 So my name is James Pepper. I'm the chair of the Remind Cannabis Control Board. It is Wednesday, November 16th. It's one o'clock and I call this meeting in order. A few comments before we get started. A note to all licensees. Please review the tax guidance on our website. We link to a handy cannabis tax guide that the Department of Tax has prepared for us. This guide contains step-by-step instructions on how to collect, itemize, and remit all necessary taxes including the excise tax, the sales tax, if applicable, a local option tax, and the tobacco products tax. When it comes to remittance, the tax department does not accept cash payments of taxes. Meaning if you're a retailer, you have to have a bank account. Moving forward, we will not be accepting a cash management plan as an alternative to a bank account for retailers. We have a number of financial institutions listed on our website that are willing to bank cannabis funds. And those are not the only ones. Those are the ones that reached out to us. And it's not as challenging as you might think to get a bank account for cannabis businesses. There is no excuse for not properly collecting taxes. If you want to run a business, you need to know how to pay your taxes. For any questions about the collection or payment of taxes, you can call the tax department directly. Our number is on our website, but it's in the guide. But it's also 802-828-2551. Or the email address is tax.businessfmont.gov. On a related note, we are going to be bringing back our networking events to do deeper dives into issues that we feel need some attention. Things like insurance requirements, positive impact area, license renewals. So I'll be sure to add a one in event specific to tax collection and payment. So stay tuned for more information on this in the coming weeks. Just a general reminder, please do not verbally harass the staff here either or email or the phone or text. We have one of the most competent teams in state government, and they've moved mountains to get us where we are today. But the truth is, we are understaffed, and there is a backlog in a few areas. This is a very predictable backlog, I would add, though, given what our job is, opening an entirely new industry in a very short window. Anyone who didn't expect delays wasn't paying attention, either to what was going on in Vermont or in the rollout of every other adult use market in the country. Anyone who's frustrated that we, I don't know, didn't demand a bigger staff or ignore our statutory deadlines or whatever, feel free to email me directly, James.pepper at vermont.gov, but do not take out your frustrations on our licensing team. They are systematically attacking the backlog and helping applicants resolve their issues. Verbally harassing them or emailing them 12 times a day does not magically speed up the process. Speaking of staff, we do have a new job posted. It's for our operations director. The posting for that as well as the application portal are available through the Vermont Human Resources website. And finally, just a quick reminder that there is no board meeting next week, but our staff is streaming a live Q&A session focused on testing, inventory tracking, and product registration. That's on Monday, the 21st at 7 p.m. The link to join is posted on our website. So please bring all your questions to that session, and we'll do our best to get your answers in real time. Other than that, just need to approve the minutes from our meeting on the 9th. You guys had a chance to look at those? Yep. Right. Is there a motion to approve that we approve the minutes from November 9th? Okay. Is there a second? Second. All in favor? All right. Next on the agenda is to review our packaging guidance. Kyle, will you take us through that? Sure. Bren asked us to review packaging guidance. I know that we just mentioned that we're going to be having a Q&A on Monday. I suspect there might be packaging questions, and I know Gary and Lauren will be equipped to answer packaging questions if there are. So it kind of made sense to go over this guidance again. Again, this guidance has been up on our website since July. And I think I feel that more packaging questions than a lot of other subjects, even though that there's guidance for it out there. I recognize that there is constant confusion. I think we're getting to a better place. But please remember that our public comment session at the end of this meeting isn't the appropriate time to ask your questions. But if you have questions that arise as we kind of work through a couple web pages that I have pulled up, please save those questions. For Monday and Nellie can correct me if I'm wrong. I think that we're asking for questions ahead of time if you have them by the end of the day tomorrow. Okay. So guidance on packaging has been out since July. I really just want to go over the general rules. And as Julie did last week, I'm just going to go ahead and read. Before you understand these rules, please refer to the definition section below. And I'm going to pull up another guidance document once we get to those definitions, because it can really help people understand specifically where you need to have child deterrent packaging and where you need to have child resistant packaging and what child resistant packaging actually is. So in general packaging that is intended for consumer purchase at a retail locations shall be reusable and shall not be plastic. Examples of reusable non plastic packaging materials include glass tin cardboard and bamboo. This does not mean a vinyl sticker looking like bamboo over a plastic cap, which we have seen. And you know, things like back it back to us people. Come on. This rule does not apply to packaging used solely for the transfer of cannabis or cannabis product between licensees. So let's imagine the chairman calling pepper for this hypothetical is a grower. I'm a retailer. You're giving me a couple pounds. Really awesome cannabis that I'm going to take possession of that does not need to be in non plastic packaging. You can use vacuum sealed plastic bags. And we just recognize that in bulk, this is even harder to pull off. So we're focused strictly on the point of sale with which a consumer is purchasing something. Consumer packaging for cannabis, meaning flour or pre rolls needs to meet our child deterrent definition, which I'm going to go down to right here. It means tear resistant packaging that can be sealed in a manner that would deter children under five years of age from easily accessing the contents of the package within a reasonable time and not difficult for adults to use properly. One of the big things that we've been telling folks is yes, you can use a suction top, you can use a cork top, but put a sticker over it and not your cheap one cent sticker. We're thinking something that can actually, you know, present challenges to somebody who is under five from actually twisting that. I know that that's a little ambiguous, but I've seen a lot of folks succeed in understanding what that means. Other states I know in Canada, they have a tax sticker over the package that once it's broken, you know, it means that that product has been sold. So think think along those lines. Consumer packaging for cannabis products must be opaque and child resistant. Word opaque means not clear glass. You can have some, you know, it's hard to use a description without the word opaque, but but misty looking glass and I don't know anybody have a better word for that around the table. See, see, well see through would imply that it's clear, see through, non see through. Okay, translucent. We understand that that's a little bit challenging as well. But even if it's glass that has a gosh, I'm really struggling with word here. It's not completely clear. That means look up the definition of opaque. If I need to pull that definition up on Google, we can wander there, but I think everybody here hopefully can work the Google machine, at least half as well as we can. Packages and containers that hold cannabis and cannabis products must protect those items from contamination and must not expose the cannabis and cannabis products to any toxic or harmful substance. Honestly, this means just be careful what you're putting your your pack your cannabis in. There's a lot of great companies out there. There's your Walmart variety, Amazon, Alibaba varieties of packaging. It's also sustainable packaging options. Both of those sell non plastic options. But you know, let's let's make sure that we're not putting any other toxic substances into these vessels that are containing cannabis or cannabis products. I want to go ahead and read our definition of plastic. Because I get so many questions. I know our licensing team does as well about certain buzzwords that are present in this kind of space. And you know, it's kind of similar to the word sustainability. It can mean it's a catch all phrase that means a little bit something different to everybody. And I'm going to focus on the word biodegradability because the word biodegradability is a marketing word that, you know, doesn't always mean as it's what it means as it's conveyed to the average consumer. Just because you throw something out on the side of the road doesn't mean it's going to degrade like a banana peel. So plastic, for the, for the purposes of our rules, means a synthetic material made from linking monomers through a chemical reaction to create a polymer chain that could be molded or extruded at high heat into various solid forms that retain their defined shapes during their life cycle and after disposal, including materials derived from either petroleum or a biologically based polymer such as corn or other plant sources. And look, when we went in this direction, I've said this many times, both on the record and off the record, in public setting and to folks that contact me privately about why we chose to include the biologically based polymer portion of this. And that's because all polymers are not created equal. They all don't carry the same functionality. Some need to be put into industrial composting facilities in order to actually achieve a lot of the biodegradability or compostability claims that are associated with those specific polymers. For instance, and full disclosure, I used to represent corn based bioplastics in DC. I know that they do not break down any differently in a landfill setting than a traditional plastic. They're both going to sit there for hundreds of years. There's not you can't tell the difference because they need to be in an aerobic break an aerobic composting situation where air can't whereas air is pumped in from the bottom and you know, they're constantly at a specific temperature. It's they don't break down if they're just in a free trash pile in a landfill. That's one of the reasons why we've been so specific on the polymers, the biopolymers that we have been, you know, get granted waivers to PHA, the humidity lids. I know a lot of folks are using those. One of the reasons we went in that direction is because they will break down in a landfill a lot quicker than other polymers will. They don't need industrial composting conditions in order to break down. And if industrial composting becomes a bigger thing in Vermont and the R 11 industrial composters decide that they are they are so inclined to take bioplastics into their composting facilities, I would love to revisit this because I think a lot of biopolymers out there are really doing great things. But we're focusing on Vermont specific waste issues, one being we have one landfill that's approaching the end of its life. There's been a lot of news lately around PFAS and how we're going to manage a lot of those issues as a state moving forward. I don't want any of us to be contributing to any of those issues. And we think this is one of the best ways right now that we can stay out of that bullseye and keep that bullseye of everybody who's listening and not listening back because we don't want to be a waste problem. So I'm going to pivot after that field. Thank you for bearing with me to this friendly one pager that is on our website. I'll show you where it's on our website in just a moment. So cannabis as I said, flour and pre rolls without any additives are cannabis and must be packaged in child deterrent packaging. Opacity is not required. They can be in a clear two. They can be in clear glass. Cannabis products, edibles and concentrates including dip pre rolls are cannabis products. They need to be an opaque, non clear and child resistant packaging. Please keep in mind that child resistance, you and I and all of us don't get to decide what is child resistant. It is a federally defined term. There's a standard behind it. Packaging must meet criteria set by the Consumer Product Safety Commission before it is labeled child resistant. That's at the federal level. Child resistant packaging must be significantly difficult for a child under five to open with a reasonable amount of time, but not difficult for adults to open. Packaging must maintain resistance across multiple openings. And this is important to remember. Let's say you have your your packaging. 10 five milligram gummies in a package that child resistant top cannot only be child resistant for the first use. It has to maintain that resistance for all 10 all servings that are in there. So so 10 times it has to maintain that child resistance. Child resistance is not child proof. Some children may be able able to open resistant packaging. So please, you know, if you have one of those those children that are getting into everything, I was probably one of those myself growing up. Lock it up. The questions. Please contact us before you buy something. Please contact us. I want to be clear, though, if you ask our opinion about something and you have not put forth a waiver, it doesn't matter if I say, and I think there's better options out there. It is a no until it is a yes. It is not a yes until it is a no. So if you ask us and we don't definitively say no, we need to do we need to do more research. This may work. I don't know yet. I need to get more specifications, spec sheets on what exactly this biopolymer is. Just because something's biodegradable doesn't mean it fits Vermont's unique waste stream, our programs, how we deal with waste in Vermont. I know a lot of folks are asking me lately about recyclable plastic. We have made a very small number of waivers predominantly for concentrates for for dads. That's because there's not a lot of options out there other than some plastic tops. But our global recycling systems are failing. I think 4% of all recyclable products in the world were actually recycled last year. And that's not any recyclers fault. That's not the state's fault. That's not even well, you know, China takes a lot of the world's plastic. So we don't need to go into that kind of geopolitical conversation about recycling. But it's one of the reasons why we focus so much on landfill when it comes to end of life and have less faith in the end of life from our cycling perspective. So find all this information. Let's back up to our homepage. So here's our homepage. I know it's pretty wordy. That's ccb.vermont.gov. Correct. And we're saddled with the programs that are and tools that are afforded to us by the state. So bear with us. We hit on guidance. We have packaging materials guidance. This is that first document that I just showed everybody. We have the one pager that I showed you. We have the waiver request and I'll go here quickly. This is how you and we've had over 90 of these. And so when folks ask the day after they submit something, it's kind of like our licensing, you know, we take the time to do the research and there are still some outstanding, you know, waiver requests in our queue that are month old because we're taking the time to actually suss out and vet specific polymers. And I'm following up with, you know, some other contacts in the biopolymer space to kind of understand truly how things are breaking down. But I want to turn our attention to our proof packaging waivers because oftentimes we will still get waivers for stuff that have already been approved. Keep in mind we have so we have categorical waivers here. Let's just start at the top and I know this is small. Hopefully up my eyes can read it. Following packaging options have been approved by the board. A licensee may seek a waiver to the CCB's prohibition on plastic packaging if it can demonstrate hardship in securing non-plastic packaging for any one of the following reasons. Unavailability of non-plastic packaging. Inability to achieve child resistance or if necessary to proceed, necessary to preserve shelf life stability, prevent contamination of cannabis or cannabis products or avoid exposure of cannabis and cannabis products to toxic or harmful substances. Thank you. In order to be approved, the licensee must submit a waiver form for this particular type of type of packaging seeking approval to the board. Again, emailing me asking me my thoughts, I might give you them. But unless you've gotten through the official waiver process, it's all speculative. Once a waiver is granted, the waiver applies to all licensees. So we've had multiple waivers for the same product. Some might be successful, some might not. And that's because our waiver matrix, how we look at things, it's not just about the actual product. It's about a number of different things. From your sustainable practices to how you're going to offset plastic in our space. So some some might be accepted. Others may be lacking in a couple areas. But it doesn't matter if it's approved because it'll apply to you anyways. So we have some categorical waivers. And again, these have a timeframe on them. So don't buy 100,000 units of something because there's going to be a time well they where they may not be allowed in our in our through our regulations. Any longer. And again, a lot of people have been messaging me asking if we're gonna, you know, take our foot off the gas here. And I can tell you that that is not in our plans. This is something that will be here and it's here to stay. I know a lot of folks are not going to be happy with that. But you know, I think we're actually, despite some thoughts out there, we're actually making a difference. People are paying attention. States are paying attention. And so are packaging companies. So glass. So our first waiver glass or other non plastic jars with a metal wood or bamboo lids that utilize a rubber plastic or rubber or plastic gasket in the lid that supplies the screw top and clamp latch top options. This is for shelf life stability. We understand that a lot of folks, you know, need certain, you know, plastic is necessary in some places, unfortunately, in order to, to ensure that a safe, non contaminated product actually makes its way to consumers. So we also have a column here child resistant or child deterrent. And I want folks to pay special attention to that. Because I get a lot of requests, a lot of saying, Hey, Kyle, what do you think about this? If it's cannabis product, it needs to be in child resistant packaging, it cannot be in child deterrent packaging alone. So we have a list here that should signal whether or not this waiver applies to one if it does, there's some other, you know, there's some more basic issues where like, for instance, our next one, glass or ceramic vape cartridges that vape cartridge in and of itself would not satisfy the child resistant standard, you still need other packaging around that vape cartridge in order to be child deterrent or child resistant. Plastic or rubber dropper bottle tops, there's no way around that, you know, I think that's present in just about every whether it's a tincture, whether it's filtering medicine, whether it's eye drops, maybe that's a commonly used way on that all things been solved yet. Bone pressure sealed bottle cap liners, again, we want to ensure that folks can can maintain shelf life stability. Folks may feel like we're unreasonable, but I promise you that we are not. Plastic or rubber push buttons for the purposes of ensuring child resistant on cannabis products only plastic push buttons for flower or pre rolls will not be considered compliant. This will meet our child resistant definition. Again, we made this waiver for one year to allow certain products to ensure a place on the market. I've seen folks, for instance, take a chocolate bar and put it into an otherwise cardboard box with a plastic push button that is designed for pre rolls, but that's that's not allowed here. But people are getting creative, people are finding ways and people are actually marketing themselves, you know, by being plastic free, which is amazing. And I want folks to take full advantage of that to the extent that they can. Last one, plastic bottle cap lids, these are approved for liquids only and may not be used for any other cannabis products. This is important as it tides back to this definition of child resistance. For every serving, it needs to be child. It needs to maintain that child resistant capability. So if you have a drink, it has 10 servings in it. Every sip you take, you need to screw it back on. Think about a Nyquil bottle, pepto-bismol bottle. You know, there's not really a good option other than, you know, the plastic options that are already out there. So those are categorical waivers, meaning you can you can purchase those from any company that you desire. There's some good ones out there. There's some, you know, ones that are focused on, you know, effectuating change out there. I don't I where we can, I try not to play favorites to a specific brand. As it relates to waivers granted to specific products, that's a little bit more challenging for us to do because not every company is working with the same bio polymers. Therefore, you know, we've, you know, we've done the glass dab applique applicator syringes. You know, this is more focused on the medical program. We wanted to make sure that folks that use RSO oil had that availability. Think about the plunger that goes into a syringe opaque sandup pouches from Elevate packaging. Elevate packaging is a brand that doesn't have a lot of experience, at least from my understanding in the cannabis space, but they are really forward thinking packaging company. They often package teas, coffee, other herbal blends. But I know a lot of folks are using these. That's great. But it's important to remember that their child deterrent. So you cannot package gummies in Elevate packaging bags. You just can't. They're not child deterrent. I've heard feedback from some that say how can they even, you know, come close to child resistance because they tear so easily. And it's because we've the only state in the country where you don't need child resistance for flowers. So the community lids, lots of people are using these, you know, concentrate on other products. They are child resistant. I know some folks are packaging flour with these lids. I would encourage you to think for different options before you purchase your next order of community co lids, because there are other options out there. But I still think PHA is one of these next gen biopolymers that's going to change the way we view plastic over the next 10 to 20 years. And big multi country organizations on the NASDAQ 500 are starting to invest in PHA, which is really cool. Safely Lock. Safely Lock actually has a whole part of their website that shows you which products are available and allowed to be used in Vermont. Their compostable bag carries similar breakdown qualities in a landfill. That bag is child resistant. They have that capability. I think you can actually buy a child deterrent or child resistant. So you could theoretically package gummies in Safely Lock's compostable bag. You cannot package gummies and elevate packaging's compostable bag. And then Santa packaging. I love Santa. I love what they stand for. I think we see eye on about 90, 95% of environmental policy issues. You know, they have some reclaimed ocean plastic lid. These would be child resistant. Ocean plastic is a wide world of understanding how in fact that plastic from the ocean is captured into these products. They have they have tracking trades programs for that similar to how folks do in the cannabis space. And I'm often in the way Santa does things and I'm confident in their ability to to think forward as it relates to packaging in the cannabis space. So that's all I got today. Again, I'm sure that I have invited questions from people listening. Please save those questions on Monday. Of course, we'd be happy to take any any comments during our public comment session. But for folks that think we're going to pivot away from this no plastic language. There's no plans to do that. And I think we're just about at a space where we've we've hit. We've made enough decisions for the market to actually find a path to market for a specific cannabis product that's out there. There's a couple more that we're considering, especially if they can be reused. So we're not completely done yet. There's no process to shut down our waiver request. You can always you can always make one, but we've made a number of decisions where we feel pretty confident that we can maintain this zero plastic, the spirit of the zero plastic regulation without preventing products from being on the shelves. All right. Any questions? Um, I have just one question about ocean plastic. Ocean plastic is still plastic, right? The reclaimed ocean years. What you were saying was that there are certain products that are approved or waived into our program. Is that right? That is correct. So there's only one. There's a specific size plastic lid. It's a 38-400 screw top. It's for concentrates. It's for gaps. And through our research, there was very limited ways to package cannabis concentrates other than with a plastic lid. Without, you know, there's metal options, but I heard, you know, there's some there's some contamination issues with metal and scraping, you know, a concentrate off of a metal lid and then inhaling it. You know, we felt that this was one area where we could extend a waiver to a plastic lid, but it's in the description. It's a very specific size that's been allowed. Not all Santa's lids are allowed, but the one for concentrate lids is. I hope that that is clear to folks listening. If not, ask us before you buy anything. Ask us. Thanks. All right. Um, brand, I think we'll turn things over for a licensure update. Here we have this week's register. Okay, so we will start as always with our medical cannabis program numbers. So last week, the ninth through the 15th, the medical program received just about 150 new patient applications or renewal applications, which is about double what we received in the prior week, the week before that, the numbers that you looked at in last week's register. About 112 patient cards were issued and for new caregiver applications were approved. So working our way through the medical program applications. I'll move on to our adult use license applications for this last week. So these numbers are current as of yesterday. The number of adult use cannabis establishment license, license applications is really slowing down quite a bit. In this last week, we've received 16 new applications for an employee ID card, and really only one new cannabis establishment license application. And that was for a mixed cultivation license. If you look carefully at the numbers, you'll see that there is one additional tier three manufacturing license, but that's actually not a new application, because that applicant originally applied for a different tier of manufacturing license. So that's really just an updated application. So this week, I think this is the first, the board only received one new license application. A number of new applications for employee ID cards, but only one application for a license. And the as the chair mentioned that the outset staff are really plowing through the backlog. We have 14 applications up for approval this week. And they are I think representative of every license type except for the wholesale license. We have five retailer applications up for approval. And we have five cultivation applications up for approval, and three manufacturing and one integrated license on the list for approval. I will move on to our location of retail licensees and applicants in the queue. This is our list that shows where in the state of Vermont, our retail licensees are located or our applicants for retail license are located. So it's a little bit of a forward looking picture of where what the distribution will be of our retail establishments. There are no new retail license applications in the queue of this last week. And the total here 53 is actually the same as last week last week, the number was 51, but it did not include our two integrated our one integrated licensee and our one integrated license applicant. So this list does include those two, those two businesses. So you'll see as as last week, there are seven the most densely the densest distribution is in Burlington. There are seven either licensee retail licensees or retail applicants in the Burlington area. Or in Burlington proper. So no, no growth here this week. I'll move on now to our the staff recommendations for a cannabis establishment license. And this is our list of applicants that have demonstrated that they've met all of the requirements that are set out in rule and in statute for cannabis establishment license. You have fire tower cannabis applying for an indoor tier one cultivation license. Monarch cultivation. Also applying for an indoor tier one cultivation license. The Empress 802 applying for a mixed tier one cultivation license. Vermont Patience Alliance applying for an integrated license. Vermont garage apocry, apocry, excuse me, and applying for a tier two manufacturing license. Papa's garden applying for a mixed tier one cultivation license. Right home ranch applying for a tier two manufacturing license. Northeast cannabis applying for a retail license. Ratu's cannabis supply applying for a retail license. Iron Grove organics applying for a retail license. ETG applying for a retail license. And Valley Meade dispensary applying for a retail license. For Clover Corp applying for a tier two mixed cultivation license. And Green Mountain scientific work applying for a tier three manufacturing license. So that is our group up for approval this week. Same number of license amendments in the queue. And then our social equity numbers are here. So we have 11 applicants that are applying for social equity status that determination of social equity status is still pending. You can see where they fall in the queue in this chart here. And we have one up for one social equity applicant that's up for status approval this week. And staff is recommending that the board approve social equity status for this applicant. Their submission number is 1303. And staff is recommending approval of social equity status because the Seattle this applicant needs the criteria for a social equity business applicant as defined in board rule. And that's your list for this week. Questions for Bryn. All right. Is there a motion to approve the staff recommendations. I move that the board except each of the recommendations for social equity status and licensing approval as presented to us by staff in this meeting. Second or second. All right. All in favor. All right. Great. All right then. Well why don't we move to public comment. We'll do the same way we always do. If you join by the link please raise your virtual hand if you'd like to make a comment. Once we get through those we'll shift to people that joined by a phone. You know. Excuse me. I hope everybody's having a great day. I just wanted to also add on to what Chair Pepper was saying about the taxes. He mentioned the big tax. That's also something you're all going to have to prepare for. That is still officially a thing even though hopefully we have a path to to having cannabis excluded from it. But that's all. Thank you. Thanks to you know. David. Yeah. I hope you can hear me all right. I'm in David Busby with Open THC. I had sent in a couple of questions to the compliance email address and I had even called in and didn't hear back from anyone and it is a question about inventory lot identifiers and perhaps that's the kind of thing that'll be covered on Monday. So maybe I'll just come back then. Thank you. Yeah. Thanks David. Noted and definitely join Monday and and we'll try to get back to you before then. Thanks. Jeremy. Yeah. Thank you so much for listening. I'm being here today. We really appreciate you. I just wanted to point out something that maybe not everybody thinks about and that's maybe the older population the population with arthritis that has a really hard time with packaging open and I am personally only 30 years old and have arthritis and it's very hard for me to open a lot of these packages. So I just ask you guys to kind of keep that in consideration as we navigate this very interesting market. Thank you so much for your time. Thanks Jeremy. Anyone else who joined by the link. Dave. Hey all. I'm just going back to your opening comments James and you know just I don't know share this with the folks out here on the call. You know I have a lot of contacts with a lot of members of your staff on a regular basis both as a licensee and as an attorney for you know a couple dozen other people and I've always found everyone on staff to be super responsive super professional super easy to work with helpful trying to make it easier for the rest of us. And so when I hear folks getting so frustrated with the delay that they are engaging in harassment or abusive behavior I just folks don't do this. It doesn't make you look professional. It doesn't make your application stand out better. It's going to hurt you in the end. Don't do it. It's dumb. Be nice. That's all. Thanks Dave. Anyone else who joined by the link. Eli. Hello. Thank you. Just a comment on the on the packaging. I think loud and clear on the on the hold the line message. You know however I do note that sustainability does also include us as small businesses being able to afford to stay in business and I know that Kyle's been very forthright you know about the research and clearly extremely diligent and you know personally invested in this quite a bit in the life cycle analysis but I don't know anybody else out there drives a diesel vehicle you know and has experienced the gas scope a gallon and you know a dollar and a half in the last few weeks because it is at some point unsustainable to ship all this glass all around the country all around the world for those of us who are having to buy it. So you know I think seems like things are evolving quickly and I appreciate all the efforts under Kyle but I would just know you know it'd be nice to know that you know there might be opportunities in the future to reconsider things you know whether that's through the waiver process and just kind of thinking about a little bit of flexibility because there are circumstances that are outside our control and that are affecting a lot of us here on the ground as we buy pallets and pallets worth of glass and you know hundreds of dollars in shipping fees so appreciate all the work that's been that's been done on that I say that you know sincerely you know but again I'll just reiterate that it is you know definitely an issue for small growers on the ground that amount of inventory so thank you. Thanks Eli. Alice. Hi I'd like to second the opinion of the person who just mentioned packaging and people with arthritis or disabilities that have problems opening the packages. I have this I usually ask pharmacy to supply my pills or my prescriptions in easy to open bottles and they usually do that you have to sign a waiver or something or speak to the pharmacist or I have to have someone else open the pill bottles for me I think maybe what you could do is have this associated with a medical license or with a medical prescription for patients that might need easier opening packages and maybe have maybe have them get the convenience that way I do know anything that comes in one of those paper paper packaging with any kind of sealant at the top I just grab the scissors and remove it and that's the only way I deal with opening those so something to consider. Thank you Alice. Anyone else who joined by the link feel free to raise your virtual hand if you joined by a phone you can hit star six to unmute your phone if you'd like to make a comment. Bobby Hi I don't agree with Mr. Silverman often but I wanted to echo the sentiment of how disappointing it is to hear that y'all are being harassed especially considering how many of these hurdles were laid out in statute I know it's frustrating I myself have gone months on end without hearing back on some pretty basic questions but I can't imagine ever harassing your staff about that so if anyone is considering doing that or has done it in the past I would also like to hop on board and tell you to grow up. Thanks appreciate your effort have a good one. Thank you and again if you joined by the phone and would like to make a public comment I will close the public comment window then one thing I forgot to mention at the beginning this information is up on our website but our application portal is going to be unavailable between 9pm eastern on Friday this Friday the 18th and 12am midnight on Saturday 1119 so down for a little less than a day so make sure if you're working on an application during that window that you won't be able to save it so just trying to avoid the application portal during those hours anything else I'm missing? No I just want to respond to a couple things I mean you can also email me if you want to be upset don't do it to our staff Kyle don't hear us at vermont.gov and on the packaging stuff I hear Eli and others loud and clear I heard so much about as we were drafting rules how forward thinking how sustainable folks in this industry already were but now's the time to walk the walk not just talk the talk this is a big part of that and while we're not unreasonable and we will continue to kind of see where things go and if waste streams improve I don't want to cripple any small cultivators some have talked about shipping those costs to a consumer that's a business decision but I think a lot of consumers want to see that our small cultivators care and when it boils down to it it's saying that shipping costs and shipping emissions of glass and heavier packaging materials than a plastic bag is more environmentally degrading than that plastic itself is like driving down the highway at 75 miles an hour and saying it's windy necessarily true you're only looking at a small fraction of a life cycle analysis and I encourage anybody to go dig through the details and compare different options and come back to me I'm happy to have those conversations but if you look at the life cycle analysis of any petrochemical manufactured product versus glass especially if it can be reused like we need to reuse it here 9 times out of 10 the glass is going to come out on top of the common tropes that I heard from the plastic industry when I worked with the American when I worked alongside I did not work for the American Fuel and Petrochemical Manufacturing Association NDC on a couple issues they don't want bioproducts to even have a place in this market this is the stuff that I heard constantly and I think it's frustrating knowing how some folks really want to be environmental leaders in this space in this state to show that Vermont can do things differently fall to those common misconceptions about how a product actually gets from the very start of its life to what happens at the end of its life so let's all work together all the credit goes to Eli and everybody else out there that's complying not for Oscar asking you to do it I get a lot of I get a lot of comments from a lot of other states and packaging companies that are like yes somebody needed to step up and do this somebody need to take this head on every time I get that I'm like don't thank me think those that are complying and figuring out a different way to do this because people are watching I promise you that all right Julie anything you want to sign off we don't have a meeting next week so this is our chance happy holidays everybody happy early Thanksgiving all right I will adjourn the meeting thanks so much