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April 27, 2018 Minister’s Advisory Committee Revitalization of ALR and ALC c/o Ministry of Agriculture PO Box 9120 Stn. Prov. Govt. Victoria, BC V8W 9B4 Re:

via email:

Recreational Cannabis Farming on the Agricultural Land Reserve (ALR)

The Cannabis Trade Alliance of Canada (“CTAC”) is a federally-incorporated, BC-based non-profit society which represents cannabis industry stakeholders ( from across Canada. CTAC members include for profit & not-for-profit corporations – both public and private - and individuals with extensive experience in the cannabis sector. CTAC was established to provide expert, evidence-based recommendations to government on legislation, policies and programs related to cannabis. For the past three years it has been meeting with and providing information to a wide variety of federal MPs, the prime minister and ministers, provincial ministers and MLAs, federal and provincial bureaucrats, and other government decision-makers.

The ALR Issue In 2015 the provincial government amended the Agricultural Land Reserve Use, Subdivision & Procedure Regulation (BC Reg 171/2002) to permit federally-licensed medical cannabis to be grown in the ALR. For three years medical cannabis farms licensed by Health Canada have been operating successfully in the ALR: hundreds of jobs have been created on BC farms; thousands of BC patients have gained access to medical cannabis; and millions of dollars in economic activity have been generated for (and by) BC’s agriculture industry and individual farm families. CTAC believes that recreational cannabis should be treated the same as medical cannabis and recognized as a farm product permitted in the ALR: 1.

Recreational cannabis plants are grown in the same way as medical cannabis plants: they come from the same seeds; they use the same amounts of light, space, water and nutrients; they grow at the same rate; and they are harvested in the same manner. Their respective impacts on farmland, neighbours and the environment are identical. If medical cannabis qualifies as a farm product, so should recreational cannabis.


If government prohibits recreational cannabis in the ALR then farmers all over BC will be denied the opportunity to choose the crop that works best for their farms and their families.


Keeping recreational cannabis production away from farm communities will eliminate millions of dollars’ worth of construction activity and agricultural supply and servicing business and take

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away thousands of farm jobs that would otherwise be strengthening those communities and BC farming as a whole. 4.

None of the provincial government’s social policy goals – keeping cannabis out of the hands of children, keeping consumers healthy, reducing crime – would be compromised by allowing recreational cannabis on farmland any more than these goals are compromised by allowing it to be produced in industrial or commercial zones.


Urban municipal governments should not be the only ones to benefit from this emerging industry in terms of revenues from local business licensing, issuance of building & other permits and property taxes; municipal governments in farm communities should have access to these revenues, too.

Some may argue that cannabis production is an opportunity for small communities that have lost resource industry jobs - especially in towns that have underused or abandoned industrial properties and that cannabis production should be directed to these communities instead of agricultural ones. However, many small BC farming communities have lost agricultural jobs and have underused farm properties, too, and would benefit from the economic activity generated by growing both medical and recreational cannabis. Others may fear “well-capitalized” cannabis farmers will drive farmland prices higher, and existing farmers in other farm commodities will be unable to expand and new farmers will be unable to start. However, in many farm communities it is the construction of mega-homes or governments’ demands for transportation infrastructure or foreign speculators that are driving up the prices of farmland, not cannabis farmers. Furthermore, if cannabis is kept away from farmland and directed only to industrial and commercial properties, these sectors will experience their own pricing pressures, too. Some might think that once a greenhouse is built on farmland for cannabis farming it will never revert to soil-based farming. However, the same could be said for greenhouses used for any other agricultural commodity. Should these be prohibited too? It is already possible to reduce any negative impacts of greenhouse construction on ALR land by establishing building thresholds (in absolute terms or as a percentage of a property’s size) or construction methods (e.g. the need for concrete floors). Surely regulating greenhouses is better than banning them? Those familiar with the history of the ALR may recall similar concerns from some critics about farmers being forced out of business by new products and innovative technology. When farmers in the Okanagan first began converting from tree fruits to vineyards 25 years ago, critics complained that growing grapes for wine was so profitable that it would drive up the price of land for tree fruits and should be prevented by government. When farmers in Delta first began putting their crops under glass 25 years ago, critics complained this gave an unfair advantage to those farmers who could afford the capital required so should be prevented by government. In hindsight it would have been irresponsible for any government to prevent vineyards and greenhouses 25 years ago, and it would be irresponsible for any government to prevent cannabis and greenhouses today.

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CTAC’s Request When cannabis is legalized by the federal government: 1.

That the ALR Use, Subdivision & Procedure Regulation (BC Reg 171/2002) be amended to allow the production of both medical and recreational cannabis in BC’s Agricultural Land Reserve; and


That neither the ALC Act nor its regulations be amended to prohibit greenhouses in the ALR.

Contacts Rosy Mondin, Executive Director,, 604.346.8118 John Moonen, GR Counsel,, 604.786.7654

Conclusion The Cannabis Trade Alliance of Canada appreciates the opportunity to provide recommendations to the Cannabis Legalization and Regulation Secretariat. We look forward to continuing to work closely with ministry staff to develop inclusive public policy that will allow for a safe, thriving and mature cannabis industry to flourish in British Columbia. Thank you for allowing us to provide our input on this important initiative. Kindest regards,

Rosy Mondin Executive Director Cannabis Trade Alliance of Canada

Cannabis Farming on BC's Agricultural Land Reserve (ALR)  

CTAC urges the ALC to permit both medical and adult-use federally-licensed cannabis to be grown in the ALR.

Cannabis Farming on BC's Agricultural Land Reserve (ALR)  

CTAC urges the ALC to permit both medical and adult-use federally-licensed cannabis to be grown in the ALR.