 Good morning. Thank you for your patience, folks. You are with the Vermont House Government Operations Committee. We had a little trouble getting our feed to connect to YouTube so that we could start committee, but it looks like we are doing well now. So we are resuming our work this morning on S 25. And so we have a series of folks who would like to share their thoughts on the bill with us and the first perspective that we're going to hear from. This morning is Gwyn Zach from the League of Cities and Towns. So welcome Gwyn and would love to hear your thoughts and reactions to S 25. Thank you committee Gwyn Zach of Vermont League of Cities and Towns. I'm here to comment on behalf of the league in terms of what the first provision of the bill contemplates in section one, the mandatory March 8 by by March By 2023 having all municipalities having a vote, whether to permit to retail sales within their communities. We testified in the Senate, an objection to provision that this which would had to put it a year earlier, but the Senate was thoughtful enough to push it back an additional year to give towns and cities the time to contemplate the rules and regulations that are still pending to actually be out until, you know, fully out until next year and even give them a little time to look at other communities that have opted in and perhaps are already starting retail establishments. And so we have no objection to this provision of the bill and support it. Questions for from committee members representative Leclerc. Thank you madam chair. Good morning, Gwen. So, I'm clear here so you support that provision that's requires the communities to take a vote prior to a certain date. And so the, the, we don't object to it I would I wouldn't say we fully support it but we're not going to put any objections towards it I think the contemplating the fact that towns will at that time have had an opportunity to look and see what the rules and regulations are going to be will be able to make a more informed decision. If towns feel strongly one way or the other they can make that voice heard. It also still leaves the room for communities. Unless there's something great unless there's a establishment grandfathered within their community they still have the ability to opt out again. So it's not like all and they're losing all saying in the matter. I think looking at how towns are not able to vote whether or not to allow growers or other establishments in the community played strongly into our decision to start step back and say well you know at least if they make an informed decision and they can at least have their voice be heard later on. And, but we just wanted it to be informed and then and when you look at how towns and cities went about doing votes for liquor establishments and how for years they had, believe it was up until maybe the early 1960s they had a vote every year, whether or not whether they were going to allow the sale of spirits in their communities. And it just sort of made sense. So I think it's a it's a middle ground that we kind of fell on to with sort of being okay with this provision. Okay. All right, thank you plus for the record here I get you to testify for a minute and 36 seconds here. The YouTube delay got her offer game representative Higley. Thank you madam chair thank you Gwen. So, this is a departure from what was originally passed, as far as you know you have to opt in. And I remember years ago, having testimony from Washington State, saying that that was, that was a big mistake I can't remember if they did it and they had a real issue with the expense that it costs towns to go through that process. So, I'm concerned that, you know it is a departure from what was originally passed, and I guess, maybe a question I've got is, um, so after this date, when towns that don't approve or disapprove, I guess it would be just approved. So, when they are opened up, how, how is that going to work for a, a business that wants to are they, is there going to be an opportunity for the towns to have a dialogue with whatever business it is that's that's going to come into their town even though they haven't voted. I'm saying after March 2023, they get an application for a establishment. After that date, how like what, what then goes into play. Because, because again, I mean, I could see possibly, you know, some businesses picking a particular town, maybe a town that doesn't even have zoning to, you know, start their endeavor, because of this new provision. What, what, what is the, what is the process for that after that 2023 date. I don't have an answer, but I don't unfortunately, unlike the liquor licenses where the town can get their input put in ahead of time, the way this is contemplated for cannabis we as municipalities won't be able to have our say until after the state makes their decisions and are issued their licenses at the state level. So on the way the rules have been or sorry, the way the statute has been written under last year's belt got two years ago, whatever it was. Time doesn't mean anything to me right now on the rules and regulations have to be promulgated by, you know, the liquor control board and you folks I'm sure are going to be weighing in to a large degree so we won't even know what those rules and what to say to answer your question because other than zoning and even then I'm assuming when you talk about, you know, signage and advertising and, and perhaps they're going to put limitations on, you know, distances to schools or you know who knows what. We don't know those rules yet so I challenge even now who have opted in have had questions, and we don't have answers just because nobody has answers so I don't I can't answer your question because I don't know what the rules are going to say I'm assuming there's going sort of a list of criteria that select boards or it doesn't have to necessarily be select boards because the cannabis local cannabis control board can be other folks that the select board puts together. And we'll have to look at the rules that are promulgated or that are put forth by the state so it's we don't I don't know how that will work or play out. Well, you know, understanding your your answer is even more reason for me not not to support this section. Thank you. Representative look there. Thank you madam chair. Well, based on this extensive testimony that you're giving us. Based on the fact that I'm hearing that the timelines and the fact that their rules haven't even promulgated yet. Is there a feeling that you wouldn't have an objection to us removing that date potentially. Our position has always been that we wanted towns to be able to make informed decisions. And so, I think the, and again, having things moving a little bit slower than contemplated in the S54 bill from last year. It's kind of a struggle on and it's for towns to actually understand what they're getting into necessarily on. So I think if the timeline sticks with the way the timeline sticks where we're actually towns by the town meeting on March 8. Two years from now, but quite a distance away. That will be enough time for towns to at least make a semi informed decision. So I think at the timeline sticks, I think we're okay with this provision. You know, we wouldn't object to being pulled out. I think that I think our biggest objection to this entire proposal of forcing towns to have votes is that it's definitely putting a priority on businesses and establishments, having some level of certainty whereas municipalities are not given any. We're definitely being de prioritized. We haven't been given given any revenue sharing we haven't been getting any local taxation authority on the committee is very familiar that we have objected to that since day one. But we have lost that battle in this committee and in the ways it means committee even though we've had strong support from the Senate so I think at a certain level we've kind of risen our white flag and said, you know, like we surrender, you know, we just be be thoughtful of our have towns be making semi informed decisions with at least some semblance of understanding what the rules are. Okay. Well, thank you Gwen and my preference would be they make a fully informed decision, given the opportunity. Thanks. Thank you for being with us this morning when do stay in touch. And if you feel that you need to come back and and testify again or clarify anything don't hesitate to reach out to our committee assistant and we'll get you in. I apologize for running over by 30 seconds. Thanks very much committee appreciate it. Thank you. So, welcome. I believe that we have mark use with us. The racial justice alliance badge on on the, the snooze screen so welcome mark we are taking testimony now on s 25. Thank you for being with us. Morning. Mark Hughes, executive director of racial justice alliance. Good morning to the committee. Today, you're going to hear from a number of members of Vermont cannabis equity coalition, Vermont racial justice alliance is just one of them. You're also going to hear from some folks over at NOFA, they're going to tell you some good stuff and they're also going to kind of back up some of the things that I'm saying and, and you're going to hear from some folks over at NOFA, Vermont. They have similar stories that all of these stories are the same all of the demands are the same. You're going to hear from folks at the Vermont growers association. Again, reinforcing this common theme that we're coming to the committee with and then finally, and hopefully, we've gotten trace on the agenda. And these are the organizations that share the, the same values and have the same vision on equity in the cannabis industry in Vermont. I think that as we have this conversation today, there was a couple of things that I'd actually be mindful of. And one is that we are deeply cognizant of the effort that has gone into the work and the path that has led us to taxation and regulation of cannabis in the state of Vermont. And some of us in fact have deep historical experiences along this path, just from another perspective. So I don't want the committee to assume that our coalition is unfamiliar with the work, the hard work that has gone into bringing us as a state to where we are with Act 164. In this testimony, I'd ask that you also consider the fact that the equity piece of this policy that we bring to your attention is not a new conversation. I think that that's important to us that you would please take into consideration that we've been moving. As you know, we have been pushing from this position. We, we've been doing so throughout the entire previous biennium, and we've been unsuccessful and there has been some level of frustration within the group and within our represented communities. But definitely not a new conversation, definitely not a new conversation. So we bring into this discussion all of the testimony, all of the support in all of the background that went into our work around S54. We bring into the conversation. I just just came across my screen something from the racial equity executive director that we're that I've yet to be able to really get into a previous communication just over the last week or so from Jason Gibbs on their continued support of the work that we're doing. And the expectations of the administration, as well as the non-signing statement of the governor in his support for the work that we're doing. So we appreciate, we really do appreciate an opportunity to come before the committee today and also want to acknowledge the chairs and the vice chairs effort that have gone into this behind the scenes. I believe some of you on the committee do not know what they actually sat down with this entire coalition just over the last few days to begin to have these conversations. So that is appreciated and I think that should be flagged as as effort and commitment. So thank you, the two of you very much, Madam chair. I will primarily be talking in briefly, as you might see on the, just some of the challenges that we continue to have with with the equity component of it as it pertains in this particular case to the obstacles for and barriers for market industry for data presented by racial disparities. And so there's, there's a policy that you all are aware of. Well, that most of you are probably aware of that is on the wall. The virtual wall called H414 and it is was introduced this session. This is a cannabis social equity programs. Its purpose was to require reduced cannabis establishment license fees for social equity applicants. It was also to establish a cannabis business development fund to provide low interest rate loans and grants to social equity applicants to pay for ordinary and necessary expenses to start and operate license cannabis establishments and to establish a community social equity program and permit and permit existing licensed cannabis dispensaries to begin selling cannabis and cannabis products in the fall of, I think that might be a misprint in the date there upon payment of substantial fees and support to support social equity programs. This policy is, is really a return of request that we brought before you last year that was, it was not in the form of a policy and may look familiar to some of you, because it was suggested as some of the language that we would incorporate in Act 164 to make clear barriers to market entry for certain demographics of folks. I want to go now to the policy that I came to testify on is 25 and I just want to go immediately because my colleagues will be testifying to the various other various aspects of this policy but I wanted to talk a little bit about section 11. And in general, I also want to talk about just broadly about our approach to addressing equity in this particular policy and, and what hopefully would be the, the legislature's attitude towards the priority that should be placed in this particular type of work. And one of the words that comes to me is, is, is definitely urgency. I think that when we talk about a emerging market. We know, and you'll hear more testimony on this one equity. What we know is is that market entry in those barriers to market entry, they basically define the market and they also establish the precedent upon which folks who are participating in the market have the ability to do so and what we know generally speaking. And this is based upon our history as a nation is is that when we look at folks who are economically disadvantaged that proportionately that black and brown folks and we won't talk about other harm that has has emerged that has come from this this weed in these communities but just proportionately what we know is is that, you know, and this is just establishing a baseline that the that black folks. When you start looking at our population, you're going to find, you're going to find less economic opportunity. In other words, we start looking at poverty and this whole testimony all five of us is about the intersection between race and class. And this is where this is where we convert this is where we agree this is where we understand one another. So this is a very important point here because everything that you'll hear it premises. In the fact that there are certain folks that just are not going to have as much opportunity to move forward in this market is others when it at its onset so what that means is and this is the. This is the foundation of what I'm getting ready to go into in chapter in section 11, and that is simply that. That means that the this in your committee and in the legislature, increasingly, this is where we're going to, we're asking you to lead, we're asking you to own as much of this as you possibly can because otherwise it's relegated to an appointed entity. It's relegated to other folks to decide and that right there in and of itself is problematic because you have the authority and the power to do so and you also have the language before you to make those determinations and it would have an immediate impact. The other part of it being problematic is is when you have another entity that takes responsibility for not only does that telegraph that it's less of a priority for you but it also relegates that responsibility to someone who may or may not get it done in a way in which it needs to be done. All the time while we have the language right here in front of us that could quite possibly be at least part of the solution. In the, in chapter of so that that's the first thing is is make it a please make it a priority make it your priority because it's that important equity in this particular bill. Right now, it's in your hands, you have the ability to affect change now and we hope that you signify that with, you know, establishing this as a priority. The other thing here is is the message that we send to our surrounding states and partners and so forth surrounding the work of equity in and especially with the emerging market in New York. Just briefly go through the social equity program here and it starts with fees and section 11. If you get down into the business development fund in in 986 for those who have the policy 986 it talks about the fund itself and it does speak to the 3% growth sales made an integrated licenses prior to October 15 but it limits the integrated folks only $50,000 each. We feel that that is a limitation that's unnecessary. We think that that cap should be higher. We think there's actually another approach that we could take in order to get this done. We're going to share that with you. It's an H414. The other thing that it says is it talks a little bit about the funds being used for various purposes. There are a few purposes that are listed there. I feel that there are other things, there are other requirements, other priorities that these monies could be used for. I'll seek to share a couple of those with you as well. It's also in the other policy I'll refer you to that. The area over in section 13 is, and that's the, it's on my page 22 or 23 is the cannabis control board advisory committee. And it speaks of its responsibility and consultation to develop criteria for social equity applicants we've already essentially defined these in H414, all of these criteria have already been defined. We feel that it's a decent definition that we feel that these definitions could in fact be incorporated in this policy now. And in fact, it's our assertion that to not do so and again, it goes back to my primary my first point to not do so at this time and place that responsibility cannabis control board. What it does is it, you know, it creates the risk that this is just not going to get done at the level that we'd like to get it done. And it may miss the mark and then finally, here I'll talk just a little bit about the, the, this whole fiscal year, this section 14 transfer and appropriation. There is a fiscal year 2022 transfer in a match and appropriation of $500,000 this this being an emerging market in the state of Vermont and with this particular industry. Again, I think, and also in light of the fact that some of this is kind of proverbially being kicked down the road with the cannabis control board that we fear that it might be too little, as well as too late. So, those are the high level overviews in the last few minutes I'm just going to take you over to age 414 with some solutions to some of these challenges. What we have here is is the cannabis control the cannabis development fund and if you have accessibility to age 414, and it's in front of you that would be section 987. If you don't have it in front of you if you could note please section 987. We feel that there's a better approach to implementing set said fund. And I think that, you know, to in respect for the time that I've been a lot it. And I'm not going to belabor you with the details surrounding it but I didn't want to flag it as a solution for an approach, an alternative approach that we feel is more innovative. And the other thing that we flag there is is with the emergence of the upper funding, particularly in light of the fact that there are one time monies that there might be some creativity that you can backfill some of the, some of the resources that would be that would be invested here. The 1988. And I would say that, you know, this is a clear section 988 this is my page 720 this. This is the clearest definition prescription, or I would say framework of how this includes, you know, a community social equity. It's a combination. It talks about a program board. It allocates there it assigns their responsibilities. And, and at the end of the day, I'm in. Ultimately identifies communities that are in high need underserved disproportionately impacted by historic economic disinvestment or ravaged by violence. So strongly urging that this, you know, this, so this, this language that defines the social equity program, instead of asking the cannabis control or to start from scratch, when we have this vital data in front of you're strongly urging that the committee would take into consideration the adoption of this language, particularly in its current state because it's pretty well fleshed out. And then finally, and in almost enclosing is I did want to just direct your attention over section three, where there's a discussion on integrated license licenses, and within that discussion. That takes us to, there's a, there is a clear definition here on how we can leverage the integrated licensees license holders, how we can leverage their, their background, their experience, their success, their economic advantage, and also how we can even incentivize them to pull this market along in a very structured way that's laid out. So I encourage you to take a look at this language because again, this is a priority if this is a priority and I know that it is to you. Let's, and I know we're trying to get this, you were trying to get this thing marked up and voted out by, by, by Thursday, I get it, I see that I get it. But I think that we're so close right now committee on getting the language that we need in this. In closing, I would just say, I, I appreciate it. I appreciate the opportunity I appreciate the willingness and the olive branch that the, the chair and the vice chair have held out to us. They invited our entire group to this, you're going to hear from them more. We're all Vermont, Vermont Growers Association trace these people that you will talk to these are the individuals that I've collaborated with over well over the last year have grown to be friends, and you know I really trust and respect their best that is you consider equity in this very, very important policy that you would hear them and let's do the best we can to create the best policy to ensure that everybody has the ability to benefit from this market and moving forward. Thank you. Thanks for being here and I hope that you can hang out because I, if there are committee questions after we get done with our next witness. If we've got time before 10 I would love to have the opportunity to, to ask you some questions. Representative murwiki with a quick question. Thank you good morning I wonder if we can get a copy of your testimony. I have a written testimony today, but thankfully it's being recorded. I didn't, I did not prepare written testimony, but representative murwiki, I can prepare some, some notes for a committee if, if that's, if that's what you're getting at. Okay. All right. Thank you. Thank you. Jeffrey Pizzatillo, thank you for being with us and we would welcome you to share your thoughts on as 25. Thank you madam chair. Thank you vice chair. Good morning, committee members representatives. Thank you for your time. Thank you mark. That was excellent. Good morning to you. And I'll be brief. It looks like we've got just to be clear up until 10. Okay, excellent. Thank you so much. I'll speak. I just want to introduce myself. Since Vermont growers association might be new to many of you and myself as well. And then I'll move over to some policy and hopefully we have some time for some questions afterwards as well. So a little bit about myself. My name is Jeffrey Pizzatillo. I'm the co founder and executive director of Vermont growers association. And I'm one of us as the Vermont growers association but for cannabis. We are the trade association for the producers, the retailers, really all aspects of the, of the emerging marketplace. So it's, we think it's valuable to have our voices be heard for these matters. So again, thank you for your time. We've been in Vermont for a little bit back in the 2000s. We followed the medical bill. I'm talking 2007. And around that time I helped bring SSDP to the campus of UVM. If those are familiar with the drug policy alliance that students for sensible drug policy. So I've been an advocate in the space for a while. I've been a registered caregiver in our Vermont marijuana registry, since it's been operational in 2007. So I'm well aware of the ins and outs of that state program. I've been growing cannabis for a couple decades, professional cannabis grower, I consult in other states. And that's a little bit about me. About Vermont growers association. We formed in March 2019. Our first four way into the legislature was in January 2020 when S54 was being discussed. And, you know, we had amendments such as doubling the canopy size for the craft cultivation license from 500 to 1000 square feet. And that happened. That was a major win for the small producers. So we thank you for working on that and getting that done last year. Speaking to S25 moving over to policy. I want to touch upon some of the activity that happened in the Senate back in February and over the past couple months. So we do have some proposed language are Vermont cannabis equity coalition. And hopefully you guys have those documents in front of you. But specific to S25. If you do have that in front of you. I just want to comment that in section two of the bill. There are a couple provisions that we are grateful that the Senate has adopted in the bill. And I just want to bring them up and reinforce their importance really quickly. That would be the provision for under section two, which is the removal authority for the CCB. That gives the advisory committee, the opportunity, if need be to hold accountability over the cannabis control board. We think that's important. That came from lessons learned in other states, it's just inching towards a little bit more accountability in the regulatory agency, we would like to see that persist in the law, or in this bill. Moving on, the other provision that we have under section two is under provision age, which is for the advisory committee we had asked that senate gov ops included 13th member of the advisory committee to reflect medical patients interests, the unique challenges that patients have need to be represented in the regulatory agency, to some extent, since we are all aware that the CCB will be managing our state medical program. So, we asked that that 13th member be defined as someone from the ANA Vermont, or a medical professional, who is aware of the unique patient challenges. Unfortunately, that 13th member it turns out was defined as someone from the Vermont cannabis trade association, and we would like to see that fixed that was not our original intent. Back to the Vermont cannabis trade association we think that they have a role in this industry, but the intent of that 13th member was not to give it to industry representation. It was to give it to patient representation. So I just want to make that clear, and we would like to see that change happen. Moving on to some of the larger points that I'd like to discuss with you guys this morning. And that surrounds licensing, licensing, licensing equity. And licensing equity is very important. Why is that important. It's commonly said that one of the primary barriers to entry for small businesses, small producers is capital. That is a concern. But putting aside for a moment, you need characteristics of a social equity program and social equity applicants. Financing is not the primary barrier to entry for small businesses. Money is not the primary barrier to entry to small businesses. It is licenses and what we call license equity. And that's incredibly important that as an adult use marketplace rolls out and we see this in other states that we don't need a fully defined mature marketplace on day one but we need to have license equity across the board. And so we achieve that by our proposed language. Through what we were what we're characterizing as a craft license tier. So the craft license tier. We took very much the intent of 164 where they start defining this craft license tier vis a vis the craft cultivation license and there's actually if you guys look there's a provision that says the CCB shall determine a craft delivery craft. So there they allude to building out this sort of craft structure. We do that now. And we also apply costs. And why is that important. That's important because let me let me refer to actually and by the way, thank you for having chair pepper on yesterday that was incredibly insightful. And I'm going to refer to some of his comments. Yesterday chair pepper mentioned that some states similar to Vermont took their time did a very enacted a very great in a very nice bill, very thoughtful. However, when it came to roll out implementation and formation, it sort of fell fat and we didn't see the successes that we were intending in our legislation. And so I want to I want to consider some of those states and look at some of those issues and how they've gotten past them really really quickly when it comes to licensing. Chair pepper had mentioned Massachusetts, Massachusetts, past the similar to build to S 54. And after about three years of their market they found themselves with, for the most part, an inequitable licensing outcome, which was not only was there in a negligible amount of social equity applicants that actually had businesses operational, but the ratio from corporate actors to small business actors was inequitable. What Massachusetts found was they had no issue with capital, but they had hundreds of small businesses waiting in line for their commission to assign them licenses. So licenses was the issue. And so what did what did Massachusetts do to rectify that. One of the things that they did well specific to social equity was they took the time to provide funding and technical assistance that their social equity program did not have. So that was specific to bringing some of those applicants to market. In addition to that, for everyone else outside of the social equity program. They defined new license types through their legislative body. So license types are accessible delivery licenses. And that in and of itself was seen as bringing greater equity to the marketplace that allowed small businesses who were having trouble obtaining licenses for whatever reason, obtain, have access to the market through a more accessible license type. So they course corrected through adjusting their license type in their licensing structure. What this craft here that we're proposing you guys adopt in S 25 this year. Not only brings a uniquely Vermont licensing structure to our state, but also which is really important we think because of the significant delays with implementation. It helps repair some of this process that we're undergoing right now. Case in point, two of the primary. Provisions that chair Pepper stated were required this year were advertising and licensing fees. Licensing needs to get done this year. And that's more than just costs and fees that's including Vermonters in a more robust accessible licensing structure. Now I want to be clear. We don't want cannabis to be treated like a tomato plant. We think that there needs to be smart mindful regulation. So no one in our coalition is asking for the Wild Wild West here. What we do recognize is smart meaningful mindful regulation. If it meets the interests of the residents in the small businesses of the state can help transition the legacy actors which are currently operating in our state. Let's be clear, we've got a robust cannabis marketplace right now. It's underground. We want to bring those individuals above board and I do believe that was one of the original intensive s 54 a licensing structure will do that. And I want to conclude because I want to be mindful of time in case you guys have any questions and I just want to end by saying, look at what New York State and other states are doing around us. If we don't get this right. We will lose our talent. We will lose our talent. I want to share with you. We've heard from farmers producers retailers. They don't see themselves in terms of a licensing structure yet in this law. And that speaks to confidence that speaks to assurances and certainty in business development. In adult use marketplaces, businesses cannot get going until they get their license first. The dispensaries have that have that assurance in in 164 and that's fine. Their licenses are defined for them. They have that insurance. Again, we think they have a role in this marketplace. We're asking you to value Vermonters and include them at an equal footing in statute. This year. In statute. This year. So we can get going as quickly as possible. We can bring certainty and assurances to our businesses. So they're not thinking about maybe going to New York State, where they see more approachable licenses offered to them right now. So things to consider. I had a little bit more to share about what some other states are doing. We've been studying state cannabis law for over a decade. And I'm also more than happy to at some point, you know, be invited back or share some of our insights or resources about what other states are doing. And I'll end by saying that our coalition represents really the intersectionality of cannabis. And something that chair pepper had mentioned yesterday, when we start talking about cannabis policy, you ultimately start talking about every corner of state government. And this the plant is the fundamental intersectionality of so many things. That's what our coalition represents. So it's important to have racial equity, agricultural equity, equity, the economic equity that we're talking about through licensing structures, all occur at the same time. We think that it's possible we think we can walk and shoot government the same time. We think that the work that the racial justice alliance did with h414. is a fantastic starter for bringing equity to the marketplace. We think that the craft licensing tier that we've developed is a fantastic starter. I thank you for your time. And happy to take any questions that you guys may have. Thank you so much for being here representative with Claire has a question. Thank you Madam chair and thank you for testifying Jeffrey. You referred to this a couple of times is this craft licensing or craft growers. Could you just briefly elaborate on what what you mean by that. Specifically with regards to our proposed language. Pardon me. Well, in 164. You guys had to find a craft cultivation license type. And also in 164 there are there is language that says to be determined let's let's maybe fill out this craft structure. There's language that says craft delivery and whatnot. And so Vermont does not compete in terms of commodity. We can meet in terms of craft. So, where we're positioning ourselves in terms of that craft definition is. It's a federal sooner rather than later. Okay, so we will have a federal right, a federally regulated marketplace probably, hopefully in Biden's first term. We are positioning Vermont to be able to export our high quality craft product to other states. We have 8 million residents beneath us in in New York State, I'd much rather have us be in a primed location to export a craft product. We have to then have to spend that time to then work up to that point. So really, it's a race and the sooner we can sort of define and build out a craft sort of marketplace a cottage industry that represents or reflects our beer or our cheese or maple sear, the better. I hope that answer your question if not I'm happy to elaborate more. Okay. Thank you. Representative Anthony. Thank you Madam chair and thank you for your testimony. I'm concerned as are you in trying to avoid the Massachusetts initial result anyway, which is a highly concentrated group of folks who are holding the licenses. And I'm wondering, not just about the initial award of life or the number, or the identity of the initial holder. I'm sort of thinking about the next iteration in a historical process, which I'll liken to the standard oil business model, which is to say, just go buy up a bunch of licenses and create essentially a pyramid structure of integrated, but nevertheless subservient people who are growing or shipping or packaging or marketing. But the, the head head honcho so to say is holding essentially a clutch of licenses. So how do we stretch out, if we can never present a prevent over say 50 years how do we stretch out that tendency for the licenses to become concentrated. So I'm thinking of transfer sale time dimensional hurdles, sell it to a fellow Vermonter. I don't know but I just worry that it's not only the problem is not only the initial award universe. I'm concerned on that. And I sort of want to think as you do. So what happens 10 years from now what will it look like, and try and anticipate some of the less desirable tendencies that for which there's lots of historical analogues. Thank you. Thank you at Anthony. Fantastic question. We have considered this when we were developing the craft here so I'm happy to provide an answer for you. A couple things. Oregon, Massachusetts, so they ran into similar scenarios so in Massachusetts, had they deal with this first of all they did not have the excellent consolidation parameters that you guys worked into 164. They did not have that. So we have a leg up on that we learned that lesson that's fantastic but that's not the silver bullet there's more to that equation. We don't have accessible licenses nor production caps. So what that allowed was that allowed exactly what you detailed was the pyramid scheming the large players that we feel are inappropriate for certain states. Okay, so right now in 164 we don't have production caps. We respect at least the three corporations that operate in our state in our medical industry to develop to build 30,000 to 50,000 indoor facilities. 30,000 50,000 square feet indoor facilities. That is factory farming. That is able that is technically legal right now under 164. We think that is wholly inappropriate. So to diminish that interest in corporate desire by doing a couple things. First of all, we've got market consolidation parameters. Secondly, you impose production caps. We are asking through our craft license tier that we impose statewide production caps. We have a mix light rate. So stepping back for a moment. The way that we define cannabis cultivation is what's through a, a, a plant count ratio. This is what other states do. So what does that mean that means a one to two to four ratio for indoor mixed light and outdoor. So for every 1000 square feet indoor. That's 2000 square feet mixed light. 1000 square feet outdoor. You kept production by canopy size, and that severely diminishes the desire for companies to come in invest in your state. These large out of state actors. In addition to that, you do not have limited licensing, limited licensing allows corporations to value those licenses more and sell them to one another and consolidate. We have a rolling application process with production caps. That's what creates a safe marketplace, a well regulated marketplace, and a small business centric marketplace that is not so desirable for these what what are called MSOs or multi state operators. And again, we have three, three of them in our state right now. So any any questions for either mark use or Jeffrey Pizzatillo before we sign off for the morning or not for the morning but for a break. Wishful thinking. Okay, thank you gentlemen for being with us today. Thanks for sharing your thoughts on as 25 and do feel free to send any follow up. If you have any testimony or or bullet points to our committee assistant and she will get them up on our committee page. So thank you so much for your time this morning. Committee we are on break until 1030 and we have a pretty heavy meaty topic to dive into at 1030 so do please try to come back. So that we can get right started. Thank you see you all in 25 minutes.