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Subject: Recommendations to the Cannabis Control Commission to

Ensure the Full Participation of Farmers in the Regulated Marijuana



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 second recommendation of Farm Bug Co-op, which is accompanied by an online

petition, is to lift the location caps placed on a Craft Marijuana Cultivator Cooperative. As an
autonomous, democratic organization, which functions on the basis of communal efforts,
we believe that a cooperative should have the authority to determine the number of
cultivators and manufacturers that join the cooperative. This means that cooperatives
should be able to determine how many members should be allowed to produce and
manufacture cannabis for the cooperative organization. Cooperatives have a right as
autonomous, one member, one-vote organizations to determine their membership based
on the needs of the cooperative and the needs of the communities that they serve. By
limiting the membership of a Craft Marijuana Cultivator Cooperative, this regulatory
structure restricts the full participation in the regulated marijuana industry by
Massachusetts farmers. We also believe that, by limiting participation in a cooperative, the
Commission will reduce equity among cultivators/manufacturers for two primary reasons:

1) By limiting the number of member cultivators/manufacturers within the

cooperative, a cooperative will be less able to include minority farmer groups
such as women and black (or POC) farmers.
2) Many small farmers wish to produce a seasonal cannabis crop—the way that
nature intended the plant to grow. A seasonal cannabis crop is the epitome of
"craft cultivation” and is the most environmentally sustainable way to grow
the plant. Limiting a Craft Marijuana Cultivator Cooperative sets up a
structure that encourages a "max profit," industrialized approach by which a
cooperative is incentivized to produce cannabis all year round in order to
achieve their profit margins. That means these caps will leave out farmers
that only want to grow cannabis seasonally, thus not achieving “full
participation” of farmers in the industry.

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:

1. Recommendation: Addition of Cooperative Requirement.

To Section 500.050 Marijuana Establishments, Part (C), Craft Marijuana Cultivator

Cooperative, add the following language below item (1) as follows:
(2) It shall be a condition of licensure that a Craft Marijuana Cultivator Cooperative operate
cooperatively, namely, that it is an agricultural business whose operating plans and
agreements and actual operations reflect the following features:

a) That all stakeholders involved participate autonomously and voluntarily;

b) That they do so to meet their common economic, social and cultural needs;
c) That they are an agricultural entity involved in an aspect of the local agricultural
value chain (e.g. agricultural products other than cannabis, community
workshops/education, etc.).
d) That they associate themselves together to pool and share, for economic benefit not
otherwise available to stakeholders as individuals, the
1) additional economies of scale of operating cooperatively (e.g. lower cost of
2) risks, debts and other and hazards associated with any business venture; and
3) their resources, their experiences and their talents.
e) That each participant having an ownership stake is actively involved in management
and operations.
f) That the craft co-op aims to produce marijuana and/or marijuana products distinct
from that produced by large commercial operations insofar as
1) They are produced “by hand,” i.e., without significant automation, with close
personal care by skilled cultivators; and
2) Their production and distribution provide opportunities for individuals,
farmers and businesses of all sizes who would not otherwise have a foothold
in the new cannabis industry and
3) They provide consistent cultivator standards and a pre-qualification process
prior to regulator testing.

2. Recommendation: Lift of Location Requirement.

To Section 500.050 Marijuana Establishments, Part (C), Craft Marijuana Cultivator

Cooperative, replace existing item (4):

(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.

REPLACE WITH (now item #5 with addition of above requirement):

(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.

3. Recommendation: Reducing Security Requirements.

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-

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
Farm Bug Co-op