 My name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is Monday, March 27th. It's one o'clock and I call this meeting order. Quick update to the agenda. Staff here is recommending social equity status denial on three applications who have applied under the community-based criteria. So I'd like to add an executive session to the agenda to discuss the specifics of these recommendations. I'll put it right between the executive director report and the discussion info. I'd like to start just by mentioning the passing of Raphael Machoulum on March 9th. The U.S. spent the past half century immunizing cannabis for political purposes. All we were doing that, Professor Machoulum, was studying its chemical compounds and unlocking its therapeutic potential. Cannabis research really would still be in the dark ages right now if it hadn't been for his courage and determination. So I just wanted to note that he passed away. The Budget Adjustment Act has become law. This bill made some small yet significant changes to the cannabis industry. The first relates to the tobacco products tax sometimes referred to as the vape tax. Section 91 of the VAA exempts from the 92% tobacco products tax cannabis products including non-tabacco containing cannabis vaping liquids. This section does not take effect until July 1st. So please don't change anything about what you're doing now with respect to collecting taxes or remitting them. Another important detail, this exemption was not extended to vaping devices, just the liquid. This is a very important distinction. The Board is going to work with the tax department to release specific guidance on this. In the meantime, I would encourage retailers, product manufacturers, wholesalers, or anyone that is dealing with vaping cartridges and devices to go back and watch a Q&A session that I did with the tax department back in on February 3rd of this year. It's up on our YouTube page and we discussed the application of the vape tax right around the 36-minute mark. The VAA also authorized the creation of a state-run reference lab. This is going to be a huge benefit to the market as a whole both on the quality assurance of products and on increasing testing capacity at the commercial labs by shifting all the CCB testing needs to a state lab. Our proposed rule amendments will be filed with the Secretary of State very soon. This filing initiates the formal processes around public comments, submission, and review. For those who remember the process last year, the CCB held a number of public hearings where we listened to comments on our proposed rules. We'll be doing this again for the proposed rule changes. The public comment hearings will begin the week of May 8th. I don't think we have an exact date quite yet but if you will publish those when we have them and if you can't attend these meetings everyone should still absolutely review the proposed rule changes and submit written comments to the board. We review each of these distinct comments and consider whether to amend the rules based upon them. You can find our draft rule amendments on our website under the hyperlink laws, rules, and regulations. Just a reminder that at our last meeting in February the board voted to temporarily close the application window for new outdoor and mixed-year cultivators between the dates April 28th and December 1st of this year. This closure does not impact existing licensees who are seeking a renewal of their license. It applies only to new applications for outdoor and mixed-year cultivators. Given that under the best case scenario issuing a new license takes about five weeks, the rationale here is that there's no way for a cultivator to get an outdoor harvest if they're not getting their license until late June or July. Last year the CCP was willing to make some allowances for outdoor cultivators that had a pending application but had already begun operating. It wasn't a good position for anyone to be in and it's not something that we're going to do again this year. One last time this seasonal closure runs from April 28th through December 1st and it applies only to new applications for outdoor and mixed-year cultivators. At our last meeting we got quite a few comments about closing tier five cultivators so I'd like to address those directly. I'd start by offering a little context as to why this tier exists in the first place. Given the complexities that federal illegality imposes on this market one of the early things that the CCP did was to engage an economist to estimate the demand for Vermont grown cannabis by our residents by our border consumers and non-legal states and by tourists. There's a tremendous amount of uncertainty in any economic model because of all the assumptions that economists have to make. Things like how much people consume, when will neighboring state adult use programs come online? Will the price and quality of the legal system attract consumers? Will things like the vape tax and THC caps stifle demand on the regulated market? Probably more important to this conversation is how much entrepreneurial interests are going to be amongst smaller operators. Given how much uncertainty there was going into this experiment the board created a market structure that heavily favored smaller outdoor operators but in the event there was very little interest in these license types we also created some larger tiers and by large it's always important to keep facing the perspective. The largest tier that's open tier five would be a tier three out of 11 in Massachusetts. The largest tiers in Massachusetts in New York are 100,000 square feet. Maine has a 20,000 square foot cap but that's a flowering canopy limit because of the way that our statutes are defined in Vermont canopy encompasses anywhere where live plant production is occurring not just flowering canopy. That's how we got to the tier five but the question is should we close it? In response to that I would say it's too early in this market to even consider this. I mentioned the uncertainty about the size of this market and our model suggests about 200 to 250 million in annual sales. The joint fiscal office's estimate is much smaller however the revenue reports that we're currently seeing suggested that it might be bigger. We don't know how big this market will grow to be we do know how much canopy we've licensed but we don't know how much is being utilized. Given the outside interest in outdoor cultivation we also don't know what the supply chain is going to look like the late summer and early fall. Retail has only been open since October. We haven't been through a single renewal cycle yet of cultivators. We haven't yet seen any real innovation like a cooperatively owned cannabis cultivation facility might necessitate a tier five canopy. So while I appreciate the concerns around consolidation and giving small operators a real opportunity in my opinion we don't have a clear enough picture of this market to decide to close any of our tiers. We did ask the chairs of the Ways and Means Committee and the Finance Committee to put the CCB on a traditional three-year fee evaluation schedule meaning that next year we're going to do a deep dive into the overall strength of this market and make recommendations as to whether the structure of our licensing should change. To me that would be appropriate time to discuss the ongoing efficacy of a tier five cultivator. But Julie Kyle we haven't had a chance to talk about this and I know it's not on our agenda but if there's anything you'd like to add on this topic I'd like you to do that now. Yeah I don't think I have anything to add right now I think to your point I think we need to get a little further in the in the market and I think at renewal we'll probably have a better idea about utilization of the space of the cultivation space. Yeah I agree I'm thankful to a lot of folks out there that that are bringing this concern to our attention. I think I want to see how this summer goes who's actually utilizing the canopy that we've licensed. We get a lot of that qualitative information from our our compliance agents but again we've been going at this for less than two years. I want to see us through another outdoor cycle. I want to continue having the conversation and kind of keeping our our ear to the floor on this issue but what I don't want to do is for the existing tier fives to accidentally compound the monetary value of that specific license type which which could happen if we shut that down completely and then the current tier fives you know we might be giving them more than they initially thought they would have from a what is your license worth perspective and I think we just need to be careful on how we approach that issue moving forward. So this feels like it's an ongoing conversation as the market moves and changes to me. I also remind folks that at our last meeting we noted that we've made the decision that this fall in time for that outdoor harvest we're going to be shifting our testing protocols to require pesticide and pathogen testing of each individual cultivar strain instead of each harvest plot. We're updating our testing guidance and there will be more to follow on this but it's important to keep this change in mind as you plan your grow for this upcoming season. We're not going to meet again until late April. I just wanted to say please stay safe and be responsible on April 20th. You know we are the ambassadors for legal cannabis every licensee is and I know we all share a common goal of destigmatizing this plan you know a spike in DUIs any incidents involving youth blatant violations of public consumption or advertising laws really just play into the hands of detractors and give legislators what they need to restrict this industry. If you're planning events or if you have advertisements specific to 420 please submit them to the board now don't wait. Lastly I just wanted to touch on product registration again at this meeting given its importance both the licensees and the overall market. I always want to start by saying that registering products is a statutory responsibility it's not optional. We don't dictate at the board who needs to register products do require that every product that is being sold to the public be registered so who ultimately retailers need to be keenly aware of whether the products on their shelves are registered. You will be the most immediately impacted if our compliance team needs to pull any unregistered products and a product is not registered when a person submits a registration form or makes a payment. The product is registered when you're notified by the CCB that it's been approved. We have a list of all currently registered products up on our website at ccb.vermont.gov slash licenses. You know we are well aware that the process for registering products has been challenging. Product registration was not a statutory requirement when we were building our licensing portal and the temporary system we created was insufficient to review and approve products in a timely manner. We fixed that system we've dedicated additional staff to clearing the backlog and I can say that as of last Friday with only a few technical exceptions everything in the queue was submitted on or after March 13. There are quite a few older incomplete submissions and I'd like to turn things over to Kyle to discuss some of the common issues he's seen that might help licensees get through product registration more quickly. Yeah thanks Pepper so I had the pleasure of assisting the product safety committee over the last week or so with making a huge push to try and really clear the product registration backlog. I can say that that backlog is in fact clear for the most part. If you've submitted something odds are we have put and if you've submitted something even up to the middle of last week we've put our eyes on it which is how the system is designed to work. There were so many submissions at one point we were implementing completely new technology for folks in the community but also for us we had to stand up standard operating procedures but we were really able to get through a lot last week. There's and Bryn's going to talk more about this moving forward but we have just about a thousand products registered right now. I encourage everybody that's waiting on product registration to check your email. There's 399 currently in incomplete status over the weekend. I only saw about 30 resubmitted as of this morning so I think it's really important that if you're waiting on something please check your email. You should be getting an email as to why something was marked incomplete. It's really important for folks to kind of measure twice cut once as it relates to submitting product registration. I don't know if some folks thought out there that because we had such a big backlog that we wouldn't take the time to review every product and we would just rubber stamp everything but I guarantee you that is not what we did and that's not what we're going to do moving forward. We need to see five things at least in the uploads. We need to see final potency of your product. We need to see pathogen and pesticide results. We need to see a copy of your label with child warnings and texts. We need to make sure it's the correct warning. I've seen wrong warnings. We saw one product that was submitted with alcohol warnings. People are not submitting the right warnings and that's a big issue not just for us internally but for folks that are buying these products and taking them home and folks that are our detractors that are going in and looking at what's on the shelf. We also need to see a picture of your packaging. That doesn't mean your label. That means the actual container that this is put in so we know one if it's a manufactured product that it's in child resistant packaging and two we have a lot of folks you know that are frustrated by the package the plastic packaging regulations but they are what they are and we need to make sure that you're not putting something that's going to present you a notice of violation down the road onto a shelf. We've seen issues with things that are appealing to children both from a labeling perspective and a product perspective. We've seen COAs with moisture content that would put a product that would give you rotten weed. It would rot on the shelf. These are things that are going to damage your brand reputation down the road and present you potential issues with the cannabis control boards compliance department down the road. So it's hard to think about the long term when it relates to product registration because everybody has been focusing on getting through this initial push. But if we think about it from the long view we're saving you potential issues and fines and suspensions and you know so on and so forth down the road. Again the backlog is clear. We're going to be able to do this a lot more effectively and efficiently moving forward. But we need to focus on complete submissions. If you just submit your potency that's not enough. We need to see everything else. So remember the four P's and the one L. Potency, pathogen, pesticides, packaging and labeling. If we see all of that we can really move these products quickly. It gets a little bit more complicated when we're talking about products and not flour because often people are mixing strains to create a product or they're creating something from distillate and we still need to see final potency results for addables. So some of those take a little bit longer but we're instituting operating procedures right now that are really going to help this not be the bottleneck that I know it has been for some folks. And very quickly before I stop I did get some points on common issues from the product registration team that they've asked me to share. Number one if your product registration submission is stuck in draft form and the status won't change be sure that pop-ups are allowed on your browser. The status cannot be changed to submit until the portal can complete a pop-up notification. Not a tech guy but I know how to disable pop-ups or enable pop-ups. So try that trick let our product registration team know if that doesn't solve that specific issue for you. Number two when you answer packaging and labeling questions on the product registration form yes on those forms we do ask is a child resistant is a child deterrent. That's not enough we want to see you upload a picture or documentation a receipt a link etc etc that we can keep on that specific strain and make sure that what you're using on the store shelf is exactly what it says in our system. Number three you can't upload certain documents or file types in the upload section try to upload it to other section other sections the sorting of document uploads is meant to be a prompt for the applicant and not meant to limit the information or number of documents uploaded uploading meaning we will see it all the same way in our view so upload where you can. So if you're looking at your portal there's chatters there's a chatter function and there's a notes function and you can upload stuff there as well so there's even if you can't upload it on the traditional uploads there is other kind of bubbles where you can talk to the cannabis control board where you can continue to upload things. You also cannot upload something if you're in submittal form you need to be unlocked into incomplete form by the control board to then resubmit. I know that some folks have had issues trying to they've submitted something and then they can't figure out how to edit so they withdraw and then they resubmit and that gets a little clunky we're figuring out you know certain things on our end but just know that we'll see it we'll incomplete it that should allow you to edit. Along this people need to stop emailing documents to ccb.products at vermont.gov. This is the old system all documents must be uploaded to the portal via uploads or posts you're really really struggling there I know that we're willing to help but you need to make the conscious effort to get all of your uploads into the portal before you ask us or email us certain documents to upload on your behalf and finally it is completing the data mapping so you will soon see product registrations from the old system on your licensing portal so please keep that in mind the data migration again I'm not a tech guy but I know things a couple things fell through the cracks and we're working to make sure that everybody has a clear understanding of what products are registered I know some folks have tried to re-register stuff just give us some time this is all sorting itself out it's going to be a smoother process for everybody moving forward that's all I got awesome thank you and thank you to the whole licensing and compliance team who really worked to get through that backlog we know how important it is both for our purposes and for the industry Julie I wanted to give you a minute to talk about the market survey yeah so something else that's coming to your inboxes is a workforce survey everyone with an ID card will get one and everyone who's like a business owner will get one so there's two different versions of the survey and the reason for doing this is that you know in most other industries there is this type of data is collected and it's really helpful in figuring out you know workforce needs or workforce training it's also helpful in understanding you know whether or not positions or high turnover all the things that really tell us kind of the general health of the market and the general sort of health of the workforce in the market but as you all know given the federal status of cannabis we don't have that for this industry so we have to make it ourselves there are other states that have done something similar and and we're we're building that here this is a pilot project for now it's intended to go out quarterly just to sort of work through some of the kinks and what it might look like and and whether or not we're collecting the right data and then we'll decide whether or not this is effective or if there's other ways to collect this information you know to help out the market we are collecting kind of basic employment information like how many employees you have the kind of general out a number of hours um rate of pay benefits offered things like that we're not collecting business name or individual name so this is all de-identified information um and we'll share out the aggregate data so the 30 000 foot sort of data about like how many of our ID card folders are employed you know what what part of the market are they employed in the most that sort of thing um it's the ID card survey should only take about 10 to 15 minutes for an individual so it should be very quick and very easy for businesses maybe 20 minutes unless you have like a huge number of employees and then it probably take a little bit longer um that's expect to launch that in the next couple of weeks so you'll see that in your inboxes and I'd be happy to take any kind of feedback on how you know the user experiences and whether or not it's useful data when we get to that point it's great yeah thank you chili um all right well last thing um we need to do before we move down the agenda is to approve the minutes from our last meeting which is on February 27 2023 if you guys had a chance to review those yeah all right is there a motion to approve so moved second all in favor hi hi three all right um brinn when I turn things over to you okay here is our executive director report for uh the month of march um as we know we it's always uh busy in the interim between board meetings so it uh this month is no exception it's been a very busy month since our February board meeting so the first part of the report that I'm going to go through today summarizes some of that ongoing work between our meetings first up is our public engagement work so this is a summary of the outreach sessions that the board has been doing since our February board meeting and a preview of what is to come next month so these outreach sessions that have already taken place are hyperlinked in this report um if people want to use this report to get to them but they are also all all of the video recordings are on our youtube page um so at the end of February after the last board meeting we had um an event on licensed renewals um where staff walked through the process um with folks on how um the renewal process will how that will unfold um we also had one of our board members um Julie hosted a developing a plan for positive impact criteria session um we also had some staff there and also one of our licensees participated in that to share um their process and then on March 16th we had another networking event on cultivation technical assistance where one of our compliance agents Chris Modica gave a great presentation on a whole host of things respected to um cultivation assistance so that was a that was also a great session and then coming up we have navigating low licensing um human resources 101 and ensuring your cannabis business um with many more to come after that so an update on our hiring activity um this has also been a busy part of the last month um we've hired and on boarded a new licensing agent Heather Munsberg Edson who is with us her first day is today um also our new financial manager is her first day as today and that's Karen Chipperly so very excited to have those new folks on board um and we are currently an active recruitment for a medical program technician um a brief legislative update because the chair really covered this in his opening remarks um but H270 the miscellaneous bill um is making its way through the process moving to the senate this week um the budget adjustment bill H145 became law on March 20th and that bill contained the authorization for the state reference lab positions and equipment and those two that has three positions that have been authorized a director a lab director position and then two chemist position so over the next few weeks we'll be working with HR to get those positions created um and the job descriptions written and then get them posted so we can fill them so I will move on now to our licensing data for the adult use program um starting out with what we always start out with which is our average days from submission to approval and this is a comparison between our social equity applicants and our standard applicants um so this slide really just gives you a picture of the time from submission to approval for the first three months of 2023 um and you can see that we've held pretty steady over the first three months and a small increase of four days for standard applicants and five days for social equity applicants just across these three months um but I think we'll need more data to see how steady we hold there in our in our time frame from submission to licensure I will note as both the chair and Kyle mentioned we've we've been devoting quite a bit of staff time to product registration during the first few months of the year um so some of that increase in time maybe due to shifting up staff resources um this is the same data on time between submission to approval but based on the license type instead so essentially with like one anomaly here the amount of time it takes to get an applicant from submission to approval remains highest for our cultivation applicants um and then manufacturers and then wholesalers and then retailers are the license type that takes the shortest amount of time to get them submission to approval um and of course our fastest processing time is for the employee ID cards because that is a much different process than applying for um applying for a license so it's just a little different way to look at that data um next couple of slides are on our new submissions from between the end of February and towards the end of March we've gotten 40 new submissions for license applications so these the number of new submissions that we get each month are really increasing uh starting in January um the first month of the the first month of the year we had 26 new submissions um but in February we had 38 and this month we have 40 so that number is growing um as the year goes on and one other interesting thing to note is that this is the first month of this year that we've had less than half of our um new submissions be from social equity or economic empowerment up both in January and February the majority of our new submissions were either social equity or economic empowerment a little change there this month so again same data different way of looking at it this is a breakout of our new submissions by license type so as usual the majority fall um into the cultivation license type um so we've got 28 new cultivation applications four new manufacturing applications one wholesale application five retail applications and one integrated license application that have come in and since the end of February this slide is um the number of issued licenses by type and tier as of uh the today 27 so we've got 29 more issued licenses this month than last month um a little more than half of all of our licensees remain small cultivators um and we continue to see the most growth in tier one the small cultivation tiers both for for all three the indoor mixed and outdoor we've got 11 new issued cultivation small cultivation licenses um seven new tier two manufacturing licenses and seven new retail licenses and so that remains pretty steady that those are the categories that are growing the most the slide gives us some data about our issued license amendments and our employee ID cards so we've got um we've issued so far 21 amendments to people's licenses and these are the administrative amendments that don't require a renewal so typically they are a change of change of name or change of contact information some other kind of administrative change that doesn't require a board approval um and then we've got 366 employee ID cards that have been issued to date that's um 67 more than last month so staff has processed 67 new employee ID cards it's the last board meeting so here is our renewal slide and this information is going to these are going to grow I mean this is probably where we're going to see the most gross over the next few months um so right now these um in that second table there folks that are applying for a renewal are businesses that that are either coming due for their renewal or they're seeking a renewal off cycle um so those numbers are are going to grow quite a bit over the next few months but right now we've got three and we've issued one manufacturer tier two renewal um so this is the slide that um gives sort of an estimated breakdown of how much of our licensed canopies canopy space is actually being utilized so it's true that this information we are still collecting with sort of informally based on our uh site visits that our inspectors are doing um but the estimate now is that our indoor cultivators are really up to their full they are utilizing all their space at this point um so we've got 100% of utilized space for indoor growers and our outdoor cultivation space is still hovering around 60% um so we anticipate having more solid numbers here um around the end of the summer when we can really collect data about how much of that outdoor grow space is being utilized so moving on to our sort of retail mapping that we do in just report um this is the updated map that can be found on our website um so just as a reminder the two pins are existing licensed retail establishments and the red pins are the general location of our retail applications that are still in the queue so those are not precise locations just sort of drop in in the general you know town area of where they will be should they be approved and issued so a breakdown of where we've got some areas of density um we've got the exact same numbers actually in this chart as we had last month that for now we've decided Brandon in the list because they've got two licensed retail establishments with one application in the queue so that's sort of the threshold that which we are adding municipalities to this list is if they have at least three including licensed and in the queue so we may want to reevaluate that over time but sort of what these are the these are the towns that we're tracking so no change other than the addition of Brandon this list okay I'm moving on to product registration that Kyle mentioned this in his opening remarks but we've got just under 2000 total project registration applications submitted um and only 150 of them are actually sitting and waiting for our review um just about 400 are incomplete they don't have all of the information that we need in order to register those products or deny registration for them and we've got just under a thousand products that we have registered and as the chair mentioned that list is available on our website under the licensed cannabis establishments page so uh just a different way of looking at looking at that data um just about half of the products that have been submitted for our review have been registered um we've got 150 and the submitted status um incomplete is around 20 percent or 400 are incomplete and then under review um we've got 229 so about 12 percent and then 11 percent or 225 have been withdrawn so breakdown by status of our product registration application and then here we have a breakdown of the types of products uh that we are reviewing so this includes products that have been registered and products that are awaiting registration so as was true last time the majority here are for flower um just over 1600 applications for registration for flower 177 edibles 44 tinctures 206 concentrates and then 52 are in the other category so if you remember that um transformal patches capsules seedlings things like that okay i'm going to move on to our compliance our compliance data for the adult use program um so we'll start by looking at our advertising put a little bit of information about our advertising review so this is the first time we've talked about um our advertising review process so this is data since um the end of november when we really started getting uh advertising submissions and reviewing them so since that date we've gotten 51 uh proposed advertisements submitted to us for our review and approval and of those 51 about half have been approved and half about half denied or were withdrawn or were incomplete and remained in incomplete status so um the primary reason for denying uh a proposed advertisement is for failure to meet that threshold of 15 percent use the audience composition there have been some that failed because they did not include the health warnings that are required to be included in all advertisements by statutes um two of them were considered to be appealing to children and three sort of black summation information so we could make a make a determination about whether or not the advertisement should be approved or denied um and that i would just note that very few advertisements were being submitted for our review in the early weeks like in um november and december but the last two months the average number of submissions that we're getting is about five per week thank you for including that um this is something that's been on my mind because there's you know we have this um directive if you will to move as much of the illicit market into the regulated market right and there's two parts to that one is moving the operators and the other is moving the consumers and consumer behavior is in some ways harder to change than the operator behavior right so i've been thinking about how that will work given the way our advertising rules and laws are written wondering what the picture of advertising is looking like so thank you okay so i'll move on to inspections now so this is a summary of all of the inspections that have been done since the last well since february 24th so this is data between february 24th and march 24th um we've had a total of 89 inspections the majority of those were cultivation sites so retail sites for big one so that's about 22 inspections per week um we broke out the average hours per inspection there down below so you can see cultivation sites tend to take quite a bit longer than other types of licenses um so the last month reporting on this information was january and february there were 159 inspections during those two months so we're we're still you know around 80 80 a month 80 and 90 a month so this slide um gives some sort of general information about investigations that have uh been initiated in the last month so we've got about 25 new investigations that our compliance team has been working on um just since february 24th and that's the the list here sort of a summary of what those investigations tend to be around so a lot of advertising uh product complaints pesticide misuse failure to track inventory failure to register products um we're operating outside of the license so i just want to note here that these investigations are really primarily based on well they're coming from coming from a lot of different sources so we've got the public complaint portal on our website um so some of the investigations are a result of complaints that have been made that way um some complaints are coming to our staff directly um from licensees or from the public um and some of these investigations are based on information that are that was received from staff through inventory tracking product registration um or site visits so there's like a number of ways that an investigation is initiated um so the licensing team is is we're going to continue to sort of fine tune how we are tracking this um because i would say it's a little bit of a web right now how information is coming to us and how it results in an investigation or a compliance action um so this is a total number of closed investigations to date and so they and so this is a the number here is 20 and i'm just going to note that um closed investigations what we are counting as a closed investigation is something that took our staff time more than an hour to complete so there are many more i'd say this number is at least doubled if you are going to include um investigations or sort of actions that were taken by the compliance team that that were relatively quick um to deal with so that's then this is the breakdown of category type so this is the rule for rule for category type of potential violation is listed there at the bottom so the majority of these closed investigations were based on category four potential category four violations so that's primarily advertising among other things um and then category one is that is four the colors are a little tricky to see here but category the big one is category four um the four is category one and those could be like a pesticide misuse um or diversion type of violation um and then category two is the five so moving on to total active investigations and enforcement actions so these are ongoing active investigations or enforcement actions that are taking place now it's got nine of them three fall in category one and category two and then the other two are category three and four i'm going to change the color so they're a little bit easier for me to reuse okay i'll move on to the in lots of questions that enforcement i'll move on to medical program um so medical program data as of march 25th starting out with a summary of our qualifying conditions um of all of the patients on the registry as of the 25th so the breakdown here you can see the the vast majority of patients fall in that other category of qualifying conditions um and this is the breakout of qualifying symptoms for other and so you can see that the majority of patients are qualifying for the medical program because they have a verification that they have chronic pain that's 2827 patients and if you take a look at that compared to our other types of qualifying conditions you can see that chronic pain are the majority of patients that we have on the registry so moving on to the numbers so this is just our sort of overtime chart that I keep showing so we can have a picture of the you know the long view picture of what the number of medical patients and caregivers has looked like over time this is the slide that gets us closer to the last 12 months um and you can see there is there was a dip last month that has increased a little bit in the month of march so as of march 25th we had 3598 registered patients so that represents an increase of about 35 patients since february um and I think I noted last month that some of that drop off um the sort of early 2023 drop off could be attributable to our backlog and processing our patient applications and renewals um since we are we are having some staffing changes in the medical program um but I would note that we are processing applications and renewals within our 30-day time frame as of today um so we are we are keeping on top of our our backlog as of as of march okay so that brings us to our staff recommendations for both social equity status and licensure so we'll start with um staff recommendations for social equity status denial um we have five recommendations for denial of social equity status this month the mission number 2256 2841 3064 1736 2036 and 1882 um these are all recommendations for denial based on um based on the faculty's applicants don't meet the criteria for social equity status as defined and board rule as the chair noted um in opening remarks um we will spend some time during executive session discussing three of these uh recommended denials um staff is recommending approval of social equity status for three um submissions this month uh submission 1241 3438 and 3067 um these applicants do meet the criteria for social equity business applicants um as defined and board rule the staff is recommending approval of social equity status for these candidates and then our last couple of slides um these this will be our list for this week of applicants that have demonstrated compliance with all requirements for their license that are contained in both board rule and statute so staff is recommending licensure for these businesses so we have um black mountain magic for a tier one indoor small cultivation license essay cultivation for a tier two manufacturing license olibri provisions for a tier two manufacturing license central pavement cannabis company for an outdoor tier one cultivation license trufella llc for an indoor tier one cultivation license gas factory for an indoor cultivation tier two license dirt rich farms for a tier two manufacturing license 802 apath for a retail license paradise shire for outdoor tier one cultivation license mid summer green for an outdoor tier one cultivation license druid flowers for an indoor tier one cultivation license euphoria cannabis for a retail license fern gully farm for both a mixed tier two cultivation license and a tier two manufacturing license density for a tier one indoor cultivation license said in cannabis for a tier two manufacturing license seven leaf genetics for an indoor tier two cultivation license, Gaston Weed Company for a Tier 3 manufacturing license, Mary Jane Junction for a retail license, Wendy Hill Farm for a Tier 1 outdoor cultivation license, Farmhouse Canvas for a mixed Tier 1 cultivation license, Green Mountain Sativa for an outdoor Tier 1 cultivation license, Earthbound Genetics for an outdoor Tier 1 cultivation license, CBBK for a Tier 1 mixed cultivation license, Burning Bush Industries for a Tier 2 manufacturing license, Greenmont Craft Cannabis for a Tier 1 indoor cultivation license, Kingdom Boys for a retail license, Rutland Craft Cannabis for a Tier 3 manufacturing license, Lean Cannabis Company for a Tier 2 manufacturing license, Decibel Forest for a Tier 1 indoor cultivation license, Marshman, CBD for an outdoor Tier 1 cultivation license, Holographic Farms for an outdoor Tier 3 cultivation license, Raid Hill Growers for an outdoor Tier 3 cultivation license, Cosmic Gable Cannabis for an indoor Tier 1 cultivation license, Loopberry Farm for an indoor Tier 1 cultivation license, and Kind Green Insight for a mixed Tier 1 cultivation license. That is your list for the week. It's great. Thank you, Bryn. Thank you, Bryn. It's a tremendous amount of work that happened over the last month. Yeah. Okay, so we've heard the list and the recommendations. As Bryn mentioned, there are three social equity denials based on the community-based criteria that staff would like us to discuss in executive session. I've read the recommendations. I would suggest maybe about 20 minutes to get through them. And so why don't we say that we'll come back at 10 after 2? Is there a motion to move into executive session? I move that the CCB go into executive session to consider confidential attorney-client communications made for the purpose of providing professional legal services to the body. And that executive session is required because premature general public knowledge regarding such communications would clearly place the board at a substantial disadvantage. I further move that the board invites Susana Davis and Jay Green to executive session, both from the Office of Racial Equity for the State of Vermont. I will second. All in favor? All right. I'll resume the meeting then. Sorry to our participants for the delay. It's 2.22 for the record and we are back from executive session where we reviewed the facts and circumstances around three staff recommendations to deny social equity status of applicants that are applied for that under the community-based criteria. And with that discussion having happened, I think we are now ready to vote on the staff recommendations. I'm fine to do it as a package unless... Yeah, no, I am as well. I'm good. Okay. Is there a motion? I move that the board accept each of the recommendations as presented to us by staff in this meeting. Second. In favor? Aye. Okay. Thank you very much. Thanks everyone who's stuck with us. We're going to move to the last thing on our agenda, which is public comment. We will handle this the same way we always do. If you join via the video link, please raise your virtual hands. We'll try our best to call on you in the order that you raise your hand and then afterwards we'll shoot the people that joined by a phone. Now, if you could just help us with the order. Absolutely. We've got Glenn up first. Glenn, you're muted. Hey, sorry, how are you guys doing? It's been a while since the virtual thing, so I just want to... I know you guys are... Yeah, maybe somebody's got a few back loops there going on or something. Yeah, hold on one second. Shane, if your name is Shane, could you unmute, please? Unmute. Or mute. Sorry. Yeah, thank you. So, appreciate. I haven't been here in a while at the table with y'all and I just want to first off apologize for spouting off with the Vermont Rows Association. I think I heard about the closing of the window at the end of this month and I have a lot of things going on which kind of made me think about this and I was like, immediately, but I know the work you're doing, so I wanted to backtrack and just say appreciate what you're doing. To that point, and I think Kyle addressed it earlier, I missed the beginning of the meeting. We do have some licenses in the Hopper, but because of extenuating circumstances, catastrophic house failures of neighbors and things that have shifted focus as life does, it shifts where we can spend our time. And so in that process of making sure that we are within the window of your application needs by that end of this month so that we can at least get something rolling for these folks that are still in the legacy space who unlike others who we've been able to help navigate through the waters and into a space where they're, I think, happily existing in regulatory compliance. Other folks have had issues with respect to operational facilities, even tax accounting pieces that all of the things that matter for what you're asking for. And so they've been working on it over the last two years, really bringing it up to speed. And I do want to see if there's a possibility of putting at least a first initial step for them into that mix because the likelihood of them being ready by June, July exists. So I'm hoping you guys will publish just a short thing that we could at least put a few people that have been in legacy mode that I think fit all of the pieces you're looking for as far as licensed applicants and hopefully future licensees they fit. And I think that's part of what your goals are. So I'm hoping that there's a mechanism that it doesn't require monthly meetings and you guys coming online and then sharing as you do, which is extremely helpful and it helps me sort of temper some of that initial. And the other that also just you understand is we've all exist in a space where many of us in the legacy space remember what it's like when your roof goes hot or drives snow in for update on the old North End. You know, it means like somebody's looking at your place for 30 years potentially by the DEA because you brought an old lights client to this community. And these are the things that like a lot of the newer growers are not really connecting. There's a sense of I think entitlement in some respects that I want to try to offset and hopefully you guys can be aware of by at least having that idea of there's still people looking to get in. If we can do that if there's a way to have just like a quick synopsis of you know, here's how to use the new system to enter somebody that is enough for you to consider through the summer that would be huge. You know, I found the new system useful. I wasn't really intimidated. I just didn't know how some of the legacy stuff transfers. So that's great. I appreciate. And then finally, and I'll make it in there because I appreciate your time. You know, I did sort of have this large experience that pretty much has pushed us away from the cannabis industry. And we've discovered a set of ancient stoneworks that were carbon 14 dating. And there's just a whole process that I want to use science to make sure we're not off on tangents, but it does bring up the sacrament of our church. And you know, I think for many faiths, and I'm not going to profess to speak for other specific religions, that piece of the cannabis experience includes sacrament. And I'm not trying to be tax evasive. I think sometimes the tenor of how I speak comes across combative. So I apologize if that comes across that way. I understand it takes funding. I personally have reservations with how specifically that funding is allocated proportionately to our impact as an industry on actual death statistics. And not to get too complicated on the political front, but I think moving that conversation forward, if somebody objects to what a municipality or rather a state will sanction or regulate, they can bring them out of in the education industry, they can bring their kid out of it, whether to an independent parochial or religious school, or just self directed stay at home kind of just to finish up really quick. I would hope that as we move forward, there's a space that we can look at the sacrament of cannabis in a religious context. And I'm willing to be a point person towards that end with the cannabis control board to help move that forward. So appreciate it. Thank you. Have a great day. Thanks guys. Thank you. Adam right there. Adam Mcpadden. Sorry, I thought I had unmuted myself. Can you hear me now? Yes. Okay, great. In light of some of the recent pesticide news that we've heard recently, I took another lap through the pesticide guidance document online and had a subsequent conversation with Annie McMillan from the agency of agriculture, food and markets. And basically the readers digest summary of that was and she confirmed that while the agency of agriculture doesn't require everybody using pesticides to be certified, they only required if you're using certain ones that are controlled by the state of the feds, the CCB requires anybody applying anything for that function to be certified. It doesn't matter which it is, it could be canola oil for all because that is listed as an insecticide. So with that in mind, she did confirm that the board's position is more conservative than the agency of eggs. And any cultivator applying anything for fungi or insects, even if it's a very common thing around the house, needs to be certified as an applicator for that pesticide. And one thing she did clarify for the others that may be on the call that weren't aware of this, there are different levels of certification and the certification for a cultivated would be private applicator. And that requires taking a test and passing a core passing a test. You can get the manual online and take it throughout the state, there are recurring sites that host it. There also is upcoming in April, a one day workshop that UVM is putting on with the agency of ag, where you can sign up and in the morning they go over the material and then in the afternoon they apply, they give the exam and you can take it all in one day right there. It's on of all days for 20. So if anybody out there is a cultivator and wants to pursue this, just do a Google search for UVM pesticide training and you'll see it come up. I think it's 40 or $45. But the main thing I wanted to put out there in addition to the course coming up is just the awareness for other cultivators because I've spoken with some who weren't aware of this that really doesn't matter what you're applying. If you're putting something in your crop for a fungi or insects, even if it's something very common, you need to be certified and you got to take the test. That's my comment. Thank you. Ben. Good afternoon, CCB. Can you guys hear me? Yes. Hey, thanks as always for your time today. I just, per my comment today, I'd like to echo something I and others have said before with these upcoming potential rule changes. I think it would be beneficial and a huge way to cultivators to be able to possess extracts. Of course, not make extracts, but the burden of holding on to however many pounds, whether it be 10 or whether it be 200 pounds of cannabis biomass and then trying to store it in a proper setting for it to not degrade. Ben, I don't mean to cut you off at all. I really don't. But that's a statutory decision that the legislature can make or they're the only ones that can make it. We've requested that in the bill that we'll fix that, which will allow cultivators to possess finished cannabis products, including extract and distillate, has cleared a very major hurdle last week and is looking like it's moving in the right direction. We can't do that by rule, but the statutory authority to allow cultivators to do that is moving. Well, great. Well, I appreciate that. Yeah, I'm here today to advocate and ask you guys to keep doing everything you're doing. I appreciate the direction that's heading. Yeah, I look forward to hopefully seeing that change. If it is to pass, we'll review that statutory authority in that bill. Again, it's cleared a very major hurdle. It's moving to the Senate, and the Senate doesn't seem to have any issue with at least that piece of the bill. Well, great. Well, thank you so much for your time, and with that, I end my comment. Great. Jeffrey. Thank you for the record. Jeffrey Pizzatello, co-founder, executive director of Vermont Growers Association. Though we have growers in our name, we represent the entire supply chain with nearly 80 members. I do believe we are the largest representative nonprofit in the state regarding this issue. I just want to say hello, board. Good to see you back. Kyle, hope everyone is very healthy and well. Congratulations today, social equity applicants and licensees. A large slate today. It's good to see that from the board. I'm here just to make a brief comment. I'll be quick. I'm here really just to voice the concern of our members with regarding two issues. The underfunded social equity program. Currently, we have social equity applicants that have sought the loans that were offered. The fund is depleted. We have licensees that are seeking funding. They're not able to get it. We are asking that you follow through on your legislative recommendation in years past to urge lawmakers to adopt funding and perpetuity for the cannabis business development fund. In addition, we'd like to ask that you support the agricultural benefits in Act 158, 2022, which came about last year. Again, we believe this is an issue that you support. We would like to see this matter included in Bill H270. Again, we're not asking to advocate. These are issues that you've expressed support for in the past. Lastly, product registration. Product registration is still very much an issue. These three are significant issues currently impacting current licensees. This is currently impacting businesses that are trying to follow the law. We need resources and staffing for product registration. There have been individuals in the agency that have expressed support that the six point reforms that VGA has assembled for product registration will completely resolve the issues that are currently impacting product registration. So social equity funding, agricultural benefits, expanding them in 158, and then product registration reforms. These are all fires that are currently impacting the entire supply chain. We ask that you help this year, this legislative session to help put out these fires. Thank you so much. Thank you, Jeffrey. Amelia. Hey, everybody. It's probably been like eight months since I sat in on one of these meetings, and I honestly forgot how they even went. So this has been interesting to say the least. So I'm not going to run through all of Green Mountain Patients Alliance's policies because you've heard them a million times from me, but I do want to just touch on a piece of Bryn's presentation earlier that was the majority of medical patients being registered under the symptom of chronic pain. That does not mean that all of those patients necessarily belong in the program under the symptom of chronic pain. It's just the qualifier that closely resembles what it is they're actually getting their card for. And this brings me to the point that our qualifying conditions are not adequate for the amount of patients that we have in the state. And again, this is something that I know you're all familiar with. Recently, before crossover of H270, all of the additional qualifying conditions that I believe you guys requested be added to the bill were removed. This included things like ulcerative colitis, IBS, autism, and several others. I would just ask that in the senate you advocate to put those conditions back into the bill. I know that the addition of those conditions was based on research out of programs such as Minnesota's medical program. There was plenty of reasoning for adding them and it would have expanded access to the registry for a lot of different people who currently either can't or won't access the registry. So yeah, I'm just advocating that you guys really, really try to get those conditions added back in H270. And that was all I had to say. Thanks Amelia. Wayne. A question about the seed to sale tracking. I was getting ready to start some seeds for my outdoor crop for this year. And on the page there, I mean, I can't really do it because it's kind of set up for like the end of process, like a final weights and process slots. Like I don't, you know, I'm going to be doing it under one harvest slot, but I don't know how many process slots I'm going to be doing. So I guess that's kind of confusing to me. And I don't know if I heard that right, but did someone say that the social equity funds already been depleted? Because I've been told that no funds have been put out yet. So I guess that's another question. Yeah, anyways, kind of confusing, but okay. Thanks for the comment, Wayne. We don't generally answer questions during public comment session. Otherwise, this really just turns into a Q&A session it has in the past. So I would just very much encourage you to shoot an email to someone on our licensing team about inventory tracking, and they can get a specific answer to you. Or even your compliance agent. Or your compliance agent. You know, the person who you've been communicating with as it relates to, who inspected your operation before your license, they should be able to help you with that. We've not been made aware that the social equity fund is depleted, that we've not been made aware of that. I may have heard that wrong. I just that's. No, it's okay. Tito. Hi, everybody. Can you hear me okay? Yes. Okay, so a few things. I agree with Amelia. Also, I'd still like to see dispensaries be able to sell to Vermont patients tax-free. I think that would do a whole lot to get the black market involved too. On the VATACs, it hardly feels like a win to me, but at least the people are talking about it and things are moving in the right direction. It adds clarity, but of course, everybody still pays the same tax on all the devices that you pay before this happened, but we'll take it. Definitely no more tier five. And I can say, and especially MSOs, I can say that at the burn gallery, we're selling nothing but craft vendors, and we're having absolutely no problem supplying our customers with everything they need. We don't need any giant producers here. The advertising, it just feels unconstitutional to me. I'm not surprised that you're seeing so few advertisements come to you for approval, because there's almost nowhere we can advertise. It's incredibly frustrating, and it just doesn't feel right. And again, it feels like we almost have the same rules as the black market. I mean, the black market doesn't advertise anywhere for obvious reasons, and it feels like we can't advertise anywhere. It's like, there's no difference. We're both restricted the same amount in my opinion. And the pamphlets, the pamphlets that retailers are supposed to be handing out, I think offering them to having them is great, but forcing us to offer them is definitely not a smooth process. First off, it definitely feels like something that the CCB should be paying for, having us to have to pay for them, that it just doesn't feel right. And then repeat customers don't need to hear it each time. It just feels like theater, and it's just annoying. The customers annoyed, we're annoyed. Everybody's annoyed. It's just not nice. And the cost is on us, so we don't want to just automatically put them in every bag. And in our opinion, it's also just not the best advice. We don't believe it's best to send people to poison control when they feel too high. Alternatives like the nurses hotline is seems way better to me. And it also just makes for this super awkward transaction. Like whenever somebody is forced to say a bunch of stuff that nobody wants to hear, it just isn't going over well, and it's definitely not helping sales. And lastly, I'd like to see higher milligrams per serving, especially on adults, but especially the drinks. You know, I went to go have a drink finally, we got some drinks going and I mean, five milligrams, five milligrams up in a drink. It was just like, it was very unrealistic for me to enjoy a drink. I'd much rather see like a 25 milligram drink. And that's it. Hopefully everybody is having a great day. Thank you. Thanks, Tito. And just to prevent everyone jumping on a bandwagon here, almost everything that you just asked for Tito is statutory and we have no control over. So really, you know, those are things that have to go through a legislative process and you have to reach out to your legislators about milligrams per serving or advertising or point of sale flyers being offered. All of that exists in the cannabis statutes, which we have no control over. We're responsible for ensuring that you're compliant with the law. So just I just don't want to have a bunch, don't want to have a bunch of people just repeat those same things because honestly, we can't control that. But I do appreciate the comments. Thanks for explaining. Thanks for explaining. I didn't absolutely understand all that. So yeah. Ebo. Good afternoon. Just want to say that over at Gaston we're super stoked to start bringing some products to the Vermont market. You know, from the teams that came out to do the inspections to everybody there. Thanks a lot for your help along the way. Looking forward to kicking some butt here. So thanks. Thanks, Ebo. D just one initial D. Did you say D? I'm sorry. I stepped away for a moment. Yes, that's correct. Okay. I just wanted to make a comment about I just have a little bit of confusion. I know you guys aren't answering questions. I'm in charge of inventory tracking and packing inventory management and packing a licensed dispensary. And I'm just wondering if we receive bulk flower and the flower has been registered by the grower, the cultivator. I'm just I'm just unclear of whether or not we're supposed to also register if we have packaging that's already been approved. We've submitted it for registration. We are not doing bulk flower. We're just packing it ourselves. So I just there's just we're just a little confused on that. And I just I know you're not answering questions, but I just wanted to throw that out there. We're updating our bulk flower guidance this week. So check the website for some updated guidance on that. Thank you very much. I think the PR team knows it's like a chicken or the egg who's going to register that and we want to make sure that folks understand. So thanks, D. Shane. Yeah, we're just I'm just a little confused at the meeting that we just had. Did everybody you name just get their license? I mean, what just what occurred recently? I do want to say that the tier five to I think that we've as you stated, we haven't seen what the real market is, you know, with half the farms producing any flower this year. So I would just like to urge limiting, you know, mega farms to as minimal as possible in the state and let's see how many, you know, connoisseur cultivators we can provide the state with as many different varieties possible. Again, we try not to turn this public comment session into a Q&A session. I will say that. No, it's alright. The board approved around 38 applications today. Those people very likely still have some contingencies, including paying their fees before they're actually issued a license. So they're not allowed to operate. They've been approved by the board. And then there's just a few last steps that those people do in order to begin operating and possessing cannabis. Okay, and then my next question is for the tobacco licensing. Is that is that going to change? I mean, are we going to go through the whole process of applying for that license to sell like, you know, rolling papers and, you know, bonds and whatnot to just not have to deal with it? You know, again, we try not to turn this into Q&A session. You know, the current law requires you to get a tobacco license to sell any sort of tobacco consumption device. And that's not changing anytime in the near future. There is a piece of legislation that may or may not pass that deals with that. Okay, thanks again. Shane, email us at ccb.info at vermont.gov. This is Nellie. I'm happy to answer your questions. No problem. Thank you very much. Thank you guys for all your work and have a great day. Next up is Dave. Thanks, James. You know, I disagree with you about what current law requires on tobacco licenses, but we'll just be disrespectful about our disagreement. Dave, you know, it's not even me. It's Department of Liquor Control. So like, you know, and they're the ones with jurisdiction. So you might want to just contest it with them. You know, I will. I want to give appreciation to the staff for getting through the six-week backlog on product registrations last week. That was an impressive lift. And you got through a lot. So thank you for that hard work. I also want to just note with appreciation something that Julie said at the meeting about how advertising by licensed cannabis businesses is an important aspect of having the regulated market succeed and draw customers away from the illicit market, which is a major policy goal that we all share. And I know the board's hands are tied in many respects. I think there's only a few things you could do in rules to make advertising easier. But I just want to, again, just note with appreciation that we hear that, Julie, and I appreciate hearing that. And then finally, I just want to throw out there for the licensed retailers in the audience and the pending licenses to recommend that you all go to crvt.org and consider joining the Cannabis Retailers Association of Vermont, a trade group for cannabis retailers. The current group of members is, I think, really representative of the entire retailer industry geographically, demographically, and so forth. So crvt.org. Thank you. Next. Thanks, Dave. Thanks for all of your hard work in the CCB. That is, you guys powered through a lot of product registrations. That was awesome. But my comment is this during this meeting, you mentioned that all indoor doors are using our canopy to its full. We're just like maxed out on our canopy, which isn't true whatsoever. Over here, MLVisions were only using half our canopy. But you're seeing for the supply that we're creating even half of probably what it will be in the next six months. And with more and more, tier one cultivators, tier two and tier three, we're all just going to be looking to increase demand. And I respect your decision to wait until next year to do anything about the tier five thing. But I do have the same concern that allowing even one or two more into this industry could cause irreparable damage. Especially once the rest of us start coming up to full capacity, then in addition to our current like five tier one or tier fives and the integrated, it's just a lot of supply and waiting too long for it. It's just it may be too late. Thanks for everything you all do. And I hope you have a good day. Thanks, Nick. Nathan. Oh, yep. Hey, I just wanted to say thank you to everybody on the CCB for your work. And just wanted to kind of echo what Tito and Nick said about the tier five licenses. Vermont is a very small state. It's not like California or Colorado. Again, I just feel like there's just no need for tier five licenses in this state and even possibly tier four. But yeah, there's a lot of people like myself that have been cultivating for decades and that are just now getting into this new legal market. And yeah, I agree with Nick that waiting a year to think about pausing tier five licenses will more than likely be too late and the state will be filled with corporate cannabis companies. So that's it. Thank you very much and have a good day. Thanks, Nathan. Peace. Hello, CCB. How are you today? Fine, thanks. I would like to update on the medical program. Currently, I understand that you have exactly zero staffing for the medical program, which is I don't know what's going on there. As a medical patient, I have no adversary in your office at this point in time. I'm just curious what you're going to do there. I also would like to know if you guys could advocate the change in H270 with Matt Boring and Mr. McCarthy to after seeing Bryn's slideshow today that crime is the highest number of people to get card score that you guys reference the elimination of the card fee of $50 for people suffering from chronic pain because that needs to be done. I've also sent a letter to Richard Sears, Matt Boring, Keisha Ram and somebody else to ask for an auditor oversight committee to oversee you guys to make sure that we know who's going on and we get some transparency from some of you that this is a bill in Massachusetts. I sent the link to you the other day by Mr. Moore, the Senator of Mass. I also would like to know if you've gotten my email regarding Americans for your Safe Access legislation platform discussing the medical program, because the medical program needs to be changed. There needs to be some things. There are zero protections for medical patients. My card allows me, not much, allows me to go to a tax-free cannabis. I have no protections. I cannot use my medication in a hospital, nursing home or any other place. This can be done because in Maine they allow you to do it. They're from Americans for Safe Access, has been working on 20 years of advocating for medical patients. They're one of the largest groups in the nation advocating for medical patients. I did send that information to you. I also spoke to the director of ASA. They sent out a report card this year for you guys and they did not get a return on that. That's why Vermont's medical program for the last two years has been rated a D. I would like to know if you guys are going to start to staff the medical program so patients have an adversary in your office because we have questions about what direction is going in. Since it's been come over, you guys have not done much with the medical program. In two years now you've done nothing with rule three and it needs to be updated for us. Mr. Pepper, you said several months ago in the meeting that it wasn't for the medical patients in this state, that it wouldn't be for the people who had HIV and cancer that advocated for the medical program. It wouldn't be if it's regulated market now and it's kind of unfair that we're getting put on the back burner. We've been here the longest and we don't get at it. I have one other thing to say is are you guys running the health program? Can you just answer yes or no on that? Because if you are, Kyle should know this because he worked in the department of that and worked on a carrier that there should be a state lab in the department back to test hemp and it has to have a DEA certification to be a testing lab and they require more stringent testing requirements to get theirs. They don't allow growers and cultivators to bring their samples to the labs. They actually send out the staff to get those samples that way they're not there. Also there's some ways around the Eagle 20 that you got in from the the grower that was up north that they can dunk it in and it won't be shown on the things. I sent you information on that as well. There needs to be more stringent requirements in transportation here in Vermont as well because it's kind of willy-nilly if you are just don't have any security in a security van that you guys have no thing. There's no license for transportation whatsoever to make a security company to transport everything. Everybody's driving it themselves and I find that highly dangerous when numerous dispensaries are getting robbed around the country and people are getting held at gunpoint. I would suggest I sent you the information as well. It's called RMD or this is a marijuana dispensary transportation out of Massachusetts. They have a 15-page basically transportation guide that you actually need a security van and everything you need there. I just think there's some things you need to do differently right now. I do agree on what you're doing. I just feel like a few changes and I'd like to do that for you guys on the medical program. There's nothing in the medical program for the peer-to-peer as well. I thank Julie for taking time out of her own time to have a half hour to an hour meeting with me. I think it's great for people to discuss the medical program because I feel it's kind of unfair as an education. Thank you very much. Transportation whatsoever to make a security company to transport. Is there someone named Frank? Yeah, thank you. Sorry Keith, there's some feedback. That's okay, thank you. Okay, thanks. Thanks for the comment. Yes, we did hear it. Yep. I've sent you my email address and lots of information. Could you just give me some feedback as the chair or the executive director on some of the information I sent you? Thank you. Nellie, is there anyone else with their hand up in the queue? We have a couple of repeat commenters. So in general, we don't allow repeat comments here. We've seen in the past these sessions tend to just invite people to kind of comment on what other people are commenting on. So we do have a public input button on the homepage of our website. If you type out your comments in there, those go to our inboxes. We will see them. We will address them. We do try and address common concerns that we hear at our subsequent meetings. So I would just invite anyone who joined via the phone. I don't necessarily see anyone who joined via phone to hit star six to unmute yourself if you'd like to make a comment. Last call for public comments. Hey, James, could I just quickly add? I know you said about the, you know, I just, while you guys are out at, this is Glenn, while you guys are out at executive session, somebody with also a username Glenn came into the system with like, like, Russia limbo blaring in the background, right? So like, I just wanted to make sure y'all know that was not me for the record. So I make no problem, Glenn. Probably going back. I'm going to close the comment. No, no worries. And I really appreciate the comments that we received again. You know, I know there was a lot of questions. You know, we do take those questions and try and convert them into guidance or deal with them kind of at our next meeting, if there's common themes around people's kind of ambiguities or anything along those lines. So please keep them coming. Please send us comments in between meetings. You know, we're at a very critical stage with the legislature in town and our rules being amended to really, once again, reengage with the public and people who want changes. So I appreciate everyone who joined today and stuck with us to the end. And I will adjourn this meeting.