 I don't think my microphone is working. We hear you. I really hear you. Yeah. Do you not hear us? I don't think she hears us. Can you chat her? No. I have disabled chat for this meeting. Okay. Well... I can ask Bryn to text her or something. Or I can email her. Hey Chris. Hi. Good afternoon. So Jen Flanigan from VS Strategies is having some technical issues. Oh no. I didn't have to get it. Oh, you got it. Okay. Why don't we get started then? Because we have everyone here. Let me get the recording going. Okay. We are recording. All right. Great. So my name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is December 9th, 2021. This is a meeting of our exploratory subcommittee of the cannabis advisory committee. The members that are present here today are Jim Romanoff, Nader Ashim, Chris Walsh, Meg Delia, and Kerry Jageir. And I think I see Stephanie Smith as well. Yes. So it's the full... Hey Stephanie. So it's the full subcommittee. And today we are really going to look at some of the policy decisions that the legislature asked the cannabis board to look into for our January 15th, 2022 report. And before we turn to that, I just needed to ask, has everyone had a chance to review the minutes that Nellie sent around from our last meeting, October 20th, 2021. And Jim, I know that you made one edit. So we're going to correct that, that you were present. So with that edit, I would take a motion to approve the minutes. A motion to approve? I'll take that as a second. Yep. And all in favor? All in favor. Great. Well, so then what I'm going to do, Jen, if you don't mind, is pull up what the legislation says that we need to report on. And we're going to take these issues kind of one at a time, but I'll just pull it up just so you can get a general sense of what we need to discuss today. So honor before January 15th, we need to submit a report to the General Assembly. This first one we don't need to discuss as an exploratory subcommittee. This is really about kind of another project that we're working on with some state agencies and stakeholders. But the second one and kind of third one are tied into each other. We're supposed to look at curbside pickup, online ordering and curbside pickup. We're supposed to look at different models of delivery and the advantages and disadvantages of each. And then under sub three, you can see make a recommendation about adding additional license types, including cooperative licenses, delivery licenses, and special event licenses. So we'll talk about all of those license types. And this next one sub four, whether cannabis and cannabis products have a minimum amount of cannabidiol to aid the prevention of cannabis induced psychosis. And hopefully people that are smarter than I can kind of walk through why that might be important. And then recommendations around the display, the sale of cannabis paraphernalia that's sold by non licensed kind of retail or integrated licenses, licensees. So I think that's the scope of what we need to discuss today. And again, I'm not going to put you on the spot to take specific votes. I think what's most helpful for the board is to hear the parameters of the discussion. I know the current dispensaries have experience in online ordering and delivery. We have Jen from VS Strategies here. She's the former cannabis commissioner from Massachusetts. She has some of these license types and has experience with this. So I'm trying to think what makes the most sense. Jen, do we want to kind of maybe start with online ordering and delivery? Yeah, why don't we just take them one by one? Because I think really the context we have to really discuss this in is what do you see as the vision of the legalized market in Vermont? When you think of legalized adult use cannabis, forget the building parts of it. What do you see as the end result? And so if we take these one by one, online ordering, delivery, CBD, all of that, we'll be able to have a better understanding, which will give the board a little bit of direction. Sorry, we're taking care of that here. Just so everyone's clear, we don't normally live stream these events, but now that we're kind of not holding six or seven of these a day twice a week, we are going to start live streaming these meetings. So we'll probably have to set aside just a little bit additional time for public comment. But yeah, no, that's helpful context. As I mentioned, the current dispensaries allow for delivery. They allow for curbside and online sales. Certainly just as a general point, we have an opt in system for our towns, meaning that not every town is going to be allowed to have a retail location. And while they are fairly well geographically dispersed, the towns that have opted in currently, I think delivery really adds the accessibility of cannabis in towns that maybe have not opted in. But the complexity really comes into how do you do this without totally cannibalizing a retail license type? Because if someone doesn't have to have a brick-and-mortar store and can kind of be a wholesaler in a delivery, have a delivery license, that could really make a retail license not as, it would drive sales away from the kind of people that have made the investments into the brick-and-mortar stores. Again, Nodder, go ahead. I appreciate you making the distinction, James. I think, though, that a lot of marketing retail is being done, and it's going to be done online through different online platforms and apps on telephones, especially moving into the future. And I think COVID really pushed that. Ignoring retail shops. On the other hand, there are also people who enjoy the experience of walking down town, protecting out different shops and doing that sort of touristy experience. And I think that kind of speaks to the idea of us trying to create this craft marketplace with different artisanal cannabis products. So, thanks for that. I guess I should take one step back. I kind of am presupposing that we're going to recommend a delivery license. Is that just the general kind of consensus of the group? Okay. Yes. Yeah. Okay. All right. Well then, I don't know the order that people popped up, but Stephanie, do you want to go ahead? I just wanted to back up. I have a clarifying question. So the opt-in for retail at the municipal level would not apply to online retail and delivery sales. Is that a true statement? Yes. I mean, I guess if we called a delivery license a tier of retail, then you couldn't have a person who has kind of a warehouse with a delivery license in that town potentially. But if we had a separate license type that was not kind of tied to, because the question for towns is whether they want to have a retail establishment in their town. So I think if the sale is happening, you know, I think the sale is happening at someone's doorstep or online, that I think that the opt-in opt-out wouldn't apply to delivery. As long as there's language that allows for delivery in any community, it's really the point of sale to retail spot. Chris, do you want to jump in? Yeah. I was just going to say, you kind of think it's out of my mouth, but you know, I recommend delivery to support towns that opt-out of retail. I also think it's an opportunity to get a license that the hurdle financially is going to be a lot less than some of the other licenses. And, you know, thirdly, once the program's up and running, I don't really see delivery cannibalizing retail. I haven't seen it in other states. And, you know, I think when you come to Vermont, a lot of tourists are going to, and local residents, you know, it's like getting pizza delivered to your house first going out to a restaurant. Like, you know, there's an experience, there's an education, there's an interaction between you and the staff at the dispensary. People that are aficionados or cannabis enthusiasts want to go talk to people that are, you know, similar to like a restaurant when you talk to somebody that understands the wine list and can pair wines. I mean, there is that sort of, you know, aesthetic to the dispensary that you wouldn't get at delivery. And then the flip side too is I think with a lot of our tourism and people staying in hotels and, you know, sometimes rural or obscure areas is another reason to absolutely support delivery. Mr. Chairman, the one question that I would ask is are we making the distinction between delivery from a retail establishment versus a wholesaler? That was my next question. Because if you allow the delivery from a wholesaler, then that's going to cut out the retail part of this business, which you're licensing. So Jen, what does Massachusetts do? So there are two types of delivery licenses. One, we have a wholesale license where we have the courier license, which is where someone delivers from the dispensary. There's a little bit of pushback saying that people didn't want to work for the dispensary. They wanted to be able to have their own business. So we do have a wholesale license, but you have to have security and safety in a building. You have to have the cars to meet a certain standard and the like so that there are two different types of courier in the wholesale. The biggest concern that I've heard from the smaller operators is that Amazon or someone like an Amazon is going to come in and buy up all the wholesalers and then you're just going to have a big monopoly on it. But there are some people who are very happy being a courier service from the delivery, from the retail establishments to wherever they're delivering. So we have both because we had pushback. Okay. Jim, do you want to jump in? Yeah, just quickly, I do want to just second on what Chris said about, you know, it is definitely an access point, I think, for people who want to be in this business and get a license and, you know, not deal with the hurdles of a brick and mortar location. Number one, you know, and obviously during the pandemic, which I think, you know, a lot of the shopping habits from during the pandemic are here to stay for at least a while. In the medical dispensary certainly proved out that, you know, delivery curbside pickup, all those things were effective and worked well. You know, and I think that the other thing is, is that, you know, there's a push by this board to make sure that the alternate markets are brought in to this new adult use marketplace. And there are a lot of businesses that exist now that are delivery based that are occurring through social media that are in the alternative market that a reasonably priced out license, I think, will bring those people in and that will benefit everybody. I think not tourists, locals who prefer buying that way will keep buying that way unless there's a license created for it. So that's that's mostly what I wanted to add in. Well said. Make, do you want to make a comment or join? Yeah, actually, the question for Jen in Massachusetts, if a delivery service is delivering from a wholesaler, who is responsible for processing payment? Does that fall to the wholesaler or does that fall within the delivery license? So they have the third party online platform that we have and it would that platform is tied, I believe, to the wholesaler. And what happens is that you would put the online order in and then the delivery person who has the product because they also that's another piece I should probably mention they also have to make sure that there's security for the product if there's product overnight. So that would work that way. But I also should tell you that there are limitations in Massachusetts you cannot deliver to hotels or Airbnbs or dorm rooms or parks and campgrounds things of that nature. You've got to deliver to people's home residences. So does that then come part of the wholesaler license that they can adopt kind of this retail aspect that allows for them to do delivery? It does. And then there's a whole set of regulations which I can get to you that we wrote surrounding the wholesaler license and the compliance issues and what they must do. And third party platforms can't even have a controlling interest in the wholesaler license. So it's a very specific license and we have a lot of restrictions that go into it. Essentially you are brick and mortar. And what happens is that was part of I think that was part of our social equity program. So for the first three years you have to be a social equity applicant to obtain a license for the delivery and the wholesale license. And after three years the commission has the authority to review and see if it's been effective and if that exclusivity has to be extended. And when you say my apologies in essence brick and mortar you're referring to wholesale that license is essentially a brick and mortar license for delivery. The wholesale delivery. Yes. Because it's called a wholesale delivery license. Okay. But they're there both the courier and the wholesaler both spelled out in the regulations as distinctive types of delivery. And can that courier then work you know say for a retail dispensary can they also deliver for them or are they only allowed to deliver for that one wholesaler thing. The couriers can deliver from the dispensaries. The wholesale retail can deliver from the wholesalers. I see. So the contracts have to be there. Okay. But Eric. Yeah, I'm I'm struggling a little bit. I do agree that this is necessary to invite the markets that already exist underneath regulated entity or be regulated entities. But to me it feels like this is a retail license. I don't know about other other folks. And then if it is a retail license. How do we get around the local zoning component? Not get around but well I agree the internal legislature was storefronts get locally zoned. But this this would be a retail establishment without a storefront. You know I don't know the answer to that other than you know I would like to ask our tax department where they consider the point of sale being. You know if someone has a local option tax. And a per a resident of that municipality that has a local option tax is doing the purchasing from a read from a delivery company that's based in a place without a local option tax where does that does that local option tax apply. I think that's a noble question. Remember though they need an address. There still needs an address to house the cars for the vehicles. So that would have to clearly if we if we're saying this is a retail establishment that would have to be in a town that's opted in. But I don't think this the sale like where the person who's receiving goods necessarily has to be in an opt in town. Yeah I mean there's all these people who would have a eBay business at home who would fall into the same kind of gray area you know if I'm selling car parts and making some odd car part. I use my car to drive to FedEx or the post office to deliver. You know I'm not sure how. Realistic. Realistically your paperwork would come from the address that you're established at. When you're filing taxes you have to have an address when you're filing with the town you have with the cannabis board you have to have an address that would most likely be your point of sale. OK. And so then if you talk about local taxes or local option they would benefit from the percentage because that's the point of sale. So I believe our recommendation will be that this model be recommended. But subject to the opt in provisions because this is a retailer. This is a retail style license. Yes. Stephanie do you want to jump jump in. I was just it's it's not related to this specific vein of conversation but I was just thinking about in reading the proposed rules and the educational requirements necessary to be a retail for a brick and mortar retail employee to sell to somebody. There's a couple of requirements such as you know determining whether or not that person is sober and I'm not saying I don't know that I'm not quoting that. But I was just wondering and I'm sure in Massachusetts there's some you have rules that you recommend to actually navigate that kind of issue and I'm seeing Jen your head. So I just wanted to highlight it and I bet it's answered somewhere. So at any point in time at any given point in time any employee of any brick and mortar retail can deny sale to someone that they feel is impaired. So it would be the same thing if you get to the door and you're delivering and you feel that there's an impairment or you believe they're underage or you can't verify their ID. Then you take the product back and there should be a process in place as to what to do with that excess product because under our regulations you're only allowed to have a certain amount of money worth of product in your vehicle at one time. So any employee has the ability to deny the sale to somebody based upon a variety of issues. We took what goes on in brick and mortar and allowed that to happen with delivery because that's just a protection the state needs that's a protection the driver needs. I mean, you know you get the wrong person who says you sold to my family member and they were clearly impaired and couldn't you know authorize the the transaction and you have to think from that side as well. So yes. But also the consumer education part you can require that they have the consumer education materials and they have to deliver those along with the package. Essentially it's retail on meals. That's basically what it is. Jen, in Massachusetts, did they limit the number of delivery licenses per town or city or anything like that? The only license in Massachusetts that is limited is brick and mortar retail. And so you're allowed 20 so each city and town has a certain number of liquor licenses if they have any you're allowed 20% of that number to have retail in your community. And these licenses don't count towards those breaking essentially considered them non retail for this purpose because what happened is. We did retail last year right so you're coming in three years later because the first retail didn't open in Massachusetts till 2018. So we always say from 2018 on. Most communities so we have yes towns and no towns. It was based upon what the ballot question was so if your town voted 50.1% you were a yes town. It was 49.9% you were no town. So for our yes towns, a lot of them maxed out their retail in the early years. So that nobody in delivery was going to have an opportunity to be able to participate if they were in the wrong town, because everybody was maxing out their their numbers. So we did not include it in the retail numbers for that purpose. And with exclusivity to social equity. We also opened it up to people who may not have been able to if they were living in a no town and couldn't participate in the program. Jen, do you have any caps in Massachusetts that you know about how much inventory a retailer if they're tied to a wholesale license, how much inventory they're allowed to sell like anything like any caps in that sense. So our retail is based upon tears, and you have to prove that you sold 85% of your product within within the six months of your renewal to be able to keep that tier or go up. So it's not necessarily a cap it's you got to prove to us you sold what your tier level is. If you're vertically integrated if you have all three. Okay, if you're if you're a brick and mortar retail and you're, you know, contracting with a wholesaler, then that wholesaler is going to have to prove that they got rid of the product legally. 85% of that product so that they sold the two dispensaries. So it sort of has his own checks and balances. We're not so prescriptive in that we do, we are prescriptive in delivery and that I think it's $10,000 or something you're allowed to have a board that product at one time in the car so and you have to retrofit the vehicle and things like that and there's two drivers which people don't like because it cuts into the bottom line and the cost and all that. But again, we our system is really set up to have some of its own checks and balances so that the enforcement team and the inspectors aren't necessarily always having to do that. Did you get any lawsuits on the exclusivity period for social equity applicants. They have not as far as I know. I can imagine that the question is going to come in two years when the exclusivity ends and if the board decides to extend it. But again, so if you if you look at business as business and take out the fact that you're you're part of a cannabis business. They say it takes three years to figure out if you're going to make or break your business and so we thought the three year exclusivity we give people an opportunity to make or break their business. The one thing I never wanted to see as a commissioner was a business open up in two years later closed down because they couldn't function under the regulatory rules. And so we tried to make it as business friendly as possible for delivery. I should say that, you know, I was the only vote against delivery because I thought it was too soon in Massachusetts to do it. We were just still getting up and running. And then we were going to add this new license type that quickly. But from what I understand it's been working. And so we're going to see in two years just how many social equity participants are in the program. Do you have a sense of what sort of fee we should charge? And again, our fee proposal B is 5000 for a retail establishment, like a brick and mortar retail, and then 1000 for a wholesaler. So you can but I think it's going to determine are you letting anyone into the industry at the for the delivery licenses or are you going to use it as part of your social equity? Program because if you are, you should keep it on par with your social equity fees, the levels of fees that you have for social equity applicants. If not, you could easily come right under the wholesaler and and have a fee that would cover the costs. Are there are there downsides to that I'm not imagining of letting maybe a cultivator retail? I mean, sorry, a cultivator doing delivery, like getting a cultivation license and a delivery license. If you're doing that, and you cut out retail altogether. Then I mean, the only thing that they're not the question is that you if they're a cultivator, they only allow to deliver flower. Or are you going to let them contract with the manufacturer and deliver edibles or deliver other, you know, what other products that are going to be allowed in Vermont at that time? Okay. I think a lot of these questions, you know, exist already with, you know, food businesses that are retail food business versus selling, you know, pies from a stand at your farm. And or, you know, selling chicken to a retailer or having a person be able to come and buy a kind of chicken they like directly from the farmer. And, you know, my concern about this is, you know, especially coming through the medical oversight committee and that subcommittee is that, you know, we're talking about special licenses. And social equity applicants and, you know, protecting retail markets. And, you know, there's a situation in the medical program where we've had cultivators want to be able to sell directly to medical patients. And we've had a lot of, I'm not going to get into the language loopholes we've had, but, you know, I think there's real valid reasons. Cost being one of them to a medical patient, being able to get a certain strain that a grower can grow that would argue that those, you know, cultivators should be able to get a license, a small business license, and sell directly to a consumer, certainly in the case of medical patient, it would be a way to try to control costs for them. And that's a huge concern. I think it's a concern that we need to look at when we look at special licensing and carefully look at how social equity programs are going to work within the adult use program, and make sure that we're not looking past, you know, cost and barriers for medical patients being a social equity issue that couldn't be solved with special licensing or fees. I guess, too, one of the questions is what is your, what is going to be your requirements for product vehicles, office space? Are you going to allow, if it's not the courier type model from the, from the retail, are you going to allow product to remain in a building overnight? Are you going to require them to bring it back to the wholesaler where the vehicles have to be parked? Do they have to be secured, like the kind of fence or in a, you know, garage or something? Those are the types of things that are going to have to come with any type of non-retail directed delivery, because those are going to be added costs to the applicant or to the licensing. Yeah. Which might limit people who don't want to pay all that, because you're going to have to ensure the cars, you're going to ensure the building, you're going to have to ensure if you have product on the premises. There's a lot of costs that go into that piece, which is, I mean, we had the courier model, people didn't want that, so we added the other one, and the complaint was all the, what it was going to cost to have all of that. But it's still going to be less than a brick and mortar retail established. It absolutely will. And, you know, the point here is not to say that being in the cannabis business is an inexpensive business to be in. It's to provide a fair framework for people to get perhaps involved in the business at different scales. Absolutely. You might decide to be in a different business because of the costs as an individual, but still should have the opportunity. And I think that's why deciding whether or not it's exclusive for social equity or not is going to be important because that's going to dictate your fees. That's going to dictate the number of applicants, possibly that you're going to get in the first couple of years. That's going to dictate sort of the expectation of what that license type is going to look like. And quite frankly, you know, it might be interesting for people to have public comment of how many deliveries does a person think they can do in a day, given the fact that Vermont is Vermont. I mean, you know, we had people in Massachusetts saying, I'm never going to get out of Boston because I'm going to sit in traffic half the time. I can only do X number deliveries an hour. But if I go to the Berkshires, there's not as many people, but I might be able to do more deliveries and the like. That's going to limit the amount of product in the car. Well, just to be respectful of everyone's time and our agenda and the other items we have, do we have a general feeling about... So it sounds like there's consensus around delivery, but do we have a general feeling about the type of delivery, whether it could be tied to a wholesale license or whether it's strictly a courier model? I think both should be offered. I also recommend that we give social equity a head start with delivery for a certain amount of time. Anyone else feel similarly or differently? I like the idea of allowing growers as well, but I suppose that needs to be fully fleshed out. Yeah, I would agree. I think it needs to be fleshed out. But I think this is the place and the opportunity to provide access both from the business side as well as from the consumer side. And I really, I do think it's something to add into this discussion to look at the possibility that, you know, we've had hearings and things like that for social equity. And yet, you know, through committees I've been involved in, we have people speaking for thousands of registered medical patients and a lot of concern about cost and access. And we know as with any medication that people can't afford it. So I wonder if with all the consideration of, you know, social equity head starts and whatnot that we look at a way to provide either through licenses or co-ops or a fee on licenses, some way that would provide financial access to some of these other areas like medical patients as well. Thanks for that, Jim. Yeah, and we are looking to have kind of another category of kind of potential license holders that would be DEI, diversity, inclusivity and equity that would include some socio-economic criteria that folks that are lower income have similar access to these license types. So all right, well, can we just kind of knock off the online ordering for curbside? I mean, Meg, can I just ask if you've had any problems with this? I mean, this has been a huge benefit for folks during COVID particularly, right? Yeah, it's been great for folks who aren't comfortable coming in. It also streamlines the process for the dispensary employees. You know, they can focus on the folks who want to come in and have those kind of more in-depth conversations. And we have not had any issues to date. Jen, is there, Massachusetts allows this as well. Is there anything that we're kind of missing here or any kind of special considerations we should be thinking about? No, the one thing to remember is that online ordering and curbside delivery really came from the fact that our adult use establishments were shut down during COVID because they weren't deemed essential. And so once they were allowed to open, people were still a little nervous. And so we allowed the online delivery. And also, you know, you can really, Meg will tell you, you can time it that there's only so many cars in the parking lot or only so many people around. And then making sure that, you know, that your security is in the parking lot with your employees just because, again, it's new. It's, you know, and I know Vermont is more tolerant and things like that, but we didn't know what was going to happen in Massachusetts. And so we had a security piece of it as well. And it's been, it's worked out well for people. You still can't have people underage in a car. You still can't have things like that. And, you know, it's essentially taking your experience from the dispensary and putting it in the park. Does anyone on the subcommittee have any objections to online ordering and curbside delivery? Okay, well, then that's an easy one. So let's move on to additional license types. The first, we dealt with delivery, I think. The other two that are called out specifically are craft cooperative licenses and special event licenses. I have some thoughts on the special event license, but in the craft cooperative license, you know, Jen, you've looked at our rules pretty closely. I feel like you between you and Dan and the team over at BS. Do you see anything in our rules that would not allow a craft cooperative license? Do you need to create a special license type and special regulations around this? Well, the only piece I would think of is your definitions in the tiering levels, because this is not going to be on the tier schedule that you may have to define a craft cooperative. And then if you're going to limit the space of the participants or just the basics of it. But other than that, I don't see how you can't include it in the current rules. Stephanie? Can I get a little explanation about craft cooperative, like what that might mean? I'm sorry. Well, I, you know, to me, I'm not positive. There's obviously a number of cooperative models. There's the, you know, I think this is mostly looking towards the producer co-op where you either have a co-located space, which we've heard a lot about, where you have kind of multiple growers with shared kind of testing and processing equipment. Or it could be more kind of along the like dairy co-op where you have a lot of diversified farmers around the state that, you know, a truck comes around and picks up a wholesaler kind of comes around and picks up your products at harvest and brings it to a central location for processing, labeling, you know, potentially advertising, et cetera. So I think it's the producer co-op model, essentially. Okay. Including testing, like pooling resources for testing and yada, yada, yada. If they want to do testing on site, then yeah, I think that would be part of this as well. But I just don't see why, you know, we have a section of our law or our rules that allows for co-location. To me, you know, it caps the maximum aggregate canopy at what our highest tier is. So, you know, 25,000 square feet. So, you know, the summation of all these co-located cultivators can't exceed our highest tier. This is something similar to Massachusetts, I think, caps their co-location at 100,000 square feet. And, you know, I would think that maybe if it was kind of a disaggregated, you know, not co-located, but kind of more of the dairy co-op model or the kind of cabin model where there's a bunch of different farms, we might want to also cap the number of total canopy. I think that's really the only considerations that I can think of that we need to regulate. Great. Jim? You know, I mentioned again what I had mentioned before, the idea of a grower, this is, could be like a craft license, but a license being available for a grower to be able to grow for a medical patient. This is something that we, you know, I feel like we kick the can in our medical oversight to try to clean up the definition of caregivers versus growers. But I think it benefits craft growers as well as medical patients in terms of cost of access to perhaps create a regulatory environment for them to do business in. And then the question about whether a co-op, I'm not sure that the rules now wouldn't allow medical co-op of some kind to exist, although it might be a more patient focus, consumer focus co-op possibility or perhaps a non-profit co-op that could again help increase access and reduce costs. So I'm not sure whether that would be considered here. Can you flesh out the first idea just a little bit for us about having a specific cultivator license type that's strictly for medical patients? Yeah, well, I mean, you know, I think the issue that we had in the medical rules in the past that we currently do have are that, you know, the definition of any person can grow at home. A medical patient has a certain number of plants they can grow at home and they can also designate someone else to do it for them. It's not easy for a lot of people to do. And right now the definition, it can be a grower and the cultivators and the growers who work with medical patients, you know, a lot of them wanted that definition left the same because we were also asking for multiple caregivers to be available to a patient and instead, you know, we want to make sure that the growing is done, you know, for a medical patient under some regulatory environment just like it would through a dispensary. So I'm suggesting the possibility of a small craft license that allows a grower to work directly with a patient and agree to grow their, you know, the number of plants for the year. And this would allow, you know, perhaps a craft grower to increase their canopy by a small amount if they're growing for a medical patient. But, you know, I think that we're trying to cut this out in one area. And yet it's an important area, you know, because we don't know the research is leading in lots of directions that might say medical patients want certain strains that might not be grown within the adult use market or even the integrated license medical market. So there's a lot of push for growers to be able to connect directly with a patient. So the idea of creating a license here at the lowest, you know, tier possible, I would imagine would be a good idea. Does that clear it up a little? It does. Yeah, it does. We're really trying to grapple with how to ensure that there's a, you know, medical program in five years, you know, as adult use kind of comes online. And I think that certainly ties into that conversation. It does because I know that the other flip side of it is that you don't want to bypass the dispensaries either. But, you know, right now there is a provision to allow somebody to designate a grower for themselves. And I think it's worth looking at whether this would really heavily cannibalize that the market for the dispensaries, or whether it would actually do more to create affordable access for patients. Gary? Yeah, Jim, to me it sounds a little bit like almost consigned sales. I understand that. So those particular plants would only be grown for one particular patient? Does that ring true with what you were? Correct. Absolutely. This is not a blanket. I want to be a medical grower. I'm just going to grow a little bit. It's for contracted with a patient. And it just, what it does is it allows a regulatory oversight on, you know, small grow potential that could really benefit medical patients in a lot of ways. Like I said, financial access, but also strains, varieties, and it would benefit a small grower as well. So, just looking at the time, is everyone okay if we go over just by a little bit today? Does anyone have a hard stop? Can we? I do. You have a hard stop. Do we have a quorum that can stick around for just maybe an extra 10 or 15 minutes? Yes. Okay. Well, let's talk about special event licensing. You know, I think I've been having some conversations with some kind of stakeholders around the idea of special event licensing. I think that there is a path forward here. You know, obviously when you have a special event, there's highway safety concerns. I think they've mostly come into play. And the lack of a, you know, saliva test or roadside impairment test that really kind of make people nervous about this kind of thing. But I do think that there's a path forward. I'm happy to kind of discuss it, but not or want. We just take your time. Just one quick question. Could you lay out some examples of special events? I mean, the first thing that comes to my mind is a music festival, but I'm sure there's other types of events. Yeah, sure. I mean, the way that, you know, this is a, there's a certain amount of controversy around this, and I laid out some of the parameters. And I think if we're going to recommend this and if we're going to do it, we would have to start on a very small scale. And I'm not sure a music concert, like a concert would be the best venue to start with. I think one, one thing that you could start with is a wedding where you have a cash bar or an open bar. You could kind of around the corner outside of public view, kind of make sure their separation with odor have a sectioned off area where you could consume on site as well, consume cannabis. And I just use the wedding. It doesn't have to be a wedding, but it kind of like what makes people a little bit more comfortable about the wedding framework is that usually at weddings, it's you've got a place where people are staying potentially on site. Or there's usually some kind of busing or transportation plan or designated driver plan already. And I think a lot of people recognize that people that are going to weddings or to any event really are consuming. They're just doing it kind of in the woods or kind of around back. And so this would be an acknowledgement that this is happening already and we can put some guardrails around it to make sure that the folks have a safe place to consume. They're consuming a product that they bought in Vermont and paid taxes on and that it's just an acknowledgement that this is kind of it's a better scenario than what we have currently. I think it's along the same lines of disrupting the illicit market or kind of shifting it to a regulated space. So what I would suggest on this, the conversation that what I've been envisioning is a company could apply for what I would call a special event operator license. And so you're a company that specializes in hosting these special events. And then you could put on a certain number of, I think in the alcohol industry, you're allowed to put on four events in a six month period. If you're kind of an alcohol operator, I don't know that for sure. We can talk to Savon about that. But then, so let's just keep it in the context of a wedding. So you are a special event operator for weddings, for cannabis, open bar at Cannabis. And you have all the insurance, you have all the training and education, you can spot consumption, you over consumption, you know how to kind of look for impairment. You have all of the kind of flyers and educational material you need. Then you apply for event specific permit. And so that permit would be approved locally and by the board. It would have kind of a highway safety slash transportation plan. It would have a plan to ensure that the consumption area is out of public view. It would have kind of a gate check to make sure that no one under 21 is entering. And, you know, require all the kind of insurance and all the other kind of considerations that bartenders at weddings have to go through. And then, you know, it doesn't have to be a wedding. I think it's just easier to imagine this at a wedding. And then, you know, we would approve the permit and then the local town would approve the permit as well. And then, you know, all of the cannabis that's supplied at the consumption site is purchased here in Vermont. Taxes have been paid on it. You know, you could have an open bar so long as there's no like over consumption going on. But, you know, it just seems to kind of be in line with what we're supposed to be doing at the Cannabis Board, which is recognizing the reality of the situation in Vermont and trying to put some guard rails around it. So I don't know, that's my thought on special event. And then, of course, when you start thinking about Vermont Brewer's Fest, when you start thinking about these other types of events that are, you know, centered around alcohol, it seems like a bridge too far currently. But I think this is, if we can kind of demonstrate success, start small and figure out a way to kind of do this responsibly, that this special event permitting could expand in the future. And we could move towards on-site consumption, which really, when you think about it, is the only way that our tourists are legally allowed to consume is a place that's been licensed to do that. We don't have them currently. You know, we have a market that largely will be driven by tourists. I mean, I know that when you think about the demographics of Vermont versus our tourism demographics, consumers are going to be coming to Vermont to consume, and yet they can't consume in open spaces, public spaces. They can't consume in their hotel rooms. They can't consume in their vehicles. So really, we're saying, come to Vermont, purchase our cannabis, and then don't consume it in Vermont. Jim, do you want to jump in? Yeah. I mean, hey, just to back you up on that, that is absolutely what we'd be saying. And it is a ludicrous thing in other states where I've seen it create unintended spillover into the streets. I think Denver is a good example of just sort of a more messy street environment, bolder even more so, because in theory, all those spaces, hotels and whatnot are prohibited. I think with the special event, one thing that needs to be considered in the wedding model is that unlike alcohol, I think cannabis is consumed in different ways that are not as familiar to all parts of the public. For instance, people who will smoke it versus vaporize it versus eat it. And eating it, an edible might have on one person a way, way different effect and might be more likely for them to be something they'd be unfamiliar with. They might have never done it. So I think in looking at that kind of license, it's going to be important to look at a really fleshed out model of the kind of experience that a vendor would need to have going in. On one hand, I completely agree. People are going to do it at a wedding anyway. And this is a way to bring it out in the open and to give it some acknowledgment and therefore a little sense of guidance and control, which would be better for everybody. But I think it is more complex in a lot of ways than alcohol. And needs to be looked at in terms of, you know, do you have a license to let people smoke it versus are you going to serve edibles and all that. So even the wedding is complex. That being said, I really support the idea of it strongly, as well as special events. I think food related special events are happening already in the alternate market. Cannabis Thanksgiving's and Christmases and those events. It is better to put people all in one place and be able to monitor it. So that's one to consider as well. Special dinner club events and whatnot. Yeah. So the one sort of some of the details that I would can, I would ask if you're going to ask for special events. The one thing that you want to take a wedding, for example, is what happens with people who are under 21, because technically they can't go into dispensaries. So are they allowed at the wedding venue? Is there a place where someone's going to consume that has an HVAC system that prevents smoke from going into a room where someone who's under age might be. So are they going to a different venue on the property? Are they going, you know, going someplace else? Does anyone need to purchase the cannabis on site themselves? Or does the vendor take the liability of the amount of cannabis being provided because I know under Massachusetts law, you're only allowed so much per day to be purchased. So do you have limits that that then need to be adhered to? And is your training different? So are they going to be trained the same in the but tender to identify over consumption, to identify the difference in, you know, understand what the product is? Bar tenders can probably tell you what kind of beers are on tap, but they're not going to really tell you much of anything else about what the products are that they have. I mean, they can tell you what kind of vodka they have and that's it. Those are the types of details that you have to flesh out if you're going to allow event licenses. And the place that I might start is what do you do for alcohol, one day alcohol licenses? What do you do for event licenses for someone trying to get an alcohol permit for the day? Is there tips training? Is there this training? Is there that, you know, those types of things might have to come into consideration. Given the fact that you have to adhere to the public safety, public health of the citizens of Vermont. Yeah. I hear you on all those things. That's why this is not without controversy. That's why it kind of got kicked over to us to discuss as opposed to being debated in the legislature. Chris? I just, someone that's done live events in the state for almost 20 years, you know, you really, DLC is extremely thorough with certification of bartenders serving people, even at a private event. You know, there's a whole list of applications and certifications that come with the ability to cater alcohol at events like this. And, you know, just to lay it out in black and white, like how you started this whole conversation, James, it has to happen. I mean, you can have one regulated product in the state that in a private event is just a free for all, while the person pouring the alcohol is adhering to these very strict rules. I mean, it just doesn't, it's too much of a contradiction. Yeah. I think this is a topic that deserves further discussion. I think maybe a more specific proposal that I can put in front of this subcommittee and eventually the full advisory committee before we can really recommend this because I agree with all the concerns I've heard, but I think it, it makes absolute sense. I mean, I've lived this life for 20 years and it's been really challenging and difficult with all the rules and regulations, but, you know, when you look at it from 10,000 feet, it's very, very smart and it works. And, you know, I'll take a look or talk to you further about any of this. You know, I just, I see it, I see it working successfully. I don't think it will be that much heavy lifting. And I think you can model it on with the rules and regulations and the training of the servers, very similar to the catering licenses that the DLC will issue. I agree with Chris. I think if you can, if you can line it up with that, and then you can look inside the cannabis rules to see their limits on possession, I mean, or purchase. Are you going to require the purchasing on property? Almost like you'd have a cash bar or something like that. Are you going to require that they only buy what they consume on the property? Sort of like you can't take the beer with you in the car on the way home. If you look at the rules and then look at the catering licenses, you might be able to find a lot of similarities that it wouldn't be such a heavy lift to create some rules around it. Yeah. Great. Well, why don't we move on very quickly and Chris, if you jump off, we all know, as you have a hard stop. Bye everybody. Last two that we need to deal with quickly is whether cannabis and cannabis products should have a minimum amount of cannabidiol to aid in the prevention of cannabis induced psychosis. Do we have anyone that can kind of help us understand why we would require this? Jen, are you, did this come up in Massachusetts at all? It did, but there was a report done, I believe, recently by the commission that shows there's not enough evidence or research to prove that you absolutely necessarily have to do this. So a lot of the concerns when it comes to composition of anything is that there's, because of the federal status, there's a lot of research that hasn't been done or hasn't been vetted. So you tend to go down a slippery slope and honestly, for now, I'm not sure that this would even be an issue. Does anyone feel differently from Jen? I mean, I would say the one thing in Massachusetts is that we were very science, scientific base, we were very data driven. And, you know, poor Dr. Johnson, who's the director of research at the commission, I think the first paragraph of every one of her reports is like, there still needs to be data, there still needs to be research. And so a lot of people are doing literature reviews, but you got to be careful of who's writing that literature. And so I'd be very careful to make any strong statements until the researchers is there. Okay, I think both sides of this issue have a lot of questions. A, cannabis-induced psychosis and studying that and B, the effect of cannabidiol in mitigating the effects of THC and other THC compounds. I mean, it's one of those things that's very anecdotally talked about, but I don't know that it's that heavily researched. The one thing I'll tell you is that my background is in mental health, which not many people know. It's dangerous to make very generalized strong statements about any type of mental health disorder or mental health functioning of any type of product. Who's to say that you're not going to have liver damage from alcoholism? Who's to say that someone's not going to suffer a psychosis from cannabis? Or they're going to, something else is going to happen with any type of prescribed drug to a person. It's, as a government agency, I think that you have to be cautious when making strong statements about anything. Yes, nobody wants someone to suffer from psychosis. Anyone to suffer from hyperemesis syndrome, nobody wants anyone to go through cannabis use disorder. No one wants to go through substance use disorder. But the reality is that not everybody in the collective population is going to be affected in the same way, which is why your consumer education piece can be so strong, because you're educating consumers to make the decisions based upon what they know of their own bodies. Yeah. Thanks for that. So the last one, just recommendations regarding the display and sale of cannabis related paraphernalia that's sold by persons who are not licensees. I guess what this is going at is, you know, can the liquor store have sell glass pipes or can the general store sell a bomb. I just don't, I think that that's what the legislature is asking us to talk about. Does anyone feel strongly about this? Honestly, I would check. I think they're able to be sold on the tobacco right now. I don't think it's specifically under cannabis. So anyone who's selling paraphernalia now, it can be allowed because it's not actually the cannabis product that they're being sold legally in stores throughout the state. I'm not sure you need to regulate this as a body. Okay. I think the liquor control, don't they have requirements for sale of paraphernalia broadly already? Or I would at least check in to see if they do. Right. I would also suggest that you don't require folks who are selling paraphernalia to also get the tobacco license if they're just a dispensary. Okay. So kind of the opposite of what they're saying right now is currently sold under a tobacco license. Well, we should ensure that these are included under our retail license. The paraphernalia can be included under retail license and the retail establishment doesn't necessarily need a tobacco license to sell the vaporizers. Is everyone okay with that? Okay. I think that'll be our recommendation then on that. So that wraps up what we have to do today. I think that again, that the special event operator permit, special event licenses requires a little bit more thought. I don't want to force you all into another meeting, especially during the holidays. This report is due on January 15th. I think what it makes sense for me to do is just send around a more specific kind of consolidation of our conversation. And if we want to have another meeting about it, just be careful about that kind of reply alls when I send it around, because that kind of triggers open meetings. But I'll send it around and maybe we can just talk about it individually with me and whether or not we want to recommend this. And then I'd like to get, you know, all of these recommendations in front of the full advisory committee before January 15th, but, you know, recognizing that this is a really, you know, people have a lot of competing priorities right now. But that's the plan. Thank you for meeting today. We do have a public comment that we need to do. So if we're going to start with the people that joined us in the room. Does anyone? No. Okay. Then why don't we just go, if you join via the link, we'll go in the order that you raise your virtual hands. No, I do see. So Eli is up first. Greenbridge Consulting. Eli. Thank you all for letting me speak. Just wanted to hop in on the events portion. I had submitted some written testimony to the board about a proposal for an events permit based on a liquor control model. That was pretty specific and discussed with the department. So some of that groundwork has been done. There's also a change.org petition out there with over 400 electronic signatures. So I just wanted to just wanted to point to those materials being out there. Appreciate a lot has been talked about there with it. And I think I think there's a great opportunity. So I'll leave it at that and happy to share that that proposal again of that PowerPoint. I just want to make sure that I was on the record. Thanks, Eli. Fran? Hello. Thank you for having us in this meeting today. I learned a lot. I want to thank you. It was very good. Speaking up really specifically to support Jim's proposal for the medical license for caregivers that he has put out today. He's essential. I'm a medical patient. I work with other medical patients and he's right there. So I'll leave it at that and thank you for teaching me so much today. Thanks for joining us. Anyone else that joined by the link or the phone? If you're joined by phone, hit star six to unmute yourself. No, it's joined by phone. Okay. Well, if there's no one else, then I will adjourn the meeting. Thank you all very much and I'll just follow up over email.