Keep it small

Two things happened on December 21st. The end of the world did not arrive, and the Washington State Liquor Control Board (WSLCB) packaged up the comments it had received to date and created a 162 page pdf.  The comments are notorious for what is not there instead what is offered. There is no input from the big boys. Not one major alcohol or spirits producer or distributor is present in the pages and pages of comments. There is warning after warning from citizens to not let “J.R. Reynolds” (to quote) types control the production. And there are numerous pleadings for a public policy that encourages diverse, smaller, dispersed growing operations. Justification for this ranges from making it more difficult for federal law enforcement to make “big busts and cripple Washington’s crop”, to continuing the public spirit of MMJ and collective gardens. A lot of the input on the micro grower issue comes from folks who have experience in growing from MMJ or admitted illegal “home-brew” operations. One fellow warned that big centralized growing operations are magnets for thief of product and money.

Keep it safe 

Numerous comments asked the WSLCB to make sure that the final product had no poisons or harmful pesticides and herbicides. One comment went into detail about the molds and spores that can accumulate on moist, recently harvested cannabis. If the WSLCB needs input from laboratory owners and operators they have it. Explanations of testing labs far exceeded the common understanding of keeping the product safe or organic. There actually was little if any demand for organic product. Hector Castro and Mark Strueli of the Washington State Department of Agriculture have said that they have been in consultation with the WSLCB about weights and measures, food safety and other on going services the department provides to the agriculture community but no one at WSLCB has specifically raised the “organic” cannabis issue. They did say they “stand ready to help in any way they can”, as does Washington State Department of Health. More than one scientist offered lengthy input about soil science and types, irrigation needs, and duration and form of light.

Keep me close

It seemed like every other page of the comment documents contained some well intended, experienced grower, scientist, or collective worker offering free advice. Two submitters actually offered money to help WSLCB to defer costs of consultations. Lawyers also were in full compliment as they offered the services of their firms and vast backgrounds of experience in business forms, agriculture enterprise and markets. Again, though no big boys, no large regional or national corporate input.

Keep them clean

A few of the comment letters offered interesting and what looked like helpful input about the requirements for the producers themselves. “No felons” one demanded. “Background checks should be a minimum” called another. It was clear, again, that even though the contributors were mostly well intended citizens, they knew who could cause problems for this infant producer business. One citizen suggested that if a user does not have a state certified receipt for their product, they should be arrested. So, people you better carry your papers with you.

Keep it cost effective

It seems those commenting on price and competitive aspects of the retail business all had met somewhere and gone over the OFM fiscal study that is available on the WSLCB website (http://www.liq.wa.gov/publications/Marijuana/I-502/502_fiscal_impact.pdf). These folks were all doing the math. From their long experience with growing cannabis they had dialed in the number of plants needed to produce enough product to meet the numbers picked out of the air by OFM. (It’s always fascinating to see state government predict revenue from taxing a product that exists in a moving MMJ market and the black market itself. They did make strong, solid points about the role of WSLCB. If the agency cannot create a production/processing/and retailing platform that matches or is lower than the street price of  black market cannabis, or at or lower than the product now available to a MMJ dispensary, the tax money will not be there. Some of the letters read like a formula for large scale orchards or vineyards; number of plants, area needed for growing, estimated production, and “time to market.”

Keep it illegal

A couple of comments were just plain requests to not create a world of retail cannabis. People openly stated they voted against the initiative. One fellow told the WSLCB that “recently, an article in our local newspaper requested public input regarding how “marijuana producers” licenses should work…isn’t that your (WSLCB’s) job? …why don’t you ask your local drug dealers to see how they do business. This solution is no more ridiculous than how this nonsense got on the ballot in the first place….Pandora’s box of exacerbation of social ills, the likes of which we have never before seen will be the only inevitable outcome. …(I-502) is an embarrassment to the Union.”  He took a shot at Colorado too.

Keep it genuine

It only takes doing background research for WSWire and this blog to realize just how passionate the present MMJ growers are about their product. Little did I know it was grown and selected for taste, potency, and unique effect. Most recreational users surely think one just gets stoned. But oh no, the grading and testing of this product is on par with fine wines and single malt scotches. And someone needs to tell the folks at the Orting Coop that when they all write essentially the same phrases in their letters and use the same signature “Orting Valley Coop” it begins to look at little like a letter writing campaign.

Keep them together

Besides input from the big boys, what was missing in the comments but was in our interviews so far was a pleading to carefully provide for a dual path of producers in Washington or a careful melding of MMJ producers and recreational use producers. This will be one of  the WSLCB’s biggest challenges as they proceed with what is just step one of implementing I-502.

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