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Comments Document

Construction Subcontractors need protection from subcontract language that includes "condition precedent" or "pay if paid" clauses to remain viable.

Oppose if not amended. The current law is clear. Less than .3% THC by volume, regardless of its form is hemp by Federal and State definition. A 1% threshold is more reasonable and may be forthcoming from the USDA. Greater concentrations of THC are considered, albeit an incorrect term, marijuanna. The hemp industry needs to remain autonomous and should not be impacted by this bill. If the goal is to discourage attraction to person underage; shapes, sizes, etc. will have little to no effect. Consider predominant labeling requirements. Warnings, safety precautions, age verification etc.

These bills need to be revisited. For all of us in the Commonwealth, we need to not rush these bills. We are Albemarle Cannabis Company. We are a Female owned, Family run small business in Whitehall, Virginia. We have have been providing not only products, but education and consulting for everyone in Virginia that needs assistance. These bills will ruin the hemp industry in Virginia, and open a large door that supports Big Corporations and Pharmaceuticals Companies. Since the Federal Farm went into effect, Virginias Hemp growers, processors, and retail establishments have had to self-govern due to lack of guidance by the Commonwealth. In that time, we have collectively self-governed ourselves in a respectable manner, and these bills as written will do nothing but ruin the small cannabis businesses of Virginia. We implore you to use us to assist set a bar for legalization in the Commonwealth that will be prosperous and fair to all of us that actually live here.

Comments Document

I am asking all delegates to vote NO on SB 391 and SB 591 unless all current language that supports the medical monopoly is removed. They must be amended to provide simple, free market solutions that allow small, established local Virginia businesses a clear path to regulated sales of intoxicating cannabis products, that is fair and reasonable. I am a Board of Advisor member of the Virginia Hemp Coalition. I am a Virginia resident, and local hemp retailer since 2019.

1. License Structure Changes Current Structure - Vertical Integration Not Allowed* i. Growers ii. Processors iii. Distributors iv. Retailers 2. Commercial Grower Licenses: Recommended Three-Tiered System a. Medicinal Use - Medicinal license holders have already received medicinal licenses and those licenses should be honored, but they should not get a head start on the commercial cannabis industry or have any monopolies in other tiers or markets. b. Craft Marijuana Licenses - Similarly to craft beer, wine, cider & liquor, craft licensees will be Virginia small businesses that attract tourists and tourism dollars while growing their local economies. These craft licenses should not be cost or regulatory prohibitive, and could be capped at 5000 lbs of marijuana annually, allowed to grow indoors and/or outdoors, and able to sell at their farm locations as well as retail locations around the state. (i.e. Much like a Virginia winery grows grapes and processes on site for their end product - wine.) c. Large Scale Marijuana Licenses - These licenses should be able to grow unlimited amounts of marijuana and sell at retail locations around the state. d. All commercially licensed growers should also be able to distribute their products to retailers by virtue of being commercial growers. They should not be forced to pay someone else to distribute their products. e. The free market should be the basis of the Virginia Cannabis and Hemp marketplace and no monopolies should exist. f. Intoxicating synthetically made hemp products (i.e. Delta-8, etc...) should be placed under VCCA regulation because Federal and Virginia hemp law was written specifically for natural non-intoxicating and non-synthetic hemp products. g. Licensed cannabis processors should be allowed to process home grow customers and small craft cannabis farms along with large scale operations. 3. Distributors a. Commercially licensed growers should be exempt from needing these licenses b. Entities who are not commercially licensed growers should be able to purchase these licenses at non-cost prohibitive prices. 4. Retailers a. Craft commercial growers should be able to have a retail location on-site. These small businesses can make up a large portion of Virginia’s cannabis industry. b. Non-Commercial Grower retailers will be subject to the regulations promulgated by the VCCA. 5. Multiple Licenses Multiple license types should be permitted without having to pay an exorbitant fee. Exorbitant license fee schemes only benefit the large out-of-state cannabis corporations & pharmaceutical companies that can afford to pay them and freeze out the average Virginian who wants to create a business in this burgeoning industry. i. Virginia laws should not penalize law-abiding Virginians who did not engage in commercial cannabis prior to legalization. ii. Creating a pay-wall / monopoly scheme to access an additional license type only benefits those large capital intensive often times out of state corporations who can afford it. 6. Tax Rates a. Virginia should cap its marijuana taxes at a 10-15% maximum i. High tax rates in California & Washington made black markets flourish ii. Oregon has a 20% tax rate iii. Colorado has a 15% tax rate iv. Federal legalization will add federal excise taxes to the total tax burden 7. Other Considerations a. Automatic Expungement of Marijuana Possession Convictions and Pardons

Marijuana poses a risk of serious mental illness and suicide. Our website http://momsstrong.org catalogs many such cases around the U.S. Our leaders are doing a grave insult to public health and welfare by pushing for retail marijuana sales. We are totally opposed to both of these bills and beg the governor for a veto.

PLEASE pass sensible cannabis legislation to continue to allow VA adults to consume and grow at home, along with equitable licenses for small time (& craft) producers, and a legal way to market their products. Thank You

Hi I’m a licensed Virginia hemp grower for three years. My business is Mineral Leaf Farm. My concern as a hemp grower as is many hemp growers in the state of Virginia is Fair licensing for those who have especially put into the hemp industry. We need to make sure small farms throughout the state are given a fair chance at getting a license. And those through social equity. We can build a great hemp and cannabis industry for Virginia if given to the right people especially those in rural communities. Thank you Jeremy Shane

Legislative Policy Recommendations for General Assembly 2022 Session for Virginia Hemp / Cannabinoid (CBD, CBN, CBG etc.) Products Hemp (Cannabis Sativa) is a Federally Legal Agricultural Product that was fully legalized in the 2018 United States Farm Bill. Hemp and its products fall under the regulatory oversight of VDACS & the USDA has recently accepted VDACS’ plan as a federally compliant plan for hemp & hemp products. All Hemp & Hemp Products (including non-intoxicating cannabinoid products) should stay under VDACS regulatory control. These regulations are put forth in VA Code 41.1 and following. 1. Hemp & Hemp products are defined Federally and in Virginia code as raw materials and products under 0.3% THC. The move to a 1% THC threshold Federally is likely within the next 2 years. 2. Virginia law currently protects farmers from prosecution for hemp crops above 0.3% up to 1.0% THC from prosecution and 3.2-4114.2.H.1-2 specifies what to do with crops that are above 0.6% up to 1.0% THC. 3. Crops that are above 10% are referred to the state police. 4. Hemp & hemp products intended for human consumption are already treated as food additives and subject to VDACS Food Safety Program. The testing requirements are laid out on page 4 of the VDACS Application for Industrial Hemp Extracts. 5. Mis-labeled or improperly labeled products should be treated the same way as any other food or beverage safety issue. Consumers or agents can report bad products to VDACS or a local health inspector and they are investigated via the business retailing along with the manufacturer. 6. Moving a federally legal and interstate commerce protected product from the 2018 Farm Bill with VDACS regulations to a Commission created to regulate non-federally legal products will almost certainly be met with a federal lawsuit that the Commonwealth is highly unlikely to win. Additionally, consumers will still be able to order non-Virginia hemp products online and access out of state hemp products, meaning that the only people hurt by this change will be Virginia’s hemp farmers, processors, and retailers who have already invested millions of dollars in the good faith on the promises of the previous administration to put Virginia’s hemp program into federal compliance and allow hemp farmers, processors, retailers, and consumers to engage in commerce just like every other industry. 7. Hemp seed, fiber & flower is currently a multimillion-dollar industry for Virginia farmers and businesses and the industry is projected to grow rapidly over next the five years. There is no reason to hinder this growth by moving it further away from VDACS/USDA and giving regulatory and taxation uncertainty once again to the industry. 8. We must make Virginia the State that welcomes and un-hinders the global hemp industry to become the best hemp state to do business in the Nation, and possibly even the World. We must provide solid footing for hemp and cannabis businesses to flourish by providing a clear and un-burdensome regulatory foundation.

Comments Document

PLEASE VOTE "NO" on SB319 and SB519 unless you are amended to prohibit ALL MONOPOLIES for the VIRGINIA CANNABIS and HEMP Industries. Thank you. Leandra D. Selah Advisory Board Member Membership Director Virginia Hemp Coalition (757) 354-2413 leandra@vahemp.org

Honorable Delegates, we appreciate the opportunity to communicate our concerns to you concerning bills SB391 and SB 591. As a dynamic hemp extract processor located in Blacksburg, VA, founded in 2019, we have invested heavily in our farmers, employees, USDA Organic certification and VDACS approved dietary supplement production facility. Our goals are to continue to work with Virginia farmers to grow our hemp operations as well as pivot to include high quality cannabis extract production. As a small producer with less than 10 employees in an economically distressed area, including cannabis extract production will allow us to improve wages, hire more employees, and expand operations. There is effective Federal and VDACS oversight of industrial hemp processing and hemp product development, of which NuTrac Hemp is an active, licensed participant. We work extensively with the top testing labs in Virginia, and across the country, to ensure our products are of the highest quality for the health and safety of our clients and customers. We follow USDA Organic and VDACS requirements for production and labeling to ensure customers are fully informed as to all ingredients, use, and contact information for our products. We ask that in the quest for legalized cannabis in Virginia, the hemp industry, which has been an economic benefit to small farmers and producers in rural Virginia, is given consideration above out-of-state corporations in accessing licenses for processing and distributing cannabis. Licenses should be fairly priced for small Virginia hemp producers. Hemp producers should be considered for cannabis licenses based on merit – and a proven track record of following regulatory requirements, not on an arbitrary number of hemp biomass processing. The current arbitrary number is 40,000lbs – half of this, 20,000lbs, would be more reasonable more producers – but producing safe, quality products and being in compliance with federal and Virginia regulations, should be paramount considerations. Thank you for your time and attention.

Comments Document

Substance Abuse Free Environment (SAFE) of Chesterfield County is asking the house to protect youth by supporting SB591 and opposing SB391. In alignment with the country's top medical organizations and the U.S. Surgeon General the risks of marijuana especially to the young, developing brain deserve greater consideration when increasing marijuana's availability and potency. Additionally, greater transparency and public awareness is needed around the risks associated with today's marijuana especially in regards to young people. Please see the attached document for more information. Thank you,

I urge you to do all you possibly can for safety of VA kids Cannabis Can Kill Kids My son's suicide note read "Marijuana killed my soul + ruined my brain." Marijuana use increases suicide ideation, suicide attempts and suicide completion. Please do everything you can to stand in the way of this addiction-for-profit industry. It encourages drug cartels to hide in plain sight and fool you into complacency and normalizing of drug use that will kill your kids. Cannabis Can Kill Kids It killed mine. Please heed my son's warning: "Marijuana killed my soul + ruined my brain." Andy Zorn, died by cannabis induced suicide in Peoria, AZ 3-1-2014

Comments Document

To Virginia legislators and whom it may concern, Please do not support SB591S3 as you’d be supporting the destruction of a strong agriculture based industry that was just created, and make Virginia the worst state in the nation and one of the worst places in the world to own a hemp business. *****(In the attachment, I provide alternative language to solve this. Please read it!)***** If this bill is passed, I will be forced to relocate my company Cypress Hemp II LLC, which is on track for a $50,000,000+ valuation and employing 100+ people by the end of this year, to any other state, because no other state in the US would have a more restrictive hemp law than Virginia, should this pass. In the attachment, I breakdown why this bill will force my business to leave Virginia, and why it will close down 1000+ businesses and many thousands of jobs that make a living off of creating and selling non-intoxicating hemp products such as CBD topical lotions. I also provide alternative language to the proposed language, that will both protect the existing hemp industry’s core businesses and prevent the closure of 95% of the Virginia hemp industry, while also preventing any “loop holes” or abilities to create intoxicating hemp products (think delta-8 THC), that are not representative of the hemp industry’s essence. My company, incorporated in Powhatan, Virginia is on track to do $20,000,000 in sales this year and employs almost 50 people, and we will immediately move our business to a more hemp friendly state, if SB591S3 is passed into law. Please contact me if you have any questions. Respectfully, and with dire concern for my home state of Virginia, Blake Bilger Co-owner Cypress Hemp blakebilger@cypresshemp.com 804-822-5431

Comments Document

Hemp (Cannabis Sativa) is a Federally Legal Agricultural Product that was fully legalized in the 2018 United States Farm Bill. Hemp and its products fall under the regulatory oversight of VDACS & the USDA has recently accepted VDACS’ plan as a federally compliant plan for hemp & hemp products. All Hemp & Hemp Products (including non-intoxicating cannabinoid products) should stay under VDACS regulatory control. Neither of these bills should make it more difficult or costly for me to continue grow and process hemp into end-use compliant products under current Virginia and federal laws regarding hemp. Furthermore, hemp should have an allowable THC level of up to 1%. The intoxicating cannabis retail market should not be created for out-of-state monopolies to control. License structure should be attainable for different scale growers. There should be a craft cannabis license available to smaller scale growers, similar to our craft farm breweries that we enjoy in Virginia. Craft commercial growers should be able to have a retail location on-site. These small businesses can make up a large portion of Virginia’s cannabis industry. The free market should be the basis of the Virginia Cannabis and Hemp marketplace and no monopolies should exist. Licensed cannabis processors should be allowed to process home grow customers and small craft cannabis farms along with large scale operations. Home growers should be allowed to enjoy their plants in whatever form they choose; botanical, infusions, raw, cooked. Multiple license types should be permitted without having to pay an exorbitant fee. Exorbitant license fee schemes only benefit the large out-of-state cannabis corporations & pharmaceutical companies that can afford to pay and freeze out the average Virginian who wants to create a business in this burgeoning industry. Virginia should cap its marijuana taxes at a 10-15% maximum Automatic Expungement of Marijuana Possession Convictions and Pardons If it is lawful to possess and sell marijuana in the Commonwealth of Virginia, then it is immoral and unethical to keep individuals incarcerated for possession, manufacture, or sale of that product, and to keep those prior convictions on their criminal record. Convictions for nonviolent charges of marijuana need to be looked at for expungement, and those incarcerated on nonviolent charges related solely to marijuana should be pardoned. Second Amendment Considerations Virginians should not be forced to choose between their Second Amendment gun rights and their cannabis rights. Possession of a firearm in conjunction with possession of marijuana should be removed as a criminal offense to avoid a conflict of basic rights. Those convicted of possessing an otherwise legal firearm in conjunction with possessing marijuana, and not related to a violent crime in the past, should have those charges and convictions expunged. Drug Testing Threshold levels of THC in drug testing should be raised to account for trace amounts of THC that is now found in legal hemp products. Also, with a legal marijuana market in Virginia, drug testing for marijuana should reflect these changes in the recent laws. Legal medical or recreational cannabis use should not be considered in parental rights determination.

No monopolies in Virginia cannabis industry!!