we had a rep at the zoning meeting, his responses can be found in the next edition of the local paper. Our written response is here:
1-12-11
On behalf of Arizona Cannabis Society we submit the following for public record:
Written responses to Prescott Valley Zoning Commission regarding the medical marijuana industry. We have included what we believe to be helpful and informative links to supply some incite into the medical marijuana industry at the end of this document.
starting at page 1 of the hearing hand out,
13-14-020 5, g. - Infusion facilities process marijuana in ways other than that which result in a "edible/consumable" product. Tinctures are very common medicines and have been for thousands of years. Extracting the essential oils (similar to making olive oil) from a cannabis plant produces an oil commonly referred to as "hash oil". This oil can be used as is or be processed further to make a more concentrated form. This concentrate is the basis for our "Phoenix Tears Program" a proposed clinical trial of the Phoenix Tears medication we intend to produce at the Arizona Cannabis Society Infusion Facility. Over 1000 products can be produced using "hash oil" or "hemp oil" which is the essential oil extraction from a cannabis plant.
We feel to exclude this from the wording could propose problems for unregulated cannabis essential oil extraction "labs" surfacing in Prescott Valley.
Supplied below is a link for more information regarding the Phoenix Tears Program and a informative video located at the bottom of the page entitled "Run from the Cure"
This documentary describes the need for our program and others like it across this great state.
13-14-020 5, i. - "...or related supplies.." related supplies is a very broad term. This would suggest that a dispensary could also sell the equipment needed to cultivate medicinal cannabis. The proposed floor plan sizes do not allow for this. Hydroponic cultivation equipment can be large and bulky and require lots of floor space to display as well as store. We would never propose anything that would limit ones ability to provide the best possible service to a medical marijuana patient. For this reason alone we recommend that the cultivation equipment be retailed at a more general location. Urban garden and hydroponic stores are open across the valley currently and operate in strip malls next to nail boutiques here in Phoenix. This would save any foreseeable conflict regarding zoning. Currently however hydroponic stores are "reluctant" to speak about cannabis cultivation and or usage on the premises of their stores. The dispensaries should be allowed to work with the urban gardening and hydroponic stores in an open an transparent relationship.
13-14-080 B, 4. - "..., public buildings, colleges, rehabs, halfway houses" will effectively zone all dispensaries out of the area and be challenged.
*please see attached note*
13-14-080 B, 7. - Regarding the square footage, make this accurately reflect the projections for patients in the area. A standard waiting area in a dispensary will be large enough to hold several couches, tables, display cases, etc. The dispensary floor plans generally consist of 5 display cases, a chilled/cooled display case for edible products, two point of sale stations, two strain advisory stations and a secure room where the storage of surplus product awaiting distribution will be kept. Most dispensaries operate with a "front" room similar as described previously however there is separation between that room and the actual dispensary. This separation is typically where a security and check in desk would be located. this will require more floor space than is being proposed. Numbers 14 and 15 in this same section confirm this statement to be true.
13-15-070 B, 4. - regarding the "dust, fumes, vapors, or odors." being released from the infusion facility. Our data indicates a large swing towards the edible market in the medical marijuana industry. The reason is the range of products is nearly endless. The most common form of cooking is, infusion with butter. The butter is then chilled and can be used to make anything a patient would normally use butter for. I guess in short we are saying, the reason we stop at the bakery is because we smell the cookies and pies being baked. The confections some infusions create are nothing short of fine culinary art. In fact, one restaurant has been proposed in Scottsdale with a menu that caters specifically to cannabis patients. Their ability to release the same fumes and odors as a "normal" bakery or restaurant should not be discriminated against.
13-15-070 C, 4. - Attempts to limit those with access to the cultivation facility other than those supplied a dispensary agent permit will be challenged. This would exclude hydroponic specialists, agricultural specialists, educational specialists, electricians, plumbers, maintenance personnel, private contractors, and the likes of many others that under the official wording of Title 36 are permitted to enter the cultivation facility.
13-15-070 C, 7 - again, adding additional facilities such as "public buildings, colleges, rehab centers, half way houses" will be challenged. Furthermore if a dispensary complied with the other rules regarding odor, fumes, etc. and was at a secure location with 12 foot walls (DHS suggested) please explain for the record the purpose of this addition to terms and the justification rendering it applicable.
13-15-070 D, 3, 4 & 5 - The law states a designated caregiver may cultivate medicinal cannabis for up to 5 patients as well as for themselves if they are a qualifying patient. This is a total of 72 plants. A properly cultivated cannabis plant can reach a size of 10-15 feet in height depending on the genetics of cannabis being used, and easily cover one square meter of floor space or more per plant. Simple math shows your suggestion of 250 sq ft including storage areas is simply not applicable. Also, suggesting that patients and/or caregivers must meet the stringent security standards placed on dispensaries is in applicable. Under the proposed DHS regulation an off site dispensary would be responsible for installing and maintaining monitoring equipment, contracts, expensive IT professionals to install and integrate the security system with the AZDHS server. under your suggestion a patient or care giver cultivating cannabis would be required to install a live feed video system in their home for azdhs and local law enforcement to view at their convince. Needless to say this will be challenged emphatically and is in direct violation of the 1998 Arizona Voter Protection Act, as well as arbitrary, and unreasonable.
Below is a list of helpful links that may or may not shed some light on what is in store for Prescott valley. The first is a link to our website. Volumes of information can be accessed form our site alone. The video at the bottom of our home page "Run from the cure" will offer insight as to our proposed Phoenix Tears Program and the infusion process.
AZCS Home (http://arizonacannabissociety.com)
the following link is to our Youtube channel. Here you can watch hours of documentaries regarding the medical marijuana history, future and go inside the medical marijuana industry courtesy of National Geographic.
YouTube - TheAZCS's Channel (http://www.youtube.com/user/TheAZCS?feature=mhum)
the link at the bottom of our website page to AzDHS's Youtube channel offers a look at our dialogue with AZDHS and the public.
We are also supplying our public proposal to AZDHS and the public regarding the patient and caregiver cultivation of medicinal cannabis.
and AZDHS's inability to monitor the situation and or regulate it.
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AZCS has made a public proposal to AZDHS,
Nov. 25, 2010
G.R.O. Proposal for AZDHS
AZCS will be offering certification classes in cannabis horticulture and cultivation, both a Beginner and an Advanced class will be offered.
As part of the certification process our students will receive continued on site training for the duration of their care giver or patient card, estimated to be one year. During this period graduates will receive visits to their garden by our staff of qualified professionals, two visits per month.
This is referred to as our G.R.O. Program or Garden Regulation and Optimization Program. These visits are intended to help patients and caregivers diagnose and prevent potential plant problems, test the nutrients solutions PPM and ph/ppm of the water at the growing facility and offer advice to help patients maximize their yields. During our assessment a report will be generated and submitted to AZDHS. This report would certify that upon arrival and through out the duration of the agents visit the patient/care giver was in full compliance with Arizona State law. AZCS will submit the data electronically in a simple format complying with the wishes of AZDHS to have an electronic tracking and monitoring system for the program. AZCS will be solely responsible for the cost of the G.R.O. Program and the submitting of the AZDHS reports.
We feel this is a win-win situation for AZDHS and our patients growing their own medical marijuana as well as patient care givers in Arizona.
Students would receive reliable, qualified evaluations of their gardens and AZDHS would not have to use ANY resources to monitor our qualifying patients or care givers that grow medical marijuana.
We understand the ability to monitor patients growing medical marijuana is a concern of the AZDHS and we would like to offer what seems to be this simple solution to the problem. With dispensaries like our (proposed) facility not being operational for some time after initial opening, many patients will be growing their own medical marijuana, we would like to help them,and help AZDHS.
Not every one that chooses to grow their own will attend our classes however we offer our G.R.O. Program to students from other schools or even those that have never attended classes for a member fee ($75.00)
We also have taken into consideration the many common issues that could arise if staff from AZDHS that was not "botany knowledgeable" were visiting patient and caregiver grow facilities. Cross contamination of any number of molds, mildews, insect pest, or even cross pollination between two or more facilities could be catastrophic to a medical marijuana cultivation facility often destroying entire crops.
Our qualified staff are already trained to prevent such things from happening and we're volunteering our services.
We feel currently this is our best solution to offer AZDHS during their monumental task of implementing the Arizona Medical Marijuana Program.
AZDHS Staff, Please contact us if we can be of further assistance.
Arizona Cannabis Society
Board of Directors
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We hope this information we have provided can be of some assistance in implementing a program that is acceptable to the city as well as the patients participating in the medical marijuana program. We currently are not seeking a dispensary permit in Prescott Valley however the location has been discussed as a potential grow facility location based on climate and geography. We want to make our intentions clear as there is much controversy regarding the program as of recent in the media. We would happily discuss at length any portion of the medical marijuana industry that is still unclear and offer our assistance as medical marijuana industry consultants free of charge in either a public or private platform.
Please contact us directly via email with any questions, comments or concerns you may have.
We sincerely appreciate the opportunity to communicate our concerns,
Arizona Cannabis Society
Board of Directors
[email protected]
AZCS Home (http://arizonacannabissociety.com)
MoHoGrow called it right, they will be spread out. And if you want to go further into this topic;
out of 124 almost 20 will go directly to hospitals and large medical facilities, then you'll have 100 or so to spread around and limit the home grown aspect as was suggested. The biggest concern was people putting their grow facilities up there due to climate. they are only thinking about 1 up there and a few grow facilities.
meet up with our rep at the next meeting