HCGA Comments Emergency DCC Regulations

Click here to read HCGA’s Comment Letter on the Emergency DCC Regulations.

On behalf of over 275 licensed cannabis businesses in Humboldt County, HCGA is pleased to offer formal comments and suggested revisions to strengthen and clarify the Department of Cannabis Control’s (DCC) proposed emergency regulations released on September 8, 2021. 

Our comments fall into three categories:

  • Proposed regulatory changes that we request the Office of Administrative Law (OAL) prioritize for legal review for clarity and consistency with statute. 
  • A response to specific substantive issues raised in September 8, 2021 proposed emergency regulations, including trade samples, financial interest definitions, and premises change application fees. This section also includes comments and recommendations for the temporary fallowing of cultivation licenses, which our members have identified as a critical and urgent need ahead of the 2022 growing season.
  • Recommendations for subsequent regulatory promulgation not specifically related to proposed changes in current rulemaking. HCGA originally provided these recommendations to regulators in early 2021, and they are resubmitted here as part of the official record as the DCC considers additional changes over the coming months. 

As the DCC and OAL review these comments, we want to emphasize the urgent and unprecedented crisis currently facing small cultivators in Humboldt County and elsewhere in California. Over the past several months, statewide overproduction has led to dramatic decreases in wholesale cannabis prices, in many cases decreasing prices well below the cost of production. 

Absent action from the state, current market conditions are not sustainable for most Humboldt cultivators, many of whom have invested their life’s savings in meeting state and local regulatory, operational, and environmental requirements. While we believe the medium-term outlook for craft Humboldt cannabis is strong due to potential federal legalization, interstate commerce, appellations, and the maturation of a market for craft cannabis, we anticipate major challenges over the next two or three years.

We believe that building a legal cannabis market grounded in the legacy and equity operators that represent California’s cannabis history and culture should be a priority not just for Humboldt businesses, but for all of California. We hope the DCC will take advantage of current and subsequent periods for regulatory promulgation to address the many challenges faced by small and independent businesses, and to help bring that vision to fruition. 

Sincerely,

Ross Gordon

Policy Director

Humboldt County Growers Alliance

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