What Farmers Need to Know about Cannabis Legalization

(Brought to you by Farm Bug Co-op)

The Massachusetts Cannabis Control Commission has been working diligently to meet a very tight
deadline to begin accepting applications for adult use cannabis licenses on April 1st, 2018. The Draft
Regulations were released to the public this past December. There are 107 pages of regulations. That’s a
lot. So, we thought we’d break down the regs as simply as possible. Here’s what you need to know:

• The adult use cannabis industry, by law, is friendly to local small business owners and
farmers because it allows for many different licensing structures, which are included in the
regulations.

• But, before we get to the nature of each one of the licenses, let’s provide a brief glossary of
key terms so that you’re well-versed in the legalization lingo!

1. Marijuana Cultivator means an entity licensed to cultivate, process and package

marijuana, to deliver marijuana to Marijuana Establishments and to transfer
marijuana to other Marijuana Establishments, but not to consumers.

2. Marijuana Establishment means a marijuana cultivator, independent testing

laboratory, marijuana product manufacturer, marijuana retailer or any other type of
licensed marijuana-related business.

3. Marijuana Product Manufacturer means an entity licensed to obtain, manufacture,

process and package marijuana and marijuana products, to deliver marijuana and
marijuana products to Marijuana Establishments and to transfer marijuana and
marijuana products to other Marijuana Establishments, but not to consumers.

4. Micro-Business means a marijuana establishment that is licensed to act as a: licensed

marijuana cultivator in an area less than 5,000 square feet; licensed marijuana
product manufacturer, and licensed marijuana delivery service in compliance with the
operating procedures for each such license.

5. Craft marijuana cultivator cooperative means a marijuana cultivator comprised of

residents of the commonwealth organized as a limited liability company or limited
liability partnership under the laws of the commonwealth, or an appropriate business
structure as determined by the commission, and that is licensed to cultivate, obtain,
manufacture, process, package and brand marijuana and marijuana products to
deliver marijuana to Marijuana Establishments but not to consumers.
• Okay, now that we got that over with, here is the licensing fee structure. This includes both
costs for license application and the annual license fee, which shall be maintained by a
marijuana establishment. What’s a marijuana establishment you ask? You must have skipped
the glossary! Go back and read it! Gotta be hip to the lingo if you want to be hip to the
industry.

Licensing Fee Structure

• In the above table, a Marijuana Cultivator can apply for licensing based upon four tiers. Each
tier allows you to cultivate a designated amount of “canopy space.” This means the amount of
green canopy space that a budding cannabis plant covers (which is measured in the draft
regulations by square footage). Here are the four tiers:

(i) Tier I: up to 1,000 square feet of canopy;

(ii) Tier II: 1,001 to 5,000 square feet of canopy;
(iii) Tier III: 5,001 to 10,000 square feet of canopy;
(iv) Tier IV: 10,001 and over square feet of canopy.

▪ The annual fee for Cultivation Licenses and Craft Marijuana Cooperative
Licenses shall be increased by $0.25 per square foot for Tier IV licenses where
the square footage exceeds 10,000 square feet.
• The 3 licenses that will likely be of most interest to you as a farmer are:
1. Cultivation
2. Micro-Business
3. Craft Marijuana Cultivator Cooperative

• Per the above table, a Cultivation or a Craft Marijuana Cultivator licensee can apply for any of
the four tiers (based on the square footage that that licensee wishes to cultivate).

• A Micro-business per its definition must cultivate in a space of under 5,000 square feet of
canopy space.

• It is also important to know that, under a Craft Marijuana Cultivator license, multiple
cultivators/manufacturers can operate under one license. But, as of now, the cooperative can
only have up to 6 locations for activities authorized for marijuana cultivators and 3 locations
for activities authorized for marijuana product manufacturers. Don’t like that cap put on
cooperatives? Sign our petition, please!

• Security… well, yeah, as you can imagine, there are some security requirements to be a
cultivator. They are long and numerous. But, if you’d like to know more, Farm Bug is here to
help. Just email us!

• Do you have any concerns about these draft regulations? Well, then, the good news is that
these are only draft regulations. The regulations won’t be finalized until March.

• Do you want to get your chance to tell the Cannabis Control Commission in person what you
think about these draft regulations or anything under the sun having to do with the legalized
marijuana industry? Well, you’re in luck because the Commission is holding public hearings
across Massachusetts in February!

• Here are the dates, times and locations of these hearings:

1. Monday, February 5, 2018 8:30-11:00 AM

(Snow Date: February 12, 8:30-11:00 AM)
Berkshire Community College
K111 Lecture Hall
1350 West Street
Pittsfield, MA 01201
2. Monday, February 5, 2018 2:00-5:00 PM
Leslie Philips Theater
Holyoke Community College
303 Homestead Avenue
Holyoke, MA 01040
1350 West Street
Pittsfield, MA 01201

3. Tuesday, February 6, 2018 10:00-1:00 PM

Franklin Regional Council of Governments
William B. Allen Community Room
12 Olive Street
Greenfield, MA 01301

4. Tuesday, February 6, 2018 9:00-12:00PM

Public Hearing Room
Barnstable Town Hall
367 Main Street
Hyannis, MA 02601

5. Tuesday, February 6, 2018 2:00-5:00 PM

(Snow Date: February 13, 2:00-5:00)
UMass School of Law
Rooms 231-232
333 Faunce Corner Rd
Dartmouth, MA 02747

6. Wednesday, February 7, 2018 9:00-12:00 PM

(Snow Date: February 14, 9:00-12:00)
Worcester Public Library
Saxe Room
3 Salem Square
Worcester, MA 01608

7. Wednesday, February 7, 2018 2:00-5:00 PM

(Snow Date: February 14, 2:00-5:00)
North Shore Community College
Math/Science Bldg Rm 119
1 Ferncroft Road
Danvers, MA 01923
 8. Thursday, February 8, 2018 1:00-4:00
(Snow Date: February 13, 1:00-4:00)
McCormack Building
One Ashburton Place
21st Floor
Boston, MA 02108

9. Friday, February 9, 2018 10:30-1:30 PM

West Tisbury Public Library
1042 State Road
West Tisbury, MA 02575

10. Tuesday, February 13, 2018 6:00-8:30 PM

Bolling Municipal Building
2300 Washington St, 2nd Floor
Roxbury, MA 02119

• Tired yet? You don’t know the half of it. We don’t even sleep anymore! Luckily, there’s plenty
of legalized cannabis to keep us going.

• Like what you see here? We’re thinking about throwing a harvest party in the Boston area
after the February hearings. Let us know your thoughts!

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Happy Growing!

Eric R. Schwartz
Co-founder
Farm Bug Co-op
Farmbug.coop
eric@farmbug.coop