 Good afternoon, everyone, Vermont, and on the line, I call this meeting for the advisory subcommittee for sustainability to order. I'm Tom Alaskao, and I'll take roll call for our subcommittee members, starting with Jacob Pulitzer. Here. Is this right, then? Billy Costa. No problem. No problem. We're still on schedule. Kim will watch them. I don't know if she was planning to attend today. Okay. Okay. And Stephanie Smith? Yep. Here. Okay. And the other CCB members in the room with you? Just myself, Kyle Harris, from a board member level. Thank you, Kyle. And Brynce. Brynce. Yep. Brynce here. You can scroll over to her. Oh. Do you want to be seen? You can. You can just stay here. I'm here. That's fine. I'm here. Bye. Thank you. Oh. And then I'm going to move on to the public as well. So since this is our first subcommittee meeting, well, thank you again for your attendance and reinstall of you that have made the effort in having you attend this subcommittee meeting. And since it's the first one, I wanted to do brief, and I want to emphasize the word and concept of brief, because we have much to do and discuss brief intros for our members before moving on with our agenda. And I'll be speaking very quickly because of our time constraints. Again, I'm Tom Nalasko. I'm the general counsel for the National Association of Cannabis Businesses, or the NACB, which is a national trade organization that specializes in creating standards and best practices for the cannabis industry. Our goal is to legitimize and elevate the growing cannabis market place. And part of our function that we do at the NACB is to consult with various state legislators and regulators as we are doing with this engagement. My personal background, I'm now a 20-plus year attorney, specialized in commercial or business litigation. I've been in the country for about 20 years, starting with cannabis lawsuits, partnership disputes that grew to, like with any good startups, they have legal needs of compliance, employment, real estate issues. I started serving on panels for the Arizona State Bar, where I'm based out of the panels throughout the country on issues ranging from licensing to AEDE to social equity. And so it's my privilege and the NACB is privileged to help coordinate these various subcommittee meetings and create good policy for the state of Vermont. So before getting into introductions, we're very knowledgeable and accomplished advisory subcommittee members. I wanted to introduce another member that's working with the NACB and specialist in this area of sustainability, Jacob Pulitzer. Jacob? Yes, thank you guys, everyone, for taking the time out of your day and joining this amazing sustainability subcommittee. I'm very happy to be chairing it. Honored and glad that Vermont is taking the initiative at the very beginning to make sure that sustainability, environmental impacts are thought about and included into the future recreational regulations. I guess a brief background for me. So I have a background in environmental science and management. I've been focusing on sustainability for the last probably 15 years. Cannabis sustainability specifically for the last seven. The co-founder of the Cannabis Conservancy where we created the first sustainability standards and certification body for the cannabis industry. I'm also a co-founder and board chair of Sun and Earth Certified, which is a regenerative cannabis certification. Also founding members of the City of Denver Cannabis Sustainability Working Group, the National Cannabis Industry Association's Cannabis Cultivation Committee and then the new Sustainability Council, as well as the co-founder of the Southern Colorado Cannabis Alliance, which seeks to bridge the cannabis industry with the conventional ag to help solve food security issues in a often underrepresented area of Colorado. And probably a few other things. And yeah, so mostly focusing on measuring and monitoring the environmental impacts of cannabis cultivation, as well as creating kind of national, internationally recognized best practices manuals. So kind of been completely immersed in the sustainability environmental impacts of cannabis cultivation indoor greenhouse and outdoor. And so while we do these brief introductions, I also wanted to throw in a question if you guys could answer, which is really what environmental impact is of greatest concern for you or your department agency? And I guess to answer that I think for me, not necessarily the greatest concern. But one thing I'd like to see is everyone always talks about energy, water and waste. But I think kind of environmental or ecosystem management and services and conservation and ensuring that there is a spot for craft cannabis and small farmers. I think it's really important in the industry in general, but specifically also to the Vermont market. Yes. So Tommy, do you want to call on someone else on the back? Thank you, Jacob. Yeah, we'll obviously get back to you shortly. Billy Koster, if you want to say hello and give a brief introduction. Sure. Good morning. Good afternoon. My name is Billy Koster. I'm the director of planning for the Vermont Agency and natural resources. I, my work involves a number of areas primarily related to land use, planning and energy siting on the regulatory policy, legislative side, my manager, agencies participation, Act 250, which is the state's land use law and represent the agency before our public utility commission on energy proceedings. And I work across our agencies three departments to coordinate on policy issues where we have, you know, kind of sharing interests across the enterprise and work closely with other state agencies and stakeholders on land use and energy issues. So just happy to be a point person to the technical staff and regulatory programs within our agency and help, you know, guide the work of the board to stand up the marketplace in a way that's environmentally sustainable and responsible and hopefully through a reliance of our existing book of environmental laws, which reminds quite robust and hopefully not seemed great need to go beyond what other industries already need to comply with. So happy to kind of fill gaps and provide information on how enterprises comply with our existing environmental regulations, but hopefully not seeing the need to do a ton of new work to expand existing protections. So thanks for having me. Excellent. Thank you, Billy. Stephanie Smith, if you want to say hello and give a brief introduction as well. Yep. So my name is Stephanie Smith and I work for the Vermont Agency of Agriculture, Food and Markets. I currently manage the hemp program, but I have experience with municipal land use planning, state environmental permitting, farmland conservation, composting and various other things. So I have the hemp background and a little bit of land use background and land use permitting. But yeah, I don't have anything really additional to add. I agree with Billy's sentiments about not reinventing the wheel related to some of the existing environmental permitting that exists in the state, but also finding clarity where that needs to happen and again filling gaps. Thanks. Thank you, Stephanie. And I still think we do not have Kim Watson, but maybe on Monday we'll be able to give her a chance to do an introduction for herself. And then, Kyle, I understand we have some folks in the room from the public as well, I think you said two. That is correct. Great. Thank you. And I want to make sure everyone knows that written public comments can be submitted electronically via the web form on the CCB website. They have been since May 2021. I want to ensure everyone that your comments have been received, reviewed and considered and we do appreciate your input. We'll be time for public comments and questions toward the end of our hour. And in addition, the CCB will be hosting dedicated meetings for public comments at both a Friday board meeting via the public link or at the CCB's public comment evenings, which will also be posted on the website. So your voice will be heard and will be considered. It's an important part of the process, but we do have some pressing deadlines upon us and it's critical we have some constructive communications between ourselves, Jake, and the board members to meet these deadlines. So I do not want the hour to be dominated by public comments. There will be there will be a time for that at the end. And again, your public comments and input can be made and addressed through the different avenues that I just mentioned. So, Jacob, I'm going to let you take over the enabling legislation for this week's Act 62 and 164. As everyone likely knows, the tasks that were listed on there are to develop regulations and standards for returning energy efficiency, groundwater considerations, solid waste, accommodations for small cultivators economic sustainability, and again, focusing on small cultivators. Those are some of the tasks that this subcommittee is is given to it. And so, Jacob, I'll I'll let you lay out. And again, this is this is the first meeting. So we're laying out kind of the scope and addressing some questions and our strategic plan ahead as we develop these. Jacob. Yeah, thank you, Tom. Real quick for jumping into the like the overview of subcommittee goals and outcomes. I did want to just mention that we did receive a few rain public comments. So I did want to address those real quick. There was one dealing with incentivizing LED lights over each PS, as they do with home cultivators, with the example of like a screen mount utility offering two hundred dollars per LED light. They had recommended establishing a separate tier fee structure and working with all utilities. So I didn't want to address that today. We'll be discussing that during the energy specific meetings that we have. But just to mention that we do want to encourage energy efficiency. And in my perspective, potentially not mandating it like they did in Massachusetts, which had seen the unintended consequences of utilities not offering rebates, at least at the beginning. So I just wanted to address that. And then there's quite a few comments and not necessarily we're dealing with sustainability, but more with the market in general, but had to do with making sure that the recreational cannabis industry follows or at least honors pertains to the Vermont pride that you have in food to table, you know, food models, the craft beer industry, that there's a direct consumer approach that allows far and so diversified offerings, what I would call kind of farm gate, as well as, you know, ensuring that there's the ability to create kind of a craft cannabis culture and kind of protections against multi-state operators, which I also recommend to kind of the direct consumers. So there's about three or four comments on that. And then lastly, like one comment on that 164 kind of favors indoor cultivation when cannabis are limited by square footage, I believe this comment here was referring to kind of the number of harvest you can get indoor versus outdoor. You know, it's usually one, if you're doing kind of like deprivation going to harvest, you can get up to kind of three kind of this season extending harvest. So I believe that's what they were talking about. But like, you know, mentioned the capital costs for indoor cultivation, which essentially creates a barrier to entry based on, you know, financial opportunities or financial ability. And then that the indoor expenses will essentially be leaving the state and not benefiting local economies. And then the large carpet and footprint of indoor roads. And they recommended adding kind of a plain town in addition or in lieu of square footage. So do you want to say that that will also be discussed as we get to the specific topics, but will definitely be are going to be considered. And then lastly, that there is definitely consideration for equity and inclusion, that, you know, core values of sustainability, equity, ethical responsibility will be considered as we go through this process. So I just want to address those written comments. Yes. So then moving on, how I had viewed since the first subcommittee meeting was taking kind of a macro level overview of what we want to accomplish. So we're all kind of on the same page as we start to really get into kind of more technical aspects of specific topics. And so I just want to make sure I don't skip something real quick. Oh, yeah. So looking at kind of the overview goals and outcomes. So my understanding is kind of Tommy just said that we are here to provide recommendations to inform the rule makings to the Vermont legislature. My understanding is what that looks like as far as the final deliverable has not been determined yet. So that is how we decide on what we actually provide to the Remarkants control board will be informed with us. Kyle, am I correct on that? Yeah, and Brent can correct me if I'm wrong. So the way that I understand this process unfolding is the subcommittee will and I don't know if there's a specific format that we determine, whether it's a couple pages, bullet points, combination of it, whatever, whatever the subcommittee, I guess at this point determines is the appropriate format for the board to easily digest recommendations is probably the way to go. The board will consider the subcommittees work, vote on that work if we are in favor of it. And if it meets our vision and mission statement that this inaugural board has kind of laid out in previous meetings, we'll vote on it if we vote favorably. It'll go to the legislature. Everybody's on board. It'll be the foundation of what informs our rulemaking process over the next couple months. I think that that's correct, Brent, but correct me if I'm wrong on anything. I don't have anything to correct. I mean, you just add that, you know, the advisory, the goal of the advisory committee is to advise the board and the board is going to submit its report to the legislature based on the guidance that received from the advisory committee and that report that goes to the legislature and the rules, the rulemaking process will all be informed by the advisory committee's work. So just in addition, no correction. Thank you. Yeah, so with that, you know, what I've seen from working in, you know, 10 other legalized states when it comes to these processes or how the rules have been rated in kind of unintended consequences is knowing that, you know, when you kind of write your rules, it's almost black and white, but we live in a very gray world into the interpretation and the attention, I guess, in the interpretation of, you know, the recommendations and ultimate rules, I think plays an important role. So kind of keep that in mind as we start to discuss these things. But I would say, and I'd like to hear kind of the other subcommittee members' opinions on this, but, you know, we are trying to see to mitigate negative environmental impacts and then, you know, the focus, you know, if we do our job correctly here would be focus on outcomes and kind of balancing the aspirational versus prescriptive as far as our recommendations. But kind of what is, I'd love to hear Billy and Stephanie kind of what your thoughts are on that as well. Sure, I think that's a great goal to have. I would just kind of temper it with the reality of time and capacity and the fact that, as I said earlier, Vermont has a very robust suite of environmental regulations to start with. I don't know if that's the case in a lot of the other states that have kind of recently legalized recreational cannabis. I think we're starting from a very high bar already. So I think, I would just encourage you to keep that in mind and I don't know that there's a lot of bandwidth within kind of the state government to stand up new programs or do anything additional for this sector unless it's absolutely necessary to maintain kind of environmental protections. I think having like medium and longer term goals to like improve conditions is a great thing and should be part of any sort of new effort. But I'm just understanding the timeline you're on just wary that, you know, anything new may be difficult to stand up in the short term. And I would encourage you to focus on where gaps exist or where there's unique aspects of this industry that does need kind of special provisions or special attention or guidance or technical assistance. I'm happy to be kind of persuaded otherwise, but that's kind of how I come to the conversation. No, I agree. I was just thinking relative to Act 164 specifically, whether or not there's a list of flex points related to sustainability and environmental regulation with this crop, is there, are there mandates that, I mean, and I've looked at it, but I'd be interested from the word perspective or from others' perspective and I don't have a list in front of me, maybe Claire. But what is mandated by the statute, where the flexibility exists? Because if we already know we have to do something and granted that could be for the short term until another legislative session comes around, but we might need to uncover what that mandate is and what the problem is with it and how to change it or it's fine the way it is and or where those flex points are. So for instance, section five of Act 164 talks about multiple potential opportunities to consider for making recommendations, but then there are other places in the law where it says, but this will happen. And so I'm just curious if we have that starting point in that box. Yeah, I started to for looking and reviewing Act 164, more with the eye of what are potential limitations for us or where the, what's great into the law has potential for unintended environmental consequences. So kind of taking that, I haven't done kind of a full gap analysis, but I do agree. Billy, what you're saying is we shouldn't be reinventing the wheel. I guess what I would love to have you as a reference point forward is now that cannabis is considered an industrial product as a commercial product and not agriculture. How does that, what implications are there for that and what potential ways do we need to encourage environmental things, because an industrial process is going to be different than an agricultural process as far as dealing with, I guess like process or licensing and one of the things I was looking at prior to this meeting was Vermont's kind of cottage food acts and how that could pertain to small farmers and like the oversight of those different agencies but how potentially that could be a guidance for some things to encourage kind of more small farmers and things like that. But yeah, seeing what's already in place with already being used, I think it's the best way to go forward for sure. Yeah, like I think there's kind of two questions, right? There's, this is the cultivation of cannabis is kind of traditionally an agricultural activity that's now being treated in a different way in the regulatory space. So what kind of updates, changes, questions need to be answered to facilitate that transition? Like, are there going to be new issues that arise because of that that we haven't anticipated and can we absorb them into the existing kind of regulatory frameworks or not? And if not, like what do we need to do to get ahead of it? The second question I think is what's the board's goal around kind of the type and mix of cultivators and processors and how can and should the kind of environmental and regulatory frameworks facilitate that outcome? And I think they're kind of separate questions. So, and they're both good ones but I think that's how I'm looking at it. Like I'm not clear what the board is trying to accomplish as far as like indoor outdoor scale mix. So I think as we learn more about that we can talk about how to kind of support and incentivize that through environmental review and regulation. But it seems like the first question might be where the kind of the gaps. I know Stephanie and I have had a couple of conversations around like things that have been traditionally agricultural haven't been regulated for like stormwater and things of that nature and necessarily how are we going to deal with hand cultivation or should we count it as cultivation? Yeah. And if you wouldn't mind what are your biggest concerns right now that you're seeing from traditional agriculture and potentially having this new industry with either farms expanding, incorporating existing farms getting into this industry or new farmers. I think it's probably more of the environmental concerns would be for new farmers who maybe not have the agricultural background coming into the industry. But sure. I think just generally speaking and you know it's kind of the use of water for irrigation. I think that's a manageable piece. It's not a significant concern but just trying to understand kind of the cumulative impact, the kind of consumption from any given operation at different scales. Like just trying to understand you know water consumption for irrigation or what that looks like and make sure it's within some kind of reasonable outside boards and if not you know then we can just figure out how we need to respond. And then the kind of management of organic waste, posts, harvest, post processing to make sure that you know to the extent possible we can try to dispose of those outside of landfills. I think landfills may be an option but to the extent that they can be composted or used otherwise I think there's an opportunity there. And then just this kind of interstitial space between ag and commercial if a farmer who has an agricultural operation also wants to grow cannabis which is not an agricultural crop. You know how do we bridge those things? It's on the same piece of property, it's the same equipment, you know maybe the same approach to irrigation, waste management. Like just understanding what opportunities may exist to provide some flexibility notwithstanding the law calling this a commercial activity. I agree with that as well. That you know just good agricultural management practices necessitate the rotation of crops and if we're putting cannabis in one field one year or every three years and switching it to another place how does that get addressed with that intersection between farming and a commercial non-ag commodity? And maybe we should use the same laws that apply in farming to these operations and they shouldn't be treated differently. I wholeheartedly agree and that actually leads me kind of to a few questions that I had which was kind of to ensure sustainability is kind of valued alongside I would say the public health and legal compliance because that's what we're seeing across the board with every state is it's always kind of an afterthought it's the public health legal compliance that take precedence is making sure that kind of the intention, the compliance and there's expertise all of that in there. So I did want to see is and if you guys know kind of who will be enforcing these regulations and who has jurisdiction over the cultivation and manufacturing side of the recreational market, has that been determined? It hasn't yet taken and that's that's tasked to a couple other committees about these mechanism. So that's still being worked through as well. Okay, perfect. Just trying to not find that. And so yeah, I guess like just some questions to think about is yeah, who will be enforcing these regulations? How will the recommendations and the regulations will they be enforced with Asian capacity expertise available, the compliance process? You know, one thing we've seen a lot of is you're talking about like, you know, an energy demand consumption limitation. You know, are there actually auditors available? Are they trained to be able to do this? You know, looking at kind of how, you know, food safety has oversight. And then specifically, I think, which is beneficial for the licensees and ultimate business owners is how will the regulations be understood, you know, the clarity of them and then how will applicants actually reach or exceed compliance with these regulations? And so I think if we're, you know, this is a new industry, even if they're, you know, already agricultural business owners or industrial business owners, you know, knowing that, you know, how they're actually going to be oversight or how the application process is gonna work is gonna be super important. I kind of deem it that customer service aspect to make sure that on every level, sustainability is valued and not just, you know, an afterthought or, you know, usually in an oversight on some level. So moving forward to kind of better or... Yeah, just, I don't wanna get too far off topic into the issues with the other subcommittees, but it is explicitly in the act that the board is encouraged to utilize strategic partnerships with the other agencies. So just out of curiosity, Stephanie, how has the enforcement handled with hemp? Are you partnering with another state agency or do you handle kind of compliance enforcement appeals within your department? Yeah, so we, within the hemp program, I mean, specifically the box of hemp and cultivation of hemp, it's within the program administered at the agency of agricultural markets. So we do the licensing or the, we call it a registration. We do the inspections and then we handle the enforcement of those, you know. Well, first we provide compliance assistance. We don't come out with a hammer. We try to inform people of how they can comply with the regulations. I think most, any regulatory program, almost all regulatory programs, it's cheaper to get voluntary compliance than it is to come out with a hammer. So that's the approach we use. But relative to like fire safety standards in a processing facility, that's administered by the Division of Fire Safety within the Department of Public Safety. So we do have relationships, but they have a clear box that they regulate and it applies to hemp processors. Likewise, I'm trying to think of other, I'll have to talk in my head, other state agencies that are involved as well. But I mean, it all, you know, again, we just regulate hemp and all of their state agencies apply their regulations and administer those and enforce those. I might add, Tom, Stephanie, and I also know that at AG, you know, they have a pesticide enforcement team. They have a nursery enforcement team. So they kind of work to, you know, I know Mike's out there doing a lot of hemp inspecting, but there's other arms within their enforcement division. Tom, for your reference, and I can share this with the enforcement and compliance subcommittee, you know, Brent and I have had those conversations with AG's enforcement team. I also recognize that this is not an AG product. So maybe us, Billy, the AGC of Agriculture can come to some type of understanding if that's a direction that we want to go, depending on how certain things shake out. I've also had contact with the Department of Liquor and Lottery on how they enforce at the retail level, you know, with ID checks, so on and so forth. So we can, I can share that in my findings there. In the inference of the health department, they inspect kitchens for the food and lodging program. And then again, as Kyle mentioned, pesticides, nurseries, so on and so forth. Within the agency of AG. What I think would be really helpful is for someone to kind of like, chart out like, what the different activities are that you anticipate, like indoor cultivation at different scales, outdoor cultivation at different scales, whatever processing might be involved and like, kind of matrixing out like, the kind of impacts the existing regulatory oversight, like gaps, opportunities. Because I like, this all depends on like, what you're actually talking about, right? Like, growing cannabis in a warehouse is gonna have a whole different suite of considerations than growing it in a field to place. So it's just, I think being able to speak more specifically about the activity will help these conversations. Yeah. Great. And I apologize, I didn't, I wasn't trying to steer this too off topic, but it is important just for the overall structure and the other subcommittees. Billy, just so you know that the subcommittee right after this, so the next 28 minutes is the Market Structure Licensing Fees Subcommittee where they are breaking that all out based on the market analysis that was just recently done. And Stephanie adds, it's critical for us just to understand, and you answered it, but the big item, big ticket items like licensing and enforcement, it sounds like your own adjudication appeals process, that is all handled within your own hemp department, notwithstanding the other agencies that you work with. So yeah, it's helpful for my understanding of it again. Sorry, Jake, if I didn't wanna take it. No, no, yeah, no worries. I was just gonna say is I can create some slides on how we see kind of the processes of indoor to a greenhouse, small, large, and then how different states have kind of tested with different agencies on things specifically with like California has had so many different agencies overseeing it, and it was such a massive to be fully honest that they actually just, I just got an email that yesterday that they have now put it all under one roof so that there's not a different agency overseeing the cultivation, the processing, the distribution, the retail and manufacturing, all of that to allow for, I mean, a lot of it had to do with taxing incentives or just tax burden and the way the market is just really struggling. So I can definitely create some matrices, provide some information for that for Monday's meeting. Yeah, just like the reality in Vermont is that I think most regulatory agencies do their own enforcement, right? So like my agency issues a bunch of permits and we have our own enforcement division for those permits. Stephanie's agency regulates their stuff, they enforce their stuff, fire safety, public safety. So it's all, I think it is this kind of distributed model that sounds like maybe the case in California. It's very unlikely that, I don't want to get ahead of it but I can't imagine that being consolidated into one thing at this time because we have to duplicate a whole regulatory framework for just one vector. So that's just like California's toy different scale, different quality. But I guess that's, you know, to me. Yeah, but I can definitely break down into what departments are usually overseeing these and at least issues we're seeing with that or how they'll be able to, because there's also the state licensing, county licensing issues, you know, we see a lot of just even how cultivation space has been interpreted, you know, it's flowering canopy based off of said square footage, like a raised bed or is a flowering, you know, plant drip line. And so that's caused a lot of issues. I think there's always paying attention to it with recommendations how to be interpreted on the Mac kind of state level, but then also with like zoning issues and making sure everyone's kind of on the same page. And, you know, I think that just helps with the easier roll out and also oversight on all levels. So as far as kind of dividing these into we're kind of on that overview of sustainability scope. I wanted to kind of see your guys's opinion on breaking this into kind of manageable sections based on topics. So in the agenda, I had kind of energy, carbon, water, waste. After thinking about it, I also wanted to add kind of ecosystem management or land management, which would include things like ecosystem services, biodiversity, wildlife, habitat improvement, conservation, erosion control, soil building, that kind of stuff. And then as well as a social equity component, which would be BIPOC community members or any marginalized community members kind of war on drugs or previously incarcerated individuals, economically disadvantaged and kind of the small farmer, craft farmer cohort. But I wanted to see if you guys had any other kind of Vermont specific categories or something that should be broken out into different categories or whatnot so I have a better understanding as I start to map out our schedule. I think that's probably the best way of doing it is these kind of specific topic meetings. I think that makes sense. I guess I'm curious as to whether all these are kind of germane to the subcommittee. I feel like there's other groups that maybe, I think like there's someone who has energy expertise on the advisory panel that's not in the subcommittee. So it seems like those topics should go wherever that person is, but I can't be wrong. There's, I don't believe there's anybody from the advisory committee specifically with that energy expertise. Okay, so you just have the Department of Public Service in. They're not on the subcommittee. I think they were charged with drafting recommendations for us to consider from an energy perspective, but they don't have a set role on the advisory committee. Okay, thank you. Yeah. I would say Jacob from the board's perspective. The board is, and this is for Billy and Jacob and Stephanie and everybody. We're very interested to see how the commercial designation triggers or does not trigger act 250 Billy from a small scale perspective, from a large scale perspective outside. So overarching in addition to the buckets Jacob has mentioned, how land use planning in the state of Vermont will be impacted by this regulated market. We just wanna make sure we're on the front end of 250 if that's gonna be a consideration that we've gotta work through moving forward. Yeah, absolutely. And I know Jacob, you know, yeah, we've, I've initiated that conversation with the Natural Resources Board that administers the act 250 program. And I think you've, the board has at least heard from some of their staff with some general comments. But I think, yeah, that's a question that needs to be answered. And they're the one who answers it, right? They control their own jurisdiction. So I think we're gonna need to interact directly with the Natural Resources Board to figure out, you know, how and if act 250 will apply in those settings. Well, maybe I'm just throwing ideas out here and I don't wanna derail everything that's under sitting here. It might be great to bring them to one of these subcommittee meetings over the course of the next couple of weeks. I don't know who should be the person to reach out, Bryn, we can reach out or Billy, if you have that relationship. But I feel like that's the top of the slope and we're gonna roll downhill depending on how this is impacted by 250. Yeah, because that, you know, there's like the, there's like the baseline environmental regulations around water quality, air quality, et cetera, that my agency administers. But then there's like a higher level of review and scrutiny if projects are subject to act 250. Right. And that really is unique. So I think that is a critical path question. You know, I would encourage your staff to reach out to them and invite them formally to come to one of these meetings. I just think that would have more than me kind of reaching out to them and do it. I'm happy to do it, but I do feel like if the board was to reach out to them and invite them in and provide some context, it would probably be a more appropriate way. Great. And in the meantime, Billy, if you do have any like primaries or, you know, overviews of 250 that you could forward to Jacob. I mean, I can ask the same with the Natural Resources Board, but I don't know how familiar Jacob is with 250 and why it's a large starting point for us. I want to make sure everybody understands. Yeah. Well, I know Aaron provided a kind of PowerPoint to you at a previous meeting. So, you know, that's probably a good primer, but I'm happy Jacob to just talk to you now or at another point to kind of give you a deeper context for the law and kind of how it can apply here, how it can apply here. Yeah. I've read the, I believe it was the one that was posted that they did during a meeting. So, I saw like that primer, but I have a very open cursory knowledge of it at this point. One of the things I definitely want to do before the meeting is I'm going to invite additional experts into each one of these meetings as needed. But one of the things I'm planning on doing is with the VS kind of marketing tool with the estimates that they've created is taking that and looking at from their estimated figures, what does that actually look like as far as energy consumption, carbon emissions, water usage, effluent discharge, waste things like that. So, we can have kind of an in-depth conversations. I think, you know, most of these energy water, sorry, energy carbon and water, probably like two meetings. So, potentially for us to discuss all of that, have the gap analysis and then bring in, you know, some of the natural resources for the second meeting. So, we really understand where we're going with it and then you can have a, you know, a detailed conversation with them. It's kind of how I'm seeing this play out. So, then I want to move along to our, so I was quickly coming to a close. And so, some of the things that I think Stephanie, you had brought up earlier, I kind of had kind of put into this as like potential limitations. So, things that I've been seeing and I talked to Andrew Livingston, who's part of the Incentive Center where he created the model. So, we've worked together on a few projects in the past on just how we're seeing kind of the environmental or sustainability, you know, what we're calling issues or limitations of what's written into the act right now. And I would say like, you know, the ideal sustainable grow is definitely kind of an outdoor hoop house. There you are getting maybe one, maybe three harvests a year. And the concern of really incentivizing or pushing for all outdoor cultivation, you know, is the overproduction that you see the seasonality. And then you have the price swings in the fall and winter. You can look at kind of Oregon for, I mean, last I checked it's been a minute, but they had a million pounds in metric, you know, continually for three years. And it's just not an economically sustainable situation. You know, California every year faces, you know, a price swing of, you know, could be $1,000 to $1,200 a pound, you know, for outdoor, everyone's harvesting in fall, winter, that drops on a, you know, 400, 600. And so it's, you know, those things definitely need to be considered as, you know, we look at what this regular, what these regulations recommendations are encouraging because there's definitely a balance between environmental sustainability and economic sustainability. I think some ways of going about that is looking at square footage caps. If people are really concerned about multi-state operators coming in, you know, if you limit the size of cultivation space, then that's not really an issue. No one's going to adjust, you know, millions of dollars. They can only have 5,000, 10,000, you know, 20,000 square feet of cultivation space. So those are some things that I've noticed. One thing that I'm wondering about the flexibility, you know, as you mentioned, Stephanie is with the product, THC limits. So what I've seen is that there's a 50 milligram per package limit, which is essentially doubling the packaging waste that we see from all other states. Most states have set that limit at 100. So you're looking at, you know, just generically doubling the amount of packaging that's going to be in the marketplace. And then the 60% THC limit in concentrates I think there's some concerns there on, it will limit kind of the overflow or the overproduction of flour that's going to enter the market. Most of that goes into distillate. Distillate usually seed 60%. So you're just kind of creating a potential bottleneck for the storage or self stability of any, you know, overproduction that you're going to see in the market. So I think there's definitely some concerns there from an environmental perspective on the amount of waste that's being generated, but then also what are farmers going to be doing with their final product and how is that going to kind of influence market dynamics? Usually you see if things are on the shelf or stored for over a year, it goes into the concentrate market to at least get another year or two out of it. And if you're at a 60% concentrating, where's all that space for everything you're going to be going? How is that all, you know, going to be impacted as well as, you know, the amount of concentrate to the bank going to be created with the material that's being grown? And then, yes, I guess any comments or questions or anything on those two points? I have something, but Stephanie, feel free to go first. Well, no, I was just thinking that the limitations are set in the laws, I understand it, and in order to change that there, you know, I mean, potentially there could be a recommendation down the road, but it's not going to be immediate. So it's a concern I get, but maybe not an immediate concern because it's going to require some legwork on behalf of the cannabis control board to get a change. And then also to think about what recommendations, what in addition to the recommendation related to sustainability for too much packaging and waste and so on and so forth as you described, what can the cannabis control board recommend that alleviates the concerns that occurred when the percentage concentrate 60% and the milligram per package was set? I mean, obviously there was a concern there, so how do I identify that and move that forward? But again, doesn't seem super immediate immediate, related, you know, but otherwise the intersection of regulation as it exists in Vermont seems something to unpack. Yeah, I was just going to say, you know, that whole conversation, you know, I would really encourage you to look at the Vermont market because I think it's vastly different than the Western states that you may have worked in in the past. I think it's predominantly flower based. I think it's predominantly indoor cultivated traditionally. You know, we've got short growing seasons, you know, there's a lot of indoor cultivation on the black market. And I think that's where the demand is. And, you know, that may shift over time, but I think, you know, just kind of based on anecdotal experience, I think that's kind of what our market is and it's distinct from the West where there's a lot more outdoor cultivation, right? There's more land, it's a better season. People know how to grow outdoors. Here it's different. So I would just test those assumptions before building anything based on them and kind of the extent there's markets, research has been done in Vermont that might help inform. No, definitely. I mean, we also, we work across all of North America. So we are, we have like a desecrescent in Pennsylvania, Massachusetts, Maine, New York, starting to get into New Jersey, Maryland. So kind of all over the place. I would say those places are Vermont though. 100%, 100% Yes, yes, indeed, indeed. And this needs to be Vermont specific. So I do take all of your considerations for perspective, better, more than mine. But I will say as you've seen kind of legal markets, you do start to see more of the baby boomers, more of the soccer marms. Now that it's been state kind of accepted, dabbling into it. And that's where kind of you see edibles, usually overtaking or at least growing pretty exponentially over flower. Most elderly seniors don't want to smoke. Yeah, that's a good point. So I get your vote. Yeah, and also just, I think from convenience, that's where you start to see concentrates. You know, it is going to depend on kind of what the FDA comes out with today or this week, as far as babes and the nicotine aspect of it. And then I've had that translate into cannabis, fake cartridges and stuff. But I think there's definitely, that's the biggest market you see growth once you get a recreational warmer kids. But yeah, I think flower is definitely a predominant product that you'll see, it all does. I was just thinking, I was having a question and I don't know the answer to it, but whether or not, again, because we're Vermont, what percentage of individuals are taking advantage of the personal cultivation of, you know, too mature and foreign mature plants or whether or not they're exploiting that and growing their own and how that's impacted any kind of market projections. You know, it can do society like Vermont who likes to grow things. I mean, we, you know, generally people do. There are people who like to shop for things too, for food and whatnot, but I was just curious if there was any information about that. Such a hard day to get together. I know. We've got some anecdotal info from like the Vermont Growers Association. Okay. But it's hard to gather that, you know, who's actually taking advantage of the personal use and who's exploiting the personal use of doing more. They should, you know, that's a good question. And Billy, we've heard a lot about outdoor growing. Like a lot of folks are very interested in it. So it's hard to assume anything, I think, right now. But to get back to your second question that you posed, I think once we see more of a market structure and how we're gonna tear this thing out, I think it's gonna inform a lot of other committees work because we'll be able to work from a starting point and, you know, there's decisions we haven't gotten there yet. But, you know, I've been a proponent of an indoor license or an outdoor license and tearing it from there. If that's the direction we go, it again remains to be seen. But recognizing that the environmental and energy impacts are different depending on your tiered, your size and your indoor versus outdoor. Right. And again, that's the next subcommittee starting in nine minutes. So I want to reserve some time, Jacob, for the public comments or questions. Partner in the room. I think we're good. All right. So I just had one last kind of question or thought, which was sustainability incentives and encouraging, you know, the regulations will obviously set or already have environmental regulations in place. So for reaching compliance with that, or really going above and beyond, which I think a lot of small farmers in Vermont will be doing or already doing, the incentive programs that are in place right now, dealing with kind of energy, water, waste management, are those state or federally incentivized or managed? What was the question again? Is it for me? I think it's for Billy. I can try and translate, Jacob. So for Billy and Stephanie, with the respect that there is incentive programs built into your respective agencies, how you handle regulatory systems, are those managed at the state level or part of a broader federal partnership? I think, Jacob, it's wondering because if there are federal incentives, it might make it harder for this program to take advantage of various incentives that your agencies offer. Yeah, I'm sure there are federal incentives. Actually, I have no idea if there are federal incentives offered through the Vermont Agency of Agriculture. There are certainly grant programs that apply to the hemp community industry in the state of Vermont, which have limitations on them currently, but I won't go into that. There are grant programs at the Agency of Agriculture that are state-funded, that aren't federal-funded. The Working Lands Enterprise Initiative is state-funded. I think there might be some state-funded trade, well, that's not gonna work. Trade shows aren't gonna happen, nevermind. Trying to think of other potential state incentives. The big one at Ag, I thought it was working lands. Which that would require conversation with Working Lands to try and get this. I think they're even, that would crack the door on hemp, even being a part of that program. Yeah, I'm not sure. The other thing that I was thinking is that farmland conservation, I think there are state funds that can be spent on that. But there are federal funds as well, but there are state-specific funds, which would make that land eligible for cultivation if it's state-funded rather than federal-funded. And then, that's what I have. If I can think of anything else, I'll let you know. Yeah, I don't know that we have a ton of incentives that would be applicable here, or like regulatory incentives. We have access to infrastructure funding through the State Revolving Loan Fund for kind of water wastewater infrastructure that typically flows in municipalities that is federally-based. We've got lots of small pots of money that we put out to folks for conservation practices. But I'm not familiar enough with those to think of any that might be applicable here, but typically they're kind of passed through money from the EPA that we get. But there are also pots of state funds that we use for a number of different things, and often they're commingled. So like, there may be opportunities to use just state funds for certain applications under an existing program, but I can't think of anything that would be directly out of here, but I'm happy to give it some more thought. And I think we try to energy Vermont, because that's also usually big things with the energy and the rebates and the incentive programs there. They're gonna do, like strategic energy management, audits, things like that. A lot of that comes from federal funding. And so just with the 280E issue, yeah, just making sure of that. How do you think about these things? There is quite a bit of state funds that go into the efficiency utilities of Vermont, though. There's surcharges on electric bills and things like that. So there is a pretty significant amount of state funding that goes to efficiency Vermont and those sorts of enterprises. So there may be opportunities for state programs. Yeah, I was gonna mention efficiency Vermont, one of their hallmarks, or they hold themselves out to the community as, we'll help you if you go above and beyond the regulatory floor. So if I'm thinking through this conversation, I think Jacob's wary of going too high from an environmental sustainability floor just so folks can still take advantage of certain efficiency programs that might be available to them. I wanna say that there was a suggestion made, and I think it was a member of the public that maybe the energy when Lauren Merlino and TJ Poor and the other gentlemen presented similar to the surcharge on energy bills to fund efficiency Vermont, whether there was a suggestion to do some kind of a surcharge or charge on at scale indoor grows that would be put into a pot to assist others you know, hand up a business. But that would require a lot of work. But I just remember hearing that and I was like, oh, that was kind of interesting. So I just let's come back to it again. Lauren Merlino is leaving and moving to Oregon, which is a big bummer because she's not knowledgeable. She has a replacement and I have the replacement's name. I'd love to get it for you. Yes. And if that's, so you should address that. So the main program I know that does that is Boulder. So Boulder has an energy impact offset fine, which is a 2.16 kilowatt hour, 2.1 cents per kilowatt hour charge that goes into kind of an energy efficiency steering committee to essentially help to offset or improve energy efficiency measures. So it's definitely something that's already been created to success of the program. I think from, there's a Boulder County program and a Boulder City program. My understanding and talks to the administrators from the Boulder City levels that it hasn't really translated to energy efficiency outcomes, but they do use the funds to install kind of smart meters and energy monitoring and they pay for kind of ASHRAE level one and two energy audits trying to develop the baseline and give the cultivators as much information and strategic guidance to improve their energy efficiency. So I think it's definitely a possibility. And I think part of that also stemmed from just the way I think utilities here initially had tried to treat the cannabis space as well and not necessarily treating them as just ordinary business owners. So I think in Vermont that'll be different, but definitely been tried before and it could be explored. Yeah. Okay, so then with that, I guess we're gonna turn this meeting early. I will work on doing a bit more of a gap analysis on some of the Act 164, they'll probably be in touch with you, even though I guess our next meeting is Monday, so we only have one day, but maybe we should be in touch with you. That's a question. I don't have anything on my calendar other than this meeting. So I don't, I need to understand kind of what the plan is going forward. Oh, okay. My understanding is that we were scheduled to be meeting Mondays and Thursdays for an hour at this time. So that would be 2 p.m. No, that's wrong. 12 p.m. to 1 p.m. Eastern time on Mondays and Thursdays. That's correct. The one and only request I made of your colleagues when we had our initial meet and greet was that people put meeting invitations on my calendar as early as possible. So if someone could please send invitations out for those future meetings, because I don't have anything in my calendar books up solid quickly. So if you want me there, I'm going to need some calendar. Absolutely. And sorry for that. I can get Deli to help with that. Okay. Thanks. Jacob, I'll take your motion to journal. I'll second it. And then we will get the minutes out and we'll be back here Monday at the same time. Thank you guys. Thank you.