Call this meeting to order at 12.02 p.m. Eastern in attendance from the Canvas Control Board. We have Kyle Harris, Kyle's or anyone else from the Canvas Control Board in the room with you. Nope just me this time but we have four members of the public. Thank you. The Sustainability Subcommittee we have myself Jacob Pollitzer. We have, who's that? I forgot your last name. Smith. 70's Smith. Billy Poster, Gina Omnilasco. We also have some technical experts, guests as well. Barry Murphy, Jill O'Connor. And so with that we'll start the meeting. Our first order of business is to approve the meeting minutes. So I sent those out to everyone and wanted to see if anyone had any comments, feedback, discussion or concerns regarding the meeting minutes. Okay so with that I was only to motion to approve those meeting minutes. All right, so any moves? Tom seconds. All of your September 16th meeting minutes. Say aye. Aye. Meeting minutes are approved unanimously. Okay so with that I got to send everyone out. I kind of came up with what I'm calling a guide but pretty much taking today we'll be discussing kind of energy regulation standards dealing with the recommendation provided by the Department of Public Service. First off I'd like to say that the recommendations are actually quite fantastic. I think they take into account those things. And so I sent out a meeting guide. Just kind of break this up a bit. Real quick Billy, were you saying that you can only stay for an hour? Is that correct? Thank you, muted Billy. All right. Yes, today I can only stay for one. Okay, okay. So then we might kind of move this along to get kind of everyone's input and kind of focus on some questions I have. I definitely want to hear from Stephanie and Billy and the experts in place as well. So it seems like with the recommendations kind of broke it down. So we're into a cultivation. Does seem like recommendations are to meet the commercial building energy standards specifically with like the cult for lighting with the non-grow areas as far as for the cultivation. So it looks like you guys are recommending the photosynthetic efficacy for lights at 1.9 micromoles per joule, which is aligned with the new design light consortium version 2.1 standards. So if you look that up so they didn't make those any more stringent. Also provided just a little breakdown of the different types of lights and what the PP is kind of in the range of. But I guess some questions I had was, was this for all cultivation space that you recommend? Just from my experience with cultivation, the HBS or the really the LEDs in propagation is sometimes a bit overkill or financially unattainable. So I did want to see if that's what your guys's thoughts were for recommending that PPE requirement. Yes, that PPE requirement would be for all kind of cultivation spaces. We did obviously, we came up with that number through consultation with no experts in the field and consultation with the new buildings institute and who have been consultants for other states etc. that have come up with these requirements and this seemed to be pretty standard ask in terms of overall light efficacy. Yeah, Stephanie, do you have any thoughts on how familiar you are with indoor cultivation lighting? Yeah, I'm not actually that familiar with indoor cultivation. From the end of the spectrum, there are a few registrants that actually grow indoors as well. Billy, do you have any thoughts on indoor cultivation lighting? I largely refer to the department and their experts on this topic. Sounds good. Yeah, I have some questions. With the 1.9 figure, was that for lighting fixtures or lighting bulbs or did you kind of differentiate or look into that? We didn't differentiate between fixtures and bulbs but that figure as I understand it is based around the bulb. It's rather than a fixture value. Obviously, LEDs and the double-ended high-pressure sodium would require different fixtures necessarily. Yeah, my understanding is like from an LED how they're tested is for the whole fixture because it's kind of integrated and then you kind of have a little bit different for HBS. When you're providing, I think there's some background information there that double-ended high-pressure sodiums do now qualify for the 1.9 and kind of go up to 2.1. Did you do or talk to experts on that because they're actually commercially kind of available from the literature and everything I've seen that we usually sell are used in the figure of 1.73 is kind of standard but it does seem like there are double-ended HBSs available. As I understand it from the consultation that we did, even efficiency Vermont, they've done a survey of the market, the bulbs, et cetera, and the other ones that also pointed out that 1.9 is available. It's a higher end, obviously, in terms of accuracy for a high-pressure sodium but 1.9 is commercially available. Okay. Yeah, there are definitely products on the market right now for high-pressure sodiums. Usually, again, the double-ended high-pressure sodiums that can meet this. So we want to make sure that people that can get into the market can still achieve a good energy efficiency. But if they can't afford the high-priced LED, they still have some sort of options that are still relatively energy-efficient. Yeah, that was my original concern was making sure that light-striking battle highlights of blinded high-pressure sodiums would fit into this and it does seem, at least, from literature and talking to some growers. Yeah, I think there's definitely a concern as more seizure legalizing of just the availability and making sure that because the 1.9 threshold doesn't force growers to find the cheapest alternative and the lower quality and requiring, I guess, more light bulb changes and efficiencies there, but just seeing as though there would be a good metric to track quality for them. Jill, I definitely have would love your insight into how the 1.9 threshold, even 1.7 for greenhouses would impact incentives that are currently available and is for mine with the energy efficiency incentives look at kind of industry standard practice to set that threshold. So rebates and whatnot related features would be available. If you go beyond that, can you talk about that a bit? Yeah. So right now, the way we're working it is obviously we will incentivize the LED products because obviously a standard metal highlight is definitely industry baseline, even the double-ended high-pressure sodiums are getting to be pretty much industry baseline. So we're looking at anything above the 1.9 qualification for probably obviously much higher on the LED products when we're rebating them. So we really want to help people be able to take that next step going up to a more efficient light than even a double-ended high-pressure sodium. So we definitely have the room we're using as of right now, we're freezing standard metal halides as oftentimes the baseline because that's what a company would be installing. So we kind of look at this on a PPFD equivalent of, you know, your cover space in the south thousands per feet. And I'm going to be totally making up numbers here. You might put in about 100 LEDs. But in that same space, you would need if you're planning on a four by four flowering area for metal halide, we would use that number of metal halides as the base number. So I think that comes out to I think it's like 62. So make sure I got my numbers right here. Metal halides on a 16 square foot basis, 62.5 metal halide fixtures roughly would go into a 1000 square foot canopy square foot area. So we would use that 62 compare it to whatever number of LEDs are recommended to make the equivalent PPFD across the board. And the wattage savings there is what we're looking at right now. So and usually there is actually even with a fairly good size discrepancy in, you know, baseline to propose, there's a lot of energy saving thought going on. So are there customizable rebate programs available? I'm thinking about like the intersection between the heat that's put off by like a double ended HBS to be used to offset loader capacity from like an HVAC system for the winter, especially in like Vermont, and how that might interact to for like an overall energy savings program. Yep, usually it's actually we see huge cooling reductions is what we've been been seeing when we're looking at these. That's not so much of a heating reduction, but the cooling reductions that help benefit with the LEDs. So the lower they have to cool even in the middle of winter when they're trying to keep these rooms around 70 75 degrees, the better off they're going to be the more energy savings. Ideally on the indoor grows, our goal is actually to model all of these. And you know, we do look at the lighting on fun scale, but overall we try to model the entire building. So we're looking at what their heating systems are. We're looking at their lights and anything else they're going to be putting into those, those spaces. And we run energy models on the overall building performance. And for a whole building, which is what we're going to try to do most of the indoor grows that we get, we're basing our incentives on the overall energy efficiency of their heating, their lighting and everything all together. So we are taking all of the heating and needs and everything in heating cooling into consideration on these phases. Gotcha. And there definitely can be offsets on these two. Does that also include like for retrofitting of buildings for the insulation above the CBS standard building standards? Right now we're using the building standards as kind of the baseline that they would be to at least have these up to code. So you know, if they're doing additional air sealing we are we can look at that and offer a little bit towards those and that would fall into our standard commercial building code improvements because the fact that it needs to be CVs code for from that. So it definitely gets a little more interesting with these projects because we're working with both CVs codes and, you know, new codes for agricultural spaces that are kind of, you know, exceed otherwise within the growth spaces. So I have a question, I have a question for us to explain it to people. I have a question and it's a question I think I asked the group when we did an energy, had an energy conversation and Stephanie I think I've asked you and broad strokes too. And as you may imagine, to the whole group, it kind of gets back to this agricultural product versus a commercial product. Everything seems to stem from there on a lot of what we're working on. But Stephanie and Jill and your experience with working with folks, whether it's through HEMP or some other agricultural products, you know, I would imagine that the greenhouses across the state are in varying degrees of up to quote unquote code here when we look at the commercial building energy standards. I'm wondering how much work it might be for some of our small cultivators to to get their greenhouse up to these codes because they typically haven't had to with respect to their greenhouses working through the agricultural product perspective. So, you know, for what it's worth, if you have any, any thoughts, I'd like to hear them. Well, I guess it was pointed out by by Jill and probably by a very either on this call or prior conversation that that currently those greenhouses aren't required to meet a code because these codes don't apply to greenhouses. Right. So, and I don't know the condition of greenhouses. And when I actually, I think it'd be important to know what we define as a greenhouse. I mean, that does not include a hoop house. Maybe I think, I think the greenhouses is defined in 164 as a permanent fixture that's standing for over 180 days. I think it was 120 or 180 days. Okay, so it's a permanent. I don't know if the permanent is in there, but it was a structure that is existing in use for 120. I'm going to butcher it. It's 120 or 180 days. I can't remember which one it was. Well, I could say that the PSD recommended a definition of greenhouse as a structure or a thermally insulated area of a building that maintains a specialized sunlight environment exclusively used for and essentially to the cultivation, protection of maintenance of plants, greenhouses or those that are erected for a period of 180 days or more. Okay, that's what I was remembering. Okay. Thanks. Well, yeah, so I would imagine that there's probably a number of actually permanent greenhouses that may or may not meet the standard and I don't know the condition of those greenhouses, but I also feel like I heard or I recall that Kerry said that that that what's being asked is actually industry standards generally anyway. But that doesn't, you know, neither here nor there, there are potentially greenhouses that don't meet the standard because the standard doesn't exist. No, yeah, and that's why I'm asking the question because I know that standard doesn't exist for my time at the agency of agriculture and it's just another step that some folks might need to take and make in order to use a greenhouse in this context separate from what they've been doing in a more historical agricultural context. That's entirely possible, but I have a question on top of that is at what point in time do these standards come into play generally, like all of these standards? Like is there a permitting trigger? Is there an occupation trigger? And then who can ensures that these standards are being met? Like what specific entity is doing that? It sounds like the incentivized like over and above is probably evaluated by efficiency Vermont, but just meeting the baseline standards. Who is envisioned in checking that out? Thanks. My initial view, but I would love to get Barry's take on this is in the recommendations. They do have at least energy, I'm selling energy auditing, but for the application part of things to have, I'm trying to see where it is in the notes of the breakdown is for licensing. It's like equipment maintenance and operation procedures and assessment of energy and water reduction opportunities as well as kind of their estimated like design plans, I would say, like energy consumption by fuel and everything. So like, I think it seems like when they're applying for it, it would be how do you comply with the standard before they get a license? And then they've recommended to do to have self reporting framework. And then once baselines are established, if they are deviating from their metrics is that kind of what you said Barry, I'd love to hear your how this came about. I think you're right. I would say I think you're completing two slightly different things. One is the building requirements and one is like the ongoing kind of operational requirements that we're working and thinking about. Obviously, with the commercial building energy standards, it's a self reporting system. What is generally happens when we deal with for instance, exit 50 applications. There was a requirement that the second after they say that they're going to meet the requirements. And then once the structure is completed, they are required to fill out a CV certificate which says in the middle of that both standards and provide evidence that they've done so through modeling or commercial building energy standards and come check to which obviously doesn't have these cultivation areas, including it because it's new to us. So there will probably be some additional form that might have to be devised for those areas just to have someone sign off and say that they didn't meet the standards required within whatever it is that the cannabis board decide that they have to meet. And on the other side, obviously that's when you get into the cultivation metrics. If you're looking at your energy use versus what your actual production is and establishing the baseline for that, which you can then use for going forward, looking at see if there's any great variation in terms of no additional energy use for the metal plant being produced. So it would perhaps indicate that there is something changed within the facility that might have to be looked at. In my mind, in regards to building codes, there will be, I guess, an inspection before operations can commence. Is that correct? There will be an inspection by Division of Fire Safety looking at fire safety occupancy requirements. Sometimes, depending on where this will be, will issue a certificate of occupancy as well. There's generally not any specific inspection around the energy efficiency components unless a town requires something specific for that. But as far as my way, there is no town that does that. Is there, I guess, expertise or even capacity for the inspectors who are doing a certificate of occupancy to validate the affidavit that's provided before operations can start? I would say that the people that do the inspection for the Division of Fire Safety are not experts, obviously, on energy efficiency and everything else there. And a lot of what you're looking at in terms of energy efficiency, you know, insulation, ear sealing, etc., you would never really be able to verify after construction has been done to any kind of adequate standard. You'd probably spot check in areas. But really, it comes down to a requirement that an architect or engineer has designed the building to meet all the standards and signed an affidavit, assuming liability for that. And a builder has built to those designs and signed an affidavit and assumed liability for that as well. And so there's a, you may say there's a high level of trust, but within the commercial building world, overall, that we have a high level of consistency when it comes to meeting these codes for over 90% compliance currently as of our last check, which is 2015, we're currently doing one right now, but I would expect that levels to be and similarly high at the same rate as well. I'd like to continue with the greenhouse requirements and wondering, provide some insight into the de-factor 0.7, which I think is kind of going to what Stephanie and Kyle were talking about with the low building, sorry, low energy building and the sections for things, yeah. Yeah, certainly. So the 0.7 U-factor, that actually we took from within the international energy conservation code for 2021, they actually include greenhouses within that, and they include a U-factor of 0.7 for the walls, but they also include a U-factor, I believe it's like 0.5 for the ceilings. On a practical basis, we didn't really think that that was cost-effective or really easily to do, frankly, it would require substantial additional cost, you might say, over what you would do for a greenhouse. Now, my understanding is from the consultation that we've had, but the efficiency from one and other people at the 0.7 is attainable as a double poly wall within your gap, which is becoming as I understand it and you'll be probably correct me, more industry stand-up now, that's probably what the target is that if you're going to be putting up a greenhouse and you're going to be using poly, for instance, that's what you're going to do or trying to. I believe it may be a little bit harder with your next class. I'm less familiar with that, frankly. But I'm also not as certain that on a commercial scale that would be the typical material that we'd use for construction greenhouses of this size in this fashion or potentially this size. And I've spoken so much, I forgot the second part of your question. Yeah, no worries. I would agree from what we're seeing from the commercial standard that like the double poly or the double wall polycarbonate or acrylic would seem to be what most commercial scale cultivation for at least a climate-controlled greenhouse are using. So I think that's acceptable. I mean, we just wouldn't allow kind of a single glass polycarbonate in the poly of structures. But I believe and Jill, I'd like to hear your perspective on this, that like those are more kind of for hoop houses and would be exempt. Yeah. And we definitely were encouraging folks in our new greenhouse program in general for any growers to go, especially if they're doing any sort of heating, to go to that double poly layer just because of the fact that there's such a heat gain. There's like a 40 percent just doing that right there and savings. So that is part of why we wanted to make sure rolling over. We do have, you know, a number of people that over the years have asked us, you know, from the start of when they kept getting talked about that, you know, this is going to legalize to, you know, then moving in and starting looking when half was legalized and everybody was jumping on that. You know, what's the best way to grow? What's the best way to grow? And the ones that were even looking at hoop houses back then, we were pushing for the double poly. We actually will offer incentives, you know, help people go from single poly to double poly right now because the fact that people, even with those, you know, we're going back to the condition of greenhouses, they don't get updated as much as as people would like, you know, plastic, the poly houses typically should be replaced every five years. And we often see people coming in, you know, oh, I haven't touched this in 10 years. I haven't touched, you know, eight to 10 years. Definitely. We've seen some that have either been longer or the other duct taking sides together and stuff. So we're trying to encourage people to go in the same with the polycarbonate. We don't want them putting on a six mil layer. We want them to install something higher. You know, we want to go with the 10 to 16, depending on what they're doing, you know, anything that's going to help hold the heat and everything. So we are offering a sense of those. So requiring that on these of the buildings that are going to be permanent, just, you know, economically make sense right from the where it go. Kind of like air sealing on anything else.  We want to encourage people to stay on top of replacing those. Are there incentives for thermal currents for green houses or additional kind of place filming to increase? Okay. Yeah. Yeah. And that's the other thing we're definitely talking when we are talking to people are looking at greenhouses, whether they're looking at a shade curtain or, you know, thermal curtains, especially, you know, thermal blackout curtains if they're going to be using a lot of supplemental lighting and are growing over in more into the evening hours, getting off the peak demands. We definitely want to encourage getting these thermal curtains installed to help hold the and block any excess light going out. On that point with excess light, are there any dark sky pollution from greenhouses thinking for the scheduling of the lighting schedules? There definitely can be issues with those. The dark sky component is definitely going to be a town by town. You know, they need to work on. So we definitely if someone is looking at growing and doing overnight in the game of style glass style green house, we definitely make sure we tell them to reach out to the town to double check any, you know, requirements. I actually have a friend that has sent me photos from Massachusetts where you can fully see the glow from her house. So I definitely know it can be an issue. I will say right now the people that I've talked with a lot of them are going indoor grows. So it's not as not as big an issue. And the people that are looking at the gavel style houses right now traditionally have been either floor cultures or we do have a couple of people that are looking to do hemp, but lighting would just be supplemental. So not as that's an issue. They're just kind of the short season, short hours on either end of the day. Do you have any hand to add for planting use on that? Yeah, I would agree with Jill that those sorts of issues can be regulated time by time, visibly. And if active 50 is triggered, the aesthetics criteria back to 50 can look at lighting issues in a very rarely they can have impacts on wildlife habitat, but it's mostly around the aesthetics and neighborly issues. OK, thank you. Barry, so yeah, the second question I had for you was Hey, Jacob, real real quick before we move on, I know Stephanie has her hand up. Oh, sorry, Stephanie, that's what that little thing was. Thank you, pop. I just wanted to mention from the farming or agricultural perspective, the excess light that gets emitted from a greenhouse today can start like for microgreens or something like that, not related to canvas, of course, is not regulated by a town. So this would be entirely new regulations that a municipality would have to adopt in order to control the land use specifically. So I just wanted to say that these these regulations generally don't exist in towns and it would be something new that towns would have to consider if they so wish. Hey, Tom, you're requiring mitigation. Tom, can we flag this for a conversation tomorrow in compliance and enforcement? OK, thank you. I was going to say, setting your opinion. I mean, is that overkill for Vermont to require a lighting or like I called our skies that's how California has a specific dark stress requirement for greenhouses with cannabis cultivation? Overkill for Vermont, what are your thoughts on that? Well, no, it's just a complaint that we get from an agricultural perspective at the agency of Ag. So I mean, it's real and it happens in a in a realm that it towns can't control. So I think it is an issue that I think it would be good to address. So I don't think it's overkill now.  So OK, I could bring up kind of the California rags and throw it into our air pollution talk. So we kind of more of a productive conversation about that for drafting rags on that or seeing with what's already happening. Anything else on this topic for a minute? Jacob, just so you know, I just mentioned in the time in case you didn't hear, I'll make sure this comes up in compliance and enforcement committee. I know that they're looking at model ordinances. The market structure committee is looking at fees associated with with a locality or municipality signing off on on a perspective business. Maybe this is something that we should consider talking about another other subcommittees. Just so, you know, that could be built into a fee. I don't know. I'm thinking outside the box, but this is an issue that will cross multiple committees like most do. Yeah, that sounds good. So it's very I had some questions on the low energy building exemptions for greenhouses and kind of the total peak energy usage being under one lot or three point four BTUs per hour per square foot for space conditioning. How did you decide on that baseline and what is meant by space conditioning? Well, that baseline is actually as contained within the commercial building energy standards. And that's the definition we use for low building energy. Anyway, what would be by space conditioning would be that energy used for the purposes of heating or cooling a space? Generally, under the commercial building energy standards, that's mostly the trigger that kind of mean the low energy is just to know if that code is going to be actual and so building and if you condition or the space within it, then all the other requirements can kick in basically. So not circulation or airflow.  And we do have fine power, but obviously we're not really concerned about it if it's just on the air temperature or you're moving air from one space to another within a building. It's not really because you're not using energy to heat or cool that space. And is this for permanent heating cooling fixtures? I'm just thinking from like a more passively cool greenhouse. So definitely up circulation fans, especially in Vermont, because I think the tritus is going to be a big issue of having to deal with the relative humidity and moisture within a greenhouse to kind of tap down on like disease. If so, that's excluded. I'm wondering for like season extending burners if they're only being used temporarily with that load should be factoring into this or is this for? Yes. OK. Yes, I mean, basically the intent for that is basically a building that's intended to operate in that fashion. If you're going to be bringing in supplementary equipment, which will impact that space, you are then conditioning that space, even if it is just temporary equipment, what it wouldn't trigger necessarily a full requirement for meeting the commercial building and energy standards, etc. In this particular case, I would say that if you were going to be trying to put a greenhouse up that met that low building energy exemption, but your intent was to still condition the space in order to extend the growing season, that would not meet the intent or the desire behind the requirements for the low energy building piece. You're trying to circumvent the code. OK. It's the way I would view that. Are there exemptions if they're solar powered or wind powered or hydrothermal or like off grid for heating and cooling? Actually, any exemptions really to that we do off actually, I'm lying a little bit that there is the oil exemption regarding heating and cooling, but it's related to your believe it or not that if those are renewably sourced energy for heating and cooling, whether that be slower panels to run electric heaters or heat pumps or something almost, then those buildings would then necessarily be exempt from the code. Obviously, greenhouses were not something we consider because they were outside the scope of our code. So that's why some of these exemptions that make sense to apply to greenhouses are necessarily included here. Doesn't mean that they couldn't be, but I don't think that when we were contemplating this we were contemplating these spaces being on grid generally, because we were approaching this mostly from a new construction building aspect with the supplemental part of the greenhouse being, as I said, new to us, because we've never had to develop codes related to greenhouses before. And then with the language you have in there, it's just like those with a peak design rate. So this is being I guess, compliance is based off of the plans that are being submitted and then verification with, like, I guess, Jill, do you I research a bunch of different greenhouse manufacturers, I know, and growers, but haven't heard back in Walker Square footage, if, you know, a more of a passively cold greenhouse, if they did have, you know, minor supplemental heating and radiant flooring, if this, if that would be allowed to do this or not, do you know, is there anyone growing in kind of a passively cold greenhouse with any kind of equipment that would be in this exemption? I wouldn't be surprised if we see someone that tries to fall into this. I don't think I've seen anybody yet, but we definitely have a lot of people that are definitely reaching out to us. And like I said, over the years, they've reached out to us with a variety of different ideas, a lot, you know, converting the former cattle barn into a grow space and, you know, heating and drying and everything in these spaces until they find out what the energy used for their lights are going to be. And then they kind of, so we'll have definitely shifted gears. So I think it's definitely something we want to definitely be talking about right now so that we're ready for this. Like I said, I've talked to a lot of growers over the years and I know a lot of them are ready to move in right now and start right now. You know, they're they're looking to set up shops and they're already starting locations and working on locations. So I know there's going to be greenhouses that will be coming up that they're, you know, working right now. Everyone's asking, you know, what's what's going to be required? So the sooner I think we can either establish some of this or are for some of these places that are existing right now, existing buildings and getting retrofitted to grow what sort of timeline they have for eating these new standards, including of, you know, low energy usage standards. You know, I think that's going to be really valuable to them. It will be very valuable to me. I can tell what their energy use is going to be right now, but I'm hoping they're they're all going to definitely meet the code and so far the lights that, you know, the big things are looking at the lights, the heating. Yes, definitely, definitely. They're any, you know, so I mean, these are performance codes, right? And is that how we would characterize them or are they just standards? Like, I was just thinking whether or not there's a way to say, like, you would meet the standard if you did A, B and C or A and B, you don't have to do C. But like that's more prescriptive so that we tell them what they need to do in order to succeed rather than saying, oh, I mean, more specifically, I know, you know, so many BTUs per square foot of space conditioned, but like something like, you know, I just a little bit more information about how you do it. Yeah, examples of that. I'm sure who's answering that when you're going to do. Actually, you know, if you haven't answered great, if not, I think right now it's kind of on a case by case basis. You know, that's that's how I'm looking at it because of the fact that growing is so unique that, you know, especially in my case, where I'm dealing with all of it, you know, from someone growing the lettuce, just, you know, someone growing tulips to someone growing, you know, cannabis, it's all the space needs are so different. I'm trying to get more and more info so that we can hopefully get some some good baseline information. And so we can say, do this and that'll help you reduce this portion or do that and do this portion. So people do have that information, you know, leads of where they're going to find more of that. I'm always trying to compile more and more so we can figure this out. But I do like that idea of if we know a person needs to be this, this and this, you know, help them rate which ones are going to be, you know, easier for them to do, quicker for them to do and get, you know, up to date or, you know, what sort of, you know, as a timeline is that a year, two years if they do these two things this year, do they have the third year to do or a second year to do the third and they'd still need or, you know, how that's going. Yes, Stephanie, I started to compile when I was thinking about this, I reached out to growers really designing greenhouses all themselves to say like what is industry kind of standard practice from a greenhouse design for the leading kind of energy efficient heating, mostly heating, I would imagine in Vermont. I think you probably get away with fans and venting of the greenhouse for most of the summer. But of what those baselines are, haven't heard back yet. But I think my question I used to use a regulator at default to you would be if we are prescriptive and what we're putting, does that like stymie kind of ingenuity or as setting it as a, you know, energy intensity metric, then they have kind of any way to comply with that government solution to different things. I totally I understand that that by being prescriptive, you can stymie ingenuity. But there could also be the regular standard that says and if you don't do these things you can always meet the standard. So that you open the door. I just think of there's an example of I think it's an erosion control standard slope and how many trees you have to have per, I don't know, spare footage. And you can meet this erosion control standard by doing a number of activities. And I just think from the from the user or the customer perspective, sometimes that helps you along. So that's the only you know, but I understand that there are definitely downsides to that. I'm going to be quiet because I see Billy's hand is up. Yeah, I would just say I think having a reference guide could be useful, Billy. And this is just a question that shows my ignorance in this space. But are there any provisions to allow or incentivize heating of these spaces with modern wood heat or high efficiency wood burning appliances? Yeah, we we have had people that have been asking about wood chips and pellet boilers and stuff. So that's definitely not uncommon to hear. I've actually got one person asking about using hot water from a compost pile. So we are and we're willing, you know, any of these, we want them to obviously heat are the standard efficiency for wood boilers and all that. And we just roll that right in with our wood boiler programs. But yeah, like I said, you know, they like stuff is that they come up with some really unique ideas and the folks that are looking at, hey, I'm going to have all this compost. Can I just, you know, run my hot water loop through and use that? Oh, sure. Oh, yeah. Yeah, this sounds really good. You'll fill me in some more, you know. So we're definitely we are hearing a lot of the DIY projects that they want to do this is definitely a group, you know, like any other framework that more DIY they can do the happier they are, especially right now with the shortage contractors and stuff of the state that we're running into. Great. Thank you. It's good to hear. I would say yeah, from a greenhouse perspective, I was just reading. So I know Penn State or University of Pennsylvania has a good greenhouse heating efficiency cultivation. And there's a whole section there on what fuels and all the new technology, especially on commercial scale. I mean, I would say my experience greenhouses where you've seen them most ingenuity from like wallopini style, which are buried into the ground to what using any kind of heating cooling and things like that. So that's where I was just trying to see if we can create the standards or regarding this like exemptions for doing kind of above and beyond best practices. I know like Cornell came out with a really good high efficiency greenhouse study as well on ways of doing that. I know you have to go soon, Billy. And I did want to get your perspective. So you're dealing with the kind of Vermont climate change goals. There's recommendations here on renewables and requiring lots per square foot of solar connection. I think I'm trying to find what you thought about that and what your thoughts on our core offsets or the capacity for renewable systems in the future. It's a complicated question. I think certainly encouraging folks to take advantage of programs to self generate their energy is is a positive thing. I get a little wary about requirements because it's a pretty dynamic space right now in how the state is kind of structuring and incentivizing your net meter program, which is a program that sets the rate for people who still generate. I think at the smaller scale, like below 15 kilowatts of input capacity, there's probably always going to be a lot of opportunity to be there. But when you get into the larger self generation for a greater load, it's a pretty dynamic place where there's tension between whether that power renewable power should be delivered by the distribution utilities at a savings versus by individual customers. And I think the climate council is weighing those questions given the amount of public investment that's going to need to go into mitigation of emissions and the transportation and heat sectors. How much of that incentive is available in the electric sector? I think that that's all kind of in the mix right now. So that's a very long way of saying, I think encouraging it where it makes sense is a good idea. Mandating it may be a step too far. But if others feel like that's appropriate, you know, there's a way to kind of craft it smartly that it can be successful. So if I could just point out briefly, it's their recommendation is that these buildings and greenhouses that would be identifying here for like solar ready within the commercial building in the end of the standard, there is a option that they can do in order to get the required points for a building in order to meet the requirements. And one of those options is also to install a photovoltaic or renewable energy system. And within that, for the different building types, we we produce we have a value of what's per square foot requirement for that generation. And this is basically just building off of that piece so that if a cultivation building or greenhouse etc. chose to install a solar energy system, the requirement would be point five square watts of conditions floor space for that space. We're not saying that they have to install it. We're saying that if you're going to if you're going to choose to install it, this is the this is the minimum amount of solar, the good one you did and install for that space here and potentially be serving. And obviously you're correct of those issues. I think if it goes over two and a half thousand KW, I think it is, it triggers different requirements. I forget exactly what it is. Different licensing requirements and everything else. So those probably should be considered like an upper limit to that size or it goes into a different administrative or process basically for approval, as I understand it. But that's standing. That's standing. You just articulated seems logical to me. Yeah. Billy, I don't have to go soon. Is there any just needed? I think she's talking to us. Yes, sorry. And that also applies for anybody that's going into an already existing building.  How would that affect them? Well, obviously, we're sorry. OK. When you move into this space, obviously, they're going to have to bring the building up to the current code standard. And within that standard, there is the newest options. The solar option is one of them. If, obviously, the building can't support the load of solar, then the solar-ready requirements are now going to apply. So that would be easy enough to demonstrate through, you know, an engineering calculation that the load isn't designed or the roof isn't designed for the wind loading and snow loading and the additional panel loading. Really, as I say, the requirement is either to identify that space or identify that they couldn't necessarily do that for the solar panels. And as I said, it's not if we're not suggesting that the people are required to solve solar panels. But if they do, then that would be the minimum requirement for the generation. OK, so only if they're looking at doing solar. Only if they're looking at doing solar. But if they're going to be building a new building, they would basically have to designate a space either on the roof or, you know, on the land outside or demonstrate that where they're putting this building, there is no usable roof space or civil land in order to install a solar array that would be required. That's all described in appendix of the commercial building energy standards. Yeah, and I strongly support that kind of planning for readiness as a minimum step, understanding that kind of the feasibility of actually installing the plan may vary in the future. So that works from my perspective. I have a question for you, Barry. With the retrofitting of commercial spaces, are you seeing with the way the CBS is the new building standards? We see a lot of it in other states, like the split dilemma between the owner of the building and then the occupant and the actual operation and who's planning that cost and all of that. Just thinking from more of the small farmer perspective, they're going into a smaller space, but then have to bring it up to code. Yeah, have you just seen a lot of issues with that on protections or anything or how those financial things split or anything like that? Well, to be honest, when you're dealing with rental space, it's always going to be difficult to decide to address. As I understand it, generally the burden for bringing things up to code is falls upon the renter rather than the landlord, simply because they want to use that building for that purpose. It could very well be that they come up with an agreement with the landlord to split costs, etc. But that's not generally something that rises to the level that comes to my attention. Gell may know more about that since efficiency for mine probably are more in the weeds when it comes to that kind of occurrence. Yeah, we often try to let the you know, we'll point out where code needs to be.  We don't want to get involved with that tug of war at all. Just let us know where we need to send send the check to at the end for the rebates on that sort of stuff. But it definitely like I said, I know it's a concern. I don't know how much of any of this information has made it out to the general public of what sort of code may be coming down the pike on these as people are starting to to look at spots and red spots. And I just I hate for some of it to get caught without knowing that all these codes are coming. Is the CBES already in standard practice right now and enforceable? They're all mentioned in here, Barry. Well, obviously, the commercial building energy standard has been in place since this version, at least it's been in place since September last year. But there's been some version of the commercial building energy standard since 2005. OK, and all municipalities and things, etc. They are obviously aware of it. But not all not all times municipalities have the ability to enforce these codes. So it doesn't mean they're doing a new bill, they're benefiting that they be aware of these, at least. And then we should be asked is probably one of the requirements currently when they are looking for permits for doing stuff like that is that they are given copies or at least access to the commercial building energy standards and that copy of the CBES certificate. So that they know this is what they have to meet. That's generally at the point of permit application. So these standards should be well known that they exist. And obviously, I mean, to go back to something you were talking about earlier, these are generally performance standards. You can be on a descriptive basis if you so desire, but you would probably end up with a building that is very much over a year as a result. The codes allow for tradeoffs in certain areas and insulation, lighting, etc. Depending upon how you want to do things, we're trying to obviously have a building that's designed to be as energy efficient as possible without being so cost ineffectual that no one would want to build it in the first place, which is why I would always encourage that they're going to do anything along those lines that modeling should be the first thing that they do to try and figure out what they actually have to do and what their actual costs are going to be before they take too many steps down the path of applying for permits and construction. Billy, any final thoughts before you have to go? Thank you. And again, I really, you know, the OSIRS department folks are really kind of the experts within state government on this suite of issues. So I really defer to their judgment here, but thank you. And I'll see you all next week. Sounds good. Thank you. Thank you, Billy. Thank you, sir. Sweet. Very nice. Sweet. Yeah. Gary, I guess, and Joe, I have questions. So I saw that like manufacturing wasn't really included in this. And you do have a lot of equipment that is definitely power consuming and talking with some manufacturing experts who are building out facilities kind of across the country. You know, it's always kind of cabx costs is the biggest motivator in what equipment they're purchasing and not energy efficiency or operational costs. And so I was wondering, I see like there's different codes mentioned for like fans and motors within the cultivation space. And in my research, I was looking at what came up across it. I don't know if it's enacted yet, but there was the appliance efficiency standards and you know, appliance efficiency standards and the efficiency or energy efficiency modernization act. And I was wondering, does that take into or is there anything to be of note for manufacturers that are putting in, you know, industrial size chillers, vacuum ovens, all of that. Well, I mean, obviously these are building energy standards. And so we're looking at the energy of building we'd use. We're not necessarily looking at the miscellaneous uses, which could be no plug loads or even any heavy industrial equipment you might put into the building. Those are generally regulated outside and they're definitely far outside our remit to find mandate requirements around. It could very well be that, you know, the Cannabis Control Board could implement some equipment efficiency standards for the various equipment that's necessary for the processing or anything else around the production of a manufacturer of the cannabis products. But that's not within the scope of the commercial building and energy codes. That's not something that we generally or we can actually not generally we cannot mandate what that is. Generally, for a lot of that stuff, at least on the residential side and probably on the commercial side, that's where efficiency come on. Generally comes in with incentives and custom programs, etc. to encourage best practice and most efficient equipment, cellars, etc. to being installed in these spaces rather than just the cheapest possible if they can put in. Hey, Barry question, are you aware of any other state agencies that do kind of look at specific pieces of equipment and set a mandate or a standard? Well, I'll correct myself a little bit. The department obviously is responsible for applying standards within the state, but those are generally small things like your residential dehumidifier, your computers, power supplies, a lot of shower heads, even, toilets, we we're kind of identified as the agency responsible for those applying standards, but for large manufacturing equipment and that's not something that we deal with. I'm sure that within other states are probably maybe and within other energy offices that deal with energy efficiency in other states, perhaps they have someone that deals with that. I am not familiar with that in the case, however, but I can't really, it exists. Stephanie. Yeah, I just wanted to mention I mean, it's not related to energy efficiency, but fit for use kind of on equipment. I think the fire safety division from their perspective may have some input on this. Again, it's not energy efficiency, but it's equipment from the building, which is why it triggered my memory. And then the other thing to note is use of like propane heaters in order to dry crops. That's actually potentially addressed by DEC or the Department of Environmental Conservation through their climate, no, their air quality and climate division. So there are potentially some other Asian or departments within state government that have some input on specifically equipment and the use of that equipment, not necessarily electricity. I know. Can we definitely encourage people to reach out to especially the Department for the Fire Safety.  Make sure you've got everything that, you know, is lined up right and reach out to them and talk with them. So, and we look at, you know, we do look at some of this equipment, but again, we don't have any sense, quote unquote, standards of what they need to have to have. We'll look at like if they're looking at a cryogenic freezer, we'll look, okay, you know, here's kind of, they're looking at a couple of different ones. We can look at them and say, okay, yeah, this seems like the bottom of, you know, you know, energy efficiency, it uses 1,000 watts and this one here, you're looking at and it only uses 500, but it is, you know, two types of costs. How would we be able to help you get into that, that 500 watt one instead? So we, we will help with them or even just if they wanna, a third party kind of look at the two and, what am I, you know, they're both 1,000 watts, but one is, you know, $50,000 and one is $20,000. What am I missing? We'll help them kind of look at that and see, you know, what they might, might miss and kind of that second set of eyes. Okay. Now let's get to know. I mean, I know with the fire credit safety, especially for concentration concentrators, a lot of it has to do with the air exchanges and all of that and like where things are placed to just make sure that all of this, you know, flammable hazardous material isn't creating, you know, a safety hazard to employees and neighbors and all that. So that's more of what they look at than like the efficiencies of these equations. So I guess, yeah. You kind of answered it, Joe. You guys don't look at or basically standards or standard incentives like this. Yeah, not at the moment.  Unfortunately, some of the stuff we were going to be doing and metering and everything, you know, COVID hit as we were in the middle. So getting everything organized and, but yeah, so we are definitely, you know, seeing more and more and, you know, we're talking more and more with different people and we're seeing different dryers and such, you know, and what can we do to help, you know, how is this one operating versus, you know, ourselves looking and, you know, how is this person doing it versus how that person's doing it and looking at it inside, you know, in our records to try to see, you know, what's coming, what's common, you know, what's the most common ways to do this versus, you know, who's thinking far outside and which one's working the best. We're just kind of trying to gather as much info as we can of what's working in this area and talking with the other states to find out what's working in their areas. Gotcha. Yeah, and on that point of late, I mean, data is just, there's not much of it and a lot of most borrowers of these originally didn't want to share their secret sauce of getting information was hard. Yeah. Are their incentives or programs either through, you guys are through the utilities for smart metering. I'm wondering, because we do have this recommendation for self-reporting and I'm wondering if taking it one step further, I work all the way with Boulder County, they require that if there's anything like that you've seen in other industries or the other availability to have cultivators, be smart metering, so they actually have the data. A lot of it's going to depend on the utility company and if they can offer any of that, I don't know why I put them, worked on it, but I believe some of them will help work without getting them installed. We've done some, we will help with some basic metering. We like that meters, I think so. It depends on how far down the meter, grab a hold, they want to go of what we can do to help and we've kind of, that shifted around over the years, but definitely, you know, you said, getting the data in the past was always extremely hard. It's definitely the past year has been a lot, this past 2021 year, getting information from growers. That's definitely been a lot easier for us, before even getting quotes on which light are you gonna use at times. They just want to know what the reading is, I'm like, I can't do it without, without knowing what are you doing for run hours? Which lights are you looking? Yeah, I'm like, I'm not sharing it with anyone, but I need this number to run your phone. Could be difficult to some of them. So it is kind of nice that now we're getting more and more opening the doors and yeah, come on in and check out, this is what I want to do. How can I be more efficient? So it's encouraging that they're interested in sharing this info. If they should see Vermont, I mean, I'm guessing you guys have the capacity to help the industry with that. I think there's an estimate of like 200 potential cultivators coming in to guide that or pay incentives and having that available during the application process, you know, be helpful. Yeah, that definitely would be helpful. You know, I think that we can all put together that, you know, hey, you know, here's, most people thankfully a lot of stuff that right now I've been dealing with this, you know, the lighting and some of the HVAC stuff, you know, so they know a lot of the basics of it, you know, this way needs to run for this many days of this many hours and this we need to run at this many days of, you know, some of those basic stuff is really good. Getting into the more technical goal, what are you doing for de-mutification?  And we know a lot of it is going to be very dependent on their building type, which strains they're growing. So it is very hard to do this. We do point a lot of people to the resource innovations institute and their best practice of that. They're coming out with more and more right now and we work a lot with them and which is fantastic that, you know, here's another third party spot I can send them to to say, hey, you wanna read up on the HVAC, here you go, reach out to them and, you know, download their info right off the website. So, but we definitely, those are some of the questions we do when we're asking and this is those are all growers, you know, when I'm asking anybody, I'm like, you know, either the two of them, what are you looking for temperature wise in your greenhouse? Well, it kind of, you know, a lot of them don't have a solid idea of where they wanna be. They know they wanna put fans in, they know they wanna do heating, but they don't know what temperature point they want right now. So this actually, this industry, this has actually been one of the best things for the growing industry in general, actually, is we're getting much more data for everything, for all the equipment for other greenhouses to use. Can I just, there was something out here, just to that point, Jill, do you think that there would be any interest within efficient Vermont for, you know, possibly including some incentives or anything along those lines from some sort of like energy monitoring system or automation system? Because obviously, a lot of these metrics can be very interactive, especially when you meditate and everything else. And I think that at least in the case of, you know, if you could get a few of these systems down and if they were willing to share that information it would give us a whole lot better insight into how these buildings would actually operate. Yeah, yeah. Which we probably currently do. Yeah, we would love to get more data. And it's funny, some of them are really, you know, that I've talked to, they're like, yeah, it looks like I've got the info. Yeah, no problem. I'll hand it all over to you. And we do offer incentives on our controls. We would, ideally we would love to see more building automation control systems in these areas. And the big growers are definitely more interested in the ones that can control their lighting, control their heating. You know, there's control systems out there that will, you know, they can put out with their watering and it'll mix in all the nutrients and run all that. And that's all been out in the industry for years. So we're more than happy to help people, or at least, you know, talk with people every time we mention it. You know, some people are interested in taking it up. Some, not so much. They're, you know, they're still small enough that they're not interested in historically in the past. So again, being able to have this new industry they'll be a little more interested in it. Usually what we've heard is, yeah, I'm interested, but give me a year or two. They want, they need to get the rest of the building up and running first. So even though it makes sense to tie it all together, they just, the capital isn't there for them. They need the capital for the lights, which is gonna be one of their biggest expenses. And then, you know, upgrading HVAC, if they need to earn solid HVAC and solid the building, you know, all the other stuff, all together. But I would love to see a good, you know, VMS system that could do energy monitoring, modeling for everybody. And then like I said, we do industry, you know, we'll do energy modeling that we can and we'll be interested to see how our model is compared to what adds actual usage and updates that they can tweak things.  Let's see the questions here. Well, as you know, and others, early Stephanie is aware, we've been exploring a lot of different technology when it comes to seed-to-sale tracking. Is there any platforms that maybe they all do? I just don't know that take into consideration from that tracking perspective, energy inputs, outputs. Yeah, so there's a few, they're constantly changing. I would say the cannabis operational software industry is just full of lots of M&A these days. But I'd say it's like three or four overlay programs that will link up, let's say, with an API with metric and then with your, you know, if you have a smart meter or if your utility provides smart meters that will tell you on a, like per gram per day, per stream, like what your energy water not necessarily weighs usage is to really help to track that over the coming cannabis big data. I believe it's all around to do that. And there's a few others. I know like the Brainslay operation, so like the control system management programs, so like Wadsworth controls or Argus or whatnot that are essentially interplaying between the lighting, PPFD, the soil, which is really where you're gonna see the operational efficiencies and can overlay that like DPD, like vapor pressure deficit and different things to really find the most efficient way to use the equipment in there or now producing a lot more metrics on that level as well. But yeah, so I think it's out there, solely being adopted. I think from the biggest point, it's just looking at temperature relative humidity just because that's what you're most interested in from a quality and harvest perspective, quality and yield. But yeah, at Wigs, I know we're, yeah, no worries. I know we're running out of time a little bit. I wanna get to a couple things, but I wanna say, Jill, I think I'm not sure I know people at Efficiency Remind aren't in touch with like DMN Markowitz over at Resource Innovations, because I know he's leading the Excel Sensei program, which is doing the more of the operational side for all of these cultivation facilities and have gotten pretty buy-in because they're actually paying people for reduction of energy. But that might be a good tool to look into if John's to standardize it, I guess, program. Barry, before we kind of run out of time, I did have some questions on the kind of HVAC. I'd say I can have some on page like six, do you have like...  Communication systems and sample code language examples, which it looks like we're taking from what was recommended in the Remind CBA ES like 2018, and are those derived from, I guess, Cuban occupancy standards? Because I know for a lot of things, especially campus cultivation indoors and climate control greenhouses, the latent load is this of concern the most and not so much what a lot of like Sierra E.R. ratings are looking at, so I was just kinda wondering where these were derived from. As I understand it, these are specifically for this type of environment. As I say, our consultant and new buildings institute know they develop many of these different codes and standards that have been implemented in other places, and this is what they recommended to us specifically for these growing spaces. Obviously, the rest of the building, if there is a rest of the building, obviously would fall under the regular CVs requirements and the other heating and ventilation and no air changes for our requirements or standard, but obviously these growing spaces, they require something a little bit different overall. And there's the likelihood where these might actually have to be served by separate systems entirely, just to make sure that their environment is maintained. If you can see it, I don't think that many people are going to want to sit in a building that's sitting in degrees and temperature and like 89% humidity. But as I said, these requirements were specifically for those spaces, any spaces outside of the cultivation or other gross spaces, muller room, et cetera, but the fall under the auspices of the standard CVs requirements. Yeah, great, now that's good to know. I guess the last question I had was for you to ask earlier was with validating or quantifying kind of the PPE for non-LED lights. Do you guys know of a way of doing that or is there an organization? I know DLC only does LEDs, I believe. So is everybody like manufacturing, manufacturing specs or? Well, I mean, honestly. Yeah. Oh, sorry. Use the manufacturing specs. Any of the testing labs that DLC uses that are approved, those are open to anybody submitting whatever lights they want to. A lot of the standards are the same. A lot of them haven't been tested over the years. Or are infections that haven't been tested. It's been a long time. Because really until this came around, nothing had really been done on lighting for growing since the 70s. That's when the last big information about lights and growing came about. So it's kind of one of these things that historically, they've used the 1.7, kind of on the average. They can get tested. There are some that I have gone out and got tested, but I don't think there's a lot out there that really have that. Because most places where we're talking as much about PPE at the time. Yeah. And obviously, you know, qualifying for the design line, design light consortium and certification of the lights. That's an additional manufacturing cost. It is certainly not cheap. So that's why a lot of these lamps are qualified. In general, I would say the manufacturer information is pretty good. Because they still require a test to set the standards in order to do it. But obviously, there's no third party verification of those numbers. But as I say, generally, we find that their numbers are pretty good. Even including their overall hours of use. I mean, obviously, they, no, I'm going to stop there before I say something else to get me in trouble. No worries. I think we need to open it up for public commenting. I thought it doesn't seem like we have any public comments in the room, unless anybody's changed their minds. OK. So we can go right up to the bottom of the hour if you would like to do it. Yeah. I've got a bunch more questions to go to C70 as we're hand raised. Yeah, no, I had a question regarding the order control filters and the ventilation system. Is that an efficiency item? And I know, Barry, I heard your conversation the first time. So I know why. But I'm wondering whether or not that might be more appropriate in a, god, somewhere else. I could argue some efficiency requirement because it would use a fan. But much beyond that, no. That's really more a ear quality issue, perhaps, or something along those lines, or perhaps even, I don't know. I'm sure there must be something out there around control of orders from manufacturing processes or other processes. So it probably does fit elsewhere. But as I said, it was just something you paid issue, shall we say? Actually, for the compliance and enforcement group that it might fall squarely within their responsibility, if you review conditional use requirements and a zoning code for the state of Vermont and chapter 117, it talks about conditional uses if you can have standard control orders and so forth. So I just wanted to mention that, and I'll read it elsewhere. I think 164 does specifically state that municipalities can put local order control measures on a license from the municipal perspective. OK. Yeah. And then I had one more question. I'm sorry, I'm going to squeak it in. So there's a number of the commercial building energy standards that apply to these buildings, just generally, as a matter of course. And then there'd be additional ones with respect to greenhouses or additional higher standards for the elements associated with indoor cultivation that's not in a greenhouse. Is there a plan to incorporate these items into the commercial building energy code at some point in the future? Like, how does this play out over time, I guess? For that, I might actually consider deferring that to my deputy director, Kelly Wanzer, who hopefully is paying attention to the question. Attention to the question. We haven't considered that at this point because it's not applicable to other agricultural greenhouses. It would just be specific to the cannabis establishment. So it says we're going to our statute. There's language, and this was in our recommendations. But it says that CB shall not apply to and includes agriculture buildings. So there's a specific exemption in CBs for it applying to anything except cannabis greenhouse or high establishment. And once that changed, I would say, no, we're not considering right now a plant changing that statute and applying it to anything else. So then I come back to my question I asked earlier, is if, typically, this is administered through an Act 250 process and or a local permitting process. And if it's not a part of the commercial building energy standard book standards, then who applies this? So obviously, for most of those examples of commercial building energy standards apply. These are kind of, and we've done this with Act 250 previously, and these are like additional conditions or modifications to the existing code. And those were applied specifically by Act 250. And it's part of the requirements and the permitting requirements that they not only meet CBs, but they also meet all the additional actual standards such as these. I mean, obviously, as CBs gets updated on a very regular basis, there will probably be a need to come back and review these standards as well and see if they need to be also updated in time. Obviously, these are going to be adopted by rule. So it would be a process that would have to be between ourselves and the Canvas control board to figure out exactly the timing of that and when it would be required. But I would imagine that as we are updating the CB standards, we would also be having this issue in the back of our minds and seeing where what we're doing could potentially be impacting or doing away with our requirement but then here because it's already within the code that we're going to be adopting in the future. Or if something we were adopting in the future has an impact, it would mean that we would probably have to consider coming back to this and updating the fan requirements, et cetera, because obviously those change. We're going to be adopting a version of the 2021 IDCC something in the next year and a half-ish. So basically that piece kind of goes away as far as this goes. But as we progress through the various codes, obviously, there may be definitely need to come back and revisit these standards to see if they need to be updated. After this conversation, sorry, we're getting close to the end. I am reconsidering what I just said. I suppose that we're getting ready to go into the new code update process. And I suppose we could consider the more I think about it. We'd have to think about it and talk to our legal division about whether we could include the specific cannabis code language or not. I'm not sure with, again, the statute limitations I mentioned, if they would be comfortable with us kind of including that additional components and how there's an out for them not because they're not considered agricultural establishment. So we can look into that. I think we could consider that. But we'd have to look in a little further. Thank you. Thank you, Kelly. Thank you. I guess to close out, I was going to talk about when I had the question, I'm just like carbon offsetting and where that stands. But I would say with having, you know, before I guess it's mid to this in July, so in the last few months, is there anything else that kind of have come to mind that you should consider as far as recommendations? I would say not at this time. I know that there's a number of studies that are currently going on, one sponsored by the DOE and the one by RII around indoor agriculture and cannabis cultivation. Those are going on currently, I believe. And when those reports come out, there may be some, you know, insights in there that we would probably want to try and incorporate. But that's going to be probably well after this goes into effect and everything else. But I mean, other than those insights, I haven't really thought of anything additional. You did bring up, which I thought was a slight oversight in my part, the off-grid solar-powered or renewable-powered building and or greenhouse and what those standards generally would require. And I'd say we do have exemptions within the CVS code that would mean, like, keep building such as that it is entirely self-sufficient in terms of power is not connected to the care, et cetera, would not need to meet codes. But obviously, greenhouses were in a consideration at the time when we wrote the code. I think that perhaps if someone were willing to be brave enough to try and run a 24-7, 365-day indoor agriculture operation utilizing solar and battery, then I would applaud their bravery. So that could potentially be an exemption, but that would require that it was not connected to the electrical grid at all. I was thinking, I think for reversing in other states, that'd be more like cogeneration for something like that, because that's like megawatts of power needed. But for greenhouses that are in between a proper climate controlled and passive that would use solar for lighting. And I used to talk about the lighting requirement of the four kilowatts per connection. But yeah, I'm doing that to extend seasons to make sure that transpended plants are established, vegetative plants aren't pre-flowering for season extension to go beyond just construction string lights and have some kind of equipment. But that's all off-grid. Like that's all provided through renewables. So I would say that's probably the only piece that I would think about, but that's very difficult to work correctly. But that's possibly the only piece that I would come back and revisit and try and see if I could come up with an appropriate way to define it and work it. Gotcha. Yeah, but I'm happy to kind of look into that as well. I just had a question. If you have a couple of minutes on that 40 kilowatt because it's like a connection for connected for lighting. And I was wondering how that came about and how it will be assessed. So a connected load is obviously, you have a light switch and then it's all the load that's associated with it.  I think it was a four kilowatts or I don't know. 40 kilowatts. Yeah, 40 kilowatts. Okay, 40 kilowatts. Yeah, if that whole connected load was going to be less than that, but that includes everything, that doesn't mean obviously for certain cultivation types, they would have, they might have like one set of bulbs that use for one purpose and another set of bulbs that use for another. We consider both those set of bulbs as being the total connected load and we wouldn't consider just the bulbs that are being operated currently. So even if they're on different switches, the total load is what would count there. That requirement again, that's, I believe in Massachusetts, I don't sound like requirement, I believe Colorado may have, or some of the cities in Colorado where they're not Colorado, the state of sale, has similar requirements around that connected load. And so that came from our discussions with RII and NDI, our contractors. Okay, I think it was just categorized as like the low lighting, low green, low lighting, low green house. So I thought it's on there, that was like four lighting, I was like wondering how that differentiates essentially a green house that has 40 kilowatt connected to it. Basically the intent there is potentially increasing or extending the growing period within a day and possibly even shorter seasons, but not necessarily a greenhouse that's going to be heated or killed to any great extent. So it's not for year-round operation. And do you see a need to differentiate size for that at all? If you have a smaller greenhouse, you're more likely to comply with that than if you had a bigger, more penciling flow that you might, you know, intensity. Well, no, I think that generally, you know, your low energy buildings do tend to be your smaller buildings. And as you scale up, your connected load is going to increase almost exponentially when you're talking about the fixtures that you use for the growth. So you're very quickly, once you go over a certain size, you're going to go well past that 40 kilowatts if your size is... No, I could give you an exact size because it really depends on what your light fixtures are in terms of, I mean, it could be a reasonably large facility on a grand scale thing, but they're using LEDs versus, you know, a small facility using double-ended sodium, or actually the single-ended sodium because it's for all the greenhouses, but the 1.7 EVE requirement. But, yeah, I don't see the need to do an MGA intensity size differential for that piece. Okay, sounds good. Yes, go over. Can I ask a quick question of you guys? This is Kelly. So you mentioned a different subcommittee. I think you said it was like regulatory permitting, subcommittee, you referenced a couple times. Is that correct? I think the compliance and enforcement subcommittee was referenced a couple times. Okay, so I would be curious if either folks on the call or if that committee would look into, I'm thinking, so noodling around about, you know, the idea of us putting in cannabis establishment requirements into our CVS code, and I just wonder if, you know, where the authority currently resides and if the cannabis control board or something would have to give the department specific authority or would have to reference or something for us to be able to include those kind of requirements and the commercial code energy standards are not. Kelly, if I may, I might ask my general or the cannabis control board's general counsel to look into that. You know, he's done that and for other reasons, you know, for instance, if we did go with DLL, would they need to have any legislative fixes to give them authority to regulate retail establishments in addition to tobacco and alcohol and so on and so forth. I've got a laundry list of potential legislative fixes that might need to happen with strategic state partners to give them certain authority. So I might connect David with, David, sure with you if that works for you. Sure, yep, yep, and I can pull in one of our, our lawyers that work on that energy standard. So that'd be great. Thank you. Thank you. Yeah, so just last I threw in some energy use information, I used the RII, that's an 18 report, they go in front of your data, it's definitely not too accurate, especially in the Vermont context, but kind of some of the better information is also reported and definitely slanted with Oregon. I think the 81 grows there and not that many greenhouses outdoor, but you can see from there, like I did it based off of kilowatt hour per sport foot and per grams, those are the two market estimates we had from VS's kind of initial market report. So I'd say it's probably somewhere between those two, I'm working on getting some more better figures, I just had to dig them up and ran that time, but for the whole industry, we could be looking at 30ish, I would say gigawatt hours of energy consumption, but could be as low as one and a half gigs and a size 40, give or take. And that's just what the 60, 20, 20, plus 60% outdoor, 20% greenhouse, 20% indoor, which is a number that turned over some reason stuck in my head from the last meeting. So, well, thank you guys, everyone. This was great, I think our most productive meeting today. Yeah, just do a synopsis of kind of what we've discussed and where we stand on certain things. It seems like most of what you guys have recommended looks like we're in agreement about and then just get a little caveat here and there that we will touch it up. So. Can I just take up that we're more than willing to answer like any questions and writing too, if you have more that come up and also we still, I believe Barry can correct me, I believe we saw the MDI on contract within the year. So if there's other expertise that would be helpful, we can pull them in as well. Okay. I'll put that up. Thank you so much for that. Thanks guys. I think, yeah, once we kind of figure out where these little, good rest of your day. Thank you guys. Thanks everyone. Thank you. Thanks everybody. Can you?