Professional Documents
Culture Documents
Sections:
I. Introduction
II. Recommendations
III. Conclusion
I. Introduction:
Farm Bug Cooperative is an organization that represents an alliance of small farmers in the
Commonwealth of Massachusetts that will be applying for a Craft Marijuana Cultivator
Cooperative license. As a group, we believe in the seven principles that guide every
cooperative and believe that these seven principles need to be preserved within the area of
the draft regulations for adult use of marijuana (935 CMR 500.000: ADULT USE OF
MARIJUANA) that specifically addresses a Craft Marijuana Cultivator Cooperative. In the
following document, Farm Bug Co-op will put forth its recommendations to the Cannabis
Control Commission in order to ensure that, by law, per Chapter 55 in the Acts of 2017, the
Commission “promote(s) and encourage(s) full participation in the regulated marijuana
industry by farmers.” This is a requirement that the Commission must adhere to as put
forth by the Massachusetts legislature and as signed into law by Governor Charlie Baker.
The first recommendation of Farm Bug Co-op is to include language that requires any
organization applying for a Craft Marijuana Cultivator Cooperative license to be a
cooperative organization (namely, that it works in a democratic, cooperative manner). This
requirement will protect small farmers banding together as a cooperative to ensure that
large-scale corporations do not take advantage of the “craft cooperative” designation, thus
diluting the label of “craft” with an inferior, environmentally unsustainable product. We
feel that this requirement can be achieved in a straightforward manner by adding language
to Section 500.050 (Marijuana Establishments) that more specifically defines the elements
of a cooperative organization (see Recommendation #1 below). These requirements will
promote the participation in the cannabis industry of small farmers and will bolster the
local economies of small farming communities. In addition to this, we believe that such a
structure will benefit the consumer by creating a product that is both of the highest quality
and also organically grown to ensure the safety of the public.
The third recommendation of Farm Bug Co-op is related to the security requirements in the
draft regulations. We have heard concerns from many farmers about the stringent security
requirements for cultivators. Farmers know that security will be an important measure for
the cannabis industry to ensure the safety and well-being of both the farmer and the public.
That said, the layered approach to the security requirements in these draft regulations puts
an enormous financial burden on the farmer and will prevent many farmers from entering
the industry. Farm Bug Co-op recommends that the Cannabis Control Commission consider
implementing security requirements based on the nature of the operation rather than
introducing broad requirements. Many of the security regulations are specifically
restrictive to farmers that are cultivating in an open space or greenhouse.
II. Recommendations:
(4) A Craft Marijuana Cultivator Cooperative is limited to one license, under which it may
have up to:
(a) 6 locations for activities authorized for marijuana cultivators; and
(b) 3 locations for activities authorized for marijuana product manufacturers.
(5) A Craft Marijuana Cultivator Cooperative is limited to one license, under which it may,
as an autonomous, democratic organization guided by the seven principles of every
cooperative, determine its voting membership, including the number of cultivation and
manufacturing locations. This membership shall be specified by the cooperative at point of
license application.
Remove from Section 500.120 Additional Requirements for Marijuana Cultivators, Part (D)
as follows:
(D) All phases of the cultivation, processing and packaging of marijuana by a marijuana
cultivator shall take place in a designated area that is not visible from a public place
without the use of binoculars, aircraft or other optical aids.
Eliminate Part D.
III. Conclusion:
Farm Bug Cooperative thanks the Cannabis Control Commission for all of its hard work and
dedication rolling out the legalized adult use cannabis industry in Massachusetts. It is our
hope that these recommendations have given the Commission helpful information in which
to use for their final drafting of the regulations. Should the Commission have any questions
about these recommendations, please feel free to contact the Co-founders of Farm Bug Co-
op.
It is our hope and the hope of the farmers that we represent that these recommendations
will be considered in good faith. The recommendations put forth in this document are the
result of speaking to many farmers throughout the Commonwealth in person, over email,
and through agricultural events. We are confident that these recommendations represent
both the desires and needs of the farmers across Massachusetts who we have been
speaking with regularly throughout this legalization process. Farmers and the agricultural
communities that they live and work in are the life source for humankind. It is these
farmers that grow our food and raise our livestock. Our farmers deserve a level playing
field for the legalized cannabis industry. We believe that these recommendations move
closer to creating such a level playing field. We hope that the Commission feels the same.
Respectfully Yours,
Eric R. Schwartz
Co-Founder
Farm Bug Co-op