 If that is everyone, now that I'm screen sharing, I don't have everyone's beautiful faces in front of me. So with that, I will call the meeting to order at 12.05 p.m. Eastern time. And I guess first point of business will be to approve last Thursday's meeting minutes. All subcommittee members should have gotten an email. With that, is there any, has everyone had a chance to look over that? Are there any points of discussion, corrections, or amendments that need to happen? Or how's everyone feeling about the meeting minutes from last Thursday's meeting? I think Billy's the only member of the subcommittee here. We might have to wait until next, we might have to wait until Thursday to actually motion and second. Okay, yeah, that was going to be my other question. Is how's the quorum work? I wasn't sure if you were considered a member of a subcommittee, so we'd have three out of the five. I'm not technically a subcommittee member. I'm more of a observer. And again, assisting you if there's anything I can do to help from my perspective here. Okay, well then we'll have to postpone the motion to approve Thursday's meeting minutes until the following meeting. Nellie, is that okay with the state guidelines for the five days? It's five business days, so it should be, yes. Okay, we'll do a good bye email on that. Okay, well thank you everyone for our second standard release of the meeting, for figuring out the adult use cannabis regulation recommendations for the beautiful state of Vermont. So for today's meeting, because you can all see the screen I'm sharing, and I think hopefully in person in that room you have a screen set up. We're going to be talking about kind of the environmental requirements that are in Act 164 and 62, as well as the existing regulations. So kind of taking it a next step from our last meeting. So I've gone through to kind of help guide the discussion for today, and kind of outlined, pulled out kind of the environmental perspectives for discussion points, as I've seen them with what's contained in the Act. So kind of went through and looked at like what are requirements, I guess our objectives of the subcommittee has written, and so there's definitely the groundwater quality requirements, and seeing with like a gap analysis, or if there are experts in the committee, if there are additional protections we need for groundwater resources. There's also building energy standards, in comparing to what we're seeing, and I know from a previous CCB meeting, we have gone recommendations, cannabis cultivation facilities, then energy audits, and then their frequency, and then any other energy efficiency and conservation measures that may be applicable to cannabis establishments. The other thing I wanted to kind of point, sorry about that, point out is making recommendations for the permitting licensing, for cultivators and cannabis product manufacturers, and what those conditions would be, and then also in Act 164, there was the priorities of patient licensing, so it's whether the project incorporates the principles of environmental resilience and sustainability. So I feel like that should be in the back of our mind as we move in future meetings, and start to really get into the nitty gritty of what kind of standards and regulations we want to see is that does have a beginning to come up with recommendations for how the licensing is going to take into account. What I thought was interesting within the definitions, so the three that I think are most important to sustainability, environmental issues involved in cannabis cultivation and processing and manufacturing is that enclosed locked facility means a building and a greenhouse or an outdoor fenced-in area so that pretty much everything is allowed under the law is the square footage dedicated to live plant production. It doesn't include areas of office space or storage, et cetera. So I did want to kind of discuss on the plant canopy part is since it says live plant production, that's including propagation, veg, and flowering plants. Is that how youth interpret it? I think right now that's what that broad definition means, yes. Okay, so I think that has some serious implications when you talk about small farms and has it written with a thousand square feet, which is the next point, that small cultivator, because a thousand square feet of canopy is very small if it's including all aspects of cultivation. And just realizing that if people are applying for small cultivators, I think there's going to be more of them, probably some impact on that. Very interesting, section 863, when it says regulation by local government. So, Billy, I really like your input on this. It has, I didn't write the actual, I should probably put in what the language says, but my question on that was what control over licensing and licensing cuts do municipalities have? And I was thinking of is, can cities, municipalities, towns, then are there zoning implications? Like are we going to see a clustering effect when it comes down to the local government level for issuing permits and licensing? Because I think that's going to have a lot of environmental implications. So I was wondering where we were at as all these committees are working on the role and the enforcement, I guess, in the power of local governments. Do you want me to respond now or wait until you kind of go through your deck? No, no, please now. This is not, yeah, the deck is not going to be dead by our way. Just kind of making a way. Yeah, I'm certainly no expert on kind of municipal law in Vermont. And I would encourage you to reach out to the Vermont League of Cities and Towns who are kind of a representative broadly of local government in Vermont. You know, but based on what I do know, since the Act defines cannabis cultivation as non-agricultural, I'm assuming that whatever agricultural exemptions to local zoning exist for traditional agriculture goes away. So towns may be able to zone and regulate cultivation if that's the case. If it's a commercial activity. That said, I believe, but you know, you really should talk to the experts on this. I believe that you can't kind of spot zone based on the particular activity. You have to treat like all commercial things the same. You couldn't treat the commercial cultivation of cannabis differently than a commercial activity in a zoning district. So I think if there's municipal regs related to commercial activities, those would, they may apply to cannabis cultivation. And I'm not sure that a town could create special zoning designations for cannabis cultivation outside of just a generic commercial activity. But again, I think the folks at VLCT and there's a number of kind of attorneys who work for statewide on municipal law issues would be great resources in that regard. And just kind of for a future reference, like if I get like an agenda, like a week or so ahead with some specific areas of inquiry, I can do some work in advance of these meetings to try to have better answers. But just coming in cold, there's only so much I'm going to be able to do. Yeah, no, absolutely. And that's not why I was doing this PowerPoint. Because, you know, from our last meeting on Thursday until now, it's only been one day. But now that we have until Thursday, I'm going to get some more stuff out tomorrow and try to do as far as many meetings in the future as possible. I do have a question with like your experience with the planning and in Vermont, are we expecting or are you guys expecting kind of, are there any towns or areas you think that would be against having a different cannabis cultivation or processing or retail throughout the state? Yeah, there's certainly and you know, Kyle can probably speak to this. There's a provision in the act that allows towns to kind of opt out of hosting retail outlets and some town or opt in. I forget which it is. Some towns have already taken action on that question. Others intend to. There are some sense of municipalities who are kind of supportive and not at least of having retail outlets in their communities. I don't know if there's been any debate locally around cultivation or processing. Okay. Yes. So Jacob, my understanding is towns can opt into having retail establishments but they don't have as much control from a cultivation perspective at the local level. I will also say just for the knowledge of this committee because I'm sitting in multiple committees that this local control, local fees, local ordinance model, local ordinance question has come up in compliance and enforcement and the market structure committee. And those committees are definitely looking to make sure that everybody is of the same understanding when it comes to local control. I agree with Billy's overview from a retail commercial perspective for the most part on local control. You know, I think they're going to be resigned to having those traditional local responsibilities when it comes to advertising and so on and so forth. But as Billy said, they can't pay too much attention specifically to this industry if they aren't doing the same thing to other ones. The cultivation side of it and how Act 164 talks about local enforcement of cultivation is something the board is still working through with our general counsel to make sure we understand exactly what that means. Okay. Yeah. I just wanted to bring that up as we're going through this. I'm wondering if we have to be clustering in the intensity of the environmental impacts. If, you know, we're going to see, you know, we will see them in more major cities for endocrine cultivation, but if there's that layer we need to add to it when looking at setting potential energy efficiency levels or, you know, looking at power consumption, things like that. There's a couple towns, I think, in the Northeast Kingdom, which is more of the rural part of Vermont, for your knowledge that have decided that they don't want retail establishments in their town. I wouldn't, if we're looking at a macro of Vermont, I wouldn't say that they're towns that are going to severely impact our market analysis or anything like that. We do have a survey out to all municipalities in the state of Vermont that are asking their intentions about putting this on a ballot and kind of seeing who is prioritizing this over the next six months to a year. Yeah. So moving on, there's a section on prohibited products. Yes, on this section is so, cannabis flower, producer's cell, cannabis flower that's greater than 30% THC. And my, what came out of thinking about this in an environmental perspective is, one, what are people going to do with it and the enforcement sector, what happens when you cultivate cannabis and growing it and all of a sudden it tests above 30%. I'm guessing it can't necessarily be sold for retail, but is that going to be allowed to be processed into manufactured products, edibles, concentrates? Or does that need to be destroyed? In which case I think there is a waste management issue there and making sure that this organic material can be, you know, that it's not, it's being diverted from landfill. So that's kind of what came up for that point. And then we can talk about all three and then have the conversation. I guess the other one is the solid concentrates no greater than 60% THC. And so I was wondering, this doesn't necessarily have to do with environmental sustainability, but out of just more like public health things, what are the dilution protocols and how is that going to work? If, you know, you make a run of distillate and it's 70%, you're going to have to dilute it with something, just something to, I guess, maybe think about in other committees. And then with the cannabis oils have to be sold prepackaged for use with batteries is if everything, you cancel like syringes or bulk oil, you're going to have a lot of prepackaged vape cartridges. And that is also another waste management concern. So potentially we should be discussing kind of recyclability of that, or potentially requiring kind of a take-back scan of the industry. So I want to kind of see what your guys' thoughts are on those two points as we kind of, you know, we'll have a whole meeting kind of on waste management, but within the rules, I think those are two kind of concerns with the laws written right now that are going to, I think, create more waste. I would definitely support the idea of having like a dedicated beauty on waste management where I can have kind of experts within our waste management division kind of speak in a higher level sophistication to these questions. You know, I did talk with them a little bit and understand that it's likely that some of the state's existing compost facilities can provide like a proof of destruction or I forget the exact term, but something to certify that a product has been decommissioned and is no longer available for retail use. There's a number of different companies that have export requirements around in-country use of the materials that they produce and need to demonstrate that they've been destroyed if they remain in America and our compost facilities can achieve that. So I think that can provide at least proof of appropriate disposition. I think the main question with the compost facilities is whether they have adequate security to meet the requirements of the act. Again, talking specifically with the waste management folks in our environmental conservation department, I think can inform both that question and questions around waste associated with the materials, packaging materials. Yeah, I think when we have the waste management discussion, we definitely are going to need to invite leaders in the environmental conservation people but also the waste management because my understanding from other states that I imagine Vermont's going to be the same is everything needs to be disposed of in-state. It's going to have issues you're trying to cross state lines to use another state's landfill or something like that. So we need to know what capacity is and also I think what, especially from a recycling plastics perspective, what is actually going to be able to be recycled and captured with the technology and systems that have been placed. Yeah, so we could get representatives from the waste industry to kind of talk to those things in addition to our state regulator folks. So then, as far as like the rulemaking cannabis establishment section, so there's the tiered system based on plain cannabis so we'll have to think about that. I think we're pretty good with the pesticide use aspect of it with it being at least as rigid as the VAFMs as like control regulations. And so that's, there is some a deep to that. We do need to create standards for indoor cultivation and then as far as kind of manufacturing laboratories. Not so much for the, well, it kind of goes into the last slide with the products not containing more than 50 milligrams of THC. I think it's just kind of doubling the amount of vape cartridges or concentrates we're going to see in the market. So just another reason to really look at the waste management aspects. But then also, yeah, thinking about with the laboratories, there's the procedures for destruction of all cannabis samples. And so I think that's another waste management item to see how that can be destroyed or if it's organic material, how we can put in regulations or recommendations for trying to divert any organic materials from the waste stream. And then moving out, so there are six licenses written into this law to think about that a cultivator, wholesaler, product manufacturer, retailer, lab testing, integrated license. Kyle, I did have a question for you I thought would be good to discuss is with an integrated license, I saw that they can't have more than one license in each category. There was nothing explicitly written or that I saw talking about locations. So are they allowed to do multiple activities and have multiple licenses under one facility? It's a good question. And I'll get back to you with a more firm answer. But my understanding is, you know, I know that there's some facilities that would be eligible for an integrated license that kind of are have, I've been in at least one facility that looks like it has everything, all the license types working under one location. So I would imagine that we would allow for a combined location of these different license types. But I haven't been to other integrated license potential, you know, operations to kind of see firsthand how separate or combined things are. And I quite honestly haven't thought about that distinction all too much. So we'll get back to you. Gotcha. Yeah. Just working on creating a using the BS market predictions to try to figure out, yeah, how many facilities, how many sites we're going to be seeing. So like what those impacts would be. And so if they're, you know, I can then see, well, it wouldn't matter if they're how many integrated licenses would be for the model, if each one has to be separate, you know, but if they're combined, you do get some, I think, economies of scale savings on environmental impacts. So then going to the cultivator license. I did have a question or we have a discussion. We want to create recommendations for this, but in the in the act, it says each cultivator shall create packaging for its cannabis as it's moving along, I guess the process. And so my question was, what is non retail packaging going to look like? And should we be creating recommendations for that? So if the cultivator needs to create packaging that has all the list of requirements on there. So everything dealing with track and trace, you know, created data, et cetera. When it goes to a wholesaler or a product manufacturer or an integrated licensee dispensary, et cetera. Do we want to create recommendations for the packaging to kind of promote a reusability of packaging or limit kind of the waste stream, the waste generation from that kind of system? Jake, it might be helpful to know how other jurisdictions that you have experience with approach that non retail packaging and keeping, you know, the supply chain intact all the way to the retail establishment. Yeah. I would say that it kind of runs the gamut. In my experience, there's some or there's no regulations at all. I don't think there's too much stipulation on it. There's a lot of just the regulations on creating it's like the manifest as you will. That includes all the state required things in the act. I think there's definitely opportunity to at least in the licensing application aspect of prioritizing licensees who want to do a standardized kind of unit. I mean, a lot of things are in these like black bands with yellow tops. A lot of things are distributed throughout the supply chain with that and are reused, you know, and washable, cleanable, food safe, et cetera. And so I think there's opportunities there to award cultivators, manufacturers, processors who want to take that initiative and kind of create those systems. I think the only thing that would prevent that is if there are going to be regulations on the locking of this material during transport or any kind of those kind of safety concerns. So I think that's just something to keep in mind. I think in the, if there's a transportation or processing manufacturing committee when they look at those rules for that. Yeah. We have a compliance enforcement committee and it might be helpful to get a quick order from you, Jacob, on that and its impact for that committee if we're going to zero in on how what additional requirements might be, you know, there for moving this throughout the supply chain. Yeah. You definitely pull from what's going on in the food agricultural supply chain industry for sure. And then the other thing I saw that Act 62 included was that the dispensary canal also is permitted to cultivate and manufacture cannabis for the purpose of transferring and selling to an integrated licensee. So just keeping that in mind when we're talking when we create these recommendations and creating these environmental requirements for the cultivator that those are also going to have to be included on some level of the dispensary license. If they're going to have the opportunity to also cultivate or manufacture. Yeah. So I had some questions and wanted to have a discussion. I know this is probably more Stephanie's area of expertise and so I will be talking with her after this meeting so we can get her input at the next one but that cannabis is not going to be regulated as farming under the required agricultural practices but is going to have to comply with the required agricultural practices. And so what I really liked about how the role was written I haven't had too much time to go through it but that it doesn't disqualify I guess already agricultural businesses their land or buildings if they're going to the cannabis industry from their use value critical program which I think is a really good environmental program you guys have in Vermont. So I think that's a big win for environmental and sustainability efforts. There was this B on this where it was saying that the processing, cultivation, processing, manufacturing of cannabis has to comply with all of these regulations and I was wondering in Vermont are additional areas, cities, counties, kingdoms that have local environmental and energy regulations that we should be aware about as a committee. So just broadly speaking most Vermont has state laws and then municipal laws we don't have much of a county government or other sort of structure in that regard so there are municipalities that do adopt local bylaws related to environmental issues so it's a really kind of town by town analysis to see if they have adopted rules that kind of exceed the minimum set by the state so I don't know that that would be the my sense is that this board should be focusing on kind of compliance with state law and then letting the individual operators with requirements that they also comply with municipal law and letting the individual operators navigate the municipal system because we have 251 municipalities or kind of units in the state and their approach to these issues can change broadly. Yeah I was going to do my follow-up question was like should this even be a concern of ours I do even though we're on a very strict pretty deadline would it be helpful your experience if we had created recommendations or guidelines or some kind of guidance for the municipality level as they're looking to you know looking at the permitting side of things to have some kind of resource. I think so and again that organization I mentioned earlier the Vermont League of Seas and Towns they put on kind of annual trainings for municipal administrators both kind of paid folks and the volunteers who run a lot of the towns and Vermont's boards and commissions they do a lot of outreach provide technical assistance so I think some outreach to them to see what their members would find valuable in this space would probably be a good step. Perfect yeah I think we'll probably bring them in towards the end once we have the state recommendations and everything starting to be fleshed out yeah so the last thing on this was with their complied with the required agricultural practices which I'll go into in the next few slides so the thing that pointed out to me is like in the way the Act is written it is saying that Canada's cultivation needs to comply with the RAP but when looking into the RFP I did see that you know cannabis farms they don't fit into any of the categories there there's the smallest category which is certified small farms which I believe is going to be over 50 acres I just don't see many cannabis cultivators being on any kind of scale so I do think that there is going to be some language I'll have to create it makes sense for licensees to adopt these things so right into the law there's section 6-8-12 so I'll go through those real quick I don't know are you familiar with the required agricultural practices I am but not in a very in-depth way Stephanie's agency is the one that administers those yeah so was that you Kyle? I was just saying correct if we need to get folks from Ag here to go over these more specifically you know that's something that we can do yeah yeah so I can go through this pretty quickly it's really coming down to just kind of pulled out a bunch of things to have a discussion on this but we can wait until Stephanie is at the next meeting but essentially I think it's really good that this from an environmental sustainability point of view is required because it does cover I mean the main point of the required agricultural practices it does seem is for water quality and water discharges and protection of the environment in surface areas surface water areas so it doesn't allow for discharges the surface water mainly through directly pipes or culverts etc it does have regulations on appropriate storage the nutrient management planning and so it did pull out some things that stood out to me on and we need to figure out how that's going to get like make sense because a lot of it is made for regular traditional agriculture so it refers to UVM recommendations for a lot and I don't think those exist or are created for cannabis so it's definitely Stephanie's question with her expertise in the hemp and medical industry this for me raises kind of a larger and I think more significant question about like how are we actually regulating these impacts because the RIPs are largely a proxy for other state environmental laws that don't apply to agriculture because agriculture is exempt from those laws in one way or the other you know it's not 100% but basically if this is a commercial activity there's probably state laws and regulatory programs that address all these issues that may be the same or approach or may be different than the RIP so I think we probably want to go kind of resource impact by resource impact and just kind of clarify which you know which rubric is going to be applicable and then we can figure out if there's gaps in either of them that need to be filled was that that makes sense I was under the impression with the way Act 164 was written how it has the language of Canada or adult use, cannabis cultivators must comply or will comply, can't be the exact language to the required agriculture practices so what's stated in that so I was thinking that this was the minimum and then expand upon with the other state agencies that's helpful, yeah I guess I think if they're complying with the RAPs if they're applying with other kind of applicable state law they're going to be complying with the RAPs as well would be my sense because I started to look at the different state like the Vermont Statues like Title X and Title VI and then once I was going back they were reading the Act explicitly states the required agricultural practices so Kyle looked to get the board's opinion on that I'm taking note I want to say also and I don't have the statute in front of me I'm trying to pull it out so I can make sure that I have the words right in my head but because the small craft cultivators within that thousand square foot are considered commercial the RAP language also almost kind of like a backstop to make sure that those small cultivators were also their practices were reflected through those those specific sections of the required act practices did that make sense? yeah so that language is in the statute I guess in section 9 and 12 it goes through groundwater quality and subsurface tile drainage so the things that I noticed for the gaps from 164 into other sustainability things is with the RAP the sustainability state in the Act 164 about sections 5 or 9 which I think might be important to make recommendations on so once the water quality training to make sure that they're knowledgeable and have a base knowledge expertise on the water quality issues in agriculture in Vermont and then section 9 which is the construction of farm structures I think with cannabis I do believe that a lot of licensees will be building power facilities or expanding existing farm structures so that might be something to look at as well but I also think that that might be covered in Act 250 which I'm hoping to get your opinion on Billy and a little bit more education on that and then other things that we might need to be looking at is there's no air quality pollution or odor control regulations we think about there is odor control as it pertains to applying manure but mainly with the cannabis industry we're seeing as odor issues odor nuisance amongst like neighbors in different areas that cultivators are beginning so it's definitely something that we need to come up with recommendations for and there's no energy regulations and there's no like land management biodiversity regulations it's really very water centric there's air quality regs at the state level that exist that have already been I think exercised in the context of the hemp market so I know that air quality and climate division has been involved in kind of oversight in investigation of neighbor nuisance complaints of hemp processing and cultivation so those regulations do exist outside the areas I really wish that she runs the hemp program so if you need help connecting with her Jacob to get a better understanding of certain things before our next meeting I can certainly help facilitate that I am curious on how her program has worked through the air quality pollution and odor control regs especially on odor control because we have right to farm laws in Vermont which help alleviate some of those nuisance claims that neighbors might have but because this is not considered an agricultural product what does that right to farm actually look like here and how do odor control regulations maybe apply differently from a nuisance perspective and even when they do apply I can say that these are some of the hardest considerations to enforce because there is so much subjectivity to what is perceived as a nuisance odor and so we struggle outside the act sector in enforcing odor regulations in the state just because there is so much variability in subjectivity to them so I think we can share that information both the kind of statutory and regulatory information as well as the direct experience of our regulators in trying to investigate and enforce these concerns and this may be a place where the board chooses to just come up with their own standard if they so choose to to help mitigate odors so we don't have to rely on a regulatory framework that is hard to enforce sometimes what we're seeing in a lot of places with the mitigating of odors because it is so subjective and very localized is having safeguards in place if a cultivator is making their best effort by using industry by using your best practices with mitigation equipment that they can't necessarily be penalized because of that and the whole kind of good neighbor thing but if that also is very much on a municipal level as well and so definitely something to when I reviewed the standards I did not see too much about odor issues so I'll definitely reach out to Stephanie when we start discussing that and then yeah so Billy I was hoping you could shed some light on because I know we had mentioned it in the last meeting started to dig through it from my understanding for Act 250 that the areas that this would trigger requiring Act 250 permit for cannabis cultivation or processing would be with the improvement to commercial industrial use above 200-500 feet improvements on more than 10 acres within a town without permanent zoning subdivision regulations if I was reading that right any kind of change to a grandfather building so something that's pre-1970s and then if they were drawing 340,000 gallons of water is that correct that Act 250 will get triggered if any of these happen? Generally yes and then there's probably more right so the subdivision one is probably less applicable that's going to look at just the subdivision of land for whatever purpose so yes if land is being subdivided and a resulting parcel is going to be used for a cannabis related industry that subdivision is going to trigger Act 250 review but that applies broadly and I would imagine these folks are going to focus on lots that exist and not be subdividing land to create their enterprise but that seems less applicable the construction of improvements is probably the biggest one and it's actually on more than 10 acres of land only in towns that have permanent bylaws and subdivision regulations in towns that lack zoning and subdivision regulations it's a one acre parcel trigger so in towns that don't have good or robust municipal bylaws any acre any parcel an acre or larger that is supporting those improvements which trigger jurisdiction and it's not just like it's not the area of disturbance it's the actual size of the parcel so that's why the whole agriculture like the farm question raises some questions for me so like most farms are bigger than 10 acres and they don't have a component of their agricultural operation the cannabis cultivation and that's commercial is that going to trigger Act 250 jurisdiction at that site and then are they going to need to obtain Act 250 permit for some portion of their enterprise Billy that's my biggest question in my understanding of 250 and how this works that's certainly my biggest question and my biggest concern as well and I've talked to Greg Boble as the general council the natural resources board that administers Act 250 and you know discuss this question with him a little bit and I'm not entirely clear where they stand on it he indicated that there's ways to likely kind of reduce a limit jurisdiction to just the area being cultivated for cannabis and not pull the rest of the farm into Act 250 but given what Stephanie said last week about the tendency for crops to be rotated and that cannabis you know plot to maybe move around on the farm there may be some challenges there there's also other activities that require Act 250 permits where the permit goes away after the activity has concluded those are primarily gravel and sand extraction operations in all other cases Act 250 leans basically are perpetual encumbrance on a parcel but for gravel and sand pit after you've kind of closed out your extraction and met all your decommissioning requirements Act 250 jurisdiction does go away so there may be an opportunity to kind of apply that model here if Act 250 is in fact an exert jurisdiction over these operations that's great to know Billy and you probably don't know the answer to this from a timeline perspective procedural perspective I'm sure that there's not a whole lot of examples of well maybe there's a lot of examples of that process playing out how long does that typically take to work back out of Act 250 it can go pretty quickly usually those sorts of businesses are operating for many years it might be like a gravel pit that's going to operate for 10-20 years and then they decommission and jurisdiction is released I think the kind of close-out process can be fairly quick it's basically like going through another Act 250 amendment process just showing that you've met the conditions of your decommissioning plan and the permit so I don't think it has to be overly burdensome but there is some process associated with it I think it would be much simpler here you just have to show that you're no longer being cannabis with those projects there's engineering and other things that need to be brought to the table with this I think you would just have to put in an affidavit or something that says you're no longer doing the activity and on that point I did pull from the Vermont Agricultural and Food Systems Plan for 2020 and so in the hem section which I believe Stephanie had a role in it was saying that 60% of growers were less than 5 acres of the cultivated acreage by 8 growers and they were averaging between 50 and 100 acres so I give you some kind of understanding the size of growers at least in the hem world what we might be seeing as far as applications and licensing Jacob I actually helped put that whole plan together so any other questions you have on it I wrote the Ag policy brief oh nice no I mean I was just looking at it because I was just digesting everything about the Vermont agricultural kind of what's there I did like the way looking at climate change and looking at what Vermont is concerned about with the farmers right now as far as issues that they're facing and will be facing more of what's the things definitely to be of concern I want to kind of relate this to what we see in the the rap and then the other many other potential regulations in comparing to kind of best practices of recommendation so these are definitely things we'll be focusing on it does seem as though with the water quality phosphorus runoff is a huge concern especially with your lakes and streams and then one thing that came I wasn't quite sure what section it was but kind of I thought was a good opportunity was for the young farmers and looking at the social equity components and seeing how we can encourage that from an environmental sustainability you know cultivation to align with you know what the goals are of the state does seem like succession is a huge issue the amount of retired farmers predicted in the next five years or I guess three years by now and so I think it's a big opportunity when we start to talk about social equity and then just going back to previous slide it does seem as yeah if Act 250 is going to be in vote yeah it covers pretty much all environmental impacts that we would have to to look at so I guess Billy since you have the most familiarity with Act 250 is it worth us going through and pulling out language that might be useful when it comes to you know water conservation wetlands soil erosion and drainage as we're looking at the recommendations if not all of the farms are going to need to essentially require an Act 250 permit what I would recommend you do is work with the Act 250 Natural Resources Board and task them with developing guidance for how and if Act 250 applies to this sector it's a highly complex and specialized body of regulation and there's a significant amount of guidance documents that have already been developed for each of the criteria through my agency through the NRB so I think that charging them to come up with that is your best bet I think what's really needed from the Canada Board is a clear articulation of how and if Act 250 will apply to this work I think once those questions that like if and how are answered then there's capacity within Act 250 in my agency to kind of come up with guidance for how folks navigate the process but that threshold question needs to be answered first if any of these criteria can be satisfied by other state permits for instance to satisfy the wetlands criteria generally you just have to get a wetlands permit or show you don't need one so it isn't as complex as this officially reads but it still is a lot my understanding is like reading through it is that like Act 250 though is kind of the most stringent environmental regulations that Vermont has yes it definitely has considerations that are unique to Act 250 jurisdictional projects that don't apply to other forms of development but it only applies to I think less than 10% of all development in the state so it's not broadly applied but when it is applied it is more stringent than the baseline and Billy just Jacob if we could just stop for public comments for a moment sorry we just wanted to thank you one final 15 seconds just for information for the committee we the board has you know contacted some community planners at ACCD and made contact with the NRB to start understanding the impacts or intended or unintended and expected impacts that this emerging market will have on Act 250 we have not gone as far as asking for any formal guidance from the NRB or through the attorney general's office or anything like that but you know something that we'll consider yes and I'll open it up to public comments dude no I know that's a process I'm sure we'll talk to you actually do you have any public comments no we're good on this end okay yeah and so like with that Billy who is a good person for me to reach out to that's overseeing Act 250 I would I would contact their chair which is the person who's in charge of it it's an interim chair Don Rendell the other two staff people who will be most helpful is their general counsel Greg Goldberg and the state coordinator Aaron Brondike that's kind of I think their executive leadership at this point and you know this is a pretty you know high levels question for them to dig into so I would start right at the top I'm happy to do those contacts but they have a website a natural resources board Act 250 either though she gets you there and all their contacts are on that website and Jacob we didn't work on our end of Connecticut you know we know the former chair fairly well too to the extent that might be helpful for just a download yeah I think getting a download and also since this looks like it's going to be depending on where we're doing if in the lens or if and how this does I'm going to play as much as possible Greg is going to be the most he's probably the person who's in the best position to kind of explain how Act 250 may apply what the implications that are and kind of get into that level of detail so I think Greg Boble the general counsel is very knowledgeable and I think I've prepped him for the conversation so you're just looking for like an initial kind of point of contact to frame the question I think he would be a good one okay perfect Jacob if we need to work through our general counsel to talk to their general counsel to get that more less informational topical understanding and start digging into what may apply what may not apply we can certainly do that as well okay that's good to know and then I think as I show for our next meeting where we have a few minutes we're definitely going to talk about how things the next month will go for Mondays and Thursdays and kind of get ahead of this as well as the cannabis process presentation I guess I'm creating I don't think we need to talk too much about the what government agencies are going to be overseeing one and their capacity and all of that we could look at that I think towards the end once things are written and then looking at the way things are written right now for cultivation and with the the RAP requirements potentially these Act 250 want to talk to Stephanie and see what else would be there I think that covers a lot of the environmental impact sustainability for outdoor cultivation and then really we need to focus on indoor cultivation so I wanted to talk to you Billy about what resources should we be looking into so that we're not reinventing the wheel that would be most applicable for indoor cultivation and manufacturing in the context of permitting or what exactly do you mean by resources so in the context of environmental sustainability so I know that there has been submissions of for building infrastructure efficiency for lighting between what else is out there as far as the environmental impact mitigations for indoor cultivation that are already on the books or other agencies are overseeing that I know there might be lead standards already existing in Vermont but it is more occupational focused we can look at to see what's there for recommendations or requirements for indoor cultivation aspects of things um yeah so I think from like on the energy side I think the efficiency utilities that I mentioned at our last meeting like efficiency Vermont and some of the distribution utilities are going to be in the best position to provide guidance there the Vermont public service department potentially as well I'm kind of more broad environmental considerations like air quality water quality waste management you know I think our agency has expertise there and you know can provide guidance you know I would approach it more from like topic specific you know like let's talk this week about kind of water quality challenges opportunities let's talk this week about kind of waste management you know opportunities and challenges um because I think that just may be an easier way to manage the conversation than trying to have like a broad sustainability dialogue because there's just so many I don't know all the implications of indoor cultivation so I can't tell you what the best kind of resource is because I just don't know enough about it yeah yeah no no this makes sense and we're not yeah we're all going to have those that's how it's gonna like for energy indoor outdoor waste indoor outdoor I just wanted to pick your brain to see if there's anything we probably have like DMPs for like basic manufacturing and other sorts of commercial enterprises that I can try to dig up but I just don't know if there's anything specific to this particular activity gotcha yeah so I've been going to be sending everyone a bunch I've got five or six best management practices, guides for sustainability and indoor and outdoor cannabis cultivation just kind of try to weed them out so I'm not sending everyone 140 pages of documents rather like the 15 most important pages kind of thing but yeah I was just seeing if there's already things that Vermont has in place that we could build off of but we can come discuss that as those meetings start to go down so I'm going to try to get the schedule out to everyone tomorrow or early Wednesday for our Thursday meeting I think it's just going to be back to back plan out those future meetings so we can bring in the experts we need to discuss the different specifics so I think with that we can adjourn this meeting okay great yeah I think just scheduling like a loose agenda for every meeting we have between now and we have to end would be really helpful for me to make sure I can line up the right people for the conversation absolutely you don't want to hear any speculating for the next month yeah no worries we'll really appreciate your time your insight and thank you as well Kyle and Nellie and Gina and the two public community members who came and sat in and we'll be talking on Thursday thanks Jacob that's a new adjourn but I don't think there's anybody to second you yeah thanks bye guys