 Good afternoon, everyone. I'm going to call the meeting of compliance and enforcement subcommittee to order. Just take a quick roll. Mark Borman. Here. Ashley Manning. Here. I have. I have. Here. There we go. Here's. I actually actually Reynolds. Just taking roll. Yep. Present. Ingrid Jonas. I'm here. You I also see David Cuba. And then he could Scott as well. Yes. Yes. Carl, if you could just give me the names of the board members in your room as well. Um, yeah, we have myself. We've got Julie Holberg, a cannabis control board member. We've got James Pepper, chair of the cannabis control board. And we've got Nellie Marble, our air traffic controller. And we've got right here our executive director. And then we've got two members of the public and Brandon came. And Brandon came from the department of liquor and lottery. Great. Thank you. I just got an email from Tim that he's going to be running late. So I expect him to join us later in the meeting. I just need a motion to make. Well, I want to make sure everyone got copy of the minutes of last meeting. And then a motion to improve those minutes by anyone. I can make that motion. Thanks. Anyone have any issues with the minutes? Otherwise, I'm going to. Prove those and then get to our agenda. Great. Thanks. I'll prove the minutes. What I have is, uh, obviously we've got a, we've got a pretty formidable list of items within this subcommittee. And I, I ranked that priority list last time. And what I'm focusing on are the local ordinances, uh, including the fees. That's also going to be tackled by the market structure subcommittee. Um, I also have cultivation, seed to sale, uh, and enforcement. Those are the four ones that I wanted to focus this subcommittee to focus on first. Now she had some time since the last meeting and the weekend to digest some of that. Um, I'll take anyone's thoughts on that order that we're going about tackling some of these items. If anyone has any comments on that, I'm happy to entertain it. Okay. Good. Um, let's, let's jump into, uh, local ordinances and fees. And I think everyone, again, we're all reading the public comments. Um, we're receiving them and reading them. One of the public comments was talking about changing. It was kind of a request to change act 164 to opt out rather than, uh, voting to opt in. And what I want to make clear for everyone at other scope, we're preparing a recommendation report to the board and then they will recommend, uh, make the recommendation to the legislator. So obviously it's written the way it is right now, written for a reason. The fact that some of them, uh, the county's already opted in means that process has started. So it's, it's certainly within the subcommittee's power to make recommendations. Um, otherwise, but there need to be certain steps taken. I want the public to understand that, uh, to actually go in and change, uh, what the legislation is saying. So when we had some discussion about local ordinances and fees, I wanted to try and put this more in perspective. They're my understanding there. So there's 14 counties in Vermont. Most pop, most populated is chitin in the least populated Essex. And when we're looking at deadlines, there's a reason the market structure subcommittee is coming up first for a reason. A lot of other subcommittees like us are dependent on that. And in other states, uh, there are a certain number of licenses determined, uh, by the market. And then typically limits are set for each county, uh, or area. That's how it is in Washington, Arizona and Maine. There's certain tiers, um, for cultivators and they're accepting, I understand retail on a rolling basis. So they're five or six licenses. So I don't think Tim is on the call yet. But if any of the other subcommittee members have thoughts, I mean, I had, I've notes and questions written down. On some of the concerns were, well, we have to make sure the fees are covering, uh, for the counties. What, what the effect is going to have. And there was the analogy to what's happening with alcohol. Does anyone, and I'll ask Tim this and I can ask him this, I'll, I'll line again, but that is. Um, does anyone have any input on that? Any subcommittee members on Tom, Tom, this is Carrie. I don't suggest we cable this until 10 gets here. He really is the expert and the only one with any real weight associated with it comments on municipal regulation. Um, I have opinions, but they might not. They might not drive with the cities and towns and, and, you know, that's specifically what Tom was here to represent. So I think in terms of your priority list, we jumped down to the second thing on your, on your list. Sure. Um, yeah. And again, I mean, I'll have conversations with Tim and whoever else. What I suggested last time also was, and I understand Tim's just representing one county. Uh, and I think Julie's already initiated a survey to the other counties, but I, I want to get some more input and some outreach to those communities. So we get a better handle on this. So that's, that's fine. Um, we'll come back to, to local ordinances and fees once Tim's able to join us. Hopefully the next thing I had on the list was cultivation. And I don't know if you've had a chance to kind of review or digest what the NACP model was, um, at least looking at some of the guidelines. Certainly there's a lot of other state guidelines on this, uh, on cultivation. And there are public comments on this mostly as you might expect, uh, what are you going to do to protect, uh, the small growers in the state? Um, and what are you going to do to ensure that it's not going to be overrun by, um, large agricultural MSOs? So as a starting point, um, I mean, I'm prepared to at least disseminate within the next week, kind of a draft model for everyone to at least consider. Uh, and we'll, I think the majority of what we're looking at it, they'll be for outdoor and indoor grows. I think the majority will probably be indoor, um, to begin with. Um, but at least we can get kind of the structure, even based on the NACP model of where some of the regulation, what some of the regulations need to be addressed. Did anyone, Dustin? Yeah, I'll carry again. I feel like, uh, the opposite is true in Vermont. Um, largely what we're hearing from folks is the outdoor model. Um, they want to see that prior. Uh, that's, that's actually more important to folks here. And it kind of represents what's in place already. Yeah, and I think, I don't think Stephanie's on here, but I was curious to see, I mean, hemp's a little bit of a different crop. Um, but. So Stephanie, uh, works for me. And so we have about four indoor growers and maybe 600 outdoors. Right. Um, and I mean, how, how big do you think those, of those 600 carry? Can you just kind of break down the size, the acreage of your outdoor growers for him? It varies. There, the majority are less than five acres. Um, we have less than a dozen that are 20 acres or greater. And some, some of those are reaching 100 acres. Okay. Um, do you have an understanding? And I can ask Jim Romanoff this as well. But of, of the, the medical candidates, producers or growers, um, are those outdoor or indoor growers, of those, those five retailers? The medical facilities, um, all do indoor. Right. Two of the licenses last year, they did have outdoor as well behind their building. So CVD had indoor, outdoor, indoor and outdoor. And they were growing for basically three other dispensaries. Okay. Interesting. I mean, I would think with, um, So, you know, our, our sort of back, our home grower, everybody is pretty much got everybody who wants to have probably six plants outside. Right. Um, the, the discussions at least in the sustainability subcommittee, um, are that just the, the weather being what it is in, in Vermont. Um, they at least were predicting most of, and yeah, in Canada, the marijuana clients is, um, is a lot more delicate than him. Uh, and requires much more specific growing conditions. Um, their inclinations were that most of the, of, of the grows would be indoor. But, um, I mean, I, I need to gather the data and thoughts on, on what that looks like. There will be, you know, grants for both indoor and outdoor cultivation. But yeah, thanks for that because I was, I was relying on what they were saying sustainability. Um, that most of it would be indoor cultivation, at least to get the, the harvest. Hey, Tom, I can, I can speak, I can speak to that quickly. Yes. I've been in that committee. I know Billy had kind of made some assumptions. I know we're making a lot of assumptions, at least from our model perspective. I think, you know, whether we start with indoor or outdoor from a standard or compliance perspective is, it's for the subcommittee to decide. I would like to see a mixture of both, but personally, I think, you know, the model will help us understand from a production perspective where that line is between indoor and outdoor. Again, there's, there's a lot of assumptions in that model that I'm sure will be adjusted by that subcommittee. There's assumptions that were made in the sustainability committee, just recognizing, you know, controlled ag environments, um, you know, produce a more consistent crowd, so to speak. But Kerry is also spot on where there's a lot of, our market could be made up of a lot of small outdoor, or a majority of small outdoor growers. And where do we strike that balance between the two is, you know, something still has to be figured out. And I do feel like, you know, when, when we do have enough, I believe where we'll see people grow outdoor in the summer and then move it indoor in the winter. Because you can get two crops indoors while you're waiting for it to get nice outside again. Yeah. I'm not trying to derail the conversation here. I just think we are going to see preference for both, especially from the small, small field, where we're going to see preference for both. Um, one of the other topics that I wanted to make sure we covered is the requirement for seeded dale. Um, that was originally part of the coal memo that's more or less now defunct. And I don't think we need a seeded dale system in Vermont. Only because, you know, it's sloppy in Colorado. They use the RFID tags. Um, it, we're not really in a position where we're necessarily concerned about diversion as much as other crops. That's what the other states were. Um, this, you know, diversion being sales to other states, right? That's what this was trying to keep a handle on. The seeded dale was dale to other states and making sure that it stayed, that stayed in the market in the, in state. Um, we're seeing bleed from the other markets into Vermont now. So I'm feeling like seeded dale isn't necessarily a requirement that we need to include in a Vermont system. But we don't need to hear what other people have to say. Carrie, I think that's a requirement in 164 though. So we're tied to that. We're tied to that right now. Yeah, it's, it's absolutely in 164. And it's actually one of the ones that I selected to be in this kind of top four list for a number of reasons. I'm not, I'm not aware of a state that doesn't have this as part of the regulations. And it's not just, I mean, there's a lot of different purposes for it. Certainly one is to prevent interstate dissemination of the product. But the other one is when the market matures as it's been doing in a lot of states, and these businesses want to get things that normal small businesses have access to in order to be successful like banking services, like insurance services. Um, the banks that I know, um, the audits are very aggressive and they're very thorough. And one of the things that they take off first on their list is the tracking and tracing mechanism and how vigilant that particular business is with it. And I think you're going to put some of these businesses that kind of behind the other states if you don't, if you don't mandate this. And it's certainly, you know, a different way of doing business. Um, but, you know, as, as we grow in legitimacy, um, that that's just that that's how I know banking specifically insurance is going to look at this. Very good. I just thought it was worth having a conversation. No, that's exactly what I want because I want to make sure we're all on board with with the reasons we have as priority lists and why they are important. And, you know, see to sale is one of the things that I think the license holders need to have in place. And I don't think I don't think it's that's an item that's going to be more difficult only because it's fairly prevalent out there. And I don't know if it's necessarily, you know, I don't know. That's one of those things you have to tweak that much for Vermont. So that was another thing I was going to suggest. I mean, there's certainly a lot of software programs out there. And, you know, we're not pitching one over the other, but I was going to disseminate some model rules for that to have you look at and see if they made sense. That's very good. Okay. Okay. I don't see Tim yet. So I'm going to move down to we had discussion about enforcement and more specifically who would be handling enforcement going forward. And I think it's positive. I mean, the way the legislation is written, I think it's a three year sunset for the CCB. And certainly that can be extended or revisited. But if anyone else has had thoughts and again, there's also the language in the legislation that encourages the board to make use of strategic partnerships and other agencies out there. And I know we also do have the representative from the DLL in the room. But for maybe we get to that introduction. If anyone else had any other thoughts about other agencies that we can bring in and just kind of ride first what they could offer. Tom, if I may, I don't want to put my colleague from DLL this box. He came, not intending to, but Dave Huber's on the line and he's had enforcement for the agency of agriculture. And I know Brandon and myself have had conversations with Dave on how they go about from a cultivation enforcement perspective and other services that they do. Dave, again, this isn't my meeting. I'm sitting in this helping calm. But for fear of putting you on the spot, maybe a rough overview of how you approach things with your agency might be helpful for the group. That'd be great. Sure. And, you know, hi everybody, I'm Dave Huber, director of enforcement for agency of agriculture. Before I jump into anything really about enforcement and agency of agriculture, are there any specific questions that everybody has? I mentioned that everyone has already researched plenty about this topic and Tom sounds like you've got quite the expertise. Are there any questions that you have about that? I actually don't have the Vermont expertise in this. That's why I'm curious. So, could you just describe how large is the enforcement division? Is there, does that also include kind of, is there an appeals process for that? Just the broad brush strokes for now or at least me a lot. So, it's all administrative law. It's not criminal, it's not civil. I haven't practiced all those as well, but this is Bren and Butter administrative law. So, what we have over at the agency is an administrative law section. We handle all enforcement across the board for the agency. So, this is for water quality, air culture, non-point source, water quality, feed seed, fertilizer, pesticides, nursery, ginseng, seed potatoes, apiary, hemp. And then we also provide any help to any other division that is looking to start up enforcement such as maple pathing. And there is also enforcement that's done through dairy sectors and meat inspection and animal health. So, we do have quite a large robust process for handling multiple types of subject matters needing enforcement. As far as the administrative process and appeals, every action comes with its own set of appeals from the lowest level all the way up to the top. We do have the ability to file any of our actions with the Superior Court. Generally, we choose not to. It's just a lot easier to keep it in house than it is to go through that system. We find that it works out pretty good. I think one thing to note is that the agency does employ a very good approach to administrative law enforcement. We do have discretionary enforcement discretion when it comes to where to start a case and how hard to take that case. We do have MLUs in place with other agencies. Agency of Natural Resources turning generals off. Just in case we have a case that we would like to bring another agency in on. So having an MLU or a process there to help bring that case to fruition is not unique with any agency, but certainly the agency of agricultural authority employ such a technique. I just wanted to add to sort of that process. We do inspection in the program. So we have strategically played field staff throughout the state who will do an inspection if they find a violation that case comes to the office for enforcement review. If they have a violation, it gets referred to the enforcement section. They take that, send out a letter of a notice of violation with an opportunity for a pre-hearing or a hearing. Generally it will be a pre-hearing process. If it is not settled in a pre-hearing it goes to a hearing with a hearing officer. But we've got a pretty good track record of closing these cases with assurance of discontinuance documents at the pre-hearing level. Thank you both. And it's my understanding from Stephanie that the HEMP program has its own investigation of enforcement or have you assisted? It's the same. It's the same. So every, you know, all Stephanie's cases go through me. Anything dealing with any of Kerry's cases go through me. And we try to settle as many cases as possible as long as they're right for settlement. We'll take them the entire way if necessary as well. So David, it's your field agents that do the investigations or inspections for the HEMP farms? Mike DiCamasso is one of the HEMP inspectors who reports to Stephanie. Which I was trying to describe, the field agents are in the program and we're a little bit broken up. It's the same agency but the program staff do the field inspections and that gets referred to enforcement if there is a violation. They've handled that and but I'm willing to use the basically six positions I have right now to do inspections and enforcement at cannabis facilities because it will be a joint because they already do nursery inspections. They already do pesticide inspections. And this is a good fit for that field staff and we would utilize that field staff and the enforcement process that Dave has outlined. Now the report that the previous cannabis commission put together for the governor two years ago envisioned a model where the agency did the consumer protection quality control for the growing, the processing and the Department of Liquor and Lottery maintained enforcement authority over the licensing and retail inspection of cannabis products. So it was a combined effort split where the agency of act took it up to the point of growing, processing seed to the point of sale and those because liquor and lottery had experience with municipal government interaction as well as the sort of underage verification process that they would do the retail inspections and enforcement. So we would have the agency of act would handle growing, processing and all the nursery inspections, seed certification type part of the program, the consumer protection quality control piece and liquor and lottery would handle the enforcement of underage sale and retail whatever came along with retail inspection. That was what was proposed to the government in the last report. Okay. Thank you. Sorry people. I think you may seem like I'm asking the same question. So Stephanie Smith under the hemp program has her own field agent that does the inspection or investigation and if there's a violation then the enforcement is sent to David. Do I have that right? You do. Okay. And do you have any idea how many field agents that are within the hemp program? Mike, one. One. But I have more that I'm willing to devote to cannabis inspection. Right. Okay. Carrie and Dave, can you, this is actually, I just, I was real just curious if you can even ballpark this, but like in the four or five years that this program has been, and that program has been enacted. How many cases a year are we dealing with here? They go to enforcement. Yeah. Zero. I don't know if we can talk about that. Isn't that a ballpark? I mean, not cool. Yeah. There's been some significant enforcement actions and you've heard about a bunch of them in the news over the years. Most of the violations are letters of warning about registration. There have been instances where folks are growing something other than hemp. And those are the ones you hear about. Those are sort of bigger enforcement cases. Yeah. Okay. I'm just curious. And I can't say how, I don't know exactly how many, Dave, are you aware of how many letters we've sent out to folks who have not registered? For this year, for last year. Or combined both, sorry. So probably around 20 total just for that specific interaction. Most of those do result in compliance very quickly and are closed out as soon as we ascertain compliance, which sometimes is just as simple as receiving a check or we're just having the appropriate registration completed. What about on the medical side? Is there a dedicated agent for that as well? Yes. Yes. And that's with the Department of Public Safety. Right. Okay. And the enforcement, does that end up with you as well, David, or it depends on the violation, I suppose? If it's something that goes to public safety, we do not have enforcement for that. Well, we have a referral done to us from public safety and we have referred to the new public safety. Right. So if there's, so right now from the medical program, if there's a violation, at least with something on the growth side, the cultivation side, that's being investigated by a public safety agent? That very much depends, right, other agencies are involved. The only thing that the medical program really latches onto is diversion, diversion of product. The consumer protection and quality control piece doesn't exist. But for all of their growers, all of the medical facilities do have certified pesticide applicators and we have enforcement over their pesticide use. Okay. Use storage inspection. So the pesticide piece is with the agency of ag. The wait and measure piece, like if you're selling an ounce, it needs to be announced. That's with the agency of ag currently. But the diversion and regulation of those medical facilities, medical cannabis facilities is with the Department of Public Safety. Got that. Okay. All right. Thank you. That's, that's extremely helpful. Mark, did you have any other questions with the existing structure? No, I did not. Tom, can I provide a comment from a board level perspective? Sure. And Dave and Gary, if I'm wrong in my rough back of the napkin numbers based on our previous conversations, let me know. So I know, you know, somebody calls and complains about the program for one reason or another. That's something Mike may go out and investigate. It's also my understanding that Mike typically tries to get out to 20% of registered users in a calendar year. Okay. Good. That's, that's a correct number of my head. I think it would be helpful for me as well. Go ahead. Yes. 20% is an accurate number problem. So I know Kerry is kind of waiting to see our market analysis to kind of see if, if, if we were to come into an understanding with the agency of agriculture and their enforcement team to, to, you know, provide resources to hire more inspectors or devote more time to this emerging market, what it would look like. But I think it would be helpful for the board, for the subcommittee to determine, you know, if Mike's only doing random inspections of 20% right now, what would that random number look like for the high THC cannabis market? Would there be enough consumer protection and community safety aspects to where we're only randomly inspecting 20% of, of license holders a year? Does that number need to be higher? Does it need to be 100%? So keep that in the back of your mind. I think that's something that the board is interested in understanding more of. Kyle, I feel like the sampling and the testing and sampling requirements are going to drive some of that and they're going to drive it really close to 100%. Totally get that. Just, you know, what number makes sense? I'm just, I'm just throwing it out there. It might be that 20%. I just, I would love to get all the smart minds on this call to help us make that determination. Yep. That makes sense. Thank you. Because I know that will also drive those resource numbers here, you know. Yeah, I do. I don't think, I mean, there's still some time left for Tim to join us. But, Tom, there's one more thing I just wanted to add real quick, if that's all right. When it comes to the division that handles this over agency of agriculture, as far as the, all the, you know, public health and agricultural resource management division topics, which it sounds like this would probably be fitting into that if that were the case. All the agents that Kevin's talking about outside of Mike, who's strictly hemp, they are cross-trained in all the other programs that the agency does do and does do enforcement for and does ascertain compliance. So if they go out to an area and they see something that might be a violation, but it's not a violation of the program for which they're going out there specifically for, they would also be an internal. And they may go back out there with the hemp inspector. And likewise, when the hemp inspector has been out to other farms and see something that might not be a hemp violation, but does see something that triggers, hey, this might be a violation of another program that the agency does do. The internal referral is very simple, very easy. It's a very watered down version of our referrals to outside agencies or outside council over at Attorney General's office. So, you know, we already do have this in place with the agency of agriculture where there is a very, very broad knowledge of all the programs that are run jurisdictionally through agency of ag. Very good. That's helpful. Thank you. And Karen, what were the numbers again on the number of field agencies you had? It's up in the air. Depending on me to see what the resource demands are could be potentially fixed. That's without asking for positions from the legislature. Okay. Okay. Thank you. I wanted to, most of what I had discussed was on kind of low ordinances and I know we still don't have Tim. But let's hear what you had to say, Tom. I was hoping to have a dialogue on recorded, with Tim recorded just so it would be on record, but let's hear what you put together. Well, it was mostly more just information gathering and we do need to have that conversation in the meeting. But if we're looking at 14 counties in Vermont and... Tom, let me just, Massachusetts has county government. Vermont has no county government. So we do have individual towns. So we don't have a... There's nothing in a county that pulls that county together in a governmental model, unlike Massachusetts. You know, we're dealing at an individual town level. So it's 246 pounds, not 14 counties. Yeah, and that's exactly what I was trying to get a handle on because Tim was saying in the last meeting in some of my conversations, different towns, different counties, level of resources. I mean, even his county, his town, it sounded like he said, yeah, we've got everything on board, we've already opted in. And the survey will go a long way towards getting a better handle on this, but what does that spectrum look like? Even within, if you're talking 240 plus towns, what are the level of resources? Because at the end of the day, they're going to have to put their local ordinance together themselves, particularly in zoning, on how they want to control some of this. And that's going to drive a lot of the success of the program. Yeah, I think that's going...Zoning happens on a town basis, not on a county. Right. Yeah. So, yeah, and maybe this is... Yeah, maybe these are conversations, Julie, that we need to have with the surveying and getting that information. I want to be able to help kind of steer the education of those towns if that's what the level is going to come down to. And also find out what the level of receptiveness is or knowledges of what's going to be rolled out. So I would say that the survey, yes, and then maybe also hearing from the legal cities and towns. Not all, but many of the towns in the city of Vermont have a membership with the legal cities and towns, and they could probably give you a pretty good overview of what that depth and breadth of a town is in terms of their resources. The legal cities and towns. Tom, while I spoke to what the governor's, the previous reports of the governor has stated in terms of breaking out a career in enforcement, but since folks from liquor and lottery are in the room, it might be nice to hear from them if that's still a scenario that they would entertain. I don't know. So for the record, he showed up as a member of the public. We did not formally invite him, so I fear too much to put him on the spot, but to the extent that you have any. Yeah, I'm happy to just speak with that real briefly. I mean, I think that that model to me, I'm not in a position to make decisions for us, obviously, but I think that that model makes a lot of sense to me. The agency of AG clearly has that in their wheelhouse to manage the crops and stuff where we would be much better positioned to handle the point of sale. Yeah, and Kerry, just so you know, I have had conversations also with DLL and they are willing, certainly, to lend resources, not just kind of the gross side, but also with licensing as well. And we'll continue to have those conversations. Yeah, Tom, I know we're all kind of like a broken record here, but they are my conversations with Styler, who's kind of the head of enforcement at DLL. Like everybody wants to see our market analysis, what we're looking like in terms of expected number of licensees to the extent that we're able to provide that in October to kind of get a handle on resources and what might be required through an MOU from a cost sharing perspective. Yep, and that is a meeting coming up in just a couple hours here as well. I've also noted, and I have our general counsel looking at Title 7, where DLL gets enforcement jurisdiction and what type of legislative fixes might be appropriate to include those inspections when it comes to how the current lottery functions as a state agency. Good. Yeah, and as I said, I mean, there are states, in Washington, it's called the Department of Liquor and Cannabis, and certainly in Nevada and Las Vegas, there's a lot of control on the liquor side. That model is out there as well. We have about five minutes, so I wanted to open it up. I also want to try and leave about 10 minutes for public comment. Any other topics that the advisory committee members want to bring up, and then I can kind of give us the action items for next meeting that I want to address, and I'll try and get hold of the team between now and then as well. Nothing? I've stunned everyone with the level of information that we've got. We're going to have to digest and get ready. So what I will do then as far as action items, I will have a conversation with Tim, just trying to get some more information and data from his perspective on the towns and the counties. I will also send out kind of a more comprehensive version of cultivation, breaking it down between outdoor and indoor cultivation. And also I will send out, just as far as reference materials, some models for C2CELL tracking legislation as well. Anything else anyone wants to add? Because at each meeting now I want to keep going through these four items. It's going to be local ordinances, cultivation, C2CELL, and then more thoughts and ideas that we can give a good solid recommendation on how enforcement can look going forward. Okay. This time I'll open it up for any public comments. Anyone in the room might have comments? Yeah, we have one. Hi, I'm Dave Silverman. I'm the High Bale of Madison County. That's what counts for county government around here. I have no duties, so yeah, no power. I'm also an attorney in Middlebury, and I've been actively involved in getting this legislation passed for the past six years. Tom, I just wanted to give you some feedback. The idea of pushing a legislative fix from opt-in to opt-out, I mean, I just think you're going to be wasting a lot of political capital on an effort that will never succeed. And, you know, it's just, it's opposed by the governor and it's opposed by the town lobbying organization, and I think you're going to be swimming upstream on it. And look, I completely appreciate that the current system makes it very difficult for towns to get retail in. Getting a vote is a complicated process, particularly when your local boards are not in favor. As it was in my town, it was very difficult to get the vote, although we did it. I think you might find more success if you were to focus on getting stronger incentives for towns to opt-in, such as by having some local revenue sharing, maybe not quite as much as what VLCT was asking for last session. They were asking for 5%, but if you made a more reasonable ask, you might find a more reasonable response from the legislature. Thank you. All set. Any further comments? I think that's it here in our room, Tom. Appreciate it. And just to clarify, that was another public comment regarding the opt-in and opt-out. I'm glad there was a response to it. Certainly, I'm not personally pushing one way or the other, but those comments are out there. Thank you. Anyone else have anything to add? Tom, I would just say in broad strokes when it comes to, you know, I know Tim, we're talking a lot about fees. I think what might be important for this subcommittee to help the board with is a model local ordinance on how towns that don't have real municipal government and they exist in Vermont and look to the state. And we can do that through VLCT as well. But what is this going to look like? What does local control actually look like? I know the board needs to make that determination as well. But from a local ordinance model perspective that we can share with towns to the extent that we can, that's something that would be important. So I think separating the fee conversation that points from just what does this look like from a local control perspective, that differentiation will hopefully help get things done. I understood. And it's going to be challenging to develop and model local ordinance for a town that's not given any feedback. Now again, I know these are a big part of that, but what kind of control do they have on advertising? What kind of control do they have on areas where retail can actually take form and brick and mortar perspective in a town? That kind of stuff. I just don't want that to get lost in the fee conversation. Sure. Understood. Still a little more time if anyone has another issue. Otherwise I'll take a motion to adjourn. Work on getting that material out to everyone. And then we'll begin again on Thursday. Can I get that motion? Any second? Second. Great. Thank you everyone.