Outdoor cannabis farmers provide feedback to regulators
Photo | Courtesy of Regenerative LLC
An outdoor cannabis cultivation site in Uxbridge
Mindful of how difficult it is to grow much of anything in the outdoor climate of Massachusetts, never mind growing a crop that is legal here but still entirely prohibited at the federal level, the Cannabis Control Commission traveled to Great Barrington on Thursday to hear from outdoor growers about the challenges they face.
"There's 24 outdoor cultivators in Massachusetts for cannabis, and you guys have about 1.5 million square feet of canopy, of outdoor canopy. That's an average of 62,500 per cultivator," Commissioner Kimberly Roy said, though she later said the most up-to-date number of outdoor cultivators is 25. She added, "Today, we want to really have a constructive dialogue and feedback. But what you yield, literally yield, for the state of Massachusetts -- you are the top crop, right, you outpace cranberries now as the most lucrative crop in Massachusetts."
Indoor cannabis cultivation gives growers a more predictable (and potentially more profitable) environment but is an energy-intensive operation -- powerful lights help the plants grow and HVAC systems work to maintain temperature and humidity settings around the clock. By 2021, indoor cannabis cultivation was responsible for about 10 percent of all industrial electricity consumption in Massachusetts, the Northeast Sustainable Cannabis Project estimated.
Outdoor grows, while not as prolific in terms of total harvest yield, allow farmers to deploy organic farming techniques and generally produce cannabis flower that is more rich in terpenes and favored by some consumers.
Growers brought a variety of concerns and ideas to the CCC on Thursday, touching upon things like product and soil testing, site inspections, registration requirements for harvest-time workers, and the tags required to be placed on each plant to get them into the state's seed-to-sale tracking system.
Roy said after the listening session that the CCC's goal is not necessarily to promote or expand outdoor cultivation, but "to not see folks go out of business because of overly burdensome regulations."
"We want to make sure that the regulations we have don't put our farmers, our outdoor cultivators, out of business. And we want to make sure that, at the same time, we don't sacrifice public health, safety or welfare as we do it. So we're [at] an inflection point where we heard some really good suggestions today, recommendations, and we want to consult with our staff and our experts to make sure that if we move forward with any of those proposal[s] ... we want to make sure we don't jeopardize those three pillars," she said.
A group of growers who together make up the Sun Grown Cannabis Alliance presented a number of asks to the commission, including requesting that the CCC increase its "unnecessarily stringent" allowable microbial levels and eliminate two other tests for cannabis grown outside, eliminate soil and water testing requirements, provide greater guidance on the ways outdoor growers can provide quality control samples to staff members and retailers, eliminate the need to have tracking tags on certain small plants, and tailor the size of regulatory fines in accordance with the scale of the operator being fined since a large, multi-state operator could likely absorb a fine that would be a death knell for an independent local business.
David DeWitt, who runs the organic vegetable farm Dave’s Greens in Truro and is also a founding member of the High Dune Craft Cooperative cannabis operation, explained the kinds of biological farming practices he uses on his vegetables and how they can be employed by outdoor cannabis cultivators.
"We try to work in concert with the environment, trying to foster microbial activity -- not just in the soil, which is kind what you would think would be the normal thing ... It also includes the microbes on the leaf of the plant, and that's really where you guys get involved here," DeWitt told the CCC. He added, "We are using a lot of indigenous microorganisms to produce our crops, our lettuces, our cauliflower -- everything, everything we grow -- we're actually encouraging and spraying microbes onto our plants to have ... biological warfare, basically, on the leaves of our plant and flowers."
He said having the CCC restructure the microbial testing requirements is a key "first step in allowing us opportunity to compete in the industry and grow truly regenerative plant and products" since many outdoor growers currently cannot sell to retailers without the flower first going through some kind of remediation.
The tracking tags that are required as part of METRC, the seed-to-sale marijuana tracking system the CCC uses, were another popular topic of comments Thursday. Matt Allen, CEO of MA Craft Cultivation and its outdoor marijuana farm in Colrain, asked the commission to no longer require the METRC tracking tags be placed on autoflowers, cannabis plants that flower early and therefore remain fairly small. He said the tags weigh the small plants down, blow around in the wind and can damage the crops.
Nick Rosati, co-founder and COO of High Plains Farm in Plainfield, said his company grows outdoors and tries to run "a real sustainable practice." But the METRC tags, he said, are "one of the least sustainable things we deal with."
"So if I grow 5,000 plants throughout the course of a year, that's 5,000 METRC tags at 45 cents a piece, or about $2,500 after the cost of tax and shipping associated with them," he said. "Every one of them is RFID. None of them are recyclable. So multiply me times every other indoor grower and outdoor grower in Massachusetts, that's a lot of RFID pieces of plastic ending up in a landfill every single year."
Roy said that she had heard from METRC that the company "was doing a pilot with hemp-derived tags," but she did not know the status or outcome of that trial.
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