Here They Come

Below is a statement sent out this morning about the alleged second set of rules proposed by the Liquor Board for the implementation of I-502, Washington’s recreational cannabis use law.

Outdoor Grow Creates Serious Growing Restrictions

The Liquor Control Board releases the draft of rules re: I-502 is due today. The new rules will include caps on production and possession. Caps on production were introduced late into the process of rule making and did not have the benefit of public and stakeholder feedback. We hope that the current release will take into account public and stakeholder feedback and be modified accordingly to create a healthy I-502 market place. Please see the attached comments submitted to the LCB re: our concerns with the proposed caps. The OCA will be available for comment after the release of the rules at 509.322.4772.

The OCA recommendations regarding caps:

1. Adopt separate caps for what a producer can hold and what a producer can sell with the amount allowed to be possessed 1.5 times greater than the amount allowed to cap. This creates market storage and allows growers to reach their selling targets and transfer excess to the next year production cap.

2. 2. Use weight in pounds to determine what selling caps and possession caps will be and avoid using canopy cover as a cap which would lead to crowded growing conditions.

3. 3. Use these separate caps to build storage capacity into the market that can be used to quickly respond to potential market scarcity or transferred to the next year’s production cap.

4. 4. Assess the effect environmental compliance permitting will have on total production and timing and availability to the market related to the requirement that indoor growers obtain State Waste Discharge Permit (DOE Form 040-179 or Form 140-177). Permits must be obtained 60 days prior to discharging water to ground, surface, municipality or retention ponds.

5. 5. Rely on the traceability system and penalties to deter leakage instead of limiting what can be possessed by a licensee.

6. 6. Caps for outdoor based operations should be greater recognizing the fact that outdoor growers are limited in yields and number of harvests and should be greater than indoor caps which can continually sell to avoid a possession cap resulting in greater per unit productivity then outdoor growers.

J Jeremy Moberg

OCA President

509.322.4772

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