Background

• The CCB was tasked with building a regulated market that ensures fair and equitable access for Vermont’s many small producers. The current retail licensing pause is promoting the opposite—consolidating power among existing vertically integrated retailers and locking out new entrepreneurs.
• Retail licensing has been paused for nearly 12 months.
• During this pause, more than 40 cultivators have relinquished their licenses, while not a single retailer has done the same.
• Of the 110 existing retailers, at least 44 also hold cultivation licenses, reducing shelf access for independent cultivators.

Impacts of the Pause

• Market imbalance: 379 cultivators are left competing for limited shelf space, often cut out entirely as vertically integrated retailers prioritize their own product.
• Business closures: Small cultivators are forced to sell at rock-bottom prices, destroy product, or relinquish their licenses—sometimes losing life savings, retirement funds, and home equity in the process.
• Legacy market growth: As licensed operators exit, many will return to the unregulated market, undermining the goals of legalization.
• Exploitation: Certain manufacturers attempt to purchase biomass at unsustainably low rates ($50/lb), taking advantage of cultivator desperation.
• Consumer access: Many towns still lack dispensaries—some counties have none at all. This leaves consumers traveling long distances or relying on the legacy market.
• Retail monopolies: Single-shop towns face micro-monopolies, while a secondary market has emerged where retail licenses are being advertised for millions of dollars.
• Secondary Market for Licenses:  Producers are receiving advertisements from realty companies promoting dispensary licenses for sale at prices in the millions of dollars. While few will likely pay such inflated sums, the fact that licenses are being commodified illustrates how the pause is fueling speculation instead of encouraging fair market access.This trend further locks out small and mid-sized operators, leaving retail opportunities in the hands of those who can afford speculative investment rather than those committed to building equitable, community-rooted businesses.

Equity Concerns

• Prospective cultivators were given an annual one-month window to apply after cultivation licensing closed. No such opportunity has been offered for retail applicants, leaving many who invested heavily in future retail locations stranded with no clear timeline.
• This pause has left new entrepreneurs locked out while established operators consolidate power. 

Our Request 

We urge the CCB to:

• Reopen retail licensing immediately with regional restrictions to prevent over-saturation in towns that are already crowded (such as Burlington, Rutland, and Morrisville etc).
• Prioritize underserved areas by granting new licenses where consumers currently lack access, including counties with no dispensaries.
• Protect market stability by ensuring cultivators and manufacturers have fair shelf access and are not forced into exploitative pricing.

Conclusion

We are not asking for unrestricted retail expansion everywhere. We recognize that certain towns already have more than enough dispensaries. Our call is for balance—expanding retail where it is needed, not where it is already over-saturated.  There is still so much room for growth. 

We ask the CCB to initiate an emergency rule procedure under the cause of welfare to implement the redlined version of Rule 1.7.2 that enables the Board to avoid issuing new retailer licenses in towns that may already have enough shops, a rule it developed with extensive input from the industry, then reopen the retailer license to new applications. These steps will help reduce harm and safeguard the welfare of the regulated market.

Vermont has built one of the most accessible cannabis markets in the country for small, independent operators. Without swift action to restore balance, that accessibility will be lost.
 
We thank the CCB for its work in building this market and for supporting the average Vermonter’s opportunity to enter the cannabis industry. We respectfully request urgent action to reopen retail licensing—strategically, regionally, and with fairness in mind.