Oppose unless amended.

The goal of licensure should be to invite and encourage compliance. The trailer bill –while well intended—will create an un-level playing field which will lead to decreased rates of participation and decreased rates of success.

Thankfully, the trailer bill can be improved significantly with some very minor changes. Unfortunately, these changes will trigger concerns about consistency with the intent of Proposition 64. It is critical that all stakeholders work together to seek consensus in order to strike the best possible balance. Your support will make a difference! Please review the proposed amendments and sign the letter below. 

Proposed amendments: 

Establish a limit on the total number of licenses that an owner may hold. Proposal:

  • An owner may hold up to four licenses total.

Establish limits on vertical integration. Proposal:

  • An owner may hold licenses in any two categories, including distribution.
  • An owner may hold licenses in more than two categories, and in numbers greater than four with the following limitations:
    • A Type 10A may hold up to 4 acres of cultivation, 3 retail licenses, manufacturing and distribution.  
    • An agricultural cooperative may hold any number or combination of the following: nursery, processing, manufacturing distribution, and up to 3 retail licenses. 

Ensure a level playing field for distribution. Proposal:

  • Self distribution (no license required) for Type 1 and 2 cultivators that only hold a single license and only distribute their own products.
  • All businesses that hold two or more licenses, one of which is a distribution license, or businesses that self distribute, must submit to inspection by a third party inspector before products are distributed. 

Comments can be sent to policy@cagrowers.org 

Please show your support by signing the letter below: 


Dear Governor Brown: 

Bridging the gap between the MCRSA and the AUMA is a challenging process with many considerations. The first draft of your proposed trailer legislation demonstrates a solid understanding of the policy issues that must be addressed. We recognize your efforts to develop one unified regulatory system while honoring the decision made by the voters in 2016 with the passage of the AUMA but we urge you to amend the proposal and strike a better balance.

Unfortunately, we cannot support the legislation unless it is amended. Our primary concern is the proposal’s removal of all limitations on vertical integration. Thus, we have taken an oppose unless amended position and offer the attached proposal as a starting point for discussions.

It is imperative that California strike a better balance on cross licensure. As written, the proposal will lead to rapid consolidation of the marketplace, a significant barrier to entry and an even more significant barrier to success. The result is that few cottage, specialty and small businesses (both existing and startup) will remain viable. Under a system of unfettered vertical integration access to capital will become the primary driver of success and most of our members have severely limited access to such resources.

The dramatic negative impact this will have on regional economies across the state is antithetical and counterproductive to the stated goals of regulation to improve public health and safety and protect the natural environment as well as the stated intent of Proposition 64 to:

(a) Take non-medical marijuana production and sales out of the hands of the illegal market and bring them under a regulatory structure that prevents access by minors and protects public safety, public health, and the environment.
(b) Strictly control the cultivation, processing, manufacture, distribution, testing and sale of nonmedical marijuana through a system of state licensing, regulation, and enforcement.

We urge you to support policies that will provide California’s cannabis businesses a pathway forward. Only through compliance will our state be able to achieve the goals and intent of regulated commercial cannabis. 

474 signatures

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