 And just as always, if you wouldn't mind kind of running us through the procedural opening, a table setting. Sure, I'll call the clients and advisory subcommittee to order. As far as attendance, it looks like we have Tim Wessel, Carrie, can you pronounce your name? Yep. Ashley Reynolds. We have Mark Gorman just about to join us. Ingrid Jonas. I know we've got Kyle Harris. Kyle, do we have anyone else in the room with you? We have Wendy Knight from the Department of Liquor and Lottery with us. James Pepper is watching on the sidelines as well just for the record. And then we have four members of the public. Great. I know we also have some guests that have spoken that are in attendance, David Kuber and Jen Flanagan as well. And Jen Flanagan and Ashley Manning. All right. Did everybody? Go ahead, Tom. I think that's everyone in attendance. Yeah, four members here too. Great. Yep, I got you, Mark. Did everybody have an opportunity to look at the minutes from last meeting? If so, and nobody has any concerns. Motion to approve those minutes. Motion. All second. All right, all in favor. All right. Well, well, today I want to continue our discussion on retail enforcement. We heard from agency of agriculture and the Department of Liquor and Lottery and more than one previous meeting where, and then after we have a conversation and if we have a consensus from the subcommittee, I have some some language that we can that I'll share on my screen. That we'll give some guidance to the board on how to proceed and explore relationships with strategic partners. And then I want to kick off our security conversation with starting with outdoor cultivation. Tom and Mark put together a summary on other jurisdictions, how they do things over overall thoughts and takeaways. And if we can get your perspective on how you arrived at certain regulations for security at outdoor cultivation sites in Massachusetts, I think that'll round out the hour quite well. So, but without without further ado, Wendy Knight, Deputy Commissioner, Department of Liquor and Lottery. I think, you know, we've seen Skyler's presentation. It was fantastic. I think what would be very helpful for us is to get your perspectives on this. DLL's thoughts on this and how you think this might fit into what you already have kind of working from a alcohol and tobacco perspective, but also recognizing that this is going to look differently than your typical corner stores that you guys or bars that you guys are operating in from a enforcement perspective and an education perspective and your approach to education and enforcement and so on and so forth. And how we can utilize DLL from the perspective of bringing in folks from the legacy market and so on and so forth. So I'll give you the floor and then if any members of the subcommittee have any questions, don't hesitate. Thank you, Kyle. I'm happy to be here. So you've had you have the detail from Skyler, who is the director of our enforcement compliance and enforcement division. I just wanted to give a little general overview for you and be able to answer questions. I think the approach that we are trying to take at DLL is to lead with education, right? So the assumption is that the licensees, whether they're bars or restaurants or hotels or ski resorts or retail stores are wanting to comply and wanting to work within the rules, the statute and the regulations. So our job is to educate them about what those rules are and they're quite complicated. As you all know, alcohol and tobacco are highly regulated at the federal and the state level. So it's very complicated. And so our job is to educate them first and foremost is to the guardrails so that they can operate within the guardrails. And you've heard Skyler talk about the three legs of the stool. And then we have compliance. So we have tobacco compliance checks that we do where we go into retail stores, we use minors. And then there's the enforcement arm, which is when there's violations. We have a board hearing and, you know, sometimes there's criminal activity and the law enforcement team works those cases. So again, I see our role as regulators as being business support. We look at our licensees as being customers and how we are able to support those customers in those businesses is by educating them about the rules and the regulations. That's basically the approach that we're taking. So obviously, when I first started having conversations with James and Kyle, the idea is that DLL has the infrastructure and the expertise to be able to help the cannabis control board as it looks to figure out the details. So we obviously have the infrastructure. We're working, you know, with alcohol and tobacco and it's not necessarily a heavy lift from an expertise perspective to add cannabis to that, which is another controlled substance. I recognize that there's differences that you talk about. When we talk about a retail operation, so we have licensees who are the, you know, the manufacturers we give licenses to. And we give licenses to the bars and the restaurants and caterers, et cetera, a whole slew of licensees. And then the retail operation is where, because we're a controlled state, we only have 78 agency stores. So they're 802 spirit stores and we contract with them to be able to sell the alcohol that we purchase. So the state purchases the alcohol from the suppliers and then we sell it through our 802 spirit store. So we have a real partnership. I don't know how you're envisioning setting up your retail stores, whether you're going to do a contract or license. So we have that arrangement. We do an agency contract and there's specifications of what they need to do that may be relevant to what you're doing. So we would have individual license holders. We won't have a system where it's like 802 spirits or anything like that just for your knowledge. So there would be individual license holders that seek a license and there will have a slew at this point of regulations that each license holder would have to maintain or follow from a retail perspective. In addition to other licenses or permits that that establishment might have to seek from other agencies depending on the size, scale, nature of what they're intending to do in this market. So what our compliance and enforcement team does is when we are in an establishment, some of the things that we're looking for, you know, making sure that they have the training, because training is required for licensees. So making sure that they've done the training, making sure their licenses are visible, you know, just, you know, observing, making, you know, if your bar or restaurant can't drink on the job, things like that. So making some observations and then just ensuring that people are complying with various rules and laws that are in place. So the other thing to remember is or to know, I should note is that while our enforcement and compliance team is made up of law enforcement personnel, the work, all of the work doesn't necessarily need to be done by law enforcement. And there are other models in other states where because a lot of the work that we're doing is educational, you don't necessarily need a law enforcement person to do some of that. Now, some of the work that's clearly identified on the liquor laws requires law enforcement when you're talking about, you know, investigations and such. But, you know, the day-to-day kind of compliance doesn't necessarily need a law enforcement personnel. Great. Thank you. Any other general thoughts before I invite subcommittee members and our advisory or our consultants to ask questions? I'm here to answer any questions you have. Tom, any opening questions? Mark? I know Mark is from the Distilled Experience world, so he might have some questions for you. But Tom, Mark, any questions? You know, at the moment, I don't. I think these guys at DOL know what they're doing and have a ton of relatable experience. I think it's great that you can engage the two organizations to, you know, create a good safety program. And I think we were talking in our earlier subcommittee, public health subcommittee today, about youth access and where our recommendation is going to be on restricting youth access. I think it all begins right there at the retail store. I mean, I'm sure there's advertising components to it and so forth. But I think you've got the right people for the job. Tom. Thanks Mark. Tom. Did Tom have something to say? I saw multiple mics come off mute. So, Gary, you go first. I just wanted to thank the deputy commissioner for joining us. It's my fault. We were about to vote on Monday and I insisted we hear from liquor and lorry prior to, I didn't want to commit them to something as another state agency without hearing from them first. Mark, I appreciate it. Thank you. Thanks for joining us. Pleasure to be here. Tom, did you have a question? Yeah, more, more of a comment and then just my typical question, Kyle. Thank you, Wendy. And we, Mark and I spoke before with Wendy. So we appreciate all the information. And Wendy, it wasn't really Kerry's fault. It might have been my, my probing that that's burn. Kerry just asked a question, but my question for all the other agencies, just because nationally I know that everyone's from an agency perspective, everyone's stretch pretty thin is if you could just comment on how the DLL is operating kind of capacity wise from an enforcement perspective and whether or not they can absorb, you know, this, this new industry coming online. Yeah, so we wouldn't be able to absorb the new industry without additional resources. I'm not suggesting we have the capacity to take on the extra work. I'm just merely articulating that we have the expertise in infrastructure. Could you just comment on a separate apart from, from cannabis? Are you, could you just give us an idea of what enforcement is like? Just dealing with, with liquor and lottery right now? What do you mean what enforcement is like? Are you, are you talking about what the, what we do for enforcement? Are you talking about current capacity without the, without the cannabis angle? I think we're familiar enough with now with, with the programs and enforcement. Do you, do you have an idea of, I mean, are you making more requests for more, more agents or more investigators? Are you overwhelmed or is, are you at kind of a good status quo? Well, if you were to ask Skylar who runs the, that particular unit, he would of course say that, that we're understaffed, right? Isn't that what then the good manager says? We are in the, we are in the process of recruiting for a vacancy that exists in the department in the, in that unit. So within the Office of Compliance and Education, we're, we're going to be starting a recruitment for a law enforcement person. One of the, one of the priorities for the governor when appointing me and my colleague who at this point focuses more on the lottery side, is to integrate the department. And so anytime there's a new vacancy, we're trying to establish whether or not that can be an integrated position. You know, it often can't, right? I mean, there is really no enforcement necessary or compliance on the lottery side. Sometimes we have customer service folks that go in and, you know, check the stores, but it's a much less complicated process. So, you know, we have an online licensing portal that will be able to license an establishment, whether they're selling tobacco, lottery tickets, you know, alcohol, potentially cannabis as well. So that's a real plus. So, you know, so yes, we have actually one position that we're recruiting for, a new one that we're recruiting for. Ashley, Tim, Ingrid, any, any thoughts? Not at this time. No, thank you. I think Tom asked the question I was interested in, which was just whether you would need more personnel to achieve this. That would be my assumption because it would be a pretty heavy lift. Yeah, I would say, I would say yes, you would definitely need more personnel. Again, you don't necessarily need them to be law enforcement personnel. And one of the things that we've been just sort of thinking about is in reorganizing the entire department. When you look at the Office of Compliance and Enforcement, if we're saying we're leading with education and that we want to make sure that we're giving enough resources and times to educating the licensees, then perhaps you rearrange the organization so that you have, you know, you have a few law enforcement people that are, you know, so you break down the state into zones and then you dedicate the law enforcement people to do the investigation and the enforcement work. And then you take some other personnel that are really more about education and compliance and those folks don't necessarily need to be law enforcement. So as we start to see turnover, right, people leave or they retire, I think that gives us an opportunity to reevaluate the resources. And as a leader, that's what I'm constantly doing. Like, okay, what do we need and where do we need the resources? So when I think about leading with education, I would be looking to put more services and more resources towards education and customer service. And we get a zillion calls and emails about I'm trying to get a license and I don't know which one or, you know, can I do this? And I imagine you're going to have some of that on the cannabis side. Like people just really want to know what the laws are and where the guardrails are. And so I think, again, you go back to customer service, business support and education. And again, that doesn't necessarily need to be a law enforcement personnel doing those duties. And I think from my perspective as a board member, what we're really focused on is creating a culture of compliance. So that starts with education and guidance and understanding. So that all makes sense to me. Ashley, do you have any thoughts? I want to give you an opportunity to raise them now before I put some language up on the board for the subcommittee to consider. I appreciate that. No, I don't have a comment at this time. Thanks. Okay. At this point, you know, we've heard from liquor and lottery. We've heard from Kerry and Dave and their team on retail enforcement. We've heard from Jen about the, you know, advantages, disadvantages throughout all options to bring this in-house at some point down the road. Considering that we don't have the resources right now to do that. But I want to put some language up. This is some language that we've drafted at the cannabis control board that will essentially ask the agency of agriculture, the department of liquor and lottery, to think about resources that would be required, what security and retail compliance means in the cannabis context. And come back to us with a proposal on how this would work and look if we were to partner with their agency. I can find the right import. So I'm going to give everybody an opportunity for a couple of moments to read this, provide recommendations for revisement. If anybody has any questions or comments, don't hesitate to unmute and ask them. I can't see anybody's face with this plugged into my screen. I'll give it about 20 more seconds. If not, I'll take it down and if we have a consensus. Kyle, this is Ingrid. I'm just thinking about what type of training or whether that would be something that the departments would ask for. Would you want them to propose what they would need for training to pull this off or is that a separate conversation? That's a great question. I think we would have to develop some trainings once we kind of understand the lay of the land and our regulations. I'd say as a starting point, recognizing that we've got to get included in our report resources necessary to the legislature before the end of October, that's something that we could likely maneuver on the back end of this conversation. I have a question. Ingrid, when you say training, do you mean training the employees at the respective departments in Canada's control or do you mean training at the retail level? I thought your question was about training agents from DLL or the agency of agriculture on the program itself and how to make sure they're conducting proper inspection and enforcement procedures as they're outlined throughout this program. That's what I'm thinking in terms of state police when we would be tasked with taking on another aspect of enforcement, we would want proper training around that. I think training and that couple of hours to maybe, I don't know, a couple of days, I don't want to box us into an hour limit, but that could be built into the resources that you would think. Again, it's hard for me to conceptualize that because we don't necessarily know what our regulations are going to look like at the moment. I think both agencies could work with the cannabis board to get a better sense of what we mean when it comes to retail compliance in the cannabis space. Maybe you need to be checking cameras where you typically want to be checking cameras in the alcohol and tobacco context or cash management products on a shelf, so on and so forth. There's going to need to be some lines of communication and to the extent that you're able to build any training costs into this, I think that would make sense. Any other questions? Thank you, Inger. That was a good point you raised. Now, this is Dave Cooper. Would you mind putting the full name of the agency there in terms of comma, food and markets up there just for completeness of the name? Sorry about that, Dave. I should have known better. And I think if we have a consensus, and I'm going to pull this down just so I can see everybody, if we have a consensus, I can send this language around and make sure everybody has it. I'm not sure if I need to call a formal vote. Maybe raise your hand if you think this is a prudent direction for the board to go in. Kerry, is that two hands up? Okay. No, it's one. All right, great. So this recommendation is approved from the subcommittee. And we can, I know that this said October X 2021, we can have further conversations. And Kerry and Dave, we can have further conversations as well about what certain things will look like from that perspective. But I wanted to make sure that you had an understanding of what we're hoping to accomplish over the course of the next couple of weeks. We're used to it at this point. So, well, thank you, everybody. I think this gives the board some direction on what to look for in proposals from our strategic partners as it relates to retail enforcement, recognizing that we've got some defining to do on what that means throughout these conversations. So I want to switch gears now. Thank you for that first part of our meeting. I'm glad we were able to get another recommendation checked off the box. I want to pivot to Outdoor Cultivation Security. I sent her on a document that Tom had sent me this morning. I'm hoping that folks had an opportunity to peek at it. But Tom, just in case they haven't, I'm hopeful that you and Mark might be able to give. I know you provided a summary in there, but just to kind of go over your summary, go over your thoughts, go over your 30,000 foot recommendations on security and open it up to the floor for questions. I also want to make sure we give Jen some time to talk about how they did things in Massachusetts. Sure. And this, as much as Mark and I want to take credit for it, this was Ashley Manning's research. And it looks like it boils down to, when you're looking at physical security, when you're looking at the security systems, the components are really the fencing and different states have different fencing requirements. But mostly, Ashley was taking from Colorado. There's good stuff in Alaska and California as well. Fences can be anywhere from six to eight feet. So there's fencing. The other component looks like the camera security of what's required. And then the other kind of physical component looks like lighting. And then in addition to that, some of the regulations that Ashley cited go on to other different facets that we've included in our initial draft, like cash management. But those are the main components, Mark, if you want to jump in if I'm missing anything. Yeah, I don't think you mentioned alarm systems. Sorry, yeah, alarm systems, right? I mean, these are kind of obvious security kinds of things. But, you know, and then the cultivator's got to be able to demonstrate to any inspector the layout of the security system and security zones and that sort of thing. So it's a lot of good examples in here if you have time to check it out. Yeah, and some of them are detailed enough where they're talking about what's required as far as where the cameras are actually supposed to have coverage, you know, the particular gates, the entryways. And some of them are also detailed enough to talk about. It's not just security from necessarily people, but also, you know, potentially wildlife and other things that can affect the crop. Anybody have any opening thoughts after looking at this document? Well, Jen, why don't we go to you and kind of get an overview on how you did it in Massachusetts, what's generally required? Carrie, I'd also like to hear about if there's any outdoor security around the HEMP program and what we're used to in Vermont from that perspective. But Jen, if you wouldn't mind giving us that overview, it would be great. I think one of the other things to include too is that in some states, any outdoor cannabis cultivation is considered a limited access area, which means that there are very few people that get to actually go on to the property inside the gated area. And that limits the exposure that it would have to people who don't need to be there, especially if you have cultivation and dispensaries on site or if you have cultivation and manufacturing. So having the limited access limits the number of key cards, key codes, any type of lock system that you have with the number of people. But in Massachusetts, really what Tom alluded to is what we did. I mean, you have to have fencing. You have to have the security cameras. Security cameras have to have 90 days of footage that can be requested and that can be given to the commission or law enforcement or anyone who needs that information. Really making sure that the area is secure. One of the biggest things we did is that it cannot be seen from the street. Like it cannot just be out in the open. And by that, I mean, if you can see the plant, then it means it's out in the open. So if you have these fences that are there, if it's hidden from the public, then for us that was good enough. The other thing too is what we did, and I think a lot of other states have done as well. I'm not going to claim credit for it, but if you can't adhere to the security requirements that the Cannabis Control Commission requires, present an alternative, which then can be reviewed by the police chief or can be reviewed by someone else to ensure that the same standards are met, although in a different way. So you may want to consider something like that going forward. But outdoor cultivation is really pretty standard. I mean, there's not a lot of diversity in the types of security systems. Some states had a 20-foot radius that the camera has to see. Massachusetts, we said that it has to see people coming and going. You have to be able to have a still photograph taken from the video and given to law enforcement that they needed or given to the Cannabis Control Commission if needed. So it is pretty standard. The one thing that we understood in Massachusetts is that there were going to be small grows, there were going to be larger grows. And we just wanted to make sure that the product was secure because in the end, like I said the last time that I was in your committee meeting, you have to weigh the product at the end. So the scraps versus the part of the plant you're going to use all have to be reconciled at the end of the day. And so that was an important thing for us and for our inspectors to have in the regulations. Any questions for Jen before Kari gives a... I have a couple of questions that I'm going to say for general conversation starters. But if there's no specific questions for Jen yet, we can go to Kari. All right, Kari. So Kyle, in the hemp program, there are no specific requirements for any sort of security, but that's not to say that there isn't any. The growers have decided we have eight-foot chain link fences, we have hemp standing in an open field right next to the road. We have some with security cameras and in fact also some with hired guards. So it's run the gamut. It's run the gamut. None of that is a state requirement. It's all been at the producer's discretion. And I think since we have Ashley here, it's worth sort of hearing what security that you have in place for insurance purposes. Yeah, just what you guys have written down for alarm system, every part of the building, all the windows, every entrance, security cameras, lighting all day long, but we're not cultivating in this facility. And that was all deemed from our insurance agent, not from, like Kari said, from the state. So we needed to ensure the whole property. And even that, it's just people on the property, incidentals, workmen's comp, but none of our actual raw materials are insured. So we have many different chains of security, different lock doors. So it's not just you get in the facility and then you can get access to the rest of the product. There's many other locked rooms and coolers that all those things fit in that we had to be certified by our insurance company and agent to look at the facility. Yeah. It presents an interesting dialogue that we need to have, Kyle. And that's the standard for the home grower is basically an out of sight, out of mind, right? You can have your six plans in your backyard as long as it's not visible from the street. Sort of where do we draw the line for commercial enterprise? Is it a dialogue? I think that needs to go through this process. Thanks, Kari. And so yeah, this all kind of leads into my just general questions for everybody who's listening here. Recognizing that license holders are going to have an extremely vested interest in security without necessarily strict regulations. They're going to, as Ashley kind of alluded to, all the measures that she needed just for the sake of her products but also for insurance. How prescriptive do we need to be as the cannabis control board in the ways that we look at security from an outdoor cultivation context? And in what ways are the typical ways that other states have done things, using security cameras, fences, and everything else, lighting that's been mentioned, what ways is it duplicative? I'm thinking about costs to especially our small cultivators and these 1,000 square foot canopies and the 3,000 square foot canopies, and it seems like a lot of chain link fence to me, the higher up you go. Jen, I don't know if this is a question for you necessarily, but I'd love your perspective. Is all of it necessary to achieve a culture of compliance through security? Or is there ways that we can be less prescriptive as a board recognizing that folks will have an interest in making sure that these are locked quote unquote facilities? I think the board has to determine what level of security they want across the industry. So of course everyone's going to have an interest in security, but does that meet the level of obligation that the board feels is necessary for an outdoor grow given the fact that it'll be accessible to people. You sort of have to think of both sides of people that want to do business the right way and the people that know how to get around and find loopholes. I think what Massachusetts did, and we had a really big conversation of we wanted to come from a compliance and enforcement standpoint. If you want to participate in the cannabis industry, you're going to have to adhere to what our regulations are. And that's why when we spell out the requirements, we also gave that alternative that if you couldn't fulfill those requirements at that level, what's your alternative? And tell us what your plan is. Because at the end of the day, our enforcement team needs to know what their plan is so when any inspections are done, when they're seeing cameras or monitoring systems or if you don't have barbed wire on top of the fence or a higher fence or things like that, that the enforcement team knows that so they're not found deficient according to the regulations. Ingrid? Ingrid, you muted. Look, that's going to be on the t-shirt after. After we're done doing zoom-mutes. I try really hard not to do that. Anyway, just coming to mind as we're talking, I'd be curious what other states were documenting in terms of the type of thefts. So obviously we don't want youth to be having easy access or it would be overly tempted to steal this kind of thing. I just would be curious to learn from the states ahead of us. Because I agree with you, Kyle. It should be inherent in the process that folks who are growing are not going to want to be having this stuff misuse or was handled or stolen or whatever the right term is. But can we learn from states ahead of us what's the right balance of security that doesn't cost too much for people but is also reasonable for what we know as folks who want to take advantage of vulnerable systems? Just my two cents. Anybody have any thoughts? I don't know, Jen. Did you guys have any outdoor compliance issues while you were on the board? Well, our outdoor growth started later because we had some issues in the beginning. But as far as I know, with our security requirements, no, there haven't been a lot. I mean, I think it's more of, was the company compliant according to the regs? Did they do what they want? Was the camera on? Was the lock locked? You know, you have your everyday things that can happen. We're not talking major thefts that happen to plants that are being uprooted and taken. But I really think that because we also, we have the micro grows and we have the craft cooperatives, right? We have the little of the little guys that want to participate in this. And that's why we say the alternative is because, you know, as I understand, you know, the district that I used to represent in the Senate had farming in it. It had a lot of small businesses. I understand the cost. But at the end of the day, as a regulator, I also stood understood that we needed to protect the plant itself and protect the public and protect the, you know, diversion and protect a whole line of things that if there's a problem with purchasing a fence that's eight feet tall, then what else, what other problems could there possibly be down the line? Because I mean, don't forget, we also have pesticide testings and we have compliance that they have to follow environmentally. So all of these things happen at the same time. They're not, they're not separate from each other. Yeah, no, I understand how, I understand how that works. If somebody can't afford one thing, what does it mean for the rest of your ability to be in good faith and compliance, you know, so Dave and then Tom. Thank you, Kyle. Just this question that you said during your presentation last time we were stuck with me, which was a similar mindset to what I have, which is your looks here, what other states have done and learned from their failures. When you chose your security measures, more Massachusetts, what did the other states specifically tell you was overkill? What didn't work? What realistically was happening on learning security because it turned out that it was just, it just was not realistic that this was going to happen. What is, or what is not going to happen? I mean, overkill or do these scenarios really happen? So in 2017, when myself and the other commissioners were talking to other states, they really gave us a balance, the most part of balanced area, answer of, listen, if you have a fence that's six feet with a foot of barbed wire over it, or if you have an eight foot fence and you haven't locked or you have a code, those types of things are very basic. One of the things that I didn't think of, I should have thought of, given where I live, is that animals can also get to the plant. You don't want animals getting into your crop, depending on where it's located. And so the type of fencing they use prevented animals from getting at the crop. There's really been no major reports that I've known of that major thefts have happened. It's more of, if you have a security camera and there's a monitoring company or you have footage 24 hours a day available or making sure that if your alarm goes off, can they get a message to the staff that's responsible for that crop at night? Things like that. It really wasn't overkill. And I think that's what the provision of if you can't do this, tell us what you want to do, what happened so that we gave people an opportunity to say to us, all right, I can't do the camera plus the monitoring system, plus the fence, plus the locks, plus whatever. And I don't think it's been used as much. I think people using fences, cameras, and lights have just worked. And it works in general businesses. And, you know, keeping in mind, again, part of the reason why you're keeping also the crop contained is that it's federally illegal. I mean, people can't just come and take these plants and then have a large amount of product on them. So we always, and don't forget at the time, well, you would know at the time, we had a U.S. Attorney General saying we were coming after everybody. We don't care if you're the attender or you're the cultivator or you're the trafficker or you're, you know, whatever. We're going after everybody. So we had that sort of in our minds as we were crafting our regulations. Tom. Thanks, Carl. I think just taking a step back, your question kind of applies to everything we're doing on the committee. It's, you know, are we over-regulating and causing too much cost for cultivators or small cultivators? And, you know, it struck me when Mark and I spoke with the Vermont League of Cities and Towns, one of the things they said, which was a little surprising, is, okay, we understand, you know, what the board is doing, just kind of show us the way. And then I thought I heard kind of a similar theme when Wendy was talking, you know, if you want education, show us the way. So I mean, Tim, I don't want to put you on the spot, but there's two kind of counter-vailing theories that I hear from these subcommittees, which is, one, Kyle's concern, which is, I think, all of our concern. Yeah, are we doing too much here? Can people just do it on their own? Or how much guidance do you need? And those two are kind of at odds. And I think everyone knows, yeah, the more we regulate, the more cost it's going to have for the participants in this industry. But it's an interesting dynamic. It's not just in this committee. It's in everyone. So I don't know if you have any comments on that, Tim. I would just say that, I mean, you have to have these standards, I think, because towns don't have the capacity to create these standards and the way the talk is going about how towns will be supported. I mean, imagine that every police call in a town like Brattleboro is going to go to the Brattleboro police if a theft occurs. That's work that town taxpayers are doing to support that operation. So you have to have this framework coming down from the state level in the way Vermont is designed. If you don't, then you'll have towns mostly not dealing with it at all, or towns dealing with it in varying wildly different ways, which would not be a good way to go for the marketplace. Thanks, Tim. I would say don't create an unfunded mandate either. That gets to the fees side of things, which I know I have opinions on that. I think one of the things that's important to note is that the board has to decide in and of itself what their minimum standard is going to be and go from there. The subcommittees, the advisory committees, everyone can advise the board on what they want, but each commissioner, each cannabis commissioner has to decide what level, what minimum level they're going to be comfortable with. To Tim's point, someone's going to pay. So if you have a more secure, you have a part of town that's not usually patrolled by the police and now you have a cultivation come in, is that police department going to have to now patrol that area more, or is the security system in place with cameras enough to say, well, if something happens, then we'll go there. We're not talking major thefts. We're not talking people coming in ripping out these plants and walking away and walking down the street. You're talking about making sure, and the business owner will probably want to make sure their products are secure because that's how they're going to make their money, right? They're going to either wholesale or what they're going to do with it. You have to decide what the minimum standard is going to be and go from there. So I understand what the overkill question would be, but at the end of the day, this is going to be a standard operating business for any other business in your community, but it's got to be fenced in. Thanks, Jen. Ashley, I saw your hand was up. Do you still have a question? I'm just curious in Massachusetts, are any of those outdoor cultivators ensuring their land or they ensuring everything that's fenced in or is that it's their own, that's the jurisdiction? It depends on where it is because don't forget, we're growing on any part of your land that has a federal loan attached to it. And so depending on how big your farm is or what part of it you're going to put it on or how big it's going to be or if it's staying alone, they all have to have a minimum insurance requirement. And so what the insurance company will tell them is this is what we want you to have, but there's a minimum standard that they also have to adhere to with commission. And did you consult any of those insurance companies prior to setting those minimum regulations? I did. No. One of the other commissioners could have. Okay. Don't forget, we weren't allowed to collaborate and talk. We weren't given that, we couldn't do that under the open meeting law. I can appreciate that. So we had to divide up our responsibilities and then come to the public meetings and say this is what we suggest. Jen, I just have another question for you and I'm thinking through this, you need to follow these regulations or come to us with an alternative. And I'm just curious if we can dig into that a little bit. And I know you said people didn't necessarily even go that route, what, nine times out of 10. I'm putting words in your mouth, but that's what it sounded like. So from an alternative perspective, was it more about, hey, we can meet X, Y, but we can't do Z too? Or were they getting creative in a sense of, oh my, and I'm thinking about this in the Vermont context, where we're a really rural state. You might be able to use natural barriers, something like that. Put this away from a heavily traveled road, so on and so forth, where fencing might not necessarily be at the forefront of somebody's mind when it comes to a cultivation site. I'm just curious if, and maybe you don't have a good answer, but from an alternative perspective, what were some of those alternatives that the board or the commission allowed to move forward? If there was anything other than just, I could meet two of the three, but not all three. Well, there was a way to say, if I do the fencing and I do the code and I have the camera, those are the basics. There wasn't a lot that I saw where people were coming in to try to alter that at all. And it could be because cultivation really didn't start until later after the commission. Because I mean, don't forget it's 2021, our first door opened in 2018. So between 2019 and 2020, they started opening, which they would just be going up for renewals now, but the new commissioners. So I didn't see any of the alternatives because the people, the outdoor cultivators weren't up and running yet. And we really, we didn't see a lot of alternatives because again, the basics was cameras monitoring systems and keys. I mean, we're not asking them to build, you know, concrete walls around this thing. It's just to make sure that it's actually secured in an area that's away from the street or the public view. Did you guys use like, like chain link fence with like a certain, certain, I'm going to use terrible terminology when it comes to this, but like, you know, with a certain degree of strength, I don't know, or like, you know, chicken wire for more pest control, so on and so forth. Did anybody kind of come in and alter what, what, how was fencing defined when it, when it comes to the regulatory definition of fencing? Or did you allow folks flexibility to determine that on their own? No, we have, we have language. I'm just finding it. We have language as the most states of the type of fencing that has to be required to, that could be an alternative that you allow in Vermont. To my knowledge, we haven't been asked to alter those yet. We haven't been asked. I mean, people just put up a pretty standard commercial type fence. And it has to be a commercial lock if they're using a key or it has to be a key code of some type. But those types of things were all spelled out in our regs. But we even go to the extent that we said that this can't be viewed from without using like binoculars or drones. I mean, we were that specific in our regulations in Massachusetts. Thanks, Jen. Tom. Just wanted to see if we, anyone in the room could follow the comment. Thanks. I asked once and nobody took the bait. Ask again now. Good. I think we're good. Kyle, I just wanted to express the comments about having to call the local police or state police puts this discussion at a different context for me. That's something I hadn't thought about. Very true. The strain on the, on the local folks, law enforcement in particular, when a theft does occur. That's not, you know, we have people stealing sweet corn or ham or apples all the time. And I was just sort of thinking of this as an agricultural commodity, but it is of higher value and all of those things do generate a call to the local authorities. And I just, Tim, it's valuable to have you here just so I can hear that perspective and think about it a little differently. I was thinking along the same lines when Tim was speaking about that coming from Elmore, where we're already employing state police because we don't have a police department here. And we're only allotted 20 hours of time in a month to control our town. And I remember when the Elmore store was, was the respect at the Elmore store and it took forever for the police to even get there and, you know, there was an active danger happening there and it's just really hard to get people out this way. And to your point too, Kyle about just rural Vermont, there's so many places that are in the same boat as Elmore. So just kind of getting the wheels of motion of what we're thinking along those lines for increasing that or decreasing that or, you know, it's going to be neighborhood patrol or our fence is really going to do it. Thanks Ashley. Yeah. And I guess that was sort of the spirit of my comment earlier really because from a state police standpoint, it would be frustrating to investigate that type, you know, thefts of any type when the security systems were not adequate to begin with. And it's just enormously frustrating to not be able to have material to work with. Just adding that. Thanks. I agree. I mean, the one thing that's uncomfortable is that you're all in positions now where you want to think people are going to do the right thing, but have to prepare that doesn't happen. And that's just a very difficult way to think about your neighbors and your communities and the people that, you know, come and go from your state. But the reality is that you need to your recommendations will help the board prepare themselves for if something goes wrong. So your inspector goes in there to inspect and has this checklist and it doesn't meet the checklist. Then what happens? You know, you're going to have businesses that are fine. You're going to have businesses that have deficiencies levied against them. And what that means in Vermont could be different than Massachusetts, but you're in a tough position because you have to sort of think of both sides of this issue. It's just not comfortable. Thank you. I know you got, I just wanted to add really quickly here before we go and I know that you spoke Kyle and the whole board spoke with folks from, you know, the illicit market and so forth. But, you know, lighting, having lighting, I read a lot about that in the article you provided, which I was really helpful for other states. But like lights do deter theft, but the plants don't want to be lit at night. And so I'm just curious like what people do in Massachusetts to prevent that ambient light from getting on the plants. You can have censored lighting that if there was a motion censored, that if they sensed a person or they sense something that wasn't supposed to be there, then the light would go on for whatever amount of time come back off again. And there's nothing to say that the light has to directly go on to the plant. I mean, depending on where you're directing the light, I mean, it's going to deflect someone who's trying to do something. You know, the lighting has, in Massachusetts, the lighting has to be enough that you can see the person on the camera. So if you're going to do it straight out and it comes down, you're not necessarily going to have all that lighting on the plant for the 10 seconds it's on or 20 seconds that it's on. And you can also, you know, it's the thing that think about softball fields and things like you can position the lighting different ways that it still lights up what it has to light up, and it doesn't, doesn't hurt or it doesn't affect other things. So I know the plants are sensitive, but I think a lot of them would do motion censored or if not, I think the cameras are getting so technologically advanced that they can see sort of in the dark, depending on where you are in the night or whatever. So there's, there's those options. Yeah. The light is stressed on the perimeter areas in most of the rigs. Well, thanks everybody. I think this has been a very productive and thought provoking meeting. I'd like to pick this conversation back up on Monday. I might be in touch with some of you to help help start drafting recommendations for the subcommittee as it relates to, I see a couple of major bullet points that are common practice and other jurisdictions for the board to consider when looking at outdoor cultivation security. And I think we could probably start moving into indoor cultivation security. Tom, I view that as different than retail security. If, if, if Ashley, I think of actually manning more, more work, but if he's willing to run the same kind of analysis for, for indoor cultivation, that would be fantastic and really help guide our conversation on Monday. But start thinking, keep thinking about outdoor cultivation. Where's the right line to be prescriptive? And yeah, I'll be in touch just with some folks. I want to make sure the, if we're going to enter into an MOU with the Agency of Agriculture on outdoor cultivation enforcement. I think it's, it's wise that, that I reach out to Kerry and Dave to kind of gauge their overview thoughts. So we're not being, so, so we're working in, in all the same direction. So I might be making that connection. Tom, more broadly speaking, if you would help me scope out the various different sub-bullets of this word security and how we can start mapping out the next couple meetings to be productive, that would be fantastic. All right, thanks everybody, 301. Much appreciated. Good day.