Board of Supervisors — 2021-03-09

When meeting the Santa Barbara County Board of Supervisors. Madam Clerk, please call the roll.

Supervisor Hartman

here

The next item of business is approval of the minutes from the March 2nd, 2021 meeting.

So moved.

Second. Is there any discussion? All right. With that being further from my colleagues, Madam Clerk will you please call the roll.

And Tara Nelson.

Aye

Motion passes unanimously

Madam Clerk, are there any announcements or changes to our agenda today?

Chair Nelson and members of the board. Yes, I have quite a few announcements this morning. I would like to announce that we did post an addendum to the agenda on Friday The department is requesting a continuance of administrative item number 10 to April 6 2021 Administrative item number ten is from human resources It is to consider recommendations regarding an ordinance amending chapter 27 personnel articles 1 & 2 and a resolution establishing County office hours In addition to that addendum, we also added administrative item number 22 to our agenda. This is an honorary resolution sponsored by Supervisor Williams and Supervisor Hartman.

It is to adopt a resolution proclaiming March 10th 2021 as Tipetan Uprising Day in Santa Barbara County. We also received a request to trail Administrative Item A-7 till after closed session. Administrative Item Number 7 is from County Council, it is to consider recommendations regarding a contract for outside council with Stromwasser and Wooster LLP. In addition to trailing a seven, we did receive a request to trail administrative item number twenty one till after departmental item number three.

Administrative item number twenty one is a resolution to be presented and sponsored by Supervisor Williams and Supervisor Hartman. It is to adopt a resolution proclaiming the month of March 2021 as Women's History Month in Santa Barbara County. Turn Nelson and members of the board I would also like to remind the public that the Board of Supervisors meetings are now being interpreted in Spanish. Cox subscribers can turn on SAP under their language settings. We're updating our system with Comcast, but we should begin broadcasting board meetings in Spanish by March 16th 2021 meeting.

Lastly, turn also to members of the board. I would like to remind the public who are participating in our meeting today of the boards alternative methods of public participation for alternate methods of public participation and to provide public comment on general public comment or an item on the board's agenda today. Please see page 2 of our agenda. Individuals that would like to provide verbal public comment, you may do so via Zoom by registering in advance via the link available on page two.

After registering you will receive a confirmation email containing information about joining the Zoom meeting. Once the chair has announced the item you want to comment on please join the meeting with that information provided. The clerk will call you by name or the last four digits of your phone number when removed from mute you will hear a notification that the line has been unmuted If you are using a touchtone phone, you may need to press star six to unmute yourself. Again if you're using a touchtone phone, you may need to press star six to unmute yourself.

Each person may address the board for up to three minutes and this is at the discretion of the chair. If you have any questions regarding this process please contact the clerk of the board's office at area code 805-568-2240 again that's 805 5 6 8 2 2 4 0. Thank you and that is all my announcements.

Thank you, Miss Alexander. Mr Council

Chair and Supervisors concerning the announcement of the request to trail item a 7 until after closed session I note that that's a timing request and that the matter is not agendized for discussion in closed session and this matter involves a contract for outside counsel for the independent redistricting Commission

right? Thank you, Mr. Gozoni. Next out of business is the County Executive Officer's Report. CO Miyasato, do you have anything to report today?

Yes I do Chair Nelson thank you good morning Chair Nelson and board members. I just have a couple of good news announcements to make and although we've been busy with the pandemic I think it's important to recognize our employees who are continuing to do their job every day even under changed circumstances so one of two announcements one is just to recognize someone in the Ag Department Scott Perkins an inspector from the Ag Commission Weights and Measures was recognized by his peers across the country this week during National Weights and Measures Week. The industry recognized Scott for his dedication to strong work ethic, especially while operating under constraints and impacts by the pandemic. And many may not know what a weights and measures inspector does but consider them the watchdog of weights and measures involving Commercial transactions, Santa Barbara County consumers can feel assured that they're getting what they pay for with regard to our products weight volume count duration or advertised price commercial weighing and measuring devices package content statements and advertise prices are regularly inspected to ensure their accuracy.

So congratulations Scott for being recognized by your peers nationally. The second one I want to announce is that in every March, in honor of Women's History Month, the California State Assembly Women's Caucus sponsors and organizes the Assembly Woman of the Year event at the state capitol. Due to the pandemic this year's event will be held virtually next Monday. We are proud to announce that assembly member Steve Bennett selected County Public Health Director Dr. Vaughan Dovernoso as woman of the year to represent the 37th Assembly District. She was chosen for her leadership throughout this pandemic And she's been instrumental as we know in guiding the county through this unprecedented challenge.

So congratulations to Dr. Von Dovernoso, I know we'll be hearing from her later today as part of the COVID update.

Thank you Madam CEO and congratulations to Dr. Dovernoso and Mr. Perkins. Next item is approval of the administrative agenda. Do any board members request to pull any items on the administrative agenda?

Mr. Chair, I would like to pull A11 please.

All right, I'd like to pull that item as well. Are there others?

Mr. Williams? I was going to just say something with the honorary resolution A22.

And Supervisor Hartman do you have anything down there as well?

No thank you.

Okay and we're going to hear item A7 after closed session this afternoon so can I get a motion at this time to

Excuse me, Chair Nelson and members of the board. I do have a couple requests from the public on Administrative item number seven that was previously polled 11 also pulled 22 And we just received your request on 8 administrative item number four

Okay, and how do we take up item eight ten? That's been So do we need any motion to continue that item

Chair Nelson and members of the board. Yes, we can have a separate motion to continue that item to the April 6th meeting or that can also be a part of the balance

okay? Let's keep it apart of the balance if we can So can I get a motion to approve administrative agenda with the exception of items A4, A7, A11 and A22 And Actually, I think 22 can actually be approved but yeah, it can be moved so strike that without a motion without a 22 and And include continuing item 810 to the April 6th agenda.

I Will move the balance of the agenda and the continuances requested

Second right madam clerk roll call, please

motion passes unanimously.

Okay let's go ahead and take these items in order. I believe we have item A4 that's been pulled by the public

Chair Nelson and members of the board, administrative item number four is from behavioral wellness. It is to consider recommendations regarding a behavioral wellness early psychosis intervention grant award. And we do have one request to speak from the public on this item and that is Lindsay Walter.

Ms. Walter when you're ready you have three minutes.

Hi guys, this is Lindsay. I'm the deputy director. I think I signed on to the admin link so I don't have a comment on our item.

All right well thank you we'll go ahead and can I get a motion to approve Item A4 then? So moved.

So moved Hartman.

Second. All right Madam Clerk can please call roll on Item A-4.

motion passes unanimously.

Thank you all right so that moves on to where do item A7 after closed session a 10 has been continued 246 that takes us to item A11 Madam Clerk could you please read A11 into the record

Chair Nelson and members of the board, administrative item number 11 is from Public Health. It is to consider recommendations regarding an ordinance amending Santa Barbara County Code Chapter 16 to authorize microenterprise home kitchen operations to be permitted countywide as a food facility and a resolution amending food facility fees to include application plan review and annual permitting fees for microenterprise home kitchen operations And turn also members of the board. We do have 6 requests to speak on this item from the public

before we get to the public. I know that it was pulled by Supervisor Lavagnino, Supervisor Lavagnino would you make comments first?

I'd like to hear from the public first please

and I have some concerns as well but I'll let the public go first so Madam Clerk.

Chair Nelson and Members of the Board We will begin with Joy Casting to be followed by Kay Timms.

Ms. Casting, when you're ready.

Good morning.

Joy, if you can please do me a favor and mute all other streaming devices that are in your room? Yes. And once you have everything muted, you could begin your comments. Thank you.

Okay, good morning Board of Supervisors. I think it still does this. It's

working on our end.

Pardon?

You can go ahead with your comments thank you okay thank you

Good morning Board of Supervisors, my name is Joy Casting and I am the Code Enforcement Supervisor for the City of Santa Maria. I'm here today to speak with you on the second reading of the micro kitchens ordinance or the MECOS. I'd like to start by saying I have been working with County Health for many years to include throughout this pandemic and many years prior.

I hold great respect for everything they do on a daily basis, and very much enjoy working with them. However the City of Santa Maria does have concerns about this ordinance. The ordinance negates many areas of public safety outside of food. It limits appropriate fire suppression building and zoning laws Additionally, MECO operations are in clear conflict with our current permitted home occupation laws and sets an unfair advantage to everyone who is currently operating with licenses and permits.

This is also a time when our current restaurant facilities are struggling to survive and will potentially create a mechanism that will provide an additional unfair advantage to an already stressed industry. We do have unpermitted home occupations that involve food sales. The Code Enforcement Division investigates them when we receive complaints, and we do have tools to address those violations.

Having them regulated through the Health Department will and may provide some assistance for food safety However, the adoption of SB 626 and the ordinance does not provide any safety precautions for fire building or again our sewer which are all mandated requirements that the city must abide per the state of California. The city takes these requirements very seriously and as does our community. We accomplish this through education, outreach, plan submission design all those things all to ensure public safety. This new ordinance does not account for any of those requirements which again sets an unfair standard and fails to protect public health The concerns of the community impacts and potential unfair advantage in addition to the conflicts with the City of Santa Maria's current municipal code has brought me here to request, please do not pass the second reading and allow our city and community to become fully vetted with this ordinance In addition to the impacts that will potentially have on our neighborhoods and our business industry.

Thank you so much for the time and consideration.

We will now go to Kaye Timms, to be followed by Mayor Alice Patino of Santa Maria. Turn Nelson and members of the board, my apologies. It appears K is not logged into zoom the zoom meeting at this time so we will now go to Mayor Alex Bettino of Santa Maria to be followed by Shelby sin.

Madam mayor whenever you're ready.

Okay I've got the unmute button can you hear me?

We can Alice thank you.

Okay. Dear County Board of Supervisors, as your March 9th meeting I urge you not to approve the second reading of the ordinance to allow micro enterprise home kitchen operations and instead continue the item until these issues are thoroughly vetted with the local cities and with the community. If approved this ordinance will allow residential properties to convert to restaurants without many of the public health and safety requirements Generally imposed on restaurants and other food facilities.

The proposed ordinance will create many negative impacts in the city of Santa Maria. We are very concerned about our health and safety problems, further deteriorating zoning laws in residential neighborhoods creating inequities with traditional brick-and-mortar restaurants and many other drawbacks your board must consider. The city is on record in stating the following drawbacks. Micro kitchens happen in cities and our code enforcement staff, as you've just heard are frontline in protecting health and safety. We have for decades discovered a current violations of illegal kitchen selling unsafe food out of dirty kitchens, garages, and yes backyards.

We have seen beef jerky in the back of a pickup truck, tamales being made in bathtubs In our community micro kitchens will raise greater risk for fire and sewer overflows. And if you haven't seen what a sewer overflow does in a residential, in a home I've got pictures to show you yet many buildings zoning and mitigation for increased grease production or fire suppression requirements cannot be required. These are all requirements that apply to licensed food service As you know, many of our traditional brick and mortar restaurants and facilities are now suffering due to I have had so many restaurant owners contact me complaining about these micro kitchens and if you go on to social media, you can see them.

Cut up mangoes, pineapple and other cut up fruit on the streets. And they have no place to go and wash their hands and to keep the area clean. So we have so many things going on in Santa Maria. I'm asking you, I am begging you please do not impose this on us. And so for all these reasons, I'm asking you please do not approve the second reading of the ordinance. And instead if you choose to continue into the matter is properly vetted Among the cities and the business community. And I thank you for your time.

Thank you, Madam Mayor.

We will now go to Shelby Sim to be followed by Rashmi Sharon.

Miss Sim when you're ready. Mr. Sim, thank you very

much.

No worries at all. It's great to speak in front of me today. Thank you for the opportunity. I would just like to respectfully request a continuance on this item. Thank you.

We will now go to Rashmi Sharon to be followed by Terry Strickland.

Please proceed when you're ready.

Good morning and thank you for the opportunity to speak today. I would like this is my first time participating, I'm a local business owner here in Santa Maria, Arroyo Grande and Lompoc area. I am owner of about 15 restaurants and I am opposed to this ordinance Again, as Mayor Alice Patino had she spoke earlier some of the same concerns as we follow these particular guidelines that the city has in place. I think we would be in violation if this was to move forward so I would just like to say I am opposed to this ordinance. Thank you.

And we will now go to Terry Strickland who is our final speaker on this item.

Ms. Strickland when you're ready.

Thank You Chair Nelson and supervisors I'm speaking on behalf of the reopening the Central Coast Business Coalition it's made up of over a hundred businesses in the Santa Maria Orchid area and We urge you to take a step back and re-examine this ordinance. Many of us in this business coalition, and it's not all restaurants there's other small businesses also but most of us are very active in the community and it was quite by accident that we came...

This ordinance came to our attention. We believe the outreach to those affected by such an ordinance has not been thoroughly completed. And I've been around I've been doing a lot of government stuff for many years and I understand that you do outreach and people don't pay attention. But, you know, I pay attention to this stuff and didn't know it was happening until last week.

So I think the outreach needs to be better. And, you know, the brick-and-mortar restaurants and caterers have to follow stringent guidelines to operate. And that's not even taking into account You know, there's so many questions we have about it just seems like an uneven playing field for everybody. And we're glad to see the mayor of Santa Maria speak out on this issue. I think you need to hear from all of the cities because what you do impacts all of them they have to follow your rules. So I think they all need to weigh in on this and For the Director of Environmental Health Services to say that in his letter to the board, that there won't be any increase in staff. I just don't understand how that could possibly be when you're adding more work.

You can't expect more work out of your staff. They're already stretched so thin now. This might've been a good idea but I think the impact, the negative impacts on the community and small businesses You need to vote no on this today and re-examine it. Thank you for your time.

Thank you, Ms. Strickland. Madam Clerk, were we able to get Ms. Timms back on?

Chair Nelson and members of the board, unfortunately she did not rejoin our meeting

so that

Terry Strickland was our final speaker.

Thank you. Let's go ahead and Supervisor Lavinino, you pulled this item

Yeah, thank you. You know I first heard about this a couple of years ago actually it was moving forward and I think Terry brings up a good point that that it you know I know we've done when I looked at what the outreach was and we got the response from the department on what's been done she's right there is we have our public meetings we did a lot of outreach I'm not sure what the response was that's something that was kind of missing from a letter how many people actually showed You know, what was the input from the cities?

I'm curious. Is there a way to obviously my district is Spoken up the loudest on this, it's probably most impacted. I would imagine that there's quite a few of these operations already in place and it seems to me that the city was talking about code enforcement and we were talking about sending out public health and environmental health. So I'm curious right now is when someone identifies I'm imagining code enforcement probably stumbles on these coming out and checking out other things. What is the protocol right now? What happens, do they get reported to public health and public health goes out and does it an investigation or how does it work right now?

Mr. Seifert

Yes, Chair Nelson and members of the Board Supervisor Lavagnino. Lars Seifert Environment Health Services Director with the Public Health Department when illegal or unpermitted food vendors are identified they are referred to our agency for follow-up and investigation it is currently illegal to operate without a health permit in any situation and so then we would follow up with the enforcement which includes A cease and desist as well as any remedies that are provided under the state retail food code to resolve the issue.

Okay, so when I looked at this originally and was going through this process, I kind of looked at this as not adding a bunch of new businesses but I thought it was more of an enforcement tool to deal with situations that are already out there. And forcing people into training in a permanent path and having more enforcement. It's interesting though, I don't pretend to be an expert.

Once you start sitting up here and you have to deal with 2,000 different things going on, I can't be an expert on everything so I rely on the community. And for me personally the community has responded in a way that taking something that I wasn't too overly concerned about and A good tool moving forward that I'm not going to try to impose something on folks that are this adamantly opposed to it. So for me personally, either we need to do more outreach but I'm not sure that's really going to get us anywhere because I feel like these folks are going to be opposed anyway.

But I'm going to take a step back on this one for me personally.

Thank you Supervisor Lavenino. Supervisor Hart?

Yeah, I think that Supervisor Lavenino is probably right to be sanguine about the ability of us to do more outreach and to bridge the gap but I always want to defer to that and give it a chance because we really don't know. I think there is a great deal of misunderstanding about what this is and I think understanding the facts would help the dialogue And so taking a little more time to make sure we have, we circle back and have this conversation. But you know ultimately this will require I think a balance between what folks are concerned about legitimately health and safety making sure that these operations are high quality and the impacts on the neighborhoods are modest You know, but the purpose of this is to create opportunity and economic opportunity for small scale entrepreneurs.

And if you know if the argument's going to be that bricks and mortar restaurants don't want competition, that's not what this is about. And we won't be able to resolve that. But if there are issues that are legitimate about how this is gonna be enforced or we have the proper level of staffing at the county to make sure that there can be enforcement You know, did we underestimate that? I think those are absolutely legitimate questions and deserve a thoughtful response and reply.

And in that sense, I would support a little more time. Thank you, Supervisor Hart.

Supervisor Williams.

Well, I mean, I think there is a number of Folks who hope to do this in my district or already do it. And we have had an experience here, right? A similar piece of legislation was passed about cottage food industry. It's been already implemented by the county. It has already been a success. It has already increased public health. It is essentially a way Legalize the ones who are doing this safely and have an enforcement mechanism on the ones that don't.

When you try to enforce on anyone that makes food at home, you are in an unwinnable enforcement quandary. You're trying to punish both the righteous and the wicked at the same time. That doesn't work. So one of my sort of questions is just practical, right? We already know that the department has successfully implemented this kind of change before on the cottage food area.

We already know people are doing it and that that has a great degree as Mayor Patino pointed out, great degree of public safety problems And that the intention here is to have the guidelines, trainings and safety resources to home cooks. To do this in a way that increases. It increases public safety and increases food safety to the public. The other thing is philosophical is it's just kind of weird to hear for years and really try, you know I've tried to join this effort to reform the county on not trying to regulate every aspect Create business opportunities for themselves and it's just kind of weird.

to hear for a long time. We want you to give us business opportunities we want to give us business opportunities and then finally, we have one example where where the county's going to legalize something that now is a great business opportunity and then we have most of those same folks going whoa let's take more public input so I mean I guess if it's genuinely to create more outreach I might be persuadable to that, but I honestly think that this is simply a reaction to the moment of insecurity that we are in.

You know, as shown by the cottage industry situation. It's not as if like every bakery has been forced out of business by a little home bakery in the last couple years since it was legalized. I think that maybe the timing in that way is sensitive That people are looking at their balance sheet, they're looking at their business in trouble because of COVID and lockdowns.

And it feels like a moment of insecurity where this might be something that people feel nervous about but I just don't see how us not pursuing this makes the situation any better.

Thank you, Supervisor Williams. Supervisor Hartman, please. I'll come

after you if you like.

No please.

I did have several questions if Mr. Seifert is still with us and the first has to do with alcohol and the ABC licensing process and how it's I assume it's the same as it would be for anybody very rigorous very expensive and very rare

Supervisor Hartman through the chair. Yes, the State Department of Alcoholic Beverage Control has put stated guidelines and requirements out on their website regarding MECOs in specific and they would be subject to the same ABC licensing requirements as any brick-and-mortar or other facility that would be seeking an ABC license Additionally, we have the also indicate that on site consumption of beverages.

If people brought beer wine to a home location would also be subject to ABC licensing requirements as well so They would be subject to the same requirements. We did separately reach out to a couple of counties locally in Southern California that have been early adopters of this, both Riverside and Imperial County. They have stated that to date they're not aware of any of their home kitchen operations that have been successful or have sought an ABC license. I think maybe one or two are in the process but Their facilities do not, you know they've been directed through ABC and have not pursued that at this point in time.

And then I have a second question, and that is about enforcement and what we expect in terms of additional burden for county staff. And specifically, I am interested in what Mayor Patino raised about grease or things clogging up the sewer system. Could you comment on those?

Supervisor Hartman through the chair The current, you know staffing and potential enforcement burden has been evaluated for what we would see is probably the extent in scale and scope of MECO operations. And so we are adequately staffed to be able to accommodate that. We currently respond to these sort of complaints of unpermitted businesses and currently changing to allow MECOs to be a permitted facility and providing that pathway to compliance would not change And so, you know, I think it's important to note that this is not a sort of enforcement burden and actually would lessen it over time giving these folks an opportunity to. You know, be safe and, uh, and be licensed by environmental health.

Um, with respect to the sewer again, Comments from sewer agencies, particularly on that issue. Again this is a very micro scale operation it works out if if our home kitchen was you know they're allowed up to 60 meals a day or week That would be about 10 meals a day so a typical family is going to have you know 12 to 15 meals served in their home kitchen This would be the additional You know additional 10 if you put it in that scope So we don't anticipate that this is going to be a issue with sewer agencies. However, we would certainly be willing and able to provide that outreach and guidance and assistance with local sewer and sanitary agencies to make sure that it wasn't a problem.

Thank you then I had some comments. First of all, we have been as a county trying to offer people more and more opportunities to generate revenue in their homes. We have SDRs homestays were working on farmstays were working on an agricultural entrepreneur or enterprise ordinance, the cottage industries. I think it's part of a larger societal trend where individual entrepreneurs are arising and indeed many have in their home kitchens coming up with various things that eventually catch on get into a bigger market.

It's my belief that this is an opportunity to provide healthier foods in food deserts, it also as people have mentioned is an opportunity to bring more training and regulation to what's already happening and elevate that And most significantly, it's an opportunity for those who can't raise the capital and deal with all the regulatory hurdles initially to take a step in a direction to becoming an entrepreneur. And in that sense I think it's really a road to promise for many people and it's a matter of creating more opportunities and social equity so I'm very supportive of this.

Thank you, Supervisor Hartman. And I'm generally supportive of the concept of MECOs. You know there's a feeling that in the gig economy that we have everybody has a side hustle right? That not everything makes ends meet and this is a bridge Hopefully, in theory for a young entrepreneur and a young chef to try to see how they can figure it out. And in a legal way I see this ordinance as bringing people that are in the dark and bringing them into light and having actually more level playing field. That's something that I've heard from the public is that their concern about the level playing field here You know this is.

To me, this is definitely the JV team working their way up you know the some of the standards that have been put in place with this ordinance is a $50,000 a year gross revenue so and up to 60 meals a week. So if you're doing 60 meals For 52 weeks, we're looking at $16 a meal. And that's not something that's going to make ends meet if that's your gross number. This isn't a business I think would compete with a lot of the brick or mortar businesses in our community.

Do we need to try to look at all these things and see if we can't find something that has less impacts? I do. But I am in favor of transitional businesses. In Old Orkut, we actually have a food truck that is moving right now so that they've started off with the food truck and they got a following. And now we're going to have a brick-and-mortar restaurant in Orchard. So I like these entrepreneurial opportunities, and I'm generally in favor of them.

That said, you know, I've heard from the restaurant community. I've heard from my chambers, the South Coast, Santa Maria Valley Chamber, and Lompoc Chamber all asking for a timeout to get some additional input. I understand that Environmental Health had done some outreach but obviously not enough You know the alarm wasn't sounded until the second reading and so I would be in favor of getting back and meeting with our stakeholders for some meaningful conversations. I like to have our chambers and our restaurants actually on board with this ordinance ultimately, I am also Persuaded by the idea of what are the maximum impacts?

You know 30 meals A day, you know that could be all within the same. You know our two window You know if you have a bunch of couples coming on site to eat in which I know that's something that is done in some places I mean that could be a huge impact to a neighborhood And ultimately maybe even twice a week and that's not necessarily something I want next to my home and so I think that we should look at that as an issue and But generally, I want to allow more.

I want to get rid of some of these regulations. I like to see this be an opportunity to look at things like allowing wineries and other businesses to do more as well. And so I'm generally wanting to head in this direction but I think Doss you're right it's a moment of insecurity and it's a warranted moment of insecurity. A lot of these businesses are not back on their feet because of our actions and I don't wanna throw another brick on them So I'm definitely willing to take a step back, have a conversation and potentially maybe even delaying the implementation of this ordinance into the future once we can get outside the pandemic which is also another reason why the outreach might have been not quite adequate was because I think we've had a lot of other things that our mind has been on over the last year.

And if there's an additional input that we can get from this and get more people on board, that would be my preference. Supervisor Williams?

Mr. Chair,

I just. I appreciate the dialogue, I just don't think it's a real brick. I mean this is not coming from out of nowhere. This was legislated legislation debated at the state level. I'm pulling up the bill analysis right now. The supporters include the California Asian Pacific Chamber of Commerce, California Hispanic Chamber There's no chambers in the whole state in opposition to the legislation.

So I think it's a perceived brick, and if the outreach will give people time to understand that this is productive and not a big deal, I guess I'll go along with it. We're making a whole much ado about nothing here. This is something that will give some, you know the gross revenues that you can have to qualify for this is $50,000 a year or less right? This is some very small businesses that are not going Effective competition for the chamber members.

Supervisor Levin, Mr Chair?

Thank you. You brought up a point that I had a concern about and had not even When I was originally thinking about this, it wasn't even a thought until these letters came in. But on-site consumption, I was always looking at this as you were speaking about like a side hustle, a gig economy, somebody making pies from home, somebody making cookies at home and selling them either online or taking them somewhere. But the onsite consumption, I think is something that really needs to be looked at.

And the numbers that are associated with those, that could have a significant impact. And then the other thing is I think this all comes back to enforcement because the thing that drives me nuts here is the amount of rules we make and the regulations we make and And then at the end of the day, who's really going to be looking is that company 50,000 or less?