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 definition of “Canopy” in 500.002 (Definitions), and in the way licensees’ compliance with the Lighting Power Density standard is determined in 500.120 (11)(b) (Additional Operational Requirements for Indoor and Outdoor Marijuana Cultivators).
- The market needs clarity on how “Average” is determined related to compliance with the Lighting Power Density standard. For example, how can the regulations distinguish between cultivators across different facility types (e.g., indoor vs greenhouse) and their use of natural light with supplemental light (greenhouse) vs. sole source lighting (warehouse)? Previous verbal clarifications associated with weighted averages across rooms have been helpful but ongoing clarifications should be written and include examples of calculations.
- There needs to be additional clarity around how medical growers, particularly those who sell into the adult-use market, are regulated by current energy and environmental regulations.
Measuring energy use intensity and equipment efficiency
- There is currently no energy use baseline for the Massachusetts cannabis industry, so establishing efficiency targets is challenging. Research into baseline usage would be helpful.
- There may be better ways to measure lighting efficiency beyond the current Lighting Power Density standard. For lighting energy use, the CCC may want to consider metrics such as kWh/grams or micromoles per Joule, for example.
- The default metric for HVAC efficiency is currently driven by occupancy comfort; a more tailored metric for horticultural applications may be more appropriate.
- Likewise, building efficiency is currently determined by using metrics designed for human occupancy; many cannabis code conversations argue for a new building class to be created for controlled environment agriculture.
- A more holistic approach that considers the interactive effect of lighting, HVAC and internal loads may offer licensees increased flexibility to adopt more efficient practices; the CCC may want to consider a facility-wide Energy Use Intensity standard, for example.
Rebates and incentive design
- Given interactive effects between lighting, HVAC and dehumidification equipment, systems-based incentives should be encouraged.
- Cash rebates and/or incentives are still important for lighting because of the learning curve associated with converting to LED lighting and the higher upfront cost. Legacy growers and investor-driven projects may resist transitioning to LEDs without these incentives.
- The CCC should work proactively with the regulatory bodies (e.g., DOER, EEAC) that have jurisdiction over the energy efficiency Program Administrators in order to provide incentives and related technical support to growers who need support to comply with this law.
Education and outreach
- Case studies and best practices workshops would be critical tools in educating licensees about how to effectively and efficiently cultivate under LEDs, with guidance on how to adjust water, nutrients, HVAC, etc.
- Objective, third party research will be necessary to help the marketplace embrace technologies and practices with which they are less familiar or comfortable.
Verification and enforcement
- Prospective licensees need clarity as soon as possible to prepare.
- Compliance should be verified at the design stage of the facility, not after the facility has been built, at which point making changes to become compliant becomes much more expensive.
- There is no guidance regarding how licensees are to track and submit their data use, though there are helpful tools in the marketplace that could be useful.
- There are currently no formal channels to engage the Massachusetts research community, including universities, private sector incubators or public agencies, in the development and execution of a research agenda. The CCC should seek to engage these parties to the greatest extent possible.
We look forward to offering the Cannabis Control Commission with specific recommendations in the above areas over the next several weeks.
Derek Smith, Resource Innovation Institute
Sam Milton, Climate Resources Group