 very quickly obviously I gotta apologize all these are kind of topics that could take a month of meetings but with our mind we're trying to move quickly so before we kind of get into that though I believe Jeff or somebody circulated the meetings the minutes in the last couple meetings so do I have a motion to approve those minutes. So move, Yvonne, great. So before we get into the substance of the today's meeting which will be a lot of retail licenses and the other licenses I think Jeff wanted to take a minute or two to talk about small cultivator issues or things kind of follow up the last call is that still Jeff you still want to take a couple minutes right now. Yeah, in the interest of being green I'll keep it short but after the last couple meetings thinking of how to split up this 400,000 square foot estimate of flowering canopy under 904A is set to a theory of 1000 square feet but it doesn't set a floor so that seems like there's a lot of room to have very small type licenses within that order for the authority in that section. I'm thinking of two. Number one is a home grow permit no more than 10 square feet no sales and no tax. So mainly the idea is that somebody to set up a plant in their closet or backyard and not worry about getting seeds and pay a small fee for an annual permit. The second idea is a special license for farmers market sales only for no more than 100 square feet. That would be taxable at the point of sale and limited limited sales permission for farmers market and how to regulate a cannabis farmers market is another riddle. But I believe Vermont can probably figure it out. I just wanted to throw those out there that there's a lot of room to have really, really small life that they can raise small amounts of money that will add to the whole pot. So Jeff for a phone grower, are you talking about like allowing home growers to essentially sell to either manufacturers or cultivators who then get that product tested package and enter into the legal market similar to how it occurred either California or Michigan prior to the establishment of their medical cannabis regulatory system or are you just talking about allowing for personal home cultivation, which is already permitted in Vermont and has been before. It was written by which authorized operations. Okay, we'll take clarifying that I wasn't aware that it's already happening that the home was already happening. I was just thinking of a way to protect home growers from seizure. But if they're already protected from seizure, then it's kind of a mood point. I was thinking of just weight small amounts of money with permit. Yeah, yeah, I think there is probably not the competition I have now, but it's a larger discussion. There is, there is merit to revisiting whether or not essentially the system that Michigan had established for about a year and a half, which is allowed existing caregivers to sell into the system. Hasn't our discussion, but I don't think is likely permissible under the under the structures of current Vermont statue. Thank you. And I'll also say, Jeff, I think you'll, I think we're on the same wavelength in a few minutes. We're going to talk about some of our, some of the ideas we have to be thought of for retail. One of them was to try to find a way for for small farmers to to sell directly to consumers. So I guess hold your thoughts on that for maybe five minutes and then we'll be popping back up. All right. So, and I think I just saw that Stephanie going. So we have a full gang here. So this is just kind of our going forward our next few meetings. I kept these statutory requirements in in case anyone wanted to look back at it, but we covered them last time. Here's kind of the specific statute that we're looking at today through the license sites that are out in the statute. And then as you'll notice, the board is required to tear retailer licenses. And as the authority to tear other types of licenses should they see fit. So kind of what we want to talk about today are are those decisions like how we should tear retail licenses and how if at all should we tear other types of licenses. So again, as we get into it today, as with something I feel like I've talked about on all the calls like all of this is just slightly backwards because of the statutory requirement to get this report in on on fees. So today I think we want to talk about kind of the concepts of of these license types, whereas like the details will probably get kicked a little bit down the road. So we're trying to hopefully get some like agreement on concepts of things to explore. But each one of these license types will have to be defined further in the regulations by the board. I know that's probably things that this working group and the subcommittee and other subcommittees are going to be talking about going forward. But for the purposes of getting ready for this initial report, we need to just kind of identify what those license types are in order so that we can set a fee for them for when they're actually awarded. So starting first and probably what will take up a good chunk of today's call is I wanted to talk about retail licenses. So as I just mentioned, the boards are required to tier the retail licenses. We've kind of thought up a handful of concepts on on how those retail licenses could be tiered. There's obviously like quite a many different types of retail that exactly thought of or different ways to do this. What we were trying to do is make sure that we created concepts of licenses that would allow for access for smaller operators, access for farmers, but also trying to ensure that there are traditional storefronts available and that there's no licenses that kind of undercut other licenses or anything along those lines. What we're going to go through right now is kind of a handful of concepts that we thought of. I think what we thought was helpful would be to just kind of talk about them as concepts. Each one of these could have a lot of details. So I don't want to get too far down tangents on like how to exactly define it. But, you know, everyone feel free to voice your thoughts or concerns on that. But I think the goal would be to identify concepts to recommend to the board. And then I guess one last caveat before we get into the substance is the just wanted to say that these are all ideas and it is the board's kind of final decision on this on whether they have the authority to make all of these and set the rules on them. Some of these I think all would be considered tiers of retail licenses. Others might make an argument that, you know, that that these are different license types. So then we didn't do that full legal analysis of kind of where these would fit. So we're throwing out the concepts and what we think could fit. But, you know, all of this is obviously subject to legal review by the board's council and others. So diving into it, I guess the first tier and probably one that I assume everybody will be on board. But a project, I guess, if you will, would be the traditional storefront retailer. That's what you see in all the other states. And I don't, if anyone has any questions, I can explain what that means. But I think I'm sure everybody, you know, gets the concept and understands. And I assume everyone's on board with having traditional storefront retailers in Vermont. So I'll move on to the next. And I guess for the fee purposes, again, we need to, you know, this is going to be the subject of next Monday's meeting. But we're going to talk a little bit about projected budget. And we have to try to aim to have fees cover costs as possible. So I think these out of the retailer licenses probably have the highest fees, you know. But again, we have to kind of look at the budgetary information. Look at some of the information from other states and estimate what those fees are. But I think the rest of our options here for the most part would be aimed at smaller operators who would have lower fees than these guys. So I'll stop for a second. Any thoughts or concerns like that? Well, I do understand your concept of your storefront or your brick and mortar store. That is retail of finished products. Yes. Retail of finished product. Siobhan? I had to unmute. Definitely support the simple ones like having a proper storefront retailer. As we look into the others and I would say you almost have that in order of, you know, most traditional to least traditional. I would want to know a lot from the other subcommittee covering security before we get into the less traditional retail. You know, I mean, it takes back in the middle of a farmer retailer. I think that's one that a lot of our monsters are probably very supportive of. But before we authorize that, and I'm not at all against authorizing that, I would want to know what we're talking about when it comes to security. What regulation is going to be like? How are they going to look like for retailers? Because I don't want to create a security risk for a ton of our farmers who now have, you know, they slightly adjust what was their maple syrup selling stand to also sell their cannabis. And we've got some, you know, potential, you know, real issues. So I want to know a lot more about what the security subcommittee is doing. And then I add in, as all these go, you know, there's a lot of parallels to the alcohol side of things. And, you know, in Vermont law, we do have things like temporary sales for events. We don't have things like deliveries. There's certain kind of ways, but not really for the most part, other than the COVID exception. But I would personally advocate that matter what the answers of security that some of the last two there, you know, to get to the weird side of things, well, just the side of things. I would advocate that those are not things we start with. I would want to see this market become established and a little more mature and have the opportunity for the board to work at any kinks and to figure out other parts that actually get going. And leave those not unauthorized, just authorized for further consideration or, you know, tabled for year two or year three or something along that front where, you know, I want to help avoid an accidental wild west. So the one model that we have is not, you know, tobacco or alcohol relative to delivery and or farmer retail is raw milk. The state of Vermont regulates raw milk and you have to have a relationship with the farmer. There are specific hazards claims associated with raw milk, not that that's applicable here or it could be, I mean, it could be similar. But they do allow for delivery and they do allow for on-farm sales. And I think just recently they allowed for sales at farmer's markets. But there's a fair bit of regulation and that is not a security issue. No one's stealing raw milk in the state of Vermont, I believe. But there are some kind of like, there's a framework for how it's regulated that doesn't exist. And you could borrow a little bit from that. Thanks. Yeah. And I think, I think you did accurately crack the code of kind of how this order was put together here. I think the first two are particularly not easy, but easier ones to fit into a traditional model. The middle two are things that seem to have gotten public comments on it. It seems like things that can be very focused on trying to create the sort of license types that will work for folks in Vermont. But that you highlighted the real concerns of those are the two license types that we would need the most context about and understand how the regulations are drafted. And that's probably something that we're not going to have full details for before we have to ask for a fee. I'm not actually sure where the, because you also highlighted the other issues. Some of the concerns from that those two license types that raise are subject matters of different subgroups that I haven't been sitting on. So I'm not really sure where they are. And I think some of this will just have to be a back and forth because I don't know if they're considering security requirements and the form of retailers because they're not looking at different license types. And so some of it, some of these things, maybe the results here is, you know, we raise it, say this would be something that we could support with appropriate definition and security requirements and then let that be something that the other subcommittee group, subcommittee, you know, reviews and fill those out. Not to put things on what I'm sure is already a barrier. Yeah, and I'll, I'll, I'll slightly change what we're suggesting again is where I would go next, but in a slightly different framework, I would say we have the ability to decide in this group what the fee structure will be for those potential types of licenses without the board necessarily authorizing those licenses to exist yet. So, you know, we can say if the board authorizes, nor it's not sort of like delivery, if the board authorized temporary sales for events, the fee structure will be there. But it's up to the board to decide when they're comfortable doing so that, you know, I'd rather take it up to the board. I've been over to a subcommittee. But same concept what you're saying. And I would add one more fine point. This is part of the security part. But just another one that I don't personally feel up to date with yet, at least in our subcommittee is I want to know what payment options are going to be for candidates in Vermont. You know, obviously all cash is an disaster and federally, it's very hard to get away from all cash. But I believe that there's been a lot of exploration in Vermont of potential state financial institutions, not state chartered, not federally chartered. But I don't know many details around that. I'd want to know a lot about that, too, because especially if we're talking about all cash, that makes me even more concerned about smaller and less attractive details. Yeah, sure. I completely agree on that. And hopefully, again, it hasn't really been in our purview here. And so I'm sure the board knows a little bit more of where all that is going to hold for Vermont will have enough banking coverage so that a lot of these transactions will not be cash. You know, I think hopefully I speak for everyone on the call and hopefully at some point in the near future we have some federal legal changes that that eliminates that issue for for good. But kind of so I think I think we kind of have some good marching orders here and I think everything that you said makes sense. So why don't we then kind of approach these as these are concepts that we feel comfortable recommending for the purposes of providing fees with the caveat that the board does not have to recommend any of these. And that the board shall only recommend those security requirements and other requirements are adequate. I know that's not like a clean legal term, but I think we all get the concept and I think the board will understand like kind of what we mean. There's these are I think these all are options or I think these could all be options to help the Vermont market, but they have to be done right and they have to be done partly. And just where we are we have to kind of make a call and whether we should recommend them before we know if they'll be done right and done smartly. But I think we can recommend them with you know conditional upon future regulations and further further analysis. But does that make sense from a concept and then we can kind of quickly run through these. I fully support that and to save you some some breath in the future. I'll just remind us all that we're an advisory committee to the board. So anything that we recommend here is up to the board discussion. So, you know, we think I think we're going to solve and we trust their discussion. Excellent. Excellent. Thanks for, thanks for putting it so perfectly. So, so we covered the traditional storefront retailer. Season clones would be like a small retailer selling the clones to either home cultivators or other cultivators. So, you know, I think that's a pretty easy one from a regulatory perspective to kind of to regulate. I mean, I guess everything's relative in this world. Everything's a little difficult to to regulate, but compared to some of our compared to the next two bullet points that I feel like that's an easier one. So if anyone has any questions. I have a short question. Actually, I just I don't know the answer. Is it possible that individuals would provide services of starting? I know clones. I get the science behind the clone. But if someone were to say, here's my packet of seeds or you bought seeds and you're starting a whole bunch of plants for somebody. I guess nursery is what I was thinking more so. But I guess that's lost in the clones as well. Right. Like you're talking about all of that. Yeah. Selling seed packets, selling clones. Yeah, that was that was where I thought the concept was. I don't Andrew or Jennifer either do have different thoughts on it, but that's that's what I had envisioned. I didn't define it fully in the slides. Yeah. Yeah. This is maybe more designed for sales to consumers. But, you know, it's maybe possible that a cultivator with 5E is now depending on how the digital tracking system works. Probably the most likely for those cases, you couldn't buy seeds at retail and then just run those, you know, seeds that are then no longer into cultivation. So you typically end up with a cultivation to cultivation transfer. But again, I'm pretty sure that there needs to be a technical statutory change to enable that. You know, we spoke with some stakeholders a while ago that I think mentioned that on one of the one of the calls. So James has taken note of that as far as something that we should probably look into. Because otherwise, I mean, a nursery license would obviously not be viable if you can't do a cultivation and cultivation. You know, inventory transfers of that type of commodity. In most cases, even though the license that you have nurseries like in California, I don't know how prevalent they've been. Most cultivators do their own in-house, you know, new introduction of cultivation. This is really more so designed for retailers. I think that's actually an interesting one. I think that could be very, very Vermont-y. But, you know, because we already have legal home cultivation, I can imagine a small, a robust market of home cultivators who are necessarily the greenest of them and would be thrilled to buy from a nursery that is, you know, starting it for them. And if that takes another small part of this economy, that could be a great, you know, corner to have. I have a question. If you don't mind, this is James Pepper. You know, when we think about seeds and clones, forgive my ignorance, but these are all kind of non-flowering, lower than .3% THC. So are they even within the cannabis board's jurisdiction? I believe they would be. Okay. There's also, there's a larger question that I've worked with on our, with our HEP team about whether or not, in terms of the seeds of marijuana plants that are, will grow into above .3% THC are HEP teams. And I think that the legal analysis that I've seen shows that they're not HEP teams. Now, in most cases, that is how those are, you know, when you see seeds selling in the European Union, that's typically how they get around that, like a legal gray area, but I'm not a lawyer and definitely not a European law employer. So in the state of Vermont, we have a labeling standard for hemp seed, and it has to be labeled that, you know, the THC production is, you know, less than the federal standard. So we actually cover that. So we would consider, I mean, when you buy a pack of seeds, it's got to be truth and labeling. If you want to guarantee of some THC concentration and it's over and above a hemp concentration, it should be labeled as such as a consumer. But that's what I want to know. So yeah, no, they're not HEPs. They would definitely, I think it's within the purview of the, of the CCB. Okay. Thank you. Only that's in the back of my mind for a while and just thanks for the clarification. Of course. And so these next two are kind of the ones that are in response to what we've heard from, from public comments that have been sent online and just talking to folks in Vermont, like we were trying to figure out licenses that would kind of accentuate the Vermont culture and work with their geography and kind of culture. So this limited location retailing, both of these probably could come up with catchier names, not in marketing, but that we were thinking of basically a retail counter or section of an existing storefront. This has been brought up a couple of times by people who are thinking of towns that are very small and may have some cannabis retail needs but can't support a full store. So there could be different ways of designing, you know, designing a corner of a shop or a separate entrance to a shop or something that's in an existing store allowed to sell retail. And you would obviously, this is one of the ones that's going to have a lot of interest in how it's defined. You want to obviously make sure that this doesn't undercut traditional storefront retailers. If you allow this to be lower fee and everywhere, no one's going to go through the hassle of having the more robust license. But if you, but we're thinking if you could probably limit this via, you know, at some amount of sales or like inventory that could be held, things along those lines. So again, let's take a few seconds to talk about like the concept and if this is something that the board should explore further, we think it could be a way to provide access to consumers who are located a little bit further away from some of the population centers or who, and also a way to help support some of the small general stores that could use a little boost in revenue. But obviously there's quite a few variables and questions about how to define it and set those regulations. So, Devan? Yeah, Dan, Theda or maybe Andrew had in the model. The guesstimate recommendation, let's say that we end up saying we're going with all these types and we, you know, we have the target canopy total sizes they were projecting, yada, yada. Do you have a scale of what the recommended or what your first recommendation does, the committee would be of the dollar amount per year or whatever else it is for the electricity? As far as how much revenue they would gain? No, like what's the per license cost to a retailer? O2 for the actual fee? Yeah. I don't have a recommendation on that yet, and I think it would vary pretty significantly depending on the type of retail license. So that's even if my response to your question, Dan, is, and not 100% sure we need limited location retailer zone categories if the board cracked traditional storefront retailer with enough flexibility of what counts as a traditional storefront retailer. You know, I'm not, for example, would be, like, you know, here's the amount you're allowed to hold if your whole store only does this. Here's the amount you're allowed to hold if you're only a dedicated corner of a larger store, yada, yada, right? So you could eliminate an entire category here of license, potentially. But I qualify my entire comment with, I don't have a sense yet of the scale we're going to be recommending on fees. And so we're going to be saying that it's $50,000 to be a storefront retailer a year, but it's $1,000 to be a limited location retailer. I totally understand the difference. Or we're going to end up recommending that we're talking about a couple thousand dollars a year, more akin to alcohol licenses than that a little different, $100, et cetera. So I think a lot needs to tie into how much we end up realizing we need to recognize from these fees. Yeah, and I think that's a great point and one that's probably been underlying our kind of presentations about actually, we probably should have been clear about that. We haven't come up with our full recommendations on fees. I think we're going to aim to do that for sometime next week because we're moving so quickly through all of this stuff. Part of the reason why we put it as a tier here was to allow us to have different recommendations for fees. We weren't going to, I mean, there's a kind, we could have tiered all, I mean, we could probably, you know, scrap a lot of it, have the board do have a very expansive definition and rules for retail and then tier the fees based on sales. But we thought this was an easier way of setting up basically a traditional storefront at one fee statewide and then create lower fees for, you know, and then once the regulations and rules are set in, like these would have different limits. So I don't have a great answer to your question yet because we haven't started to grasp with what that fee needs to be. And again, I think I said it in the first meeting and sorry, set me up by in one second. I just want to finish this up before I lose it. I think I mentioned in the first meeting, but the statute says that we need to try to come up with fees that would cover the cost of operation for the board. You know, some like real quick, like back of the envelope or just the way we're looking at it. It's going to be very, very difficult to do without having extremely high fees. I think, and again, as you mentioned, we're an advisory board here and the board's final decision. I think one of the things that we might want to end up proposing is, you know, we'll put a couple of sets of recommendations on fees together. Like here's what the fees would need to be if we do have to cover the board's full cost right away. And then here's, you know, maybe slightly more reasonable fees where there's some tax revenue being kicked in because I think they're just not going to be, it's going to be hard for a state to decide, even with the board's lean budget to cover those fees up front if we also want to make sure that we have enough accessible license type with low fees. So I guess all of this is kind of a pause for now while we run the numbers and try to get back some projections, which we'll be talking about with you guys next week. But for right now, I think I'd like to, I'd recommend putting them in two different tiers just so that we have that flexibility to assign them different license fees going forward. Great. Stephanie and then Tom. I think you mentioned this, but I feel like the limited location or limited square area, you know, saleable floor area is kind of what it is, right? The limited saleable floor area here could just be nested under traditional storefront, you know? Like you could do it by saleable floor area. Like just like you have 100 square feet of floor excluding stairways and closets or whatever, similar to a zoning tactic and then, or you have 1500 square feet or you have 2000 square feet and then you can tear it out that way. I think some of this is the reason we thought there might need to be a different license type is because you would need to stand at the different security requirements. So for instance, like, you know, Vermont has a lot of very rural areas in which there's only a single or maybe a less than a handful of stores that cover the entire town and it may not be viable to have a one of those three stores in the town to be a cannabis retailer. And so the thought then is it possible to create a situation in which, for instance, you know, most of the store is open to all people including those under the age of 21 and then there's a separate door and a separate section within that store that you need to be over 21 to enter. And so some of these are essentially setting it up, you know, for a further discussion with either the, you know, the security subgroup or for the the board to consider as it pertains to differential security regulations for these different lengths. And just to add a fine point to that Andrew, you'd also logically, you'd want to say a limited location one can only sell up to a certain amount or some other certain tax so that, you know, if it is much cheaper to be that, you don't want to incentivize people that would have been storefront retailers to just be limited location retailers and find a way to put a coffee shop into just to, you know, to game it. So you'd want to say you want to really do the full shebang your traditional storefront retailer but here's a way to enable smaller towns to have the side counters better. Yeah, I completely agree with that. Tom? Yeah, sorry, just quickly. I know you got a lot to go through Dan, but one issue to consider with a limited sale which is a great concept I think especially for the smaller towns but when we're talking about buffer zones, which I know is another subcommittee but you're likely going to run headlong into some of those restrictions because if you've got an existing store it's likely not going to have to follow the 500,000 foot restrictions for a school, you know, church, however you want to define it or even, you know, a lot of things have residences. And so, yeah, it's just one more thing when you're talking about gaining it it's going to be tough to distinguish between that and the traditional storefront. Yeah, I agree. I think that falls into kind of Siobhan's point earlier where I don't want to limit us here. Again, we're not getting paid to make the tough calls. That's on the board on kind of how they, but we just, it seems like it's a, we thought the concept was valid enough to put forward. But there's quite a few, it's not an easy concept for all of these reasons that would work. But if it's something that if any state was going to try to adopt it, it seems like it's, with Vermont it could be a win-win with both helping some of the small town general stores and also helping, helping figure out a kind of a low cost entry to this market in some of these towns where it's not going to be economically feasible to open a full storefront retailer. So, yeah, sorry, Mark. Just was going to say, Dan, this is a familiar concept in the alcohol industry that you guys probably have, you probably modeled it like that. But, you know, the state of Virginia, like where I live, has a lot of rural areas. That's pretty much how to service the rural areas, which is just, you know, a lot of licensee who's, you know, who can stock a couple of shelves or whatever it is. So, not saying this for four Vermont, but, you know, it's common. Yeah. We can't take credit for the concept. We did lift it from other people. We had the idea and we knew that alcohol does it in some of the rural areas. We just copy other good ideas for the most part. So, any other questions on that? I do want to just keep moving because we have a lot to cover. And I think, so I, I guess objections, I think are, we can recommend, recommend that the board explores this license type with all of the necessary caveats and conditions. Sounds good, great. And then I feel like this is going to be the same, it was kind of the same, same question. And this is the farmer retailer that would allow like limited products to be sold from small cultivators, direct to consumer. I think this might be something that some of the other groups are looking, subcommittees are looking at as well. But it raises the same, the concept is to help Vermonters and it raises the same question as the last license. I imagine the discussion will sound similar. It's obviously different details of how do you, how do you secure this and how do you limit the products? Because again, you don't want to, you know, totally cut out the storefront retailers. But, you know, we were thinking, auditioning some sort of like flower or maybe some, you know, some very limited production, like allowing, you know, pre-rolls or something along those lines. But again, a lot of this is do we feel comfortable in recommending this as a, as a concept with the, if the board can figure out how to, how to make it work in practice. Sounds good. I see it. Enough thumbs up. And so again, now we're kind of to the last, last two are right, are probably the, the trickiest ones. These are, these are license types that we see in other states, but they are often different license types. And I think Siobhan's already expressed his hesitancy. So I don't know if we'd want to run through quickly what they are. I think delivery has, has both benefit and some issues in Vermont. One, it's probably harder to operate a delivery in an additional way if the storefronts are spread out. It's going to, you're not going to get your products in 15 to 20 minutes if you, you know, in a state with further distances, but it may help provide access if you, you know, reserve a head or something like that on those lines. Chris, did I see you raise your hand physically in there or am I seeing things? I am, I guess I'm just seeing things. So we, I don't know if we want to open it up for a very brief discussion on, on whether we think that's something that should be delayed, whether it's something that other, other members think we should, we should recommend moving forward with sooner rather than later or kind of open to suggestions on that one. I like the idea of delivery personally, but I think it should be tied into farmer. I think it should be something available to the small scale operator that's growing and not to others. I would disagree with that respectfully. I think if we're allowing delivery, look, I spent years advocating with a small guy in Vermont, especially in the outfall space, but there is also a sense of fairness. If we're advocating for delivery, I think we should allow delivery, you know, to whether it's a dedicated license or it's tied to the other types of retailers that do it. You know, I don't know that we should be only allowing certain types of growers to do it. I would also add a different caveat to my earlier comment that I prefer waiting on delivery and events, you know, that the board wait on those till later years. I would do a strong exception to that for when the dispensaries rule under the authority of the board. And if the board were considering delivery for dispensaries sooner, I would strongly support that. Because, you know, access is a very different issue when you're talking about medical needs. Dan, can I just, this is James Pepper. Can I just weigh in very briefly that we as a board have to make a recommendation whether to allow delivery? So I would like to hear the subcommittee talk about it and think about the potential, how it could look and what the fee structure might look like. Because we have to tell the legislature one way or the other. We could just say no, but to me it would be much more fruitful to give an actual recommendation to them about this. And that goes with the special events permit as well. And just one point of clarification is that we do, the dispensaries currently medical are allowed to deliver to their patients. Yeah, I'm happy to, we can pause and talk about it a little bit now. We also can try to reserve some time at a future meeting if we want to get further into it. I think Chris, I think you're the only subcommittee member that we haven't heard from. Do you have any thoughts on delivery? Do you have any real thoughts and you can kind of personal further? I think with all the social equity considerations it's a opportunity for somebody to get into cannabis with, you know, a low barrier of investment compared to some of the other licenses. Yeah, definitely, we've seen that. Obviously, Massachusetts limited the delivery license to social equity. I don't know if the social equity subcommittee group has thought of it, hopefully they have, but that definitely is a possibility. Siobhan? Yeah, I just added one possibility to change the question is to make delivery a checkbox addition to the other license types. You know, you're going to be a traditional storefront retailer and your fee is X, but also you're going to pay the extra, whatever it is, a year to have delivery options. And that doesn't necessarily mean that only people who have storefronts with other types of licenses can get delivery. You could potentially, really you could say, well you're calling here non-storefront delivery would be non-storefront delivery and all the other ones that have storefronts could also have a delivery option. But I would certainly advocate that if we're going to allow true non-storefront delivery, i.e. a place that never has a storefront, that they still need some space, stores or stuff that meets certain rules and regulations and probably gives them just a closet in their house. So you're going to have to go back a lot from the security standpoint. But I do still, you know, my recommendation is that we allow delivery whether it's delayed by a year or two to let other things come up. I'm fully fine if I'm bothered to do that. But my recommendation would be to say less, we do support delivery but not starting it until whatever it is, year two or year three so that we know the other things have really settled down. So we kind of have a lot of delivery themes or delivery threads here to tease out. So I haven't, I don't think I can pull it to a full recommendation here. But so there's kind of different ways that we could, so we could, we've talked about delivering direct from a storefront, we've talked about delivering. I would imagine, Yvonne, as we put this all together, I would imagine that the delivery would have to come with another license to store products. You know, cultivators could, like it could, we could define whether it has to go from a product manufacturer or a cultivator or if it has to go through a wholesaler. Like they're, or by we, I mean, the board can define, but there's kind of different ways that we could structure that. I think some of the lowest barrier to entry for social equity licenses would be kind of that courier model where they would come from storefronts to customers. That could be, I think, an Andrew or Jen could pop in if they have some thoughts, but some of the population, or the limited population and the distances in Vermont could make some of those harder to make profitable straight from storefront. So that's why we're thinking from maybe a wholesaler, I don't know how quickly the Vermont delivery entrepreneurs would be able to make these deliveries just from the distances that need to be carried, covered and things like that. It'd be easier to do deliveries from the storefront around Burlington where most of your population is, like, near enough to the high that you can get there quickly, but I think generally I think we might need to have some more time to deliver delivery on a future call or try to present a couple of different options to see if everyone can get on board. Stephanie? Did you say that there would be a courier service so you're talking about another industry that would serve as delivering from storefront? Did the courier, kind of like courier model, like, I guess, Uber Eats for cannabis delivery is one of the models of delivery that's been used in other states. Massachusetts has both like the courier model and then a model where you can deliver from non-storefront from wholesale. One, the lowest barrier to entry tends to be the courier model because you don't need a whole lot other than a vehicle with the necessary security requirements and some technology to get the orders and deliver the orders. But it's also some of the hardest ones to make profitable just due to because there's just not a huge margin on if the like if you have to pay the there's just not a huge margin on it since the money's mostly going to the the retail outlet and not to the delivery driver. So I think we're quickly moving through time. So I think if it's all right everyone here we'll try to reserve some time to talk about delivery in one of the upcoming meetings and probably on temporary sales at events I think both of those are probably juicy topics where we can spend some time on it and they're both probably related somewhat to some of the thoughts from other subcommittees and both we're not particularly close to a recommendation right now so we'll move on in the second. Gina, I see you over here, Andres. I wanted to say that we will be discussing delivery for social equity candidates in the social equity subcommittee but we haven't done so yet. I can maybe take a feel about it for now to get you just to see how the subcommittee feels about that. Great, yeah, I think that could be helpful. I think a couple of these are going to be things that the subcommittee on social equity are obviously going to inform what we do here and vice versa so keep us posted on how those conversations go. We have very quickly ran out of time but the one other big thing I guess I wanted to talk about and maybe some of this will have to be kicked to another meeting too but for manufacturing product manufacturing licenses to quickly go through the concept we were thinking the board isn't required to tier this but we thought it might make sense to tier it at least for two different tiers maybe three depending on how some of the definitions of cultivation or the rules of cultivation are set by the board but our thought was basically at least a two part manufacturer's license the first one would basically be the full license where you can have solid and basic extraction may call sorts of products whatever you can do with that license and it would have kind of the higher fee out of the manufacturing license the second one we thought it would be nice to make a lower fee manufacturing license where you weren't allowed to use solid base extraction so it would be mainly focused at folks that want to make confused products or other products for retail sales but will not be kind of using the chemical process that would require additional kind of security and public safety measures so that we thought that could be a more approachable license that a more approachable fee for somebody who wants to come up with their own brand of you know, confused product acts or whatever so could have had a longer explanation but trying to move very quickly any questions or thoughts on that concept I think that would be a couple of things that would be expensive because you're not doing solid base extraction but couldn't the second tier license couldn't you still purchase solid base extractions from wholesale yeah, you could purchase the you know, you could purchase the concentrate to infuse into the product so again we have to work through like there might also be if we're going to reduce the license fee so that you know, again our goal is to make sure that every license that we recommend is economically viable and makes sense from a fee standpoint so you'd be able to purchase the product made by the tier one for lack of a better term product manufacturer and then you could use it to make your make your whatever product but not a product the actual ingredient I'm just trying to get clarity here you with the second tier less expensive license wouldn't be able to manufacture solid base extractions but you could purchase that ingredient from wholesale to use in your products yeah yeah I was a very confusing explanation by me, I apologize any other thoughts or questions on that I see one, I think I see one approval any other approval of the concept we can flesh it out further too great so and then the last thing that we're going to was we were wondering if it can do our previous conversation about whether or not if we do have a farmer limited license whether cultivation would allow them to do some like limited processing there so that they could make pre-rolls or things along those lines I think we can kick that we can probably assume that in that other conversation about the farmer license it can either be a separate tier manufacturing license or it could just be something that that license is allowed to do under the rules of the board so since we have used up almost all of our time I want to make sure that we have at least a few minutes for public comment so we'll probably skip this last slide which is about the other licenses we'll hold that for another time I think our recommendation was mostly just going to be we don't think there's tiers needed in any of the other types of licenses but also licenses and testing lab license we should probably have a relatively low fee and that when we're coming up with the integrated license fee we just want to make sure that we account for the fact that there is already a $50,000 statutory fee put on top of them but we'll just get that to another call Stephanie I was wondering if there would be a cooperative license that might encompass any number of these tiers not yet talked about putting in a co-op license because I know the social equity subcommittee has been looking at it so again again it's kind of the interplay between the subcommittees we were waiting to see what we've been I think envisioning kind of like the basic framework here and then as other subcommittees kind of recommend license types trying to incorporate them into the framework I'm not sure if that was a lot of things going on at once so we're trying to figure out how to work together with that was our concept so we're happy to hear from the social equity subcommittee on their idea for a co-op and try to fit it in and make sure it works that's why it's not here I guess would be an answer thank you and in the subcommittee we should be getting to all of that information next week I'm right now we're just finalizing what is the social equity kind of the criteria around that thank you so then that's kind of it again we'll have stuff for next fall as follow up but do we have any public comments so we've got two two members of the public here in the room that want to make a public comment so if you want to just say your name hello my name is Bernardo Silva I'm legislative director at the Vermont Growers Association I just have one question regarding the subject that was just discussed which was licensing and separation of solvent list and hydrocarbon in Vermont statutes Title 18 Health Chapter 84 possession and control and regulated drugs Chapter 01 Section 423 420H that's 4230H chemical extraction via butane or hexane prohibited Section A no person shall manufacture concentrated cannabis by chemical extraction or chemical synthesis using butane or hexane unless authorized as a dispensary pursuant to registration issued by the Department of Public Safety pursuant to Chapter 86 of this title so my question is with regard to licensing and creating a two-tier processing license would the three dispensaries under this regular under this law be the only ones allowed to attain that licensing and has the subcommittee had any discussions in terms of recommendations for the CCB or the legislature in amending that law to allow for chemical extraction to be processed by all producers and not just the vertically integrated license holders I just a brief answer I will say that I I anticipated that the recommendations of this group would be that that those licenses would not be limited just to the to the existing licenses and that would be open to anyone applying to enter the adult use market for that license type so we've had a discussion about it with the rest of the group but I think that's where my head is at I don't know where the group is in addition to that we're going to review this statute and obviously it's going to be a a decision that the council for the counter-structural board will make but many, many of the you know, based on another concentrated product are made with compressed DO2 that may not have the just a follow up with the vape cartridges I guess has the subcommittee had any discussion about the fact that the law only allows for the dispensing of oils in vape cartridges and you know other how that impacts other parts of the industry such as public health waste environmental sustainability child safety you know, it's my opinion as a consumer and former producer that it's wholly responsible for the state of Vermont to require that cartridge as the only method of consumption of vape cartridges and that's what's there right now you know, we talked about this committee discussed different levels of processing you know, solvency processing without the window when you only have cartridges and that's the one with that's the method of processing with the lowest barrier of entry you know, something Chris here mentioned as being beneficial so sorry I appreciate your time today, thank you yeah, thank you for your comment okay, it's actually the only public comment in the room right now so we can even move to adjourn all right, sounds good we have a motion to adjourn so moved first, Stephanie seconded I think we are adjourned thanks everyone we'll be meeting again