose to not layer in here to appease a few bunch of squeaky wheels that want to use bad data science so you're not even i'll submit some written rules i do appreciate your time and thank you for this thank you going all right next is fell all right thank you guys very much for all that you do it is definitely greatly appreciated um wanted to bring up a point that was already mentioned just kind of reiterated 2.3.3 under testing a testing propensity of a crop must take place within the three week period preceding a harvest i think as a cultivator as a consumer and as a board i think ultimately you'd want the the testing results on the product to actually reflect what the product is anybody who's cultivating knows that there's a lot of development that happens in the last three weeks of the plant and so you know requiring within the three week period preceding the harvest i just don't think that makes a lot of sense i do think that there should probably be a time frame as far as the earliest you could test but maybe just changing that to having it tested before it's the final packaging i think that would make the most sense because again i i personally wanted my percentages on the product to actually reflect what the product is and i think that would be incredibly helpful and then one other comment i wanted to make there's a gentleman asking me about outdoor plants and being able to bring them indoors i just wanted to point out that that is already reflected in rule two section four point seven other plants cannabis plant seeds and clones and propagation or vegetative phase of development may be kept indoors during winter months when outdoor cultivation is not possible provided that outdoor cultivation licensees may not cultivate cannabis indoors i think that's a great thing just wanted to point out that it is already addressed or from that though i again appreciate everything you guys are doing thank you thanks phil so i don't see any other hands up certainly um you know if you would like to make a comment oh all right all right it's uh nick at flovensfinest.com we can hear you nick okay great hey hi you guys doing good uh i just wanted to i have a couple uh there are actually more questions than comments but a few uh two items that we've been wondering about that i haven't seen addressed really well is the the time frame as far as upgrading from tier one or tier two to the next year we're curious what that looks like there has been any discussion on what the requirements would be and how soon something like that could happen based on the market and how quickly some of these companies can expand you know a few other people have mentioned that and so you know we want to apply for the license that makes the most sense for us but i think a lot of cultivators are anticipating expansion within the first year. That was the first question the last two items would kind of be rolled together our company is not planning on manufacturing and so we would be looking to license manufacturers and processors to you know work with our material to produce you know concentrates or edibles if we are wanting to brand our own products but manufacture them ourselves i'm hoping to see a a way to transfer those materials or to be able to you know hire out manufacturing and then be able to retail some of our own products i don't know if that would i don't know if we would have to receive a license a manufacturer license to be able to do that or if we would just have to take off our our material and then it would be like labeled essentially and then brand it it really comes down to branding and then the last part is pre-rolls the same you know we're we really want to package all of our own products in-house for quality control purposes and you know pre-rolls are another item that we are interested in and i was curious to whether that would be considered a manufacturing of the product or if you know if we're able to pack into our own flower products we would be able to pack into our own um pre-rolls and and sell those as a as a cultivator without a license and then that goes hand to hand with the concentrates or edibles that would work with other companies to do that work what does that look like thanks nick um so just a reminder that we are collecting these questions and these comments we'll try our best to answer them in the coming weeks um but we're not going to respond directly today um uh shawn i see your hand up again um i we're just gonna i'm just going to move to the folks on the phone first and then back to the people in the room and then i'll we'll come back to you next okay we'll leave your hand up so thank you um so if anyone joined via the phone um you can hit star six to unmute yourself if you'd like to make a public comment and i'll just give it a second yes we can hear you okay very good how is jeffy j with cold roses unit uh thank you guys for holding this of the commentary and i think uh i think something to be done is just all the chatting gears so i'm just going to um make um i'm i'm not gonna just move to the room for you guys for me look at that yet and so i'm just really encouraging to see um some multiple nick used here i see where we ended the meeting earlier this week you guys are thinking about in the meeting the outdoor stand or outdoor pet house in keeping the indoor thousands work needs for the second year up um thank you really wanted to discourage that um again i wrote uh a little rudder on it so you can take a look at why um so really to do maybe three weeks here this is a really simple for you guys we i know you guys have so many details to work out but just to keep it at a thousand square feet behind the outdoor stand two thousand square feet two hundred outdoor stands uh three thousand square feet and then three hundred out here in just three years um we can be visited as leaders um could be here and see the lot could be band-aid but i think that uh going out and getting multiple years is going to benefit um here are key to being in this team in multiple ways uh you know encouraging outdoor and just like rolling over indoor cultivations and outdoor running missions um encouraging small cultivators uh by reducing the alias and keeping the cultivating irrigation uh it's important small cultivators and cultivating this is um but it helps um oh everyone's really excited for the ability to take it to the role that we'll stay then uh but since the legislature has both let it have multiple licenses and each part of the supply chain which went off with gas and then i think it would also help ease some of the frustrations people are having with the definition of canopy size uh because the whole guy didn't need to be ready to carry it out but all of these things um you know would be a rig so take a look at that um and if we could start prioritizing cultivations a little bit just like missions that you guys have been out um it means early licensing applications something about cultivations um just because you know our new cultivation is going to affect everything else in using my chain um somebody just starting getting things out so those of us waiting to get a cultivation license can be ready to rock and roll um would be great also um just to shout out to michael um to make the way his growing method um and you know allowing chicken to range in order to get up to us um we also also in that way so um then i know that also which was important is sustainability and environment that they felt uh i think you can take that and then also the comment on um have these um you know requirements that need obviously so anyways um last day it's not mentioned that the office right here was reported by us in the public especially on the daily day with you guys in all these meetings and i think that i hope you guys know that um we are here to support you also when you go to legislation and appreciate all the work you guys are doing and just recognize how many second details you guys have to work out so i can't even imagine so bravo and we love it thanks so much thank you jessie anyone else who joined via the phone um you can hit star six to unmute yourself to make a public comment okay um so um i'm just going to just reset very quickly remind folks i've seen a couple people join since we originally started um we're going to be here for about another 45 minutes um regardless that people are making comments um you know uh please raise your virtual hands um if you join via the link we have a few people in the room with us that we're going to turn to next um you can make repeat comments if you've already commented but you've heard something or something else came to mind please um you know feel free to make another comment um and again we're in the phase of our rule making um where we are going to consider um and respond to every kind of unique substantive comment that we receive and um and then we're gonna we can continue to make amendments to our rules throughout this process um so it's important for us to really hear from the folks that are going to be regulated by the ccb what's unworkable what's duplicative what you know is in conflict with your current growing practices um you know everything that um we can do to kind of make this uh partnership and to make this a kind of thriving equitable market is really important to us um so with that i'm just going to turn once again to the folks in the room any additional comments for me i had some but throughout the process most of my comments were addressed okay um just one additional comment i suppose going off with um what the last one was saying about the multi-tier for the mixed use licensing i had that question about is there a small tier mixed use i guess that would be could there be a small tier mixed use if there wasn't i mean even if it's not a thousand square feet and 50 plants if it's something cut down from there i think that would offer um small growers a lot of flexibility and a lot of room for innovation and yeah and also just more consistent supply chain from the small growers because if we're so based on outdoor outdoor well as i've seen in the charts we're going to have a lot of product at certain times in the autumn and then we may have you know you may have retailers looking elsewhere maybe i'm not sure bigger players where if we could keep it small level that would that would be better for us i think yeah so um we'll turn back to the folks that joined by the link um nellie can you help us just make sure we get the order right yes uh next up is shawn uh maybe just make an interesting proposal about the mixed uh tiers it's now split between square footage and plant count but what if the mixed tier outdoor portion was also a square footage uh it you know a plant count doesn't necessarily accommodate for folks style in terms of doing uh light depth grow auto flowers any number of variations where canopy would be a better directed line and growers do whatever they do within that square footage rather than a plant count i don't mean to open a can of worms which is something else to think about in terms of mixed tier uh what originally got me to raise my hand again though is asking uh from the flip side of nick who just spoke of how to send his cannabis off to a manufacturer and how to get some kind of collaboration going or what his products might look like with his brand on it but made from another company extraction as manufacturer i would come at it from being the solvent maybe like tiers three solvent list manufacturer and wanting to know what that handshake or business or permitting would look like between those two entities yeah thanks shawn thank you yep thank you we had um a couple people raise their hands who have not previously commented so uh pepper would you like to move on to them first uh yes please and then but just kind of keep the the order of the repeat commenter commenters in your mind if you can yep yeah i've got that uh so fran is next everyone i'm fran janet down in jamaica i'm a medical patient and a grower and an advocate for other medical patients in the state uh one of the things that's come up is that the limits on concentrations and it comes to mind that in fpd6 any promoter who has a home grow is allowed to use an ethanol process to create a tincture or a an oil from it and that is not limited uh and by any percentage it really would not be realistic to do that and again i would reiterate that if you're going to limit anything on percentage you're going to force the grower or the processor to add another substance to the process uh so my concern would be a conflict with act 86 i will simply go on to say that i agree with Amelia glenn nick and a few of the other people especially the two gentlemen who spoke initially this morning i think the less that we contain and control and the more that we help people to get into the system so that we can regular system that we will do better with it thank you so much for having my comments today and i will be submitting some comments of writing thank you fran all right he goes next hello again everyone um so a couple things one you know i really want to echo the thing about testing the three that three week period a lot of times you're not even going to have cured cannabis by then um and i i do think that probably when it goes into packaging is the correct time because by that time your cannabinoid profile turbines has to climb without anything you're catching for will be present you know and i i think that's a really important important piece um also you know i want to ask you again i know this has been said before um you know what what we can do as the community to try to remove this 92% vape tax i mean this is a you know upwards of 20% and growing in the market is the vape and you know to have somebody pay like 100% tax on it is just not not good for anybody not not good for our space certainly and will drive people to the legacy or black market or whatever you want to call it um and then the one other thing i'm great for you heard this for me a couple times and i haven't really seen any regulation around it but you know i do ask that we make disposable vape products i think we should ban them in vermont it's not sustainable to throw a battery out for every half gram of oil you're consuming um i've you know i've seen this category grow when i worked in the california space and it was just disgusting to me to see how many companies jumped on the bandwagon to these disposable pens which in a in the tourism in the ticket but i think there's a lot of tourism people like that because they're you know they don't want to take it with them necessarily but you can still throw away your battery if you need to um so just something to think about you know with the product and anyone listening as a as a brand or manufacturer i also ask you that you you know try to leave the disposables to the wayside like let you know let the other states do them if they want to but you know vermont's i don't think that's what vermont's all about so i would love to see that in there and then the gun phd caps is not going to allow our marketplace to create the best products we could make manufacture cultivate vermont is known for quality products and i would hate to see us be some part of life in the canvases that's it thank you thank you all right mariah is next so mariah again thank you so much um i realized that i forgot one of the points that i wanted to make earlier um so uh one other thing i noticed in the proposed rule two under um 2.2.5 um was some notes around the uh licensee training requirements um and there was one piece that was just confusing to me and another one that i had a comment about um the confusing piece was there's a in um section a under that there's a piece that says um the agent who controlled the cannabis establishment so complete and enforcement seven or ones every three years but then for the purposes of that section it says that the agent refers to anyone who's an employee of the establishment or who works at the establishment and then there's a no in section b under that that says essentially like any employees have to have a training every year so that to me that felt like it was two saying two different things about the same thing um but the kind of so i guess the um my recommendation or comment on that is that particularly since this is a new enterprise for vermont i think it really like once every three years to me is inadequate so i would um suggest once a year is really more appropriate for where we are with um i mean it's just is what we require for alcohol licenses but also um it just makes sense because this is such a new enterprise that folks should be um a lot of what we might be training folks around is going to be still new in developing and a lot of the research around cannabis is still coming out all the time so it makes sense that folks would need regular updates to the information that they're learning um and the other piece i didn't understand from that section was there doesn't it doesn't seem to know who is the who is providing this training um and what kind of where's the information that you're required to train your employees on where is that coming from so i think that's just really important to um to also be clear about um and to ensure that that's not a necessarily an in-house training essentially because you know some of that information is really important that we're using current data and science around thanks mariah thanks for flagging that for us thank you very much thank you uh amelia's next hey um just came to mind while i was listening to everybody especially the people who are mentioning outdoor play accounts um and possibly wanting to shift to higher tiers in the future um something that i would love to see us move away from in regard to plant counts that i know i've talked about before is um eliminating the immature plant count cap if we are capping mature plant counts there really is no need to cap the immature plant count um i think any of the growers on this call would probably agree with me on that there are just so many things that you can't guarantee in growing and one of those things if you're growing from seed is the number of males versus females you're gonna have um and also if you are in the medical space uh like i know a couple of the other people on this call are and you are trying to breed new genetics that work better for medical patients that's really hard to do when you are capped on your immature plant count because you are not able to sort through your phenotype to full expression uh quite as easily so you're limited on the number of immature plants that you can have um and the other thing that i just wanted to address um that i really don't feel like i'm happy but i'm going to uh is somebody earlier said that the goal of you know prevention is that nobody should be on substances and as a medical patient i i really take that i guess personally um 70 percent of americans are on pharmaceuticals and we have an endocannabinoid system we don't have an endo non-serial anti-inflammatory drug system we are not made to interact with things like Tylenol we're made to interact with cannabinoids um and i just think that when we say things like people aren't supposed to be using substances we're cutting out a huge portion of the disabled population who rely in some way or another on a substance and if if you give me the choice between an opiate or adipropanur Tylenol or something like cannabis i'm going to choose cannabis every single time and i'm somebody who has been put on things like dilaudid and fentanyl and i still choose cannabis over everything because it is the least damaging thing to my body in the long term um so just pointing out that saying that the goal should be that people aren't on substances is extremely like it excludes so many people with disabilities um yeah so that was all i wanted to say thanks Amelia thanks for keeping an eye on us always all right we have uh jeremy collins who has not previously commented hi everybody my name is jeremy collins i live in monewski i am 29 years old and i'm a medical patient and i've been a medical patient for about five years um one of the biggest issues i've had with the medical program is the lack of individual batch testing results um i've asked series slash shampoos valid sets are many times for those over the years and there's always like a good option in the neighborhood personally i have an issue with the thc cap because i am a medical patient for a variety of reasons i've been put on most of your black suit when i was about 15 years old just to sleep i've been put on all sorts of uh variety of pain meds i wake up every single day and have a headache about an hour and a half after waking up so i'm migrating but it's a headache that's there all the time i've been going to physical therapy i've gone up to chiropractic that does preventative work and to be honest with you dealing with me i'm really touching that pain that isn't uh at a little time you know or something harder is uh medical cannabis patches the one-to-one patches i find are really good for myself other than that the only thing that can help me really are the high concentrate thc concentrates so that's the only thing that affects my pain and as a 29 year old active serial entrepreneur in the area that's very tough for me to manage that especially with the low caps that will force me back into the black market where i previously done most of my uh medicines so i just speaking out for all those medical patients that you know i have a right to i've got a variety of things going on and i could take 10 pills for probably each one of those different benefits and i they're not different so thanks for your time you guys are doing a great job and i appreciate all of you listening thanks Jeremy right Tino is next i know that i've commented about the big tax um endlessly but i guess i've just been inspired by all these other comments um but before i talk about that i just i do want to agree with Amelia uh i mean the demonizing with this planet just knows no bounds it's amazing um but with the big tax um you know it's act 28 i have an economy and it's amazing it's pretty small and it's amazing how small the adjustment has to be to basically just eliminate all cannabis intended products from this legislation um it reads act 28 taxation of e-cigarettes effective July 1st 2019 the definition of other tobacco products is is expanded to include tobacco substitutes which which include e-cigarettes and any liquids whether nicotine based or not just that little evil little comment just get that out of there and the whole thing is good and then the next paragraph it says uh uh that contain or are designed to deliver nicotine or other substances it's like what is that um you know this is a it was designed for um to attack nicotine day problems in high schools specifically with jewels uh why why these other little comments were thrown in i i had no idea but that's how little it has to be done to to make this right uh thank you thanks Tito all right Sean I just wanted to double back to the training portion as it might relate to a cannabis employee identification card and to strongly support the identification cards are held by the individual by what you're calling an employee currently and that it's not necessarily held or operated or at the behest of a company a retailer the license holder it doesn't allow a lot of room for an individual or an employee to be able to move companies be able to just be a worker in the marketplace in a free marketplace where their labor they're free to take wherever they want and so that identification card is you guys keeping records and making sure that a person not uh you know an unsavory character but it also should tie into the training where training is through the state and is to the state guidelines rather than in-house training provided by a company and so it would any of those card holders would need to re-up with the state upon whatever timeline you agree upon and we'd have to still suss out whether it's upon the employee to continuously make sure that they're good or when they enter into appointment with a company the HR person of that company needs to just always be checking records and be like hey we see your your card's lapsing uh get it re-upped before it closes or we'll take you off of the schedule until you can show us your card is renewed thanks Sean thank you so um anyone who joined via the link please um just raise your virtual hand um we'll call you in order um and if anyone joined via the phone um it's star six to unmute yourself and do you want to make any comments at any point feel free to join us here at the table thank you sir um again um this is our public comment period um you know we are collecting all of these comments and we're going to kind of systematically over the next couple weeks go through them um in a public meeting setting respond to them um make changes to our proposed rules and then um and then move on to kind of the next phase which is really uh appearing as a board before the legislative committee on administrative rules um so um yeah we're going to stay here till at least 11 um I mean one o'clock excuse me uh and and so you you know feel free to raise your hand at any point um or kind of chime in Fran has raised his hand again Fran hi I'd like to say before that the legislature we will be right behind you for in the meetings with you and I am already in contact with my legislature legislators health wise and I'd like to give a high five to what Amelia has just said thank you thank you Fran Ben is next hello again everybody um I apologize this may be addressed elsewhere um it is also kind of a tap on to one of the gentlemen commented earlier about wanting to be able to move his license um so this is just a general comment question to be addressed at some point uh with regards to the licensing process applications um I have heard questions from some folks about what happens if they uh are not ready to apply during the set application period and to the best of my knowledge all I've said is that um there probably will be other application periods they just have not been announced yet so any clarity around that would probably be helpful for people especially as we know the location search can be um a big barrier in getting to that point um and then in the same vein for folks who apply but their application does not pass muster within that one month application period whether or not their application would be kind of open and able to be completed uh you know if there will be a timeline when they would have to be completed or if the board's granting of licenses will be limited to just that one month period or if uh basically an application submit during the application period can be approved at any point beyond the month that follows the application period so I'm sorry a little bit of a clunky question but definitely something I've heard conversation around so any clarity along the way would be great for folks thank you thanks for flagging that Ben we'll definitely um discuss that and get some guidance out around that Amelia is next hi again oh yeah I just I've heard the the the vague text thing brought up a few times now um and I just wanted to make it clear to everybody on the call that um that's that's not within the CCB's jurisdiction to change um that it's a legislative thing that has to go all the way back through the state house um in legislation it's not just a rule that the CCB can change the wording of um but I really love all of the support that's been thrown on this call especially behind eliminating um that tax for cannabis intended use Tito and I I just want to let you all know that um Tito and I actually have a petition going right now um to eliminate that tax on cannabis intended use paid products um so if anybody here really wants to change that they can sign the petition and there will be movement going forward to address that in the state house but it is not an issue that the cannabis control board can just like snap their fingers and and solve um thank you thanks Amelia uh let's see I think Jeremy is next first I'm joining you all uh my concern with the tax for the vaping and support of the concern for the overtaxing of the vape products would be that especially in a infancy of a cannabis industry where there's outdoors growers new growers who are going to be met with challenges that they they don't even know we we all don't know yet what kind of challenges might still be facing us all but we do know the ones that we've already met which are you know our seasons are quick and harsh and uh mold and mildews and pests are they're out there um remediation of those products through processes of extraction and um distillation are how we can keep quality healthy products in the marketplace and also if you're overtaxing it you're creating a disposition for anybody who wants to manufacture and sell here if they're near a bordering state that doesn't that that they can't compete with in product and cost so uh appreciated that's just my two cents as somebody who's considering getting into distillation here and our extraction thank you thank you Jeremy there's a Taylor carpenter with Gaston weed company thank you guys so much for this um you know I know you I know you've heard a lot about the THC caps a lot of people talking about it I just wanted to just kind of say a few things I was thinking about it um you know for you know so I'm I'm very familiar and um experienced and testing a lot of products and you know something that just really is scary about this you know even if it even if it gets raised to 30% you know even if that's something for the flower um it's just you know test results can vary so much right so it's like you know you could bring you could cut down your plant you know take a nod take a nardator you know take some and go test it take some from that exact plant go test it and it can vary tremendously and you know I think for that poses a risk on on on every kind of you know person in this industry you know for the growers you know as as a grower if we grow really great flower and it's testing it 29% and we're right below that and you know hey that's that's great and this is this is awesome flower and then say that very next harvest that could test it 31% of that same exact you know genetic from a clone from that plant could potentially test above that you know and then we would have to throw away or whatever do something with that and then another thing too with that is just you know kind of the fake testing result or you know that you can do you can take stuff from the bottom of your plant this out you know the flower that's less developed and maybe test that and it'll test a lot lower but then you're pumping out that higher quality flower so there's just a lot of things that kind of you know brings up and then another thing too is you know as far as like a law perspective I mean there there are people's you know jobs and missions to go out there and sue people for false advertisement on packaging so I mean if we're if we're putting out there like this is 29% and a consumer goes and buys a bunch of it and tests it like who are we you know how are we going to be protected by the state of Vermont to not get sued by that and I think that's a good you know something to bring up just in general because there are people that are going to be doing this um and then just kind of the last thing like we have a really good buddy that is um kind of been helping us out with some stuff but and he's from Vermont but he just opened a pretty big um you know business in Massachusetts a store and they're doing grow dispensary kind of the whole nine yards and they're producing some really great flower and all that flower and you know this is right over the border of Vermont so um you know he he has a few strains that he's pumping out there over 30% and you know I'm not big on that I think you know as a reconnoisseur I really don't care about the weed percentage or the THC percentage but a lot of the consumers do and I know that that flower that's over 30% advertised on his you know menus and stuff is pumping out the door and so if we're going to like regulate that here you know what's going to stop people from bringing it from Massachusetts and bringing it from all these places around us that are not proposing that half so I think even you know for closing the 30% is is still a stretch and I think that puts everyone in the business at risk um so yeah I hope that gets uh gets talked about a little bit more but thank you guys so much and have a great day appreciate it thanks Taylor next is Tito hey so just uh another couple things about the VATAC so um it is true that the CCB cannot just snap their fingers and make this change but the CCB can add it to their recommendations and that could help add a little bit of momentum to our petition Amelia and but also as a future cannabis retail owner need clarity I mean the current dispensaries don't have to pay this VATAC on the same items that that I do and so when we all become um cannabis retail what's going to happen it's just really unclear so um maybe just for that alone we need some clarity thank you thanks Tito Sean is next yeah I just want to go from a non-store owner we we understand that you all cannot just snap the fingers we're just you know hoping that you hear an abstraction from us it goes in certainly um in terms of THC caps it's been largely based you know the conversation has been 30 flower I happen to be a solvent let's concentrate producer and uh 60 percent is the current cap that can be achieved through very simple uh non-solvent non-lab based methods uh that needs to be increased significantly we're removed entirely or perhaps the compromise is made where if a concentrate is produced and sold on the market that is say 90 plus percent that there needs to be some form of minimal CBD content along with uh the high THC potency uh you know I think the concern is that folks are consuming very high rates of THC and experiencing all these health issues that we keep being scared by in the headlines and we also know that CBD is essentially the the other compound that can mitigate those health concerns that have been a news crisis recently and so if if saw if concentrates are made that are high potency the CBD factor could potentially be a compromise where an increase of that cap or removal of the cap would be much appreciated and then also as it relates to testing um any any real solvent list concentrate hits that 60 percent just kind of in the in the first stage be it dry sifting ice water extraction or rosin pressing and then as you take those and continue to refine them you can move into the 80 or 90 plus percent round very quickly those products are full spectrum though in the sense that you are pulling all cannabinoid and terpene content in that process and that'll certainly help in that compromise of having not just a 95 percent THC product that has no other uh roomy or like medicinal value to it as it goes into testing if I were a solvent list manufacturer and I were acquiring cannabis from a cultivator who has already tested their product for mold pathogens other contaminants if I were to show clear chain of custody from that cultivator that it is a clean product would I still be beholden to test my final product for mold pathogens contaminants or would I just merely need to show potency other cannabinoid and terpene content in my final testing there I will say that solvent based products can be safe the process of solvently extracting using solvent to extract a product is inherently dangerous the product itself is not inherently dangerous solvent list extraction in the term in terms of rosin pressing and rosin production if you press a cannabis that does have mold other contaminants will do anything in that regard that does wind up in the rosin product and that is certainly a health concern and so people that are in that manufacturing space do need to either be able to show chain of custody that their product is clean if they cannot show it then yes they would need to final test their product for mold pathogens other contaminants along with a potency and terpene profile so any other understanding or clarity that the board can get on solvent list it's a very small craft niche market everybody's really been focused on big lab chemical extraction so any any clarity that you all can start giving to solvent list operations would be very much appreciated thank you thanks Sean Jeremy Martin I can appreciate being in Vermont as a gentleman before is expressing using you know natural extraction techniques and non-sulipants and hydrocarbons but he also did say that you know and I would agree that it can be done safely however these things weren't being done safely in the past and for good reason they but now that these opportunities have arrived we're taking technology that's 50 years old that was cleaning salt out of water on submarines and and we're using distilling distillation to distill THC out of cannabis I mean there's lots of great R&D and science ahead of us I don't want to see us get bogged down and trying to limit things to this craft you know natural I mean there's a bit there's a there's there's also science out there so I can appreciate the the green flower and the love of the plant and growing outdoors and everything but there's also a plant that has real medicine and cannabinoid and terpene and additional things that we craft don't even know about yet so I just want to keep an open mind while we're discussing each of you in this here thanks Jeremy so we're in the kind of final stretch here you know if you'd like to make a comment please raise your virtual hand if you're on the phone hit star six to unmute of course we have Michael in the room with us here anytime you want to chime in please feel free so I see Don how you doing good oh great hey I just want to second what Sean said about people and having people have individual licenses that will allow them to transport themselves to work for different outfits because as an owner operator the small owner operator you don't always need a lot of help but during harvest or during planting or in different times of your operation so there should just be an easy way for people not entities not businesses but people to be able to get into this industry to be able to earn a living and help the whole industry grow up thank you for listening to me I'll talk to you guys again thank you one more one more we got a few minutes here right so this is to do with delivery and special event licenses you know what makes sense the most to me would be to tie the delivery directly to a retail and I would love to see that be kind of part of the retail license right so if you if you're a retail store you have the right to deliver I mean it also makes sense just on a database thing right like you have all your your customer information it's all tied to metrics so your inventory management and your customers again we're already going to have that in the structure so I think I think that's a really good thing to add on to a retail license and then with the special events well you know I know we've talked a lot about writing this and that right what I didn't hear about something that I experienced in California is trade shows so you know when it's when it's trade show season or whatever and all these brands are trying to sell their products to different retailers it'd be nice to be able to go to a trade show and then have those retailers actually try some of the products what I've seen work at like the the Hall of Flowers show which is a pretty popular and successful show is they tie a retail like a retail store would be tied to the event and sets up like a little pop-up dispensary then every brand can give out tickets you know for their sample product which is again perimeter inventory um and then you would go basically pay like one dollar you pay one dollar and you get your package of samples and then a lot of times it'll be like an outdoor consumption area it says no no consumption inside but just something to think about is the whole trade show aspect that we're like you know creating this marketplace and this this space is not thinking those kind of skipped over when we talked about special events and stuff so I was going to bring that up I think that's probably it thanks Evo any other uh last comments um from um from folks Sean uh yes just a piggyback off of that as special event it's kind of more flushed out how 2.3.9 might need to be revisited I mentioned it earlier just from like a general business to business locally of day in and day out people bringing samples but then yes now as it relates to trade shows specifically does 2.3.9 need to be amended at all thanks for that yeah was that Fran saying that went up also yes just one more thing anecdotally regarding events um I'm a founding member of the Vermont Association of Weather Potentials and a board member for eight years that I've been photographing weddings that's my other job in uh Vermont for almost two decades and uh I've had every wedding I've ever been to I've never seen a problem with people using cannabis yes they had to sneak off into the woods but the even the weddings that I've been with police officers there I would always ask one of the officers who didn't seem to be drinking what he would prefer to have people doing and he always preferred a room full of people smoking cannabis to a room full of people drinking out all and that's done right in front of all the children they drink out all right from the children so I think we should be open to the idea of having a small event permit um even a a contrapreneur or or an individual who could purchase uh wholesale and then go to the events and sell that retail and that would make it actually profitable for that individual so that's just a little bit of panico evidence there you go thanks Fran so oh Nick well so we're really closing in on the hour any last kind of final thoughts Nick we saw your hand go up and then go down if you'd like to make a you might give me the last comment you're hearing just gonna hear me yep just wanted to second some of the comments from the last few callers on the the the events I think that is definitely something that needs to be looked at again and speaking on on metric I haven't been able to tune into all of these things lately but I'm curious as to whether or not there's been any movement on what the seed to sale will look like and and how that will be implemented and who will be implementing that and uh one other concern that I wanted to briefly mention that I know many months ago and I heard recently a few other cultivators bring it up it has to do with the initial rollout and in other states other cultivators that I've worked with in the past when they are transitioning to track and trace they've already been cultivating so there's already our product and plants in the system and they're transitioning into a track and trace system I know here in Vermont we're going to roll out at the same time track and trace at the same time that that rec sales and it's a big concern to me and other cultivators that we're able to bring uh plants into the building to begin uh you know cultivation many many cultivators here in Vermont are already growing either under a medical license or under the home grow provisions and you know being able to bring in our our own cultivars uh during that initial initial period I really that we see an open period in track and trace where we can bring cultivars either from friends or our our home grows or our medical grows into commercial production and the last point I would make on on that is regarding the cost of that system whether or not we're going to have to pay for that uh system and also whether or not as far as testing goes well what does it look like my friends in Oregon out there the testing labs come to you they make their own selections so it's like a real clear chain of custody and I'm curious what what that will look like in Vermont whether or not we have to supply the samples whether or not they will be coming to get them and most importantly who's going to be paying for the track and trace system and what system will it be great yeah we'll have some clarity and guidance around that as well so um thank you all for for all of the comments not just today but throughout this process um this is not your last opportunity our official public comment period will remain open um through next week we have um through our website an ability to submit comments there's a public input portal um a button um and uh you know we will again anything that comes in during the next week or so we will kind of systematically go through that's not to say that if you comment after that that we can't consider it we certainly will um it's just uh the kind of administrative procedure act has a defined period here um and we have the ability to change these regulations throughout this process once they become effective we can start the process over again I know almost every other legalized state has you know multiple iterations of their roles every year they're kind of back at it fixing unintended consequences modifying things that they are reflective of of the times of the kind of new science new research um so I don't expect our rules to be permanent um but um we really appreciate everything that you've given us to work with um and um you know stay tuned for some of the answers to the questions that you presented to us stay tuned for um us kind of considering each comment individually and modifying our rules accordingly so um with that uh is there anything Kyle or Julie that you'd like to add echoing your comments and thanks to everybody that's joined us today or at any meeting over the past nine months and and given us direction feedback good or bad so thank you great well um I'll adjourn the meeting for today um just a reminder that our meeting next week will be on Tuesday Monday is a federal holiday um so our meeting will be on Tuesday at 11 and it'll be live streams or here at the cannabis board thank you all