Vermont Legislature SmartTranscripts:

[Speaker 0]: Okay. We're live. All right. Good afternoon, everyone. Just after 3PM on, Wednesday, April 29, we are picking up continued work on, S three two three, an actor leading the miscellaneous agricultural products, and we are focusing on those couple of sections that are relevant to, hemp and hemp related products. And with us today is, Devin Dannett, co founder and CEO of Clean International Incorporated, which is

[Speaker 1]: local manufacturer.

[Speaker 0]: Not to steal your thunder, sir. How are you? Doing well. Cool.

[Speaker 1]: Thanks for having me. Appreciate Table is yours. Right. Well, thank you for the opportunity to pass out Visual Aid. I think that it'll be helpful as we navigate through the conversation today. Wanted to take a few minutes just to talk a little bit about my company and who we are and what we do. So the first talking point is the product I've passed up. This is a Vermont compliant product, fifteen milligrams of CBD, one milligram of THC. This would be considered a non intoxicating product, so under the limit of the 1.5 in current statute. So this is actually under potency for what is allowed in Vermont. So we are a hemp beverage manufacturer located in Vermont, and we are operating in the Old Bucks furniture infrastructure in Woolkett. We operate, well, I operate in both the adult use market as well as the hemp derived market. So you've got a taste of both worlds. You operate, in cultivation and manufacturing of beverages in the adult use market. That's what gave us the foresight and opportunity to enter into the beverage market for the hemp derived category for in state production for Vermont compliant products, as well as exporting out of Vermont. So just to give you a little background on who we are, Clean International currently 14 people, and we actively are working with around six subcontractors. And we expect that number to grow over the next couple of years to upwards of 25 to 30 people as full time employees. Clean cannabis currently employs 11 people in Hardwick. And, in the adult use market, we raised $3,500,000 to build out and operate our facility in Hardwick. For this operation, vitalizing the Books furniture infrastructure for beverage manufacturing, we've raised about $3,000,000 to build up this infrastructure and represent Vermont and bring a little piece of Vermont to the rest of the country. Walcott was very happy to see the old flex furniture infrastructure be utilized and bringing some job creation industry back to the town. And I'm going to breeze through some of these slides, because I really want to get to some of the talking points. I was asked to offer commentary on these three pages of line items here. There's a huge opportunity for this industry, even with the current pending legislation, consumers across the country are just consuming less alcohol. This category has grown to $27,000,000,000 in a very short period of time. And by 2032, even with the expecting ban in November, it's expected to grow to a $117,000,000,000 industry by 2032. So consumers are actively looking for alternatives to alcohol. Not that they've stopped drinking it, but you get about fifty four percent of Americans now that are consuming alcohol, and a lot of others have decided they want safer, healthier alternatives, just alternatives in general. One of the talking points and line items is addressing intermediaries and concentrates needed to formulate, properly dosed products. And it's important and there is language written, I'm very happy to see the way it is written. It's important that we, as operators, farmers, and processors, have the ability to purchase and utilize and just even possess intermediary concentrates. To be able to formulate the products that you see in front of you requires a lot of math. We need to be able to extract and isolate certain cannabinoids, in this particular instance, CBD and THC. Without the concentrated intermediaries, we can't do it safely and effectively. So being able to access those legally is very important to this aspect of the industry. Our business touches a lot of different businesses in the supply chain, from the farmers, both in hemp cultivation, to apples. You guys see that this is a collaboration type product with ColdHallow. We are very proud to have partnered with a staple of Vermont heritage and tourism that's been in business for over fifty years, and they have the trust in us to partner up in a controversial category. We are currently working with Feral Distributing here in Vermont for distribution. They're a great partner, happy to be working with them. A lot of retail, locations have picked up this beverage. You can find it in over 70 locations in Vermont right now. And we're obviously exporting a good number of these products, so we want to see this infrastructure allowing and encouraging farmers to cultivate hemp again. These are some of the businesses that we're currently working with here in Vermont and outside of Vermont. So Culhaw, I'm sure a lot of you recognize, as well as Kis Kombucha. We're going be working on some collaborative products for them as well. I'm gonna breeze through a few of these and get to some of the talking points of the actual language here, if that's okay with everybody. Yeah. First area I'd like to address, is specific to product registration and where it's highlighted the zero point four milligram total, THC for a product. In regards to the product registration, I understand the, importance of it and why it's needed. I would just ask that this be a one and done type of process. Register the product one time. There's opportunity for, follow-up and guidance, certain recall protocols. There's measures that could be put in place to ensure consumer safety without having it be an annual, reoccurring process. And I'm happy to answer any questions about that. If anybody wants any further context, I can certainly offer that. In regards to the point four, we see that as a placeholder federally. We none of us really know where things are gonna land. Would love to see the language be written in such a way that we would be able to adopt wherever we land federally. And if it is turned over to state authority to regulate just within the bounds of Vermont, that placeholder be left at the one point five milligrams, which is where the cat currently sits. So it gives the language versatility to adopt where things land federally, but doesn't handcuff us to that if it doesn't land where we want it to be, and we're not any further behind than where we are with our current stance on a one point five milligram. One point five is So 1.5 to 15 is the cap to be compliant in Vermont. So this product that you have in front of you is one milligram of THC to fifteen milligrams of CBD. So we have another half a milligram we could add to that. But we just chose to land at the one milligram and focus more on the CBD content and being compliant. I I have a question more or less, and I know you probably can't answer it, but in regards to craft processors, I listened to some of your commentary at the end of, Sam's testimony yesterday, where you were talking about setting up guardrails and safeguards, making sure that when the CCB is writing rules, that they have a little direction at your guidance. And I that resonates a lot working in the adult use, market, knowing that there's a lot of room for interpretation. So I guess if I was to have any input on defining a craft processor, I would question whether that was by employee count or revenue, or if they're not going to be subject to certain requirements that larger operators follow, would that be limited to just a producer that's making topical products, nothing that's ingested? Just a little food for thought there. The last section that I wanted to address is, the portion where it talks about regulating use of hemp processing facilities and equipment to permit processors to use the same equipment for hemp and cannabis processing, and to prevent cross contamination between hemp and cannabis. I think this is an awesome addition to this. It gives it gives adult use operators who currently possess the infrastructure to extract safely and effectively, the cannabinoids from the actual hemp or marijuana plants themselves. We wanna encourage farmers to start cultivating hemp again. A lot of the farmers that cultivated back in 2018 didn't possess the in state infrastructure to stabilize and have sales channels for their products. And if we don't have that now, then we're not going to have a lot of farmers that want to dip their toe back in the water. So allowing the adult use labs to extract hemp for concentrate gives farmers encouragement that they can stabilize their crops. I mean, if you've got farmers that are cultivating half a million or a million pounds of flour, walnut's a lot to set up in a in a space to dry it, and cure it properly. But if they had a partner or many partners across the state that could take that plant material and turn it into a concentrate, which is now shelf stable, and knowing that there's product manufacturers in state that are producing products not only for in state sale, but that their products they're producing could go on to manufactured goods that would be Vermont. We have committed to every product that we're making in Vermont, will be will be fueled by Vermont grown hemp. So every one of our cans that leaves the state of Vermont, the concentrate that is in it will be grown in Vermont. I think that if you create the infrastructure for all of that production to happen in state, you're gonna have a lot more producers that are willing to keep all of their business, in their production being Vermont based products. Right now, there's the ability to bring in concentrate from across state lines. There's also been a topic that was brought up by the control board at one of the last board meetings addressing, minor cannabinoids. And, minor cannabinoids, we're talking like CBD. That's the most commonly known minor cannabinoid. These minor cannabinoids are not as prevalent in marijuana strains. Marijuana strains are bred to produce high THC content. Sam addressed the fact that he has a lot of rec market operators that want to purchase CBD from him to basically produce less potent products. There's a lot of consumers that consume cannabis products from the adult use market for health and wellness reasons. It isn't just about getting high. The CCB would like to see, and this is my interpretation based on the meetings that I've viewed, they would like to see a lot of these minor cannabinoids grown in Vermont. Unfortunately, the minor cannabinoids are most prevalent in hemp plants that are bred for these minor cannabinoids, such as CBD, CBG, and CBN. For an adult use licensed cultivator to dedicate canopy space to growing minor cannabinoid rich plants is not cost effective. You're not going to generate enough biomass to extract enough of these minor cannabinoids to make it worth it for anyone to extract it or grow it. Now, if you have farmers that are growing hundreds of acres of hemp that are rich in minor cannabinoids, that creates a viable opportunity for labs to invest in infrastructure that's needed to basically isolate minor cannabinoids. And that would generate more in state sales for those cannabinoids. It generates more opportunity for adult use operators, it creates a bridge between the hemp farmers and the adult use market. So I think the language as written, it gives us a baseline, a good direction. We want regulation. My business belongs to the Hemp Beverage Alliance, which we're all advocating for federal regulation. We want to be told what to do. We want to produce safe products. We want to be able to have a business that doesn't have to operate in any kind of gray area. And I think that revitalizing hemp farming, hemp manufacturing, and hemp processing in Vermont is a huge beneficial addition to the adult use market. And it's going to keep more revenue in state from said producers. And that's that basically does it. I'd love to answer some questions and have some dialogue if anybody has any. Yeah. I'm more

[Speaker 2]: I might maybe I should know the answer to this. I don't can something like that would that be considered. You can't drink and drive without in your car, I would assume.

[Speaker 1]: So, this language addresses that. Right now, in the state of Vermont, it is my understanding that you don't have to be 21 years of age to purchase an infused beverage of this caliber that is considered non intoxicating. This language fixes that. If you look at my label, all of our products that are leaving the state, including in state, why would he be 21 years of age? You're not allowed to consume a beverage from the adult use market that contains THC. It's just like drinking and driving. I think this rule fixes that. We definitely support that. Okay. Yep. Thank you. Appreciate it. Any questions on the product registration piece?

[Speaker 0]: That is something I wanna touch on because right now, it's shorter timeline. One of the concerns from the CCB perspective is perishable products, especially food grade products. And that's why they're leaning toward more consistent registration practice. So as somebody who has a scaled up manufacturing facility, I

[Speaker 1]: guess sort of, like, what is your counterpoint to that? So my understanding for product registration, it's multifaceted. One, it's, they're seeing it as a revenue producer to help fund this program and guidance. And it's also to prohibit a lot of manufacturers that would love to sell one hundred milligram cans of THC beverages into Vermont. To be completely frank, a 1.5 beverage is not something that large manufacturers across the country are clamoring to make. Vermont, New York, and one other state are the only states in the country that have a cap that's that low. When you've got three states, in Vermont only being roughly 844,000 residents, and of that, a smaller percentage of people are of age to purchase the products, Me as a manufacturer, I would not if I wasn't in Vermont, I would not go out of my way to pay for a license and go through the effort to register products in a state that I'd be making a very, very small batch of product for. So you're not going to get a lot of these large producers, wanting to get licensed in Vermont. Product registration is not going to be a safeguard to keep them out. The majority of these companies are selling direct to consumer through e commerce. And there's not any infrastructure at this point that could safeguard or eliminate that from happening. If we could, it'd be great for the market. You've got consumers that can have forty, fifty, sixty, eighty, one hundred milligram cans, one one can shipped right through their door. That's taking away, dollars that would otherwise be spent in our retail locations across the state. The product registration piece isn't going to stop that, because they're still going to be selling direct to consumer. Even if our laws state that you can't sell these products in the state, customers are still going to get online and they're still going to purchase the drinks. I think the product registration piece is important in the fact that the state knows what products are out there. We're subject to a lot of different regulations in different states. The state of Connecticut wants to seek proof of licensure, that the state recognizes us as being a legitimate, operator and that we're meeting state guidelines. And there's a lot that goes along with that. CGMP, sanitation inspections, these are all things that we'd love to see built out by the governing agency if that ends up being the CCB. The health department won't step foot in any manufacturing facility that operates with any type of cannabinoid, even if it's just CBD. On one of the previous slides here, Labarge Quality Consulting. So this is a privatized, third party sanitation inspection company that we've actually brought in for a pre audit into our facility. The state of Connecticut requires some governing agency to sign off that we have a safe, food manufacturing operation, and they need proof of that. It would be great if the control board built out an agency within itself that could go out and inspect these facilities. For this to be a viable market for farmers, processors, manufacturers, like, we have to have export out of Vermont. And it's great to be able to produce products like this, where we're partnering with other Vermont brands to bring a piece of Vermont. And the one thing I haven't shared with you guys is we entered in the LA Spirits competition. So the beverage that you see in front of you actually won the best infused cider in the entire country. But not only that, we actually won the platinum award in the LA Spirits Competition. So this is was voted the best hemp infused beverage in the entire country. And that is going to receive thank you. Thank you for that. It's a huge accomplishment for a startup company that's just getting going. But this gives us the ability to bring a piece of Vermont to the rest of the country. And, you know, places like Cold Hollow, they drive tourism. If you ever driven by there in the fall, there's coach bus after coach bus after coach bus. And they're not forward facing on our label, but when people see Cold Holland, they see that collaboration, it really means something. And we want to partner with as many Vermont companies as we can, and that's why it's so important for us to be able to source all of our active ingredients and source concentrates from Vermont farmers.

[Speaker 0]: So with the product registration conversation, has anybody talked about doing a of like a tiered timeline, right? Like, you know, one year, two year for higher potency as opposed to lower potency? I've heard as far as potency or just just registering on the end? Well, I like saying, like, if you want to do it, you want you want to do want it done. Right. But I got Sam saying three years. Right. Like, has anyone had a conversation about, like, if the potency is the concern, you have something that is far more benign. Has anybody chatted with them about scaling that based on So one thing that we had discussed is

[Speaker 1]: right now the state limitation for max potency is one point five milligrams. And the way it kind of carries over into the adult use market, if it's over one point five milligrams, it's considered a marijuana product and has to

[Speaker 0]: be a

[Speaker 1]: small So what we had discussed is if you are at one point five milligrams or less, then you don't necessarily have to renew product registration like every year. There's other protocols to safeguard and to ensure, like we have to test every batch. And when we're doing manufactured products in the adult use market, you have to upload test results so consumers have access to those all the time. I think there's ways to safeguard the concerns without having to pay an annual renewal fee. And for me, the maximum number of products that I'm going to probably have in the remote market just because of what I'm producing is probably going to be four SKUs. So whether it's three years, every two year, every year, the products have been being produced in Vermont for quite a few years without having any kind of issues from a safety standpoint. It's a lot of extra that can tie up sales protocols. So if I produce a product, I have to send product out of state to Certify Labs to get it tested. And then if I have to go through product registration, that can type the product again for a lengthier period of time. I think product registration is important. It's just the frequency of how it's done and the protocols of how it's done and making it a timely process. I'm happy to pay the fee. I don't think that it's going to be a moneymaker, especially if you don't have a lot of out of state operators that are willing to get licensed and produce product consultants in Vermont. From an accountability standpoint, it's absolutely necessary.

[Speaker 0]: Okay.

[Speaker 1]: We have to have recall protocols, for insurance companies, and that's something that's required in the adult use market as well. I feel like the infrastructure is gonna be fairly cookie cutter and crossover. Anybody done CBD cheese? As it sets right now, At least in the adult use market, I'm not sure how the crops ever would work in the hemp derived category, but we're not allowed to combine dairy and THC, for the adult use market, same with maple syrup, Two major exports for Vermont are maple syrup and dairy. That could be a dangerous crossover if oversight is not done properly. Could it be done? Yeah, it could absolutely. What do mean? Meaning that we ship a lot of maple syrup out of state. If somebody was to produce maple syrup and packaging got messed up, or if it was an oversight, it was an actual THC product, now you'd be crossing state lines with, a product that can only stay in Vermont legally under our our regulations. So that was something they put in as a stipulation. No dairy and no maple syrup.

[Speaker 0]: From the gallery, please identify yourself for the record, sir. Dairy processing is regulated by FDA, so it's a federal delegation to the agency of agriculture and to get that dairy processing license you have to check it. You don't have any. So they're. Yes. So we'll see.

[Speaker 1]: It's not bad. It's just a nice.

[Speaker 2]: I guess I'm just satisfied to know that people have tried. Sounds like People have tried.

[Speaker 1]: This stone has been turned.

[Speaker 3]: You're right, it can be done.

[Speaker 0]: Just saying. Dude. Rep this, no.

[Speaker 3]: Did I hear you correctly saying that the health inspector would not inspect your plan?

[Speaker 1]: Yeah, we've reached out to the health department numerous times through trying to get registered with the control board for manufacturing, and it's a hard no. They're not willing to step foot in a facility that deals anticanotids.

[Speaker 3]: But as an ag part product, the USDA, would that fall under their purview? Do they have an inspector that does that kind of stuff?

[Speaker 1]: We have reached out to basically every agency that we could think of that would have the authority to offer any type of sanitation inspection, and it's been a note from everybody. So Connecticut has been at least gracious in saying that if you can get somebody that has credentials to offer some kind of sanitation inspection, they would accept that. It'd be great to be able to work with the governing agency that oversees us to do so. But as of right now, the health department is not willing to do that. I'm curious on this. Did you check-in with representative Nelson up in ag on this? Did I? No. Could you? Could I? I'm

[Speaker 0]: just curious, like, just to find out an answer to why on that for me. Yeah. Because you

[Speaker 3]: would think that there would be somebody that would wanna protect the consumer.

[Speaker 0]: Okay. Let's let's just sniff around on my curiosity.

[Speaker 3]: Okay. So

[Speaker 1]: he's beeping.

[Speaker 3]: I'm beep.

[Speaker 0]: Beep beep.

[Speaker 1]: Is that your ankle bracelet?

[Speaker 4]: It's a cop joke you gave me.

[Speaker 1]: Jokes. Okay.

[Speaker 0]: Alright, team. Keep it together. So

[Speaker 1]: many different angles. We've basically adopted the same protocols in our manufacturing space and the adult use market over to the hemp space. We had an initial inspection when we were setting up beverage manufacturing in Hardwick. Andy Sheberfield came on, I believe, to the control board from the health department. And so he had some experience in setting up commercial kitchens and operating in these, spaces. So I think that you got the folks over there with the knowledge to do so. It just needs to be implemented. Okay.

[Speaker 4]: Alright. We have 70 outlets.

[Speaker 1]: Across the state of Vermont. So convenience stores, liquor outlets, bars and restaurants, these are products that can be sold, and they can actually be served in restaurants throughout the state.

[Speaker 4]: What would you project your growth to be into the future over the next few years?

[Speaker 1]: In Vermont? Yeah. We're pretty aggressive. Feral Distributing is in, I believe, a little over 1,400 accounts in the state of Vermont. They only had about 70 accounts. The Delta nine infused category for them is fairly new. They're carrying us and products produced by one other company. So it's very new to them. But I think that we can get these beverages in close to 500 accounts over the next couple of years. Wow. The words I just Right.

[Speaker 0]: Say it smooth, dude, online. Just saying. So, but the biggest thing obviously is that within the context of this bill right now is that product or state registration component. Okay.

[Speaker 1]: And I don't have any opposition to any of the language. I feel like the commentary added offers a little more clarity and further dialogue to what the opportunities are. I think the biggest thing, like I said, is the crossover, the processors and the adult use. We want to create a program in state that's going to encourage farmers to start growing the skin. This is what we really need.

[Speaker 0]: Well, we all saw sort of that like bounce and drop off with the hemp industry. God, was that six, seven years ago now? Something like that. You

[Speaker 1]: as a committee, have, thoughts on where product registration should land? I mean, you've heard commentary from a lot of us. What are your concerns about where we need the safeguards in place, and what product registration actually does in that case.

[Speaker 0]: Listening to you is part of us figuring that out. Yeah. So we've got possession of just this language right now. Don't even have possession of the bill. We're just asked to look at these sections, but to do, like, real work on it because it's it is brushing so hard up against the adult use market, which is our jurisdiction. So that's why we

[Speaker 1]: were asked to take a look at this. I know it doesn't it doesn't serve the purpose today, but if you as a committee are interested in learning more about the process and how things can be safeguarded, I invite every one of you out to our facility to witness what we do there.

[Speaker 0]: That's definitely an option. And

[Speaker 1]: Matt's been to my facility in Hardwick. Yeah. A couple years ago.

[Speaker 0]: Yeah, was a little while back. Yeah. And they were really, yeah, brand new building, great facility. And I'm curious to see what you're doing in Volkert, yeah. And that it's a good interplay too with us with the with the, DLL portfolio and manufacturing of Delta Beverages. Rep Hooper, then rep Coffin.

[Speaker 1]: How many employees? So in the hemp business right now, I've got 14 employees, and we work with roughly six six subcontractors and on a routine basis. And then in my adult use business, we've got 11 employees. So overall, we're employing a little over 30 people. Nice.

[Speaker 0]: Doctor. Coffin?

[Speaker 2]: Yeah, just kind of switching gears, going back to the definition of craft processors. What could you provide us with here soon a better definition that you would think When I read into the Kraft processors based on what we've got sort of going here.

[Speaker 1]: Sure. When I read the language, my mind immediately went to size of operation, employees, and we've also had to disclose, revenue. So a craft processor, in my mind, would be somebody with two to five employees. And if they're not going to be subject to some of the safeguards and product registration, I think of those as a lot of producers that are making topicals, lip balm, shampoos, health and beauty products. If it's a consumable product that can change the physical or mental state of a consumer, then I think the same safeguards need to apply to all the businesses, whether you're two employees or 50 employees. But a producer of that size, I think, would be would be based on the size of their business in itself. Okay.

[Speaker 2]: So I when I see that, I think also, you know, how we discuss craft beers, craft brewers, small businesses there. Sure. Just trying to figure out a way to

[Speaker 1]: relate them. There's there's a lot of small producers in the state. Some of them only produce one or two SKUs, whether that's like a CBD infused lip balm. If they're working with full spectrum concentrate, even those products would be subject to testing under these new regulations, they would be probably deemed noncompliant. Point four milligrams by total contents is not a lot. Just to give you a little perspective, the one milligram drink that you have in front of you, so under the 2018 Farm Bill, the point 3% by dry weight, So think of it this way, if you were to boil down that can of cider till it was just basically the natural sugars and fiber left from that product, and you were to run the math on the amount of THC that was in that dry mixture, it needs to be 0.3% or less. That one milligram drink has 0.0003% THC by dry weight, and the federal limit is 0.3%. If and that's one milligram. So zero point four milligrams is where they're capping it. So the dry weight doesn't even come into play, really, because at 0.0003% by dry weight, that's one milligram. And zero point four milligrams, you can't even really associate the two numbers. So even a lip balm would have more than the 0.4% if they're using full spectrum oil. So 0.3% is flour. So when you harvest the flour to be compliant hemp, it has to be 0.3% THC by dry weight. As soon as you extract that, you just remove the plant material and you extract the oil into crude. You're just putting it in grain alcohol, for example, and you were to remove all the alcohol, you're left with dark sludge, black oil. You're now concentrating that 0.3% to 3%. So that's why the products need to be broken down and isolated to be able to properly formulate with them.

[Speaker 2]: Trying to get a better understanding. Absolutely.

[Speaker 0]: You know, this is really complicated, so ask the questions you want, man. Yeah. Yeah. And I'm I'm

[Speaker 1]: very serious. I'd love to see you guys come out to the facility. You can see the process and just more questions for sure. Yeah. I know we have a very limited time to have a dialogue, so. You're the CEO, and

[Speaker 4]: there's a partnership, and if there's a partnership, who's the partner? Sure,

[Speaker 1]: So in Clean Cannabis, my business partner is Derek Porter. He's my brother-in-law. So him and I own Clean Cannabis, just the two of us, 100%. Clean International, Derek is also my partner in that. Him and I are the majority shareholders. We own roughly 60% of the company. I talked about the money that we've raised for both companies. That's been self funded from our own pockets, as well as resources that we brought in from family members. Luis Guzman, the actor, is one of my partners in Clean International. He's on my board of directors. I have a couple other employees that are on the board and our partners in it as well. But Derek Porter and myself are the majority shareholders. We haven't brought any investors in that are from any significant out of state operation that could hinder or deter us from our mission and values. So Derek and I are the majority shareholders.

[Speaker 4]: In your hiring practice, how do you protect yourself from someone who might do harm?

[Speaker 1]: Well, that's a good question. I'm gonna be honest, we've brought in a lot of friends and family. We are a family owned operation. My younger sister works for us. One of my longtime friends of almost twenty years is my compliance officer. She came out on from the medical field. She worked for Royal Health Partners doing compliance for the health industry and working with the Feds in that regard. But like any other good operator, we interview folks. We ask questions to try to get a feel for personalities, and if it doesn't work out,

[Speaker 4]: we don't hang on to people.

[Speaker 1]: But we have very minimal turnover, and I think we've done a pretty good job of hiring the right people so far.

[Speaker 0]: Thank you. Anything else for Devin right now? No. It's good timing. Meetings from four to six, and I would love fifteen minutes in between. No, thanks you very much for coming in and giving us this rundown. Tech was effective and let's definitely chitchat about doing a site visit at some point. I think that's useful, especially as the