I spoke with Amanda Borup at OLCC, and she confirmed that simply reporting in to METRC does not constitute engaging in commerce.  You have to make an actual sale to participate in commerce.  The permission given for an OMMP participant to report in to METRC does not mean that they are actually selling anything.


Commissioner Morgan asserted at at Tuesday's meeting that anyone going in to METRC reporting would need to have a water right (or have water trucked in) because using this tracking system, also referred to as CTS, meant the (grower) is engaging in commerce.  This is simply not true.


OMMP growers with 3 or more cards on their property must choose either to report in to the CTS by Dec. 1, then apply for CTS tracking by Jan. 1, or reduce their plant count to not more than 12 plants (two cards).


The OLCC will not be giving permission for these growers to sell anything (the much discussed 20#) until after July 1.  There is a good chance the OLCC will determine that the supply is more than sufficient at that point in time, and not allow any medical sales in to the OLCC market.  At this point I'm told it's 50/50, and the OLCC is interested in making this allowance for medical growers using the CTS.  However it is very likely that the stock on hand at producer, processor, and wholesale OLCC licensed sites will be so large that they will not be able to reasonably allow the 20# transfers.


The purpose of reporting to the CTS as a medical grower is to help the state document our production, inventory and distribution in the spirit of the Cole memo.  To the extent that some medical growers will switch to OLCC regulated grows as an extension of this experiment the state regulators feel that that is also a benefit.  But the 20# (potential) allowance for sale is not the cornerstone of this legislation, and there is no requirement to participate in commerce along with the reporting requirement.


The state is not done with the administrative rulemaking process yet.  The most recent interpretations from DoJ just came at the beginning of this month, months after the session ended and bills were signed.


I have to reiterate that the county as a whole has spent many hours over two years discussing cannabis regulation at length.  The negative impacts of OLCC regulated grows have yet to be documented at any length.  Questions concerning RR grows - the topic under consideration now - are currently being questioned.  After looking at the spreadsheet of "Reported MJ Grows" that I sent the Panel last week, I started to break it down.  When the list is selected for RR reported grows and typographical/recording mistakes are eliminated, the list is reduced by half.  You don't have to do the work yourself, I can send copies to the Panel for review along with the steps taken to validate the copies of the modified spreadsheets.


The Actual complaints spreadsheet - reported violations that are open - goes back years, and is much more accurate than the list of alleged cannabis cultivation sites.  But only has a handfull of 'marijuana related' complaints on it.  Planning Director Julie Schmelzer admitted that many of the open violations tagged "MJ" or similarly were labeled as such by planning, not as part of the original complaint.


The difference between a complaint and a 'Complaint' has to do with the recording and documentation.  An open violation on file with planning is the result of a report that is on file.  That is a 'Complaint'.  The "complaints" on the other spreadsheet are not verified.  There are no specifics attached as to when they were called in, and we have no idea of knowing how many were generated by individual complaintants, or how many are for unique addresses.  It is quite literally the worst spreadsheet I have ever seen.  When I was in 6th grade using a Tandy TRS80 or an original Commodore that spreadsheet would not have been acceptable.


I am extremely unhappy about the fact that this 'document' seems to be the basis of the commissioners current course of action.  I'm waiting for any other information that would substantiate the ballot measure 17-81, and the order 2017-034 and ordinance 2017-002.  As of this date I have no information that supports these efforts, but I see many areas where resources could have been better spent.