Energy and Environment Working Group comments

Climate Resources Group was a proud signatory to the comments below to the Massachusetts Cannabis Control Commission Energy and Environment Working Group today. *** Massachusetts Cannabis Control Commission 101 Federal Street, 13th floor Boston, MA 02110 Submitted via email: CannabisCommission@State.MA.US September 14, 2018 Dear Cannabis Control Commission, Thank you for the opportunity to provide comment to the Energy and Environment Working Group (EEWG). On September 11, 2018, Resource Innovation Institute, in partnership with Climate Resources Group, convened a Cannabis Energy Roundtable with stakeholders in the cannabis industry and those who provide services to them. This work is funded by a Massachusetts-based foundation, E4TheFuture. The discussion among cannabis operators, construction professionals, technology manufacturers, utilities and energy policy experts yielded mutually agreeable issues of interest for the EEWG’s consideration, described below. Over the course of the coming weeks, we anticipate recommending specific language on the following topics: Clarity to current statutory language There is confusion in the marketplace about how the terms “Growing space,” “Mature” and “Active” are used in the...
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CCC’s Energy and Environment Working Group At Bat

CCC’s Energy and Environment Working Group At Bat

The Massachusetts Cannabis Control Commission’s efforts to refine its regulations for energy and environmental performance for cultivation and product manufacturing facilities are now officially underway. Last week, the Commission convened the first meeting of its long-awaited Energy and Environment Working Group (EEWG). Membership in the group is so far limited to the bare minimum required by the law: designees from the Department of Energy Resources, Department of Environmental Protection and Department of Agricultural Resources. A CCC representative sits on the EEWG but does not have a vote. The meeting itself was perfunctory, essentially a pre-game show to the main event. But it did reveal that the EEWG intends to inform itself to some degree through a series of listening sessions across the state. The Group proposed to itself a series of public listening sessions across the state later this summer with the stated objective of hearing from a range of stakeholders, including growers, ancillary service providers, other businesses and industries, and...
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Five things you need to know about the Massachusetts cannabis energy rules

Five things you need to know about the Massachusetts cannabis energy rules

Are you concerned about what Massachusetts’s energy and environmental regulations may mean for your young cannabis cultivation, extraction or dispensary business? My advice: inform yourself, do your homework, and don’t pack your bags. Before you walk away in frustration, here are five things you should know about the current rules: 1. Yes, most of the regulations apply to ALL marijuana businesses planning to operate in Massachusetts. In section 500.105: General Operational Requirements for Marijuana Establishments (1) (p), the state calls for every marijuana business applicant - including cultivators, manufacturers, labs, retails, transporters, and researchers - to demonstrate consideration of energy efficiency, renewable energy and utility rebate programs. The state has not yet offered specific guidance on what might constitute an appropriate level of consideration in an application, but an effective response will show that you have thought about how you may: Integrate renewable energy into your power acquisition plan (and if not, why not), Deploy technologies or approaches to optimize your facility's...
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CCC raises the bar on indoor cannabis cultivation

CCC raises the bar on indoor cannabis cultivation

At yesterday’s public meeting at the Massachusetts State House, the Cannabis Control Commission (CCC) agreed to include the recommendations of the Massachusetts Executive Office of Energy and Environmental Affairs. If these recommendations are included in the CCC’s final regulations filed by March 15 of this year, Massachusetts will be light-years ahead of any other state in regulating the energy and environmental impact of legal cannabis cultivation and product manufacturing. Several of the proposed regulations are groundbreaking in their own right, and in sum they are a BFD (to paraphrase Joe Biden). But what are they? What are their implications for the cannabis industry? Should advocates for a greener cannabis industry have buyer’s remorse? A lighting power density (LPD) standard of no more than 36 W per square foot of canopy for a cultivation facility with over 5,000 ft² of canopy.  [UPDATE: The final regulations offer an olive branch to growers, giving them the flexibility to meet the LPD standard as an...
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Mass CCC announces draft rules – Now it’s your turn

Mass CCC announces draft rules – Now it’s your turn

Last week we sent the note below to our Climate Resources Group mailing list. If you would like to be added, simply  submit your email under the field "STAY UPDATED" in the column to the right. And course I welcome your feedback anytime at sam AT climateresourcesgroup.com ** The end of 2017 brought some updates from the Cannabis Control Commission: draft final regulations and public hearing dates and locations. First, the draft regs are posted: https://www.mass.gov/files/documents/2017/12/22/DraftRegulations122117.pdf. As predicted, they largely defer to the yet-to-be-formed energy and environmental working group for specifics on standards for grows. Highlights include: Mandates for cultivators AND "product manufacturers" to adhere to energy and environmental standards and regulations developed by the EEWG "to reduce energy and water usage, engage in energy conservation and mitigate other environmental impacts." The inclusion of product manufacturers is a new and positive development, since manufacturing of cannabis extracts into edibles and other products can also be relatively resource intensive; Cultivators and product manufacturers shall maintain "policies and...
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Cannabis and Massachusetts Energy Efficiency

Earlier this month, Climate Resources Group had the pleasure of addressing the Massachusetts Energy Efficiency Council to educate Councillors about the energy footprint of the legal cannabis industry in the state. My overarching points that cannabis cultivation is extremely energy intensive, is on the cusp of exploding in the Bay State, and merits consideration in the state's next 3-year plan were, I think, well-received. Feel free to download and use the memo. If you share it, I'd be curious to hear what kind of response you get. Stay tuned, and watch this space. ...
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Climate Resources Group Comments to Massachusetts Cannabis Control Commission

Climate Resources Group Comments to Massachusetts Cannabis Control Commission

October 17, 2017 Cannabis Control Commission One Ashburton Place, Room 313 Boston, MA 02108 Via email to CannabisCommission@State.MA.US ATTN: Regulations Dear Members of the Cannabis Control Commission, My name is Sam Milton, Principal of Climate Resources Group, a consulting firm based in Arlington, Massachusetts. These comments pertain to the development of regulations for the adult use of marijuana in Massachusetts, and I am submitting them on behalf of the firm. We are grateful for the work of the Cannabis Control Commission and its commitment to meet the objectives laid out in Chapter 55 of the Acts of 2017.  The purpose of these comments is to highlight two of the legislature’s mandates and to underscore their importance to the Commission’s overall success: SECTION 57.  “The Massachusetts cannabis control commission … shall provide recommendations to ensure farmers’ access to marijuana licenses and to allow for the growth, cultivation, production and harvest of marijuana on farm or agricultural lands…” SECTION 78. “The Massachusetts cannabis control commission shall establish energy and environmental standards …...
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Forgot Something, Commissioner Hoffman?

Forgot Something, Commissioner Hoffman?

Last week, Massachusetts’ newly-formed Cannabis Control Commission held its first formal meetings. At its second meeting, the Commission distributed a draft working agenda (whether the CCC intended its release is not clear, but regardless the document is now publicly available - though buried - on the Mass.gov website. H/T to Dan Adams of the Boston Globe for turning it up). The agenda helpfully shows the issues the Commissioners are planning to tackle and how they are divvying up the job. It’s an eye-opening document and a welcome sneak peek into a state bureaucracy getting to work. If not no other reason, it's worth a look to see how Bain trains its people to organize projects. Glaringly absent from the list, however, was any mention whatsoever of the Commission’s statutory obligations to create energy and environmental performance standards for marijuana cultivation facilities operating in the state or a plan to involve traditional agriculture. A charitable reading of the list suggests that of course...
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Massachusetts Poised to Lead in Green Weed

Massachusetts Poised to Lead in Green Weed

Massachusetts and California continue to battle it out for the title of “The Cleanest and Greenest State,” this time on the cannabis front. Voters in California and Massachusetts legalized recreational marijuana in November 2016. Each state already had medical marijuana on the books, though California’s legal market has been operating since 1996, nearly 20 years before Massachusetts’ foray into legal weed. California regulators have been exploring the energy and environmental implications of a legal market for marijuana within their borders for several years now. CalCannabis Cultivation Licensing, California’s official cannabis licensing organization, recently completed its draft Program Environmental Impact Report (with the final due out this fall), and The California Public Utilities Commission separately is investigating the impact on energy consumption and the power grid. Massachusetts is taking a similar approach, with lawmakers charging its nascent oversight agency, the Cannabis Control Commission, with establishing energy and environmental standards for licensees operating in the state. For the Bay State, this is a major...
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Can New England Innovation Make Cannabis Greener?

Can New England Innovation Make Cannabis Greener?

As I sat in a jam-packed conference room at last week’s NESEA BuildingEnergy Boston conference to learn about the energy consumption profile by commercial-scale cannabis production (a.k.a. the “Cannabis Cultivation Conundrum”), I was struck by three major themes. First, cannabis cultivation can be enormously energy intensive, and legal demand for marijuana in our region will very likely be driving up energy and water use. Every state in New England now permits marijuana consumption for medicinal purposes, and voters in both Massachusetts and Maine recently passed ballot referendums legalizing recreational use as well. Medicinal growers can produce in all states save Connecticut, and large-scale commercial growers are already preparing to set up shop across the region, particularly in Massachusetts where legal recreational use is imminent, pending regulatory fixes by legislators. At the relatively staid energy efficiency and green building conferences I typically attend, one rarely sees speakers mobbed like rockstars by audience members gobbling up information. By comparison, this panel sparked great enthusiasm,...
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