 Thank you very much. My name is James Pepper. I'm the chair of the cannabis control board. Today is June 2nd, 2021. And I'd like to call this meeting to order. So I don't have any remarks. I'm sorry I was late. And I'd like to just jump into the substance of the meeting. But before I do. Could I have a motion to approve the minutes. From our meeting. On five. 27. So moved. Seconded. Okay. All in favor. Aye. Aye. Great. And could I have a motion to approve the minutes. From six. Our meeting on six one. 2021. So moved. Seconded. All in favor. Aye. Aye. Okay. Thank you very much. We have a really important agenda today. And we have a few guests with us. Our first item on the agenda today is to do a walkthrough of act 164. And as 25. We have some of the. Lead sponsors and long time proponents of cannabis policy tax and regulate with us here. I see Senator Sears. And, you know, as far as someone who went out on a limb. And, you know, at a very, at a time when there was still so much stigma. And so much public disdain for cannabis and drug policy. You know, Senator Sears led an effort. Along with the help of Michelle Childs and his committee. To pass legislatively. Either the first or the second bill that ever passed the chamber of any state legislature. And we also have a representative Copeland Hansis. Who is the chair of the. House gov ops committee and in the leadership of the house. And just has been such a proponent of our board and really has put. Social equity, public safety, youth safety. At the forefront of cannabis policy. So we're very fortunate to have the two of you here. And Michelle, what I would like to do, if possible, would be to end Michelle Childs. I, you know, I thank you, Michelle, and my opening remarks at our first meeting, just the amount of hours and the amount of drafts that you've put into cannabis policy probably rivals any other issue that the state has had to deal with. And so I just can't thank you enough for your commitment to this work. And so if you don't mind Michelle, if you wouldn't, if you could walk us through some of the provisions of 164 kind of with an S 25 overlay and help orient both the board members here and some of the people watching as to what the priorities of the bill are, you know, based on the legislative intent. Some of our deadlines that we that we're going to have to meet and just any of the kind of more nuanced issues that you think are relevant to our work in the coming months. And what I've mentioned to what I've mentioned to our board members is that you are not our general counsel. You're not our attorney. We need to shy away from asking Michelle questions that might lead her to be giving us legal advice or that might disrupt her attorney client privilege. But Senator Sears and Representative Copeland Hanses, if you don't mind if questions come up as they arise, maybe we could, you know, lean on you a little bit for why certain decisions were made or kind of what the thinking was maybe behind some of these provisions. Yeah, and also I want to mention Senator Pearson from agriculture and finance been instrumental in the past. Yeah, I totally agree. I actually invited him here. I think I actually do. Yeah, and I would absolutely agree with that. And he's been he was one of the original sponsors of Act 164 and S 25 and really did a lot of the behind the scenes work for the conference committee that got Act 164 across the finish line. So do you all want to say, you know, can I turn it maybe to you, Senator Sears first, just to say a few words on this issue and then maybe go to so Copeland, Representative Copeland Hanses and then Senator Pearson. First, I want to thank you for having me, but I also want to just say Michelle has been great. I mean, I started working on this during the Shumlet administration and you were a member of that. You were his league, one of his chief aides and we worked together on that bill that died in the house, unfortunately. And I look at what would have happened. I think the most outstanding figure that I keep in mind is the Rand report and the number of the monitors who use marijuana on a regular basis. That's what really led me to support the bill. You know, if you had 70,000 to 80,000 of the monitor doing something that's illegal, you know, that it needed to change. And we were fortunate to have you, Governor Shumlin, but also Michelle really is an expert in all this. You know, she can. I often ask her for help with constituent questions about when can I open my shop? That's what I do appreciate all her effort as well as yours early on. Well, thank you. You've certainly been a leader in this. Representative Copeland Hanses, would you mind just saying a few words? Hello, good morning. And thanks for having me today. Big thanks to Senator Sears for his persistence in sending us tax and regulate bill. And big thanks to Senator Pearson, former representative Pearson for being a collaborator along the way. We had a much longer path to take in building consensus in the house. And Michelle has been along with us every step of the way, drafting so many amendments. She probably knows how to unravel this bill in her sleep. But special thanks to the Senate for continuing to press and understanding that it took us a little bit longer over in the unwieldy house to bring people along. But I feel like we're in a really good place right now. It's exciting to see the board get up and starting along these initial steps. And so I'm glad to be here today. Thanks. Thank you. Senator Pearson, are you willing to say a few words? Sure. Good morning. Thanks for including me. I guess I would just he add some additional praise to Michelle and say not just the work that brings the board together, but also decriminalizing expungements, you know, the whole suite of criminal justice reform that as it relates to cannabis, she has been there. I've been proud to play a small role and really look forward to the work you all are taking on here. I think it's important. It's exciting. It's timely. It's, you know, not a casual endeavor. And I hope we do it thoughtfully. But we have lost time as folks have commented. So hope we can also be expedient and glad to help you think through any piece or answer questions as they come up. Thank you. Thank you for that. So Michelle, you know, you've done this a number of times. I don't know how many different committees this bill has actually touched, but I will just leave it to your experience. And on this, just knowing that we don't have a lot of time, you know, I know an hour is not, I'm going to try to keep things to an hour and then let, let you all go. So I turn it over to you and I've said, I've allowed the board to ask questions along the way so long as, you know, under the parameters that I had already mentioned. And we're going to try to not derail the conversation by going too far down anyone kind of piece of this. Okay, great. So thank you everybody for all the nice things you said. I appreciate it. And it's been a pleasure working with all of you. And I'm psyched to continue working with James with the chair after all our work on this through the years. So I probably should have done a little homework on sharing on Microsoft teams. I'm not used to doing it on this. So I need a little guidance from Nellie. I, what I did is I created a document that I hope will be helpful and not too confusing. But as you know, act one 64 has, is quite large. And there's things that, you know, you don't need me to walk you through and plenty of it that you can look at on your own. So what I've done is I took as 25 and I kind of overlaid. Parts of as 25 that I thought were important for you guys to take a look at to figure out how you're going to divvy up your workload and look at your timelines. And I overlaid that on act one 64. And then I highlighted some area particular areas in act one 64 and 25 that the chair said he'd like to focus a little more on. And so I wanted to just kind of walk you through that. So people, because I think just talking about it in general without looking at the language is a little tough because there's so much there. So Nellie, can you just let me know where I share my screen or share my document? Yeah. Next up at the top of your screen next to the mute button, there should be a little button. It's a rectangle with an upwards pointing arrow. So if you click that, something should pop up telling you your options to share. Oh, yes. I see that. Sorry for taking. Right. I can. So I have the document up, but I'm having a little trouble accessing it on the screen there. Nellie, can you just pop it up? Yeah, I can absolutely do that. Give me one second. Or do you know, like why I wouldn't be able to see it when I do the screen share? Like you can't see this now when I'm looking at it. You can don't see it, right? Yeah, we see it. Yeah. Oh, great. Okay. Sorry. Okay. And so I can't see all of y'all, but I'm sure there's a way that I do that. I just minimize it. Maybe. I guess if you have questions, let me know because I can't, I, I should have figured out how to use the Microsoft. So just pipe up if you need something. So, um, so what everybody should be looking at. And I sent it to Nellie. So I'm sure she'll have it posted on the CCB website. Um, is the act from last year. Um, with some provisions of S 25 in there. Um, I put a little note on there just that it's, this is not like, any kind of official draft. And I didn't include all of S 25 into this, but just the things that I thought that would be important to the control board at this point. Um, so just a little, just set up and talking about it is that. So currently we have cannabis addressed in title 18 as the health chapter. I mean, the health, uh, title. And you have it in the medical cannabis chapter. And then you also have it in the regulated drug chapter. You also, you have hemp and title six. So one of the things that this did is kind of taking, uh, cannabis, there's still the criminal provisions that are in 18. And for now the medical provisions in 18, but the medical will shift over on March 1st of next year. Um, is create putting this in title seven. So, uh, and retitling that to be alcoholic beverages, cannabis and tobacco. So it being a regulated product rather than firmly in the criminal laws and only in the criminal laws, which is how it's been dealt with obviously for decades. Um, so we're working in title seven primarily. Um, and I'm just going to move through the draft and, and just highlight some of the things that, that I talked about. So I'm going to skip a lot of it. Um, I think everybody who's on the board is already familiar with the, the nominating process and all of that kind of a thing. So I'm going to move down, um, first to section 843 on the CCB and the duties. Um, and so just something to mention and, um, is about the, that it's created in the executive branch as an independent commission. Um, and the duties you'll see in subsection B. There's rulemaking. There's administration of the program for cannabis establishments. Um, which are their current, uh, administration of the program for cannabis establishments, um, which are their commercial adult use as well as the administration of the cannabis, medical cannabis registry and for, uh, dispensaries that would be licensed, um, to serve patients. There's also the submission of an annual, annual budget to the, um, to the governor. So that's pretty standard for like, if you look at creation of new entities, you'll see that there's a lot of changes. Um, there's a lot of changes. Um, there's a lot of changes in general duties. Um, membership of the board. I'm not going to spend a lot of time on that unless you have specific questions. Um, but they're three year terms. Um, the chair and two members. Um, there is a change in this section. I just wanted to note. Um, it's a very small change. It's, I really viewed it as technical. Is that the, um, the commission has a choice that it just has to be. I wouldn't be responding to this item. That would be considered, which is similar to the green Mountain care board is that the members of the, of the board can be removed only for cause by the remaining members of the commission. Um, and, uh, and so you'll see the language in red. I've highlighted in red language that came over from S 25. Is that the board is to adopt rules pursuant to the AP, assumed when Act 164 was originally drafted and passed. And I think this is just clarifying that that's something that the Board will need to do is to do that for the removal process. There are provisions for conflicts of interest in subsection D. Again, these are based largely on what we have in law for other entities. Again, looking to the Green Mountain Care Board on conflicts sets forth the salaries. Page nine, subsection F, the designation of an executive director who's required to be an attorney with legislative or regulatory experience. And then the duties of the executive director. And I know you guys have been working hard to interview and get ready to hire an executive director who's gonna be very busy this summer. They have the Board has the ability to hire consultants. So you see subsection G. Subsection H is the advisory committee. The advisory committee are folks in the community who are experts in various fields who can really help the Board with its policy issues. You'll see at the top of page 10, the red language is new from 25 that the Board's to collaborate with the advisor committee committee on any recommendations to the legislature of which there are many to be made in the next year or so as 25 also increased the members of the Board from 12 to 14 and changed one of the existing members which is you'll see on subdivision F originally in 164 it was a member with expertise in substance misuse prevention and the Senate committee on committees would appoint that's been changed to the chair of the substance misuse prevention oversight and advisory council. And then there is a change to I so that the municipal appointment would be from the Senate committee on committees. And then the two new members are on page 11 on subdivisions M and N. So you have the chair of the cannabis for symptom relief oversight committee or designee. And so that is an existing committee as you know there's gonna be kind of a change over because that committee gets repealed next year when the title 18 medical laws are repealed and the new ones come in but we'll talk about a little later in this document about what the kind of new version of that oversight committee will be. And then subdivision N is a member appointed by the Vermont cannabis trade association. And so that is the professional organization of the current dispensaries of which there are five. There's also a change to the date for the appointment for the advisory committee. So it was originally to be May 1st that's been changed to July 1st. So I'm gonna skip over criminal background checks. I'll talk a little next about the fund. So the cannabis regulation fund is composed of all of the fees that are collected by the board. And so anything with regard to application fees, license fees, renewal fees for all three programs. So for the medical, for the dispensary and for the adult use all of those fees will be going into the fund. And it's this fund that resources the cannabis control board. So the board operates on and all the regulatory system operates on fees collected and operates out of this fund. All the tax money goes elsewhere. So there are provisions in the act that talk about if the fund runs at a deficit. So you're not collecting enough fees to be doing all the things that the board needs to be doing, then there's a provision to backfill the fund with some tax revenues. But the goal is to have the fees be covering the administration of the program. That's the way that the current medical program has been running and they haven't been receiving any separate appropriations and they've been operating off of fees. But I think there's a lot of questions now because there's a lot of, we're not really sure how everything's gonna look about whether or not you can meet your policy goals of having affordable fees so that you're moving as much of the illegal market into the regulated market. And so you're gonna be very calculating about how you establish your fees and you don't wanna make them too high because then you can't get people in. And so I think there's still a question out there about whether or not all of the boards work can be supported strictly by fees. So section 846, just your authority to be able to collect the fees. Section 847 is an appeals process. Again, this is modeled after other provisions in law with administrative agencies. So a person who is agreed by a decision of the board can within 30 days appeal the decision to an appellate officer. The board has the ability to contract for appellate officer services. So it doesn't have to necessarily be someone who is a full-time employee of the board. And then section 847 just sets out the process. Again, it's very similar to what is in law for appeals process and with other agencies you have on subsection B, the basis for decisions in which the hearing officer could decide that there was an error with regard to the board's decision. And then there is the ability for the party to appeal the appellate officer's decision to the Supreme Court. Michelle, I've got a just quick question about that. If you don't mind, this is Pepper. The Supreme Court standard of review, is that just the de novo? Is that, do you know, or do they have the kind of same like abusive discretion? It's on the record. Okay, so they would look at the record fresh. The records from the board. Yeah, it wouldn't be de novo. Okay, thank you. Sure. So next I'm gonna move on to section five we are on page 15. And so this was kind of a catch all reporting section for Act 164. And I will show you that here at the very beginning, this is already changed and this is having to do with the fees and the reporting. So originally in 164, the board was supposed to come back before the legislature by April 1st of this year and basically put forth, you know, requested resources for FY 22 and 23, including positions and funding. You'll see that 23 was kind of struck, you know, trying to just acknowledge the issues here around timing and the late start of the board. Also what struck there is all the reporting with regard to fees. And I'll come back around to that after I go through the other language because this has obviously been replaced by something new in S25. But looking at the reporting requirements that you do have still in here and obviously the dates are past. And so gonna be up to you about when you get those recommendations over to the general assembly. So, but there was supposed to be a report April 1st after consultation with Secretary of ANR and Agriculture Food and Markets recommending to the general assembly specific exemptions or criteria or additional requirements under state or local law around environmental and land use for cannabis establishments. And the recommendations are required to address whether additional groundwater quality requirements are required for the cultivation of cannabis. The executive director can provide the recommendations based on a tier type or category of cannabis cultivation or cannabis establishment. And so, you know, one of the things that's in Act 164 as well as S25 is a recognition from the general assembly's position of looking at small cultivators as perhaps their own category that may not have, you know the same need to be regulated in the same way as larger cultivation operations. And so this is where the recommendations from the board can take into consideration all the different types of licensees in there when they are recommending the rules around environmental and land use issues. So, section C is something similar but it applies to energy and efficiency requirements. So again, report was due on April 1st and the board is to consult with commissioner of public service and the chair of the PUC on recommending energy or efficiency requirements or standards for the operation of cannabis establishments. And then you'll see there the things that they're to to report on around building energy standards, recommended energy audits and energy efficiency and conservation measures. Subsection D is saying that in the two reports above the executive director is to be considering and recommending what types of permits or licenses or standards that cannabis cultivators or product manufacturers are need to demonstrate as a condition of licensure. And so this is, you know, one of the things is as people are entering the market and looking at getting licensed, you know there's gonna be, you know they're still gonna, because they're not exempt from land use laws, things like that they're gonna have to figure out, you know what types of permits at the state and local level are they gonna need? And so this was added in there to kind of help licensees understand, you know kind of all the eyes they get a dot and the T's they got across in order to be in compliance with all of the energy and the environmental roles. Hi Michelle, it's Kyle. I just had a quick question for you. So I'm fairly certain that, you know cannabis manufacturers and growers are gonna be considered a commercial product and not necessarily an agricultural product. And I know that there is some language in here around certain RIPs that they will have to abide by even though they're not technically an agricultural product but I, and without jumping down a rabbit hole I was wondering if you could help myself and other folks on the phone understand the intent behind designating the growing of cannabis as a commercial product instead of an agricultural product. I have my suspicions on why that designation was made but just for the good of the group. Michelle, if that goes too far down attorney client privilege, maybe Senator Pearson, you know. I think that's good. Yeah, that's not really a question for me but for the elected officials. Great, sorry. Keep me straight. That's okay. Do you want me to jump in and give you my shot or please? That would be great. I would say, you know, there folks want it. It was a political decision by some who were not wanting to confer some of the tax benefits and have it just be very open in terms of land use, et cetera. They wanted more control. They folks talked openly about particularly if you had an indoor grow that suddenly was considered agriculture and there was no ability to have zoning or anything look at the buildings just as an example. So it was that sort of discomfort and obviously we are quite permissive with what farms can do. And folks were not eager to just hand that over to this new industry. I think, you know, I would say for me, that seemed like a reasonable compromise but something that I hope we can move towards I mean, I think out of the gate, maybe we want to understand it and start to see what the landscape looks like and then potentially peel back and recognize that it is an agricultural crop. So I don't know if that helps but taxes and land use is the two, you know, simple straightforward answers. Thank you, Senator, I appreciate it. I just wanted, I was in a minority of perhaps one on this, but Senator Pearson has outlined the reasons but I still think we could have done not with standing language to allow it to be an agricultural product similar to hemp. And that was, I think that will create confusion down the road and something that we need to pay attention to. But I agree that there was a political compromise but I, you know, and I understand the concern about zoning and other regulations but still I think we'll be looking at that in the future. Thank you, Senator Sears. Okay, so I'm gonna pick up with subsection E, bottom of page 18. And so this is a requirement for the board reporting to the general assembly about whether or not cannabis product manufacturers and dispensaries should be considered food manufacturing establishments or food processors under title 18 for purposes of licensing by DOH. So Department of Health currently does not inspect dispensaries that are developing cannabis products for their patients. Dispensaries have asked for that and Department of Health has declined and said that they don't fit within this. And so this would be looking for recommendation to the general assembly about whether or not there should be specific legislation clarifying that if you are producing food products, regardless of whether or not they have cannabis in them that you should fall under those regulations and be regulated by the Department of Health. Subsection F, this is the advertising study which is kind of a moot point at this juncture and I don't, it's, you know, we're already running short on time. So I'm just gonna speed through the advertising stuff. But essentially there was a disagreement between the House and the Senate on advertising and House wound up passing a complete ban. Senate would not agree to that in conference. And so they were looking to the cannabis control board and working with the attorney general's office to come back with a proposal. Because of the Ms. deadline, the general assembly wanted to get something in place on advertising so that you didn't have nothing. So there wasn't just blank on advertising as you were going into accepting applications next spring. And so there's advertising language that was an S25 that I'll go over with you in a few. So subsection G is on or before next January. The board is to report to the general assembly a summary of its work with labor, ACCD and DOC and director of racial equity on developing outreach training and employment programs focused on providing economic opportunities to individuals who have historically been disproportionately impacted by cannabis prohibition. And also a summary of the experience of other jurisdictions with regulated cannabis markets that allow retail cannabis establishments to accept online ordering for store pickups and delivery and the pros and cons of doing something like that in Vermont. Also recommending whether the general assembly should consider adding additional types of cannabis licenses. So a lot of folks have been talking about a craft cooperative license. Then there's the possibility of a delivery license, special event license, cafe license, whether or not Vermont should expand. Also subdivision four recommendations whether cannabis and cannabis product should have a minimum amount of CBD in them. And then subdivision five recommendations regarding the display and sale of cannabis related paraphernalia that is sold by persons who are not licensed as cannabis establishments or dispensaries. And so that is the, that it's kind of a, it's not really straight up in your real house. It's the issue of if you are walking into a convenience store and they have pipes and bongs and things like that displayed in a case that you can buy at a convenience store but they wouldn't be licensed under the CCB how that should be addressed if any way differently than it is currently. So new language section four A, this is what replaced the language on the reporting on fees for April 1st. So because of the timeline, it's been reworked that now the board is to report on or before October 1st on recommendations instead of the general assembly as a whole to ways and means finance and the committees on government operations on the fees. And so as you know, there were no specific fees set in either bill that's left to the board to determine because there's a certain level of complexity and information that you need obviously to decide how big is your market and then dividing that up into how many acres can be grown and how many licenses out of those acres and things like that you're required to do tiering on at a minimum the cultivator licenses and the retailer licenses but you can do tiering for others. And so there's so many different possibilities there. You could have a micro cultivator license along with a micro retail and micro product manufacturer and bundle that and that could be a license. So there's a lot of different options there and how you wanna go. And so that you would be recommending the fees to the general to these committees in the fall. And so here's just the list of all the fees. And then what's been discussed in committee was that the hope is that those committees would be able to meet and discuss the proposal in the fall in order to prepare for the legislative session. So if you come with your recommendations to those committees in the fall, they work with them then they can work with me to create a bill that can be introduced right off the bat in January and then the hope would be that they would be able to enact that. And have the fees established upon passage so that when you start accepting applications in the spring, they would be there. It also at least through receiving your recommendations in October gives applicants a general idea of the ballpark figures that are being recommended and that are likely to be implemented. Michelle, what's the kind of maximum amount of decision making that could happen with those recommendations? Could the committees write a letter of support to the relevant, to the speaker and to the pro tem? Sure, nothing would prevent them from doing that. They can get behind a certain proposal and say that that's their intent to move forward with that legislation. But once it's introduced, it's all just see how it goes. But certainly if you have, I think the committees of jurisdiction all behind a particular proposal, and as well as the leadership, then you could have a certain amount of reliability there. So page 22, there's here some additional reporting requirements that they didn't fit in on Act 164. So these two new ones are on or before November 1st of this year. The first one is recommendations as to whether integrated licensees and product manufacturers should be permitted to produce solid concentrate products with greater than 60% THC for purposes of integrating it into a product that would at the end product stage be in compliance with what can be sold. But it's at the kind of the production stage that has a higher THC. So we'll go over in a few minutes, the prohibited products. And then the second one is recommendations developed in consultation with AG, whether the board should permit hemp or CBD to be converted to Delta nine. And if so, how it should be regulated. Section 4C or the addition of two new positions, the exempt general council position and a classified administrative assistant. Let's see, I'm gonna skip through a lot of this. I will just note, I'm not gonna go over the advertising but section seven on the definition of cannabis establishments, you have your new definitions of advertising and advertisement and what's included, what isn't included. So I just wanted to highlight those. Regulation by local government, so page 30. So I think everybody's pretty familiar with this. There was one tiny technical amendment to this section in S25. And that's just a clarification on the, that when you're talking about requiring towns to have an affirmative vote on allowing retail sales, it's applying to a cannabis retailer or the retail portion of an integrated licensee. Remember their reach, so integrated licensees are they're vertically integrated the way the dispensaries are now. So they may have a grow facility in a place where they have their general operations and they cultivate and they have their product manufacturing base but maybe their retail point of sale is in another town. So it wouldn't apply to the whole operation just onto their retail portion. And this is just the section in 164 that says that prior to their being retail sales in a town that the town has to put it on the ballot and have an affirmative vote to do so. And then it would stay that way unless there is a similar vote to repeal that decision. Yep. For dispensaries that already or towns that already have dispensaries in them for the retail portion, would they, they will have to be approved through a town vote as well. Like they in order. So not for dispensaries. This is only applying to the adult use retail sales. All right. I just wanted to make sure I understood that. So dispensaries would be exempt from that. They don't, there's no similar provision in the dispensary chapter. Okay. Michelle, can you go back up to Sub-B in this? I mean, I think this is an area of pretty intense litigation in other states. Is this based on our kind of liquor model? The community host agreement essentially and the community host boards, the local cannabis commissions. Yeah. I wouldn't use that term because we don't want to confuse with what's going on or what has gone on in Massachusetts. But I mean, I think it's, this is just so that the way that a local municipality may have a, basically use their select board as their local liquor control board and issue any local permits. And that's based on whatever the General Assembly has given them as authority in Title 24 to be able to regulate things like signs and public nuisances. And they could issue permits at the local level to do that. They're not required to do it. They still have to, you know, everybody's got to be in compliance with the state law and some towns maybe may choose not to do anything at the local level. But this is just to clarify that they can do that and that you have to be in compliance with your any local requirements and local permits for the good of your state license. Representative Copeland-Hanses, maybe you're a better person to ask, but Michelle, I certainly would defer to you as well. Do you have any thinking about the timing of that? You know, is this up to the board to decide whether or not we want this local license prior to the application or is this kind of a, once their application has been approved, then they go get a local control license? I guess it would be my expectation that the local control license would be required prior to a state license. I think that was the intent that folks were going for in the house when we had these discussions. Okay, thank you. So if you look at subsection C, it addresses that issue that you raised. And I think that the thing that's gonna be obviously tricky is at the startup, you know, the question is, well, maybe they haven't gotten that process. And so if you have people, so they've taken a vote and they've approved it, but yet you, and so somebody has applied for a state license, but they're still in the process of trying to figure out what they're gonna do at the local level. At the beginning you may run into some issues there, but I think it's just, if there's a system set up at the local level and things are required, then they do that. And if they haven't gotten it together yet, then that's an issue that the board will have to look at about, if you want to grant a state license, if they then the locals then add that requirement, how do you kind of follow up on that? So section 864 is just the new advertising section. And it's pretty comprehensive. It's, I mean, I think I haven't done a good look at all the advertising stuff lately with new states coming online, but I would say it's, you know, one of the more restrictive ones out there, particularly because of what you have at the top of page 33 and subsection C, kind of establishments are not permitted to advertise their products via any medium unless the licensee can show that not more than 15% of the audience is reasonably expected to be under 21 years of age. So that's modeled after provisions with a different formula, but in Colorado and California. So, you know, a lot of people express concern that there's gonna be, you know, big billboards and signs. I mean, although we don't have those in Vermont anyway, but, you know, those kinds of things are just not really contemplated by the scheme at all. So subsection D, I'll just mention the advertisements have to contain health warnings adopted by rule, by the board in consultation with the Department of Health. So there's a lot of provisions in 164 that address where the board is to be working with Department of Health on warnings and labeling. So there's also a process in subsection E for advertisement review. The fees, there was a fee in Act 164 for advertising reviews. That fee was removed in Houseways and Means and S25 this year. So there are no fees associated with the advertising review. So that'll be something that the board will need to contemplate about building into the rest of the fee structure, because you are gonna have to review all advertisements prior to their publication. Can I ask a quick question? Is that per advertisement or per advertisement type depending on the organization retail operation that is putting forward a proposed advertisement? It says all advertisements. And I think if I would look at the definition of that, I mean, again, I'm not really supposed to be interpreting at this stage now that it's left the state house, but so maybe I should just leave, I think that's probably for y'all to discuss. So education, this is a requirement that licensees complete an enforcement seminar every three years that's conducted by the board. And I'm just, sorry, I'm just gonna speed up because we're on page 34 of 115 pages. So I'm trying to go as fast as I can. So this is just making sure that licensees have well-trained employees, that they know what the law is, they know what the requirements are, things like this. Again, looking to Department of Liquor, other state agencies that do this sort of thing to say, let's make sure that we're providing enough information to make sure that our licensees are in compliance. Section 866 is youth provisions. These are really kind of, this is taking all the little youth provisions and threw out to the act and putting them all under one section. So it's really kind of belts and suspenders, these provisions are elsewhere in the act, but here's just one place. So just going over and reviewing that, the age of 21, you can't make any purchases unless you're 21, that's the age for possession in Vermont. And the board has the ability to assess civil penalties or suspend or revoke licenses of establishments that sell to under 21. Under 21s are not allowed in the cannabis establishment so they can't even come in the door. So a lot of folks who have been to them in other states, you get carted at the door. So it's that sort of thing. And then in subsection C, this is one of the provisions where the board is consulting the Department of Health on rules regarding packaging and labeling and products and things like that to try to keep it out of the hands of under 21s. And then subsection D is just mentioning the new advertising provision that was added in S25. Page 36 prohibited products. So this was added into the house in Act 164 and there's a list of products that are not permitted to be sold by a cannabis establishment under this particular for adult use. So these prohibited products don't apply to dispensaries. And that's one of, so in Act 164, I'm not gonna go through that section but there's a list in Act 164 of the things that dispensaries can do that adult use retailers and integrated licensees cannot do things like delivery and that sort of thing. And this is one of the things too is that dispensaries can sell products that are prohibited in the adult use market. And so right now under this, there's a cap of 30% THC for flour, a cap of 60% for solid concentrates. You can't do oils unless they're pre-packaged, like as a vape, you can't do flavored oils unless it's something that's like a naturally occurring kind of flavor or aroma in the flour. So if you had a lemon haze variety, that's fine but you can't add anything to make it more appealing from a flavor perspective. You can't combine cannabis and nicotine or alcohol. And then there's a prohibition on certain, on cannabis products and packaging that are designed to be appealing to under 21. Top of page 37, this is the cultivation of cannabis environmental and land use standards. I think I'm just gonna, again, I'm trying to just get through all of it so you can just kind of see everything that's here. I mean, I think we already talked about it a little bit is cannabis establishments are not considered farming under this act. And so they do have to comply with environmental land use rules. So there are some small exceptions with regard to the current use and ability to carve out a small amount for a small cultivator where they could include that in the current use program. So that's in subdivision A2. And then you'll see subsection B has to comply with all state, federal and local environmental energy or public health law unless otherwise provided. Subsection D is the bit that I think that Kyle mentioned about thinking about like the compliance with RAPs. And so that sets forth those requirements. Moving on to rulemaking. So rulemaking is obviously this really big task for the board this summer. Section 881 lays out all the possible things that you would need to address through rulemaking. It's organized in subdivision so that like the first subdivision is rules concerning any cannabis establishment. And for brevity, I'm just, I'm not gonna go through those but you can see all the different types of things that have to be addressed everything from when you're talking about the all licensees, you're talking about what are the requirements for licensure, what are the forms to look like? What do you need to submit in terms of your operating plan? What type of business organization do you have? Where is your capital coming from? All of that kind of stuff. So there's all the business sort of stuff. Then you get down to more specific things on inspection requirements, employment and training, security requirements, health and safety. So long list there and then it moves into on, and then you'll see the new at the bottom their subdivision ours, advertising and marketing. So you'll need to do some rulemaking kind of fleshing out some of the more nuanced details of advertising based on what they've established in statute. Subdivision two addresses the cultivators and licenses, subdivision three for product manufacturers, and within all of these things there are some guidelines for you around things like for product manufacturers. They say a single packet of cannabis product can't contain more than 50 milligrams of THC and then has some exception. So there are some specific things that they kind of direct you in terms of the policy there. Others are a broader, sorry. There's a vision that I had highlighted in my own notes that I think is important. And I just wanna ask the representatives and the senators here, if I'm reading it correctly if you go up just one page today, it says the board shall consider different needs and risks of small cultivators. I'm looking right there at big B, big subdivision B. So obviously there's certain standards that we can't waive, pesticides, health warnings, things like that, but am I reading this correctly that we can create some of the looser standards for small cultivators when adopting rules? Was that the thinking behind this section, either Senator Sears, Representative Copeland-Hanses or Senator Pearson? I'll jump in and say yes. We recognize that the scale of an operation for a small cultivator might give them a different ability to invest in certain pieces of infrastructure. And so we are gonna rely on you to explore how to follow the safety and security protocols, but also scale them in a way that makes it possible for small cultivators to get into the market without having to install the same level of security systems that you might for a large indoor grow operation, for instance. Yeah, thank you. It just is an important piece of this. I just wanted to make sure I was reading it correctly. Hey, James, I mean, I certainly agree with you that there's gonna be some stuff we can't waive, but are you kind of referring to what's directly above big subsection B when it comes to all the paperwork and everything else that also might be associated with submitting an application? That's right. That's kind of what I'm thinking. I just wanna make sure we're on the same page. I think it's important to recognize that there are groups of people who currently are growing small amounts of marijuana and our desire is to bring them out of the black market into the retail market. And there may need to be accommodations to help them do that. Right, yeah, exactly. It seems like a very powerful provision of the bill. I just wanted to make sure that that was the thinking behind it was the small cultivators and bringing them into the regulated market. Yeah, I agree. Okay, so I'm just gonna skip down to page 45 and I just highlighted subsection B here, which I know you're already doing, which is just the direction that the board just consult with other state agencies and departments as necessary in development and adoption of the rules for their shared expertise and duties. Okay, next. So page 47 licenses. This is just a section that's gonna set forth all the general provisions for the six different types of licenses. You'll see the licenses mentioned there in subsection D, subdivision two, as I had already mentioned, requires that you adopt tiers for cultivators and retailer licenses, but that you can do it for others. One thing just to clarify for the crowd or people watching is that, just to reiterate that folks are only entitled to hold a maximum of one type of each type of license. So you can't have someone who has three retail licenses or anything like that. So there's a maximum of one and then there's the potential of having the integrated if dispensaries choose to opt into the integrated system and have that vertically integrated one. So I don't know if there's anything in particular in here, Pepper, that you wanted me to cover. Just mentioned actually it was the one that I had highlighted. The one I said. Okay. So priorities and business and technical assistance, section 903. So the general assembly established certain priorities that they want the board to include as priorities as you're developing them by rule. They include whether applicants have an existing dispensary license and good standing, whether the applicants would foster social justice and equity in the cannabis industry, whether applicants propose specific plans to recruit higher and implement development ladders for minorities, women or individuals who have been disproportionately impacted by prohibition, whether applicants propose specific plans to pay a living wage and offer benefits to their employees, whether the project incorporates principles in environmental resiliency or sustainability, including energy efficiency and the geographic distribution of cannabis establishments based on population and market needs. That's something that is kind of brought over from the existing dispensary program where to kind of look at geographic distribution for the licensees. Subsection B is ACCD in collaboration with AG is to provide business and technical assistance to Vermont applicants with priority for services based on criteria adopted by the board. And then you remember in that earlier section five, there was the discussion about reporting on that. So that ties into the subsection B. Subsection C, no later than September 1st this fall, the board shall begin working with labor, ACCD, DOC and director of racial equity to develop outreach training and employment programs focused on providing economic opportunities to individuals who have been disproportionately affected by prohibition. I'm gonna move now on to small cultivators. So section 904. So this was just an intense statement from the general assembly. As Senator Sears mentioned, trying to move as much of the illegal market into the regulated market, recognizing that in order to do that, you can't make the administrative hurdles so big that people won't do it. And so you're gonna have to be working on trying to find the sweet spot there to try to get folks into the regulated market. And so, you know, in subsection A and further into the goals of the board, shall consider policies to promote small cultivators and small cultivators being 1,000 square feet. So the application for small cultivators is to be prioritized over larger cultivation licenses during that initial application period. And that's already built into the implementation timeline, which we'll look at in a second. They're to consider the different needs and risks of small cultivators when adopting and make accommodations where appropriate. So, you know, you mentioned, I think Kyle mentioned paperwork or it couldn't be something like around security systems. So if you have a large grow operation, maybe you would need a different type of security system than you if you had a smaller grow operation. And then subsection D, just clarifying that a small cultivator can sell cannabis to a licensed dispensary at any time for sale to patients and caregivers. So there's a new subsection, there's a new section, 8A. And I mentioned a little earlier just about health department warnings. This is something that came in on the floor in the house on S25, having the Department of Health reporting to the committees on government operations regarding their collaboration with the board on the health warnings. So that's not for you to report, but just so you know that they will be reporting on that. Section 8 is the licensing rollout. This was not changed in S25. So you're still tracked for this. So what happens in subsection A is that for dispensaries who are currently licensed, the dispensary caps are lifted as of February 1st of next year. So for dispensaries right now, they have cultivation caps and those caps are tied to the number of patients who have designated that particular dispensary as their dispensary. So patients can't go to any dispensary they want. When they register, if they're going to use the services of dispensary, they have to pick one so that DPS knows which one they're going to. And so on February 1st, in order to open it up and have enough supply so you can start selling in the spring for integrated dispensary, the caps are lifted. And a dispensary can start to cultivate and create products for purpose of transferring or selling them to an integrated licensee after those integrated licensees are licensed in the spring. So the first licenses applications would be coming in April 1st or after. And then they are to be start being licensed on or before May 1st. And so in this, and I'll just mention there is that the first out of the gate at this time of April 1st, it's the integrated licensees, the small cultivators and the testing labs. Those are all of the ones that can start applying on April 1st and then start being licensed by May 1st. There's new language here with regard to the integrated licensees. You'll see the highlighted red language is that between August 1st and October 1st, 25% of campus flower sold by an integrated licensee should be obtained from a licensed small cultivator if available. So assuming that, let's say if you had an integrated licensee start to be licensed sometime in May and then they get going and they start retail sales sometime in the summer, then in that small period of time before the other retailers come online in the fall, they would be required to be getting a quarter of their flower from small cultivators if they're able to do that. The way that the rollout works is that there's like for this opening time period only is that there's kind of like a, you have, first you have your integrated licensees, your testing labs and your small cultivators open up and then the board would start licensing them. Then there's the next period that opens up and that is for all cultivators. So they can start applying. So the ones that are larger than the 1,000 square feet can start applying in May. Then you have in July, product manufacturers and wholesalers can begin applying and then September is when you have the applications for retailers. And so for this initial rollout, the experience and Pepper you'll probably remember this is that when years ago when we were working first with Colorado and Washington, and they were kind of the only states online, one of their recommendations was to do it this way at the beginning so you don't get completely overwhelmed and have retailers that are licensed, but you don't have enough product. And so this is just for the initial rollout. After this initial rollout, the board has the ability to decide how many permits when they open up permitting, is it just, is the application always open or only certain amount of time, things like that. So as I mentioned earlier, so all of the medical laws get repealed on March 1st. These are the new ones that are in there. I'm not gonna go over those, but they are a lot, there's a lot of things that have been left behind. There's a lot of requirements under the current program for patients, like having to designate a certain dispensary or having to make an appointment with a dispenser things like that that don't necessarily make sense when you have an adult use market out there where that same patient could walk into any retail store and not have to make an appointment or not pick a certain store. So those things have kind of been left behind. There is, you'll see in section 10 of Act 164 was repealed by S25. That was moving over one of the, there's two sections in Act 164 that were moving the medical programs over on March 1st. That's been changed and now everything is gonna move over on I think January 1st. So I will show you that language, but you do have, you have separate chapters new, the new chapters that will regulate medical registry and the dispensaries are still slated for March 1st. And that's because the board needs time to adopt your rules because you're adopting the rules for adult use and for medical at the same time. And you're gonna be basing those on these new statutes that are dropping down on March 1st. And so they didn't want those to kind of happen before you have a chance to do the rulemaking. I know that the time, I see the time, believe me, I understand that a lot of what's left in the bill deals with the taxing and the use of those taxes and the prevention and funding. And a lot of those are not actually under the purview of the board. They've been delegated to the department of revenue or department of tax and the department of health and the agency of education. So please feel free to skip over that. I mean, maybe I think it makes sense if you have, unless you disagree, if you could touch very briefly on the S-25 changes around social, I mean, I apologize. I know that I was late today, so it's my fault. No, that's okay. It's always, you know, these are, there's a lot here and it's always difficult to try to get through it quickly. But I did just want to mention on section 15 here and you can see this is new language from S-25, moving it over, moving the medical program over on the first and when the program transfers over, also that fund will transfer over. I don't know what kind of monies in that fund now. It usually runs at a surplus and is entirely self-sustaining for the program or has been to date. And then also those positions will transfer over to the board on January 1st. Also just want to know the medical cannabis oversight advisory panel. So again, this is new language from S-25 and this is to kind of look at the cannabis for symptom relief oversight committee and look at how do you kind of bring that into today's kind of cannabis landscape. When it was first created, it was focused a lot more on kind of law enforcement and things like that. And so the question is, does the makeup of the committee, does the charge of the committee, does it still need make sense or should there be a new, should there be new members, new goals, new duties for them? So getting to social equity, section 11, this is from S-25 directing you that when you are reporting to the general assembly on fees that you propose a plan for reduced or eliminated licensing fees for individuals from communities that have historically been disproportionately impacted by cannabis prohibition or individuals directly and personally impacted by cannabis prohibition. So reduced or eliminated fees, that was something that was mentioned by the governor and his letter from 1x64. And then section 12 is establishing a new chapter in title seven after the other cannabis chapters for social equity programs. When we're talking about the agency, we're talking about ACCD. Section 987 creates the cannabis business development fund. The fund is comprised of monies allocated to the fund by the general assembly and the general assembly appropriated a half a million dollars for the fund for this upcoming year. And then it's also comprised of a one-time contribution of $50,000 per integrated license to be made on or before October 15th. And so this is something that the, so if it's a dispensary that chooses to obtain an integrated license, then they would pay that. So you would have a potentially $250,000 coming into this fund from the existing dispensaries who wanna participate as an integrated licensee. The purpose of the fund is to provide low interest rate loans and grants to social equity applicants to pay for ordinary necessary expenses to start and operate a cannabis business and to pay for outreach that can be provided or targeted to attract those social equity applicants, to assist with job training and technical assistance for social equity applicants and to pay for any necessary costs for administering the funds. And then D is just designated that this is a revolving loan fund. So as people pay money back into the fund that can be used to provide more loans and grants to new folks. So section 988 is designated ACCD to develop the program using the Cannabis Business Development Fund for the purposes we just discussed. The agency can contract all or part of the necessary underwriting and administration services for those loans and grants. And then if the agency can't do so, the program doesn't move forward until the general assembly appropriates the resources necessary for the agency to be able to do that. Section 989 is a reporting requirement. So the board and consultation with the advisory committee, ACCD and the executive director of racial equity are to report to the general assembly January 2023. So if you think about, cause you got to, you'll have people applying next year. So you would have at least some experience with it in 2022. And then you would report biennially thereafter regarding the implementation of the chapter, including data on the number of applicants, number of recipients, number and amounts of loans and grants and identification of continuing barriers to accessing the cannabis market for social equity applicants. Section 13 is directing the board in consultation with the advisory committee, ACCD and director of racial equity to develop criteria for social equity applicants for the purpose of obtaining the loans and grants. And then the board is to provide the criteria to the general assembly not later than October 15th of this year. So that would be, would make your recommendation and then that would be likely included in whatever legislation is introduced for the beginning of the year. Section 14 is just the money piece that I talked about for the appropriation. I'm not going to go over the taxes. I think generally, you know, there's a excise tax. There's also a sales tax, the excise taxes, general fund money, but there's 30% that's earmarked for substance misuse prevention. And then the sales tax money is specifically dedicated for after school and summer programming. So you can see that in section 17C. This, I think Pepper, you had mentioned 18C. This just has to do with talking about the rollout of how dispensaries and integrated licensees can apply deductions because it may not fit within exactly a certain tax year. Substance misuse prevention funding, the only changes here are that it was in Act 164, it was session law, now it's been codified and it's also clarified that in subsection B, there's a balance carry forward and that money should be used for the purpose of funding substance misuse prevention in the subsequent fiscal year. And if there's any carry forward, it's in addition to revenues that are allocated for substance misuse prevention programming, it's not like you can go back and sub students say, well, we don't have to appropriate as much. I think that about- Is that about it? Yeah, I think it is. I really appreciate this walkthrough, Michelle. I do have one question for kind of Senator Sears and Representative Copenhansis and Senator Pearson, if he's still on, which is just, I see the guiding principles of this bill and Senator Sears may well start with you just as kind of the original architect. And there's a lot of them, but bringing the legacy market and small cultivators into the regulated market, social equity, environmental and land use protections, youth prevention and education, consumer protection, maintaining the continuity of services of the medical registry and highway safety. And I see those as kind of our guiding principles that have been given to us as a board. Am I missing anything? Is there anything else that we should be thinking about as we move through our next phase, which is actually sitting down and doing the work of the board? I don't think you're missing a thing. And I think you've got pretty much all of it. I will say that for us, when we first started on this trail, one of the principles that I looked at, we got hit with when we went out and did public hearings was don't allow big pot to come into Vermont. And so many people mentioned that. And so that's kind of the genesis of a lot of the language that you see in the bill is doing our best to make sure that we don't get monopolized by some out-of-state cooperation that's prepared to, you know, and I think it was the mall grow of pot or something like that, people called it. But that's really started back in the beginning days when we started looking at tax on regulated market. So I think that's the one thing you'll see is an overriding issue from, and I think it was both the governor, the both governors, Shumlin and Scott, the House Senate all agreed on that particular principle. Yeah. Representative Copeland-Hanses, can you just give us any kind of last including thoughts if those are priorities or what you see are your priorities and maybe any advice you have for us as we really dig in? Yeah, I think you hit the highlights really well and I would also just add my agreement to what the Senator just said. It was important to us as we were looking at the architecture of the bill that the Senate sent over to us that we make sure that we're doing this in a Vermont way with a Vermont scale recognition that we do have growers out there in Vermont right now who may wanna get into this regulated market and really wanting to empower this board to look at creating a regulated market with those ideals in mind. So yeah, thank you. Well, thank you both. I know, I don't know if Senator Pearson is still on if he is, please chime in, but you did this, both of you, without the benefit of a ballot initiative driving it forward, you had to take incredible political risks to do it. You gave us an incredible platform to work from and I just have to thank you and Michelle for your tireless efforts on this. And Julie, Kyle, if you wanna say anything to, you know, before we turn to public comment. I'll just quickly thank you, Ditto, what Pepper has mentioned. And I think you've given us some tools to go and protect small cultivators and the kind of craft experience that hopefully our marketplace will offer. And I'm happy about that. So thank you. I don't think I have anything in addition to add. I, you know, I agree with, with Representative Coppola-Hontes on this kind of entrepreneurship spirit that we have in Vermont and the focus of that market. Well, thank you all so much. I'll let you drop off. I know that, you know, you just came out of essentially a 15 month continuous session and here you are doing a walkthrough of a bill for an hour and a half. But we are gonna turn to public comment and just thank you one last time for joining us today. Thanks for having us. Thank you. Okay. So with that- Thank you, Michelle. The next item on our agenda is public comment. We're gonna then move to a short break and kind of dig into what we just heard afterwards. So Nellie, could you just kind of manage the public comment? And I see David Silberin has got his hand raised and for the folks on the phone, for the folks that are joining us through the link, please just raise your hand, your virtual hand. For the folks on the phone, I'll turn to you after all the other folks have and you just hit star six to unmute. So David, go ahead. Thank you, Chair Pepper. I wanna just build on what Senator Sears said about Big Pot and how this bill works to counteract that impact. We have in here the strictest set of ownership limits of any law in any state in the country. We only allow a licensee to own or control one license, whether directly or through affiliates. And we spent a lot of time in the legislature working on that language over the course of several legislative sessions going back to 2016. And that language was worked on and refined and refined to the point where it talks about beneficial ownership, not just record ownership and talks about other indicia of control, almost like a securities law definition of control, where you can look to even contractual rights. And I think this is gonna be another very powerful tool for you guys to keep this market small and locally controlled. And there's gonna be room for important rulemaking here as you think about what is control and what it is that you're gonna require folks to disclose in their applications to you so that you can make sure that folks really are complying with these requirements and are not working through various affiliated entities or nominees or other kind of shell holding structures to evade these rules. So having those disclosures I think is something that, if you look at Massachusetts experience was a big problem. I've heard Shalene Tidal talk about this a bit, that they had issues finding out who the real people behind the licensees are. And I think here you have the tools you need to force those disclosures. And I would just urge you to be really aggressive about that and make sure that you protect the prerogative that the legislature took here to say that, we really do wanna limit it and not allow corporate consolidation within the industry and Vermont. So while we'll be able to have folks come in from out of state and have big multi-state operators come in, they're gonna be limited to that one store or that one grow operation or the one manufacturing facility. And that way everyone else has a level playing field and isn't crowded out by economies of scale. So thank you very much. Thank you, Dave. And thank you for your advocacy on Act 164. Jasalene. Hi, thanks so much for having us here today. I just quickly wanted to mention a few things after you guys ran down S25. You know, I appreciate being a little more thoughtful about the medical programs funding. I think this is the first time we actually have an opportunity to use that money to benefit patients. I don't think that's something that the program has addressed in the past is we actually have a fund that can help make this program better for patients. So I want to just reiterate that money I'm hoping can really stay with medical patients. I think there's a lot of ways we can support medical patients from educating the staff that's at the dispensary. I think something very common we often hear and I know I hear from patients is that there isn't as much medical expertise or knowledge amongst the staff in the dispensaries that patients could use to feel more supported or that money could go to have actual medical professionals in the dispensaries available for patients. So I think that's one thing that can set us apart. I want to quickly mention just on the THC caps and that discussion, I just want to keep asking everybody to continue to remind themselves that not all people using adult use or recreational are not patients. They can be using medicinally. When we think of veterans, we know a lot of them don't have access or are worried to lose their benefits. When I think of nurses and professionals like myself, I understand why people are hesitant to put their name into a system that says they're using cannabis. And when we look at single parents, just a few reasons people might not want to be a patient, but they are using medicinally. And I think those patients should have the opportunity to have concentrates and to have more access to products than just medical patients that have the opportunity or the availability to get that medical card. Again, we have to remember there are people who are literally worried about their life benefits if they sign and put their name on a medical card. And I also encourage us to consider allowing patients to use every dispensary. So even the adult use dispensaries because they really need more options. One thing very unique to cannabis medicine is that we have different strains or cultivars, chemo bars, whatever language you want to use. Not like here's a Prozac or here's a Zoloft pill, that's standard. One person might find one strain or cultivar and I know this from a very personal, medical necessity myself and not at every dispensary is gonna be able to have those options. So patients being able to shop without paying extra taxes at the adult use market and not only support the local farmers, but it's supporting patients to have more options. And when we look at patients, the last thing I wanna mention is consumer safety because I feel like it's one thing. I know there's a one or two liner in Act 164 but it doesn't address a lot of the lab testing moving forward. And I'm really hopeful that that's gonna be a bigger part of the conversation because if we wanna look at having a good program, a safe program, we have to look at clean cannabis. And we do know that's one area that the medical program in Vermont currently could do a lot better as far as having that third party and that contaminant testing. We know that the hemp program has put together some good recommendations but unfortunately those are only recommendations. They're not being mandated. So from both a medical professional and a patient standpoint, I just want to continue to hopefully see that conversation happen more as the consumer safety aspect from that lab testing. So I appreciate the rundown on S25. I just wanted to touch on a couple of things that I felt like mentioning after that. So thank you again. I appreciate your guys time. Thank you, Jesslyn. Are there any other folks that wanna speak that have joined through the link that can raise their virtual hands? Okay, are there any folks on the phone that wanna provide comments? And now, and again, if you would like to, you're currently muted, hit star six to unmute. Okay, well, what do we have a 10 minute break scheduled? So why don't we go ahead and take a 10 minute break? Why don't we come back at 12.50? Does that work? Sounds good. Okay, 15 for the record. Our next agenda item is to look at the board policy areas and sorry, we're recording now, right? Let me just start over. 12.50, we're back. Our next agenda item is to look at the policy areas that we saw on Act 164 and S25 and think about dividing them up. I guess, you know, I have some hesitation in getting too deep into the board's work before we have an executive director in place. And that hesitancy is just in that, you know, the executive director is the one that needs to translate a lot of the work that we do into rule, into statute. And so anything that we do now will have to play, our executive director will have to play catch up later. But given what we did today, I think that it makes sense to start the conversation about how we wanna proceed as a board and how we wanna go about tackling just the huge amount of work that we're gonna have to do, you know, prior to October 1st and then in order to meet subsequent deadlines beyond that. So I'm happy to kind of open it up for discussion with you, Julie and Kyle to think about the best way to proceed. And I can just give you a quick overview of sort of my thinking on this, which is there are express legislative intent in the in Act 164 and S25. And then there's sort of implied legislative intent based on some of the provisions that are in there. And I kind of listed them for our guests this morning what I thought they were. And it seemed to me like that was kind of what they thought as well. So I'm wondering if it makes sense for us to kind of walk through those and maybe try to assign specific areas to specific board members so that we can kind of take the lead on those aspects of the bill. And that way, you know, because we are a three-member board because, you know, anytime we communicate with one another outside of kind of administrative planning and things of that nature, we need to do it in the context of an open meeting. That would give us the ability to work on some of these priorities kind of independently and tee them up for when we come together at our board meetings. So that sounds like a good plan to me. Maybe you could list them off again, Chair, just for anyone who joined. I don't know if anyone joined during the break. So I think what I heard, and this is in no specific order, but prioritizing the legacy market in small cultivators and bringing them into the regulated market, prioritizing social equity and social equity applicants, energy, environmental and land use issues. Youth prevention and education, consumer protection, maintaining the continuity of services for the medical use program. And then highway safety is on there only because you can see a lot of the kind of, the later sections of Act 164 really, you know, go into highway safety protections, but I actually don't know if that's really under our purview so much as it is under the Vermont Criminal Justice Training Council and the Department of Public Safety. So I don't know how much we as a board need to focus on that. Certainly if we think about things down the road, like on-site consumption or specialized, special event licenses, that will very quickly come to the forefront of issues that we need to consider. But I don't know if we need to assign that one today or if we need to assign any of them today. I mean, I think we could think about that. And then just another issue that comes to mind is, you know, in the section that creates the board, you know, the express language is that, you know, this board is being created for the purpose of safely, equitably, and effectively implementing and administering the laws, enabling access to adult use cannabis in Vermont. I wonder, and again, I don't know how much of this has to happen in rulemaking or how much we can do on our own, but I'm wondering also if we wanna take some time to define what that means, safely, equitably, and effectively. Yeah, I agree. I think we should take some time. I think, you know, what can really help us as a board and the public as they interact with us is developing a mission statement or something of that nature that kind of gets to the fundamental principles with which we intend to operate. Yeah, I think so too. And when we have an executive director, maybe they can help us figure out whether those need to be put into rules or legislative intent language. I don't even really know, but I think it would make sense for us to exactly have something that as we're making decisions, we can kind of refer back to as our touchstone. So we don't have to do that now, but I do think that it's something that we should be thinking about. And maybe if we think about dividing up some of these kind of underlying principles to specific board members, maybe it'll make sense if we wanna kind of divide up, at least the initial thoughts on drafting what safely, equitably and effectively mean. Yeah, I think that's a good idea. If we kind of took each area and drafted something, we could maybe go over it in our next meeting and that would be a jumping off point. Yeah, so then, you know, if these are our kind of guiding principles, I also think that what sort of makes sense is to think about maybe having, you know, week long meetings on each one. And it's probably beneficial to us, again, to have an executive director to have our advisory committee in place before we get too far down any one path. But I do think that now might be a good time for us until we have those to maybe just hear from some organizations that specialize in these areas. But again, I don't wanna get too far ahead of ourselves. But I don't know, do you want to kind of just break up some of these issues? And, you know, the reason why I chose these kind of overarching kind of principles is because I think there's reporting requirements or work that we have to do in service to each one of them. And so while I don't have the specific statutes laid out for each one, you know, if we start to try and break up some of these and there's gonna be intense overlap between all of them and interconnectivity, but maybe if we break up some of these, maybe we can each individually go through Act 164 and S25 and find the areas that relate to these issues. You know, not today, but kind of in our own time. So... Do you think just to interrupt for a second, Mr. Chair, it would be a good idea to look at those legislative priorities and maybe crosswalk them with some of the kind of hard deadlines that we have. Sure. And set those, you know, use those as guide posts for the, you know, what we prioritize. Yeah, absolutely. Because I think what Michelle was sharing with us and in looking at the legislation, right? So the deadline that's already passed, April 1st, right? It was, I think most of those issues were around environmental and land use, energy efficiency, permits and licensing, the food manufacturing and the advertising. So I wonder if we might kind of consider that alongside of those legislative intents and go from there. I think so too. Yeah, so... I agree. Do we want to assign that just to one of the board members as the kind of coordinator for that? Because obviously we have to work with the Public Utility Commission. We have to work with the Public Service Department by statute. But then of course there's a number of experts in this state, you know, and organizations that have extreme expertise and knowledge of those areas. So it might be best if we kind of designate one person to be the point person. And then like I said, we'll do like a week of energy environmental land use to just kind of get oriented and then, you know, receive comment and try and hopefully we will have an executive director in place that can kind of then help with that. But why don't we just start with environmental energy and land use? And I would take any suggestions from either of you if anyone has a specific interest and kind of running points on that. I'm happy to do so. I know the three of us have kind of talked that we each bring certain backgrounds to the board. I would submit that my specific retailer, legal education and experience might help lendenere to those types of issues that we're gonna be facing. That being said, I know that we've also talked about just cause we come from a certain background and have a certain level of expertise in all of the different issues that we're gonna be working on that doesn't preclude other board members from having an interest in those areas. So I'm happy to kind of coordinate those issues. I think they're really important. I think a lot of people, especially after S25 likely have their ear or their eyes towards that October 1st deadline as it relates to fees, fee structures, licensing structures. But all of these issues are gonna help inform how we're gonna start really moving forward with structuring licenses and fees because energy usage is gonna look different depending on the size and scale of an operation, whether it's indoor or outdoor, same with environmental issues, groundwater issues. We can really jump down that rabbit hole, but I think if we are gonna work towards a lot of our deadlines in 2022, we really need to start getting as much clarity for folks that are planning to put plants into the ground as quickly and expeditiously as we possibly can to make sure that there isn't any shortfalls or missteps in 2022 as we look to make sure that the market, the supply and demand kind of equalize each other out and we have a successful launch of this program. So the long and the short of it is, I'm happy to take that Mr. Chair if you would like me to. Absolutely, and thank you for that. And it's going to be, as you mentioned, just so instructive on how we structure our licenses and fee structure. So yeah, Kyle, in looking at the, I'm kind of combining items on the agenda right now only because we're running a little bit behind schedule, but in looking at the advisory committee, if you wanted to kind of appoint a subcommittee of those members, and this goes to you as well, Julie, which ones do you think make the most sense? And just for the benefit of people watching, a few people have been named to our advisory committee, but I think the vast majority of them have not been named at this point. So we're talking kind of theoretical advisory committee based on the expertise that's laid out in S25 and Act 164. So just for a point of clarification for myself, I know that when Michelle walked through 164 with us earlier, there's the energy piece and then there's the environmental groundwater agricultural issue piece with the secretary of natural resources, secretary of agriculture, and because I think the, and I don't have 164 in front of me anymore, but I think directly underneath that, there was kind of a report or recommendation that we would be provided with each one of those kind of two prom combined into one larger recommendation. Is that correct? If you both can recall off the top of your head. Yes. If that's the case anyways, and looking at the advisory committee, I think we would need in that subcommittee, the chair of the public service commission, secretary of agriculture or designee, I know we've received some from the agriculture already, secretary of natural resources, I don't have it in front of me anymore. And I apologize for that. Whoever, it's easy to say whoever else makes the most sense to have in that kind of role, I guess another thing that we need to discuss is do these subcommittees strictly come from members of the advisory committee or would a coordinator invite an expert or organization in the greater Vermont community to help participate in these subcommittees? So the members that are named in our advisory committee are either state employees or private citizens. Private citizens are entitled to mileage, reimbursement and a per diem. So I think people within the state, the state government would are more than willing in my experience to help out and offer technical support for us, but we need to be careful about members of the public only because we're not gonna be able to provide them with a per diem. And most people have a job that they can't just drop to do this work. Yeah, and I mean, I think the three of us agree that public input is gonna really form the foundation of what we're trying to do. And I think one of the ways we can kind of thread that needle or walk that tightrope is, as you mentioned, Mr. Chairman, each week, what's the flavor of the week? Is it energy this week? Invite certain organizations or folks that are relevant in the state and at the national level as well or have experience in doing this with other states to come and speak with, whether it's the subcommittee meeting or the board meeting more broadly and engage the public in that respect and then have the subcommittee go over certain recommendations, thoughts, perspectives that are offered in that type of structure. And going back to your question, Mr. Chair, for this particular subcommittee, probably the person with municipal experience just because there are probably a lot of local rules that might be impacted and then maybe either someone with expertise in women or minority-owned business ownership or social justice, just so that equity continues to be sort of the thread that ties everything together. Yeah, and it's gonna, I agree, and it's gonna be challenging. I know that we've all said this today and other times that everything is so intertwined. It's gonna be hard. It's easy to stumble down, oh, this person should be in this subcommittee, this person should be in this subcommittee, this person should be in this subcommittee. So we just gotta figure out where the, excuse me, where the fine line is to kind of put a line in the sand and kind of work in subcommittees as we can while still recognizing that there's gonna be a lot of cross collaboration between these committees to make sure that all of these recommendations kind of fit together like a puzzle without any missing pieces. And I suspect we may need to amend this over time, right? We may get into a subcommittee and realize that we're missing some expertise and need to pull someone in or maybe something like that. And as our work shifts, we'll probably have to change how our subcommittees are comprised, right? So. Well, I think that another kind of looming deadline that we have that is important to all of us is maintaining the continuity of services and diversity of products and integrity of the medical registry. I'd like to take that on unless anyone feels strongly about doing it. That's all yours. I feel strongly about it, but I won't. I'll actually ask you. So for that, again, just looking at the advisory panel, it's hard to know without knowing exactly, when you see a member with expertise in public health or expertise in laboratory science or toxicology, it's hard to know specifically what that's gonna mean. I guess I will just for now, take laboratory science and toxicology given what we've heard from Jesslyn and others. So just for a point of clarification, I believe as 25 amended 164 to not, we need to hear by July one from all of points of contact informing the advisory committee, correct? So I know that we still know who the 14 members generally what buckets they'll be or what expertise they'll be bringing to us, but recognizing that we don't know specifically who those folks are, it's still gonna be kind of, let's see what we can get done over the course of the next month, recognizing that a lot of those spots are still empty. That's right. So I think, what did I say? I think we have four names that have been named at this point. And I know that I've seen the social equity caucus received an email from the speaker of the house requesting recommendations for the appointments that that office is in charge of. I've reached out to all the appointing authorities and just reminded them of their authority to appoint and the data's changed a little bit. They were all operating under kind of a May 1st deadline, but we had missed that at that point already. But I do anticipate us having these names by July 1st and hopefully before. So the medical registry, I think it also of course makes sense to the chair of the cannabis for symptom relief oversight committee or designee and the Vermont Cannabis Trade Association. I mean, the social equity piece, I think deserves immediate attention. Julie, do you mind? I'd be happy to take that on. Okay. In fact- I got to a point. Yeah, go ahead. No, please go ahead. No, I was going to refer back to something that you mentioned previous and just make sure we don't forget to mention it. And so why don't you- Don't forget to mention it. So sorry, I don't know if you can hear me. I was just, I wanted to mention that obviously you mentioned earlier that there is organizations, coalitions, experts that we want to start hearing from now that we're kind of moving more into the substance and business of the board. And hopefully we can start to line up some folks to come and speak with us next week and in the week's following. I know certain organizations focus on certain issues. Others have more of a broad focus. Some have formed coalitions. The list goes on. So just want to make sure that we take the time to find some time to schedule them to come in and speak with us. Yeah. And I think the sooner we do some of that outreach, the better. And so once we have kind of just a rough outline of kind of the work that we're dividing up, I would encourage both of you and myself included to think about who those experts are that we can call in if we're going to do, for instance, next week, week on prioritizing the legacy market and small cultivators who we would want to reach out to to come help us talk to us about it. And just for the benefit of people watching, we're tentatively going to schedule a meeting for next Thursday from the kind of nine to two area, depending on people's availability. We are still waiting to adopt a regular meeting schedule until we have an executive director. And the reason for that just is, we don't know what kind of time constraints the executive director will have. And we also want to optimize the public's ability to join these meetings. So as soon as we have that decision made, then we're going to adopt a regular meeting schedule. But and our intention is to kind of formulate an agenda on Friday and hopefully get it posted by Monday for this, for next week's meeting. But Julie, if you were thinking about a subcommittee or generally speaking, social equity issues and you know, it's a tough one because we've been advised by Susanna and others to take a very broad view of social equity. So, but if you just had kind of a first go at a subcommittee, do you know who you would want on there? The person with expertise in social justice and equity issues, if we haven't already assigned, I've lost track of who we've assigned and who we have not. The person with expertise in criminal justice reform and then maybe the person with business management. And I think that's every, or the, yep, sorry, go ahead. No, I was, no, keep going. I was just going to mention something at the end. I think that I was, I think I was done. Okay. The only thing I was going to mention is things along the lines, the definition of social equity applicant and some of the technical assistance in business management and training, you'll be required by statute to work with the Director of Racial Equity, ACCD, DOL, probably Department of Labor and Department of Corrections. So, whenever we start that work, someone from those organizations should be involved as well. Yep, absolutely. Well, this is certainly a good place to start. Dude, do we want to do just one more that kind of prioritizing legacy market and small cultivators, you know, that's clearly a driving motivation behind this bill. Is that something we should take on as a board or something that we should assign as a subcommittee? It probably makes sense to do it as a board. Because I see that going to each of the things we just discussed, right? Yeah. Yeah. It's right. Yeah, I think we all bring a certain level of interest and understanding and expertise to that important part of what we're going to accomplish. I think that authorizing legislation gives us a lot of tools. And I want to make sure that we're all working in, you know, on the same up when upward beat, when it comes to figuring out how to utilize them on the right way. Well, then for that one in particular, I would just encourage you both, and I'll do the same to just really think about who we should hear from. And, you know, maybe that's a good topic to do next week. Just, you know, I doubt we'll have our executive director in place by then, but I think it's a good one to kind of start thinking about what barriers exist and what we need to do to accommodate the legacy market. Mr. Chair, circling back, I pulled up S-25 and I just wanted to tease out a little bit more on who I think would make for a good membership on the subcommittee for energy, environmental and land use issues. I know I mentioned Secretary of Agriculture. I think somebody with expertise in the cannabis industry makes a lot of sense here as well. Secretary of Natural Resources or Designee, I think I mentioned that one. And again, you will be or we will be required by statute to work with the Public Service Department and the Public Utility Commission. Right, right. I recognize now that they're not explicitly mentioned as it relates to the advisory committee, but they will certainly play a big role in helping us understand the intended and unintended aspects of how we structure this. Well, I think, sorry, one more. One member with an expertise in business management or regulatory compliance appointed by the treasurer. Yeah. And, you know, Kyle, as you think about this, I think your initial instinct is correct that trying to lump together environmental energy and land use and groundwater all into one subcommittee is not gonna, you know, it's gonna be just, I think, too much. So definitely kind of, and if you wanna hand off one aspect of that or multiple to either Julie or me, please feel free. Yeah, let's see how it rolls. Yeah. And I think we're all working towards a common goal and we're very, it seems collaborative. So I am happy to be forthright if it's not, if the puzzle is not fitting together and that's specific area of what we're trying to accomplish. Okay. Yeah, I mean, again, you know, I hate to just be a broken record, but all of these issues are so intertwined and they're so, they're all gonna determine kind of our licensing structure. So it's hard to really be kind of not knowing what each other are doing. So, you know, we will have to, you know, this is only designed to allow us to get to work while we're outside of public meetings. And when we come together, we'll have issues teed up that, you know, you can bring information to us and then we can kind of think about how the whole puzzle fits together. Agreed. Well, I really do think that's a good starting point for us and again, we'll get together and draft an agenda this Friday for our next meeting and hopefully it'll be dedicated to one of these issues. And we can hear from witnesses. You know, the, I'd like to open a public comment before we do just an update on our executive director. So we, at our last, at our meeting last Thursday, met with our finalists, you know, we decided to, I guess, sleep on the decision about who we wanted to advance is our absolute finalists, our final candidate. We met yesterday to discuss that as a group in executive session of an open meeting. We all agreed unanimously on who the candidate should be and I've reached out to that person. That candidate's gonna join us in an executive session so that we can make a conditional offer, you know, negotiate a salary and there's a few in a start date. There's a few administrative details that need to be worked out on the back end before we can make a final offer. As soon as we have a final offer accepted, we will announce who that candidate is. And then we can really, you know, get to work on, you know, starting the process of drafting rules and starting to form the structure of this. And then, you know, we've been holding off, I think I mentioned in our last meeting, we've been holding off on interviewing or kind of requesting, I guess, bids for a consultant until we saw what the exact skill set and expertise of our executive director was going to be. So as soon as we have that candidate in place, we'll move to a consultant. And hopefully that organization or person will be able to help fill in some of the blanks of whether the, you know, missing expertise on the advisory commission or committee and, you know, market analysis and some of their kind of more nuanced aspects to the industry. Anything, Kyle, you or Julie would like to add? Nope. No, thank you. Okay. Well, at this point, I'd like to open it to public comment. For, again, I'll just, for those of you who have joined through the link and have a little hand, a digital hand that you can raise, please do that. And then anyone on the phone, I think I see one person on the phone. I'll move to you after all the people that have joined through the link have had an opportunity. So if anyone wants to mention anything, please just raise your digital hand at this point. Jessalyn. Hi, sorry to speak again, but if no one wants to take time to public comment, I definitely always have something to share or ask. So the one thing I didn't mention last time, and I think I've mentioned this possibly to you commissioner is just recognizing that the symptom relief oversight committee is a committee that does not necessarily include representation for caregivers and cultivators. It is typically representation for patients who've been appointed by a dispensary and those patients are the people that do have that privilege to financially afford that. So when I look at social equity, I do think about, you know, us considering patients and the financial feasibility. So I wanted to maybe throw out there and mention that whoever is on the advisory committee from that symptom relief oversight committee might be a good person to be on that social equity committee as well. Cause I do, like I said, just want us to continue to look at the financial feasibility of patients and how that unfortunately can be a social equity issue and the present makeup of the committee, which I do think in the future is hopefully going to be looked at and possibly changed a little bit to include more of those voices, which include cultivators and caregivers. And I, you know, I put myself out there as a perfect example of a single mom nurse that tried to use the dispensary system and couldn't afford to do that. So really lean on cultivating for my own medicine. And I like to help other people in that aspect because of the financial difference for their medicine. So. Well, just Lynn, just in response, you know, the advisory committee, as I mentioned, you know, they get a per diem and it's not, you know, necessarily fair for us to ask people in your position or, you know, parents, people that are employed, you know, full time to come help us out. But I do really want your voices at the table. So. Yeah. We'll find, we'll find a way to try and, you know, take the comments that you're giving us and incorporate them into whatever all the work we're doing. Thank you. Any other comments from, um, from the public from the people that have joined via the link. Okay. Anyone on the phone. And again, when you did currently, you have to hit star six to unmute. I hear someone. My name is Barry. Go ahead. Yes, we can hear you. All right. Thank you so much for your service. I am very encouraged by your statements of commitment to small growers and consumer protections. Consumer protections are a very, and vital part in a part of what we're going to be doing at our community. We have failed to protect our medical patients for years now. We have failed to protect our medical patients for years now. And, um, this is mainly due to no third party testing. Um, There is no one, you know, we've, we've got, we've let the Fox watch the N house for years now. There's no one looking at how the big five are producing their products. Or what they're actually giving to medical patients. And it's not enough that they can't cultivate their own and have to go to one of these inventories. I encourage them to find seeds and find a caregiver as soon as possible and stop giving their money to the big five. Um, we have an incredible opportunity, an incredible opportunity to create a craft community that rivals our craft beer community, one that continues to recycle the money time and time again to our economy. Along with this huge opportunity comes incredibly huge challenges. Some of the biggest challenges are going to be for the micro and macro businesses. That we all know are the hardest ones to create. These are the people who have been disproportionately affected by the war on drugs. These are the people who have been living in the shadows for years, keeping the plant alive. And trying their best. To stay out of the public view. We are now being told to voice our opinions. It's hard. I'd like to touch real quick on David Silverman's comments. And I believe it was Senator Sears about the Marlboro's of the pot industry. The big, big, big companies. They're already here. Purely multi-state organization under the alliance of Vermont patient under the alias of Vermont patient alliance is building a 13,000 square foot facility in more town. It's hard to compete with that. I understand that their statutory regulations that have been put into place in act of 164 and S54. It gives them incredible advantages. I also understand that they have to buy 25% of the products from a small cultivator. But if their price is set so low that it doesn't cost, it doesn't cover cost of production. And all they have to say is we couldn't source the product. And who is going to be watching if they actually buy that 25%. You guys talked about a touchstone. I think a touchstone. And I sent a public comment and written about this, but I think one of the touchstones we should all rely on is, you know, every decision we make, every process, every, every, we should ask ourselves, how does this affect the smallest of the small growers? How does this affect our micro and macro businesses or farmers who want to build businesses and want to continue to thrive in our communities? How will this decision affect them? I want to go real quick. I know you guys are running behind. I just want to go real quick on the S54 comments, the advisory committee appointment from the Vermont trade association. It's a representative from the five, from the big five. That was originally supposed to be somebody from the craft community. And it was changed the last minute. So I think we are not happy about that. I'd like to just remind you guys that whoever that person is, their comments are going to be pursuant of that opinion. You know, everything that comes out of their point of view is going to be for those companies. She structures. You guys are, you guys are clothed in the men's power. You know, she structures, rules, business plans, all the stuff that, that you're, you know, your task to do is enormous. And I really, really think you're having an incredible opportunity to help the small cultivator. And if the goal is to bring us into the market, if the goal is to take the black market and create a white market, then we need to do everything else, everything, everything we can, you know, we're growers, we're not business people. We don't, we don't specialize in making business plans. We don't specialize in regulatory obligations. You know, we're going to need a lot of help. You know, this has been tried in multiple states before that have robust economies and huge budgets. You know, you guys have to create a budget based off of fee structures. So right now, just the three of you at $250,000 in salaries, and you guys are going to hire an executive director on an executive assistant, an administrative assistant. And I'm not saying you don't need these things. I'm just saying there's a reality that you have to balance the budget. Right. And if the fee structures are going to be so high for the craft row or for the micro and macro businesses, we're never going to get off the ground. Something to think about. Department of Health. These are all things in act S20, S54, that you guys have power over working with and changing Department of Health working with edibles. Absolutely. Yes. And once again, consumer protection. Very important. Should there be a minimum CBD and THC products? Absolutely no. If somebody wants a CBD product, go get a CBD product. You know, the current market for seeds and strains that are being developed, don't consider how much CBD should be in a product. We can't start breeding right now. If we have a minimum CBD product and THC, we'll be three years out trying to make flowers. The THC caps, if we're trying to bring all of the black marketeers into the company, into the community, into the white market, we have to get rid of those. In act, in act, in a S54, they talked about taking a 60% THC and bringing it down to compliance. They also talked about not, you know, banning additives. You cannot take a 60% concentrated THC products and bring it into compliance without adding additives. So it's a contradiction within the own, you know what I mean? It's a contradiction within the own statute. The only way to fix that is to just get rid of it. Just get rid of the caps. Bring everybody into the tent. All right. Yeah. Thank you, Barry. I just am trying to be equitable here on the time, but thank you for the comments. And you know, we are at the very beginning of our journey. And, you know, I, I hear, I hear what you're saying, you know, I've been listening to the testimony on act 164 on S25. And I'm, I'm, I hear a lot of these, these same themes come up over and over again. So we are listening, but we're just so early on right now and we'll, we will be engaging with you and all other kind of organizations and by about putting this, putting the small cultivators, the small cultivators, the small cultivators, the small cultivators, the small cultivators, the small cultivators, the small cultivators, prioritizing them, putting them first, which the law actually requires us to do. So are there any other public comments? Okay. So we are going to be going into executive session. Again, the purpose of this is to negotiate a conditional offer for our executive director candidate. And we will be adjourning. So folks that want to drop off, please feel free. We won't be doing any more business. The board today. But we will be leaving up kind of our away message while we do that. So for anyone who wants to stick around. So with that, I would entertain a motion to move into executive session. To go into executive session to negotiate with executive director candidate. Seconded. All in favor. Aye. Okay. Okay. Nellie. If you're there. Could you start the recording? You got it. All right. Thank you. Okay. So we're coming out of executive session right now. It's a two 14. And we don't have any further business of the board to discuss today. So I would entertain a motion to adjourn. So moved. Seconded. All in favor. Aye. Aye. Okay. Thank you all. Thank you. Good afternoon. You too. So you can thanks. Thanks Nellie. No problem. See y'all later. Yeah.