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Committee Blog: A Guide to Navigating Cultivation Environmental Requirements

Navigating environmental requirements and reviews can be one of the most challenging and costly aspects of obtaining a cannabis cultivation license. Environmental standards and regulatory requirements differ from state to state and within local jurisdictions. While regulations may vary, cannabis operators encounter similar environmental requirements nationwide. Environmental reviews and impact assessments require an evaluation of cultivation policies and operations for sediment and erosion control, water usage, wastewater discharge, energy efficiency and carbon footprint, air quality, and odor control. This guide will aid operators in establishing the best practices for these environmental concerns to create a smoother environmental review process for the cultivator. 

Sediment and Erosion Control

Sediment and erosion control methods are required for outdoor cultivation to ensure the facility has a comprehensive mitigation plan to prevent adverse effects the outdoor crop may cause to the land. Sediment controls are structural measures intended to complement and enhance the implemented erosion control practices and reduce any sediment discharge. Erosion control is a soil stabilization process consisting of mitigating measures to prevent soil particles from detaching and moving into stormwater runoff. Ensuring this compliance may include implementing Best Management Practices (BMPs) for Sediment and erosion control. These BMPs should be implemented before the onset of the rainy season, typically in October. Sediment and erosion control devices and measures should be replaced when they deteriorate. 

Sediment Control BMPs

  • Silt fences
  • Fiber rolls
  • Hydroseeding
  • Sediment Trap
    • Inspect the trap on a routine schedule for litter and debris
    • Remove the sediment built up in the trap and sprinkle it lightly over vegetated areas to increase soil fertility
  • Gravel bag berms
  • Sandbag barriers
  • Straw bale barriers
  • Observation station on the property for visual monitoring of sediment pollution
  • Add gravel to dirt roads
  • Add stormwater detention basins

Erosion Control BMPs

  • Vegetative Swales & Buffers
    • Swales should be trimmed to prevent restriction of flow
    • Routinely monitor for any debris and overflow
    • Buffers should be added to the edges of parking lots and storage areas
  • Placement of straw mulch over disturbed land
    • Should be replaced often
  • Soil binders
  • Vegetation preservation
  • Vegetation replacement for any disturbed areas that will not be in use
    • Seed mixes containing native grass and wildflowers
    • Hydroseeding
  • Earth dikes

Waste Usage and Wastewater Discharge

Water usage and wastewater discharge management plans are required to ensure the cultivation facility legally and efficiently obtains its water and that no hazardous water is dumped onto the land surface, directly into the ground, or into another body of water where it could negatively impact the environment. Water usage may require obtaining documentation demonstrating you own the water rights to your facility or property. Cultivations connected to their municipalities’ water district may only need to report that information to meet this requirement. Such a facility may also need to contact its water provider to create a water rights letter showing the operator has the right to use that water. Cultivations that use other water supply methods, like wells, may need to provide a detailed report of their water quality and have well flow testing performed. Depending upon your state, you may also need to show how your water will be conserved. A cultivator may be required to create a water conservation plan detailing the procedures implemented at the cultivation site to conserve water. Wastewater discharging typically will require a cultivation site to apply for a Wastewater Discharge permit. Wastewater discharging plans that thoroughly explain how the cultivation will discharge any hazardous wastewater and what mitigating practices will be implemented to prevent wastewater from entering the environment untreated are also frequent requirements for this process.

Water Conservation Methods

  • Recycling irrigation systems
  • Automated irrigation systems
  • Precision emitters
  • Watering more frequently throughout the day in smaller amounts
  • Planting pots 
  • Divert the dehumidifying and cooling system’s piping into a holding tank to reuse the water for irrigation
  • Use organic mulch around each plant to prevent moisture loss
  • Rainwater harvesting, if allowed in your area
  • Substrate sensors to monitor water saturation

Wastewater Discharge Measures

  • Using planting pots to prevent excess runoff
  • Vegetative swales and buffers to capture wastewater
  • Recycling irrigation systems with reverse osmosis and ultrafiltration or thermal evaporation 
  • Recycling systems that don’t have a filtration system can hold any hazardous wastewater in a holding tank and have it transported to an approved wastewater treatment facility
  • Substrate sensors for the prevention of excess runoff
  • Stormwater runoff prevention
    • Store pesticides, chemicals, and fertilizers indoors and away from any outdoor growing areas and in approved containers
    • Covering wastebins 
    • Divert stormwater away from any stockpiled materials

Energy Efficiency and Carbon Footprint 

Cultivation energy efficiency and carbon footprint reporting are becoming more popular among regulators as the country moves toward environmentally friendly practices. Energy efficiency may require the cultivation site to comply with specific requirements for equipment and lighting. Many licensing bodies also require an energy efficiency plan that details what mitigating measures the operator will implement to reduce energy costs. Carbon footprint reporting may require greenhouse gas emission (GHG) reporting, which can require a cultivator to purchase carbon offsets. Green energy plans are sometimes required; these plans demonstrate how the cultivation will utilize green energy options to reduce their carbon footprint. 

Energy Efficiency

  • LED lighting 
  • Automated irrigation systems
  • Automated blackout curtains for greenhouses 
  • On-site composting 
  • Low-flow fixtures
  • Split ductless air condition
  • Chilled water systems for dehumidification
  • Modulating hot gas reheat forced air systems
  • Sensor motion lighting in rooms that aren’t frequently entered
  • Adjust lighting schedules based on the weather if using mixed-light
  • Installing solar panels
  • Request an energy efficiency review from your utility provider 

Carbon Footprint

  • Sign up with a clean energy provider that partners with your utility company and reinvests the funds from the program into clean energy initiatives in your state
  • Avoid generation use wherever possible
  • Install renewable energy sources at your facility, like solar panels 
  • Replace pesticides with biocontrols using predatory insects
  • Use recycled or biodegradable packaging, even for wholesale flower
  • Cultivate companion plants that deter pests and attract beneficial insects
  • Reduce or eliminate lighting requirements by establishing a greenhouse or outdoor cultivation facility

Air Quality and Odor Control 

Air quality reviews may be triggered for cultivation facilities, including the requirement to obtain an air permit. Air permits allow an operator to release a limited amount of pollution within certain restrictions. Air quality reviews for cultivations are triggered by several factors based on the state requirements, some of which may include drying, processing, generator use, fugitive emissions, and pesticide application. If a cultivator is required to obtain an air permit, they will be licensed to perform those activities. Cultivations going through air quality reviews may need to provide an Air Quality Control Plan outlining the mitigation efforts the cultivator will make for air quality pollution. Odor Control Plans are one of the most common regulatory requirements for cannabis businesses. If your environmental review includes odor control and you operate an outdoor cultivation site, you may be required to conduct an odor control study on your facility. These studies use wind patterns to measure the distance the odor from your cultivation will travel. Based on your state or local jurisdiction’s requirements, an odor control study may require you to move the border of your canopy. Conversely, an odor control study may prove that your cultivation will not be a nuisance due to odor pollution, and no mitigating measures will be required. Odor control plans should detail precisely what mitigating measures the cultivator will implement and, if available, data on how effective those measures will be. 

Air Quality Control Plans

  • Wetting the surface of dirt roads during the dry season
  • Encourage ride-share amongst your employees
  • Reduce VOCs wherever possible 
    • This can include timing harvesting to reduce ozone impact
  • Include a chemical usage plan that describes how pesticides, fertilizers, and other agents will be stored and disposed of in alliance with the manufacturer’s recommendations
    • Detail how you will maintain Safety Data Sheets (SDS) on all chemicals at the facility 

Odor Control Plans

  • Indoor cultivations and greenhouses can implement the following measures:
    • Use carbon filters 
      • Explain in your plan how carbon filters work, provide data on their filtration rates, which you can locate in the manufacturer’s guide, and how often you will replace them
    • Use wet scrubbers for indoor cultivation or greenhouses
      • Explain how the air is treated when it passes through the scrubber
    • Implement biofiltration measures
      • Explain how the air will pass through soil, mulch, or other organic matter to filter the air
    • Use oxidization treatments through your facility’s ventilation system 
      • Explain how the process of oxidization removes odor 
    • Have open communication with your neighbors regarding odor 
      • Explain how you will speak with your surrounding neighbors about any odor concerns and request your neighbors contact you if they do smell odor so you can begin an assessment into structural or equipment failures and, if needed, implement further mitigating measures to your plan
  • Outdoor cultivations can implement the following methods:
    • Hire a professional to do an odor study to prove your facility’s compliance
    • Plant fragrant flowers around the exterior of the site 
    • Use oxidization treatments through high-pressure misting devices around your cultivation area 
      • Explain how the process of oxidization removes odor 
  • All cultivation types should have open communication with surrounding neighbors regarding odor
    • Explain how you will speak with your surrounding neighbors about any odor concerns and request your neighbors contact you if they do smell odor so you can begin an assessment into structural or equipment failures and, if needed, implement further mitigating measures to your plan

As regulatory requirements vary across the country, cultivators should carefully read their regulations and contact state and local departments for guidance on requirements specific to their operations. A thorough understanding of what plans must be created, studies performed, and special permits obtained will create a smooth environmental review process. Join the upcoming NCIA webinar from the Cannabis Cultivation Committee to dive deep with industry professionals on navigating environmental reviews across the United States.

Member Blog: Soil Is A Way Of Life, But What Is Living Soil?

by Lee Spivey, Marketing Manager at Good Earth Organics

Our preferred definition of living soil is the community of microbes working together breaking down organic matter which, in turn, provides valuable nutrition to the plants.

Soil microbes are essential for decomposing organic matter and recycling old plant material. Microorganisms are the unseen majority in soil and make up a huge part of soil’s genetic diversity. This means easier absorption of nutrients by plant roots, reduced need for watering, limited erosion, and improved aeration. A combination of organic materials such as compost, coco coir, peat moss, aged tree bark, manure, worm castings, and more can be used to make a base for living soil. Like all living things, soil needs water, and flows water along the path of least resistance to bring hydration and nutrients to plant roots. Water remains in the soil by storing itself in porous minerals for later use. 

Most beneficial life requires oxygen to survive and the complexity of living soil ensures air and moisture are continually cycled to keep roots oxygenated and allows plants to breathe. Organic soil additives must be broken down by microorganisms for plants to use them and three important microorganisms for living soil to function properly are bacteria, actinomycetes, and fungi. 

Bacteria are single-cell microorganisms that exist in most of the earth’s habitats and are the most dominant group in soil. Bacteria are present in all types of soil but their populations diminish with the increase of soil depth. Though bacteria can live under starvation and dehydration conditions they reproduce quickly when optimal water, food, and environmental conditions exist. Having a diverse bacterial population increases soil productivity and crop yields over time, while also assisting in decomposition. 

Actinomycetes are similar to bacteria and fungi, but do not have the chitin and cellulose found in the cell walls of fungi. The deeper your soil, the more actinomycetes will be found as their numbers increase in the presence of decomposing organic matter. Temperatures between 77°F and 86°F are ideal for actinomycetes growth and the most commonly found are thermoactinomyces and streptomyces which help prevent molds, mildew, and other soil pathogens. 

Fungi are second only to bacteria in their abundance in soil and the quality of the soil has a direct effect on their numbers. They are found in all soils and have filamentous mycelium, composed of individual hyphae. The quality and quantity of organic inputs present in soil have a direct effect on fungal numbers. Degradation of organic matter along with help in soil aggregation are the main functions of fungi in soil. Additionally, certain species of fungi produce substances similar to humics in soil which improve nutrient uptake in the root zone. Some fungi also aid in the mobilization of soil phosphorus and nitrogen — two of the three most important minerals — into plants. With cannabis, in particular, establishing roots becomes much less challenging when mycorrhizal fungi are introduced. “Myco – rhizal” literally means “fungus – root” and describes the mutually beneficial relationship between the plant root and fungus. These specialized fungi colonize plant roots and extend far into the soil to acquire resources beyond the “nutrient depletion zone” that plants can’t access alone. Mycorrhizal fungal filaments in the soil are truly living extensions of plant root systems and are more effective in nutrient and water absorption than the roots themselves as hyphae, or fungal roots, grow much faster and longer than the roots of the plant itself. This expands the surface area of the plant root allowing for increased access to nutrients, water, and oxygen.

There are many ingredients that work synergistically for optimum growth effects and less environmental impact. It is up to the individual which ingredients they prefer, but I recommend a blend of coco, peat, and compost to start. After accomplishing a drainable media you can begin working in the biologicals and bringin the soil to life.  

Growing with organic inputs and methods not only provides healthier plants because they are grown without toxic or persistent pesticides or fertilizers, it contributes to a healthier planet. Growing in organic living soil builds carbon with less waste while keeping toxic and persistent pesticides and fertilizers out of the soil, water systems, and our bodies. Many books have been written about living soil and this is just a small glimpse of its importance to businesses in the cannabis industry. For me, it breaks down to dollars and sense, as it does with many businesses that care about their bottom line. Living Soil allows for the grower to reuse soil for many years, saving them money on labor, fertilizer, and growing media. As growers, we are always working toward minimizing our carbon footprint and living soils empower growers to consistently achieve higher yields and organic purity.

Lee Spivey is the Marketing Manager for Good Earth Organics, Inc. a premium potting soil manufacturer in Oregon. As the driving voice behind the brand, it is his personal mission to make the world aware of the benefits of using organic living soil. After seven years with the company, he is well versed in the science behind the soil and the organic mission behind the brand.

Good Earth Organics, Inc. shares this passion for clean, living soil and has a vision to bring GEO products to growers everywhere that care for increased yields and organic purity.

GUEST POST: The Real Environmental Impact – Sustainable Practices For Cannabis Companies

By Alex Cooley, Solstice

Growing greener has been making the news. Or rather, the cannabis industry’s habit of scaling up largely unsustainable grow methods in big production facilities is on the national radar.

Alex Cooley, Solstice
Alex Cooley, owner at Solstice

One widely circulated quote equates the carbon footprint of producing a gram of hydroponically grown cannabis to that of “driving seventeen miles in a Honda Civic.” And while that beats seventeen miles in a Hummer, it’s a number we have the power to greatly reduce. Part of what excites me about this freshly-legal industry is that we have the opportunity to shape it in a way that big business has thus far failed to do by not putting a higher profit margin above the health of the planet.

In August I was asked to speak about this very topic in Las Vegas at the 2nd annual NCIA Southwest CannaBusiness Symposium. It gave me a chance to reflect on something I’m passionate about – the real environmental impact of what we do, what isn’t working, and how we can create positive change for this and future generations of growers and patients.

Get Under The Sun

  • It takes vast resources to power a warehouse grow that relies on High Intensity Discharge (HID) or High Pressure Sodium (HPS) lights. Automated light deprivation greenhouses can produce cannabis of equal or greater value as that produced indoors at half the cost and one quarter the environmental impact.
  • Cannabis used for extracts can all be grown outdoors. Provided you live in a climate that allows for outdoor cultivation, sun-grown cannabis is excellent starting material for extractions. The finished form will be far from the flower, so why not take advantage of one of our most powerful (and free!) resources?
solsticecooley_warehouse
Solstice growhouse

Keep It Lean Indoors

I know that not every method of cultivation can rely exclusively on solar power. However, in indoor grows, we can focus on efficiency.

  • For most indoor grows, Heating, Ventilation, and Air Conditioning (HVAC) systems are a huge resource suck. I’ve discovered that the best method is to utilize a centralized Variable Air Volume (VAV) system.
  • Make sure the envelope is sealed. Keep your buildings well insulated to prevent energy leaks. Without a higher energy code and tighter insulation, many industrial-scale grows hemorrhage energy and resources.

Lay Down the Law

Frankly, some of the cities and states currently passing laws to regulate cannabis cultivation have the least enviable power infrastructures. Las Vegas, which relies heavily on coal and natural gas, is ahead of the curve in terms of legislation, whereas clean n’ green hydro-electrically-powered Washington State has yet to create stringent and sustainable regulations. Legislators have been more concerned with issues of security and diversion than environmental impact. The “pot is dangerous” paradigm needs to shift to “unregulated grow practices are dangerous for the planet.”

Nice Package…

We can effectively undo all the good of a smart grow with wasteful packaging.

Solstice glass jars
Glass jars with cork & wood tops
  • Think cradle-to-grave for your packaging: Where did it come from? What is it made of? Where will it go after it has been used? That plastic container might be a good fix in a pinch, but think about the impact it has as you scale.
  • We’ve got to reduce plastics and push glass, wood, or paper wherever possible. Almost every gram of cannabis that goes out into the world from a processing facility is wrapped in plastic – and we all know that it can’t be properly disposed of or recycled. However, the plastic used for business-to-business bulk orders could be saved and reused.
  • At Solstice we’ve been designing glass containers with cork and wood tops for our flower. They can be collected, reused, or returned for a deposit. Our pre-rolls are made from 60% post-consumer recycled paper and printed with vegetable ink. Every little bit counts.

Have Multiple Bottom Lines

The “Triple P bottom line: People, Planet, Profits” is the newest, sexiest take on commerce with a conscience. The Triple P works primarily because it’s a flexible paradigm; it gives business owners a framework in which they can question and evaluate the human and environmental cost of every move they make.

Across industries, innovative leaders are finding more generous, humane, and ultimately more sustainable ways to do big business. Some of these are easy and inexpensive: utilizing proper waste disposal, bike-to-work incentive programs (a Solstice favorite), Plant-A-Tree days, or making sure your pesticide program is safe for employees and the planet.

Sometimes however, there is an unavoidable immediate cost to doing what’s right. Google uses a fancy fuel cell with 2-3 bloom boxes for their building infrastructure. They’re getting loads of good PR for this – in part because very few people can afford to use them.

But it is my belief that the more you grow, the more capital you’re bringing in, the more you have to give to impeccable resource management.

Everyone knows that cannabis makes money; we’re looking at a multi-billion dollar industry over the next 5 years. Hobby systems and garage standards are not scalable for the cannabis boom. Whatever the laws might ‘allow’ us to do, we have to stay ahead of the curve and firmly within our own conscience.

Alex Cooley is the owner of Solstice, a member of NCIA since April 2013. Solstice founded their Seattle-based flagship in 2011 as the first-ever permitted cannabis production facility in Washington State. Solstice has taken an environmentally conscious approach to high quality cannabis production and has cultivated over 350 different types of cannabis, creating one of the most robust genetic libraries anywhere in the world.

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