December 5, 2017 – Cal NORML has sent comments to state regulators regarding their emergency licensing regulations for cannabis cultivation.
“We are concerned that the CDFA’s proposed emergency regulations on cannabis cultivation licensing fail to limit the total amount of acreage that any one applicant may accumulate. This opens the doors to large-scale, industrial mega-grows that could monopolize California’s limited available acreage, exacerbate environmental harm, and stifle participation by smaller growers,” CaNORML wrote.
“California does not need any new, large-scale, industrial grows,” the comments continue. “Rather, it needs to accommodate existing growers into the legal market with as few adverse impacts as possible. The total acreage needed to supply the state’s entire adult-use market is only about 1,000 outdoor acres, assuming one ounce/sq ft average yield and 2.5 million lbs. total state demand. It’s essential that acreage be allocated in a way that is fair to the many existing modest-scale growers who wish to participate and not thrown away on new industrial mega-grows.”
CaNORML suggests a licensing priority scheme, designed to minimize environmental impacts, which would allocate licenses in the following order:
(1) outdoor licenses of all types, up to a total of no more than one acre per applicant;
(2) indoor mixed lighting licenses, up to no more than one acre total per applicant;
(3) indoor high-intensity licenses, up to no more than one high-intensity license (1/2 acre) per applicant.
If there remains a shortage of applicants to assure adequate production, the recommendation is to continue issuing licenses for additional acreage in the same order:
(1) outdoor licenses in excess of one acre per applicant;
(2) indoor mixed lighting in excess of one acre;
(3) indoor high-intensity – firm cap of one acre maximum per applicant.
California NORML is a non-profit membership organization dedicated to protecting the interests of cannabis consumers by legalizing, taxing and regulating marijuana for adult use in California.