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.

Committee Blog: Everything You Wanted to Know About Cannabis Facilities But Were Afraid to Ask Field Guide – Part 1 – Cultivation

by members of NCIA’s Facilities Design Committee
Jacques Santucci, Brian Anderson, David Vaillencourt, and David Dixon

Introducing our five-part series on the behind-the-scenes workings of the legal cannabis industry. This series focuses on all of the inner dealings and industry advice from established professionals to craft this unlimited How-to-Guide to assist you in setting up your own facility. These articles cover cultivation, extraction, infused products, and retail facilities as well as support activities. In general, remember to be compliant with all local rules and regulations and contact a licensed contractor and industry expert.

Part 1, Cultivation: The Top Things to Consider When Planning Your Cannabis Cultivation Facilities

As you are planning to start your own indoor cultivation facility, there are some often ignored basic parameters that should be taken into account in the design and decision-making process. We have listed the key parameters that will ease the process of going live and may save time and money while you design your facility and the building process. Always remember to be compliant with all local rules and regulations.

Lighting Recommendations

Depending on your goals, building setting, and local requirements, you have many options for lighting, from HPS light to LED lights. Lighting standards are measured in watts per square foot. Recommendations may vary per state or other criteria. For example, Massachusetts recommends an intensity of 36w/sft for energy consumption.

Water Recovery: Minimum Percentage

Cannabis is a water-intensive crop, and consideration of effluent capacity can be inefficient, expensive, and an issue for municipalities. Depending on your cultivation practices, you should consider a water recovery system and what percentage you are able to capture. There are two types of water recovery – leachate, and condensate. An effective system will recover at least 70% of the water for utilization, significantly reducing your water and sewer expenses. Your irrigation and fertigation selection will have an impact on your water consumption.

Generator Capacity: Minimum Recommendations

Your area or your business model may dictate for a generator – which is a critical Business Continuity consideration as a power outage, even if for a brief period of time can destroy a crop. Make sure to calculate the minimum capacity requirements of your facility. Do you plan to have it for emergency or stand-by usage? Typically, 50% of your short lighting load capacity of cultivation, 100% for AHU (air handling), and some back-office and security system, including cameras, access, and server needs.

Carbon Dioxide Enrichment: New Versus Recaptured

You can consider 75% new tanked- or generated- natural gas and 25% recaptured sources, for cultivation rooms, gas-fired chillers, and gas-fired boilers.

Carbon Dioxide Alarms Levels: Cultivation and Common Areas

Carbon Dioxide monitoring is critical for worker safety. You should be monitoring common areas to ensure that you are below 3,500 ppm. Monitoring should be tied to the fire alarm system for building evacuation, with 2,000 ppm alarm levels for the cultivation area. 5000 ppm limits are required by NFPA/OHSA. Alarms should contain visual strobes, red/green room access indicator lights and/or possibly an exhaust system that is triggered by an alarm

Renewable Energy: Minimum Energy Production Percentage

To demonstrate a commitment to sustainability, a minimum target of 10% of your facility’s energy consumption should be from renewable energy production: i.e. solar power, wind energy, geothermal, biomass, and/or battery energy.

Refuse Disposal: Recycling and Composting

Consider certified disposal of horticulture byproducts with a minimum of 25% recycling or composting by volume; rendered unusable. You will want to establish and verify that your shredder or equivalent system is capable of breaking up debris to a specified size.

Airlock Doors for In-Between Uses

You should install an airlock barrier, or at a minimum an air curtain, between the business and the production side, for outside and inside egresses, to keep a controlled environment. Keep in mind considerations for ventilation systems and cascading airflow.

Wall Material

For best performance to mitigate biological hazards and contamination, depending on your region, recommend installing insulated metal panels, that are non-porous, solid core wall, insulated metal panels (IMP), with surface mounted devices.

Security Entrance: Facility Safety

Consider creating a separate mantrap style entrance to allow for better safety at the entrance point, monitor visitors, keep a controlled environment as well as avoid weather-related issues, i.e. wet areas due to rain or snow, or temperature variance due to extreme heat or cold.

Limiting doors access and key sets for employees needs to be part of your overall security plan, with proper door labeling and authorization levels. The idea is to prevent unauthorized personnel from accessing specific spaces, for proper environment control and to be compliant with the local regulatory body. Remember to be compliant with local rules and regulations.

Security Camera: Minimum Area of Coverage

In most states, you will need security coverage for 100% percent of your faculty where cannabis products will be stored or displayed, with proper recording and monitoring. Keep in mind that your security room will likely need its own dedicated HVAC systems

Security Camera: Minimum Data Storage and Resolution

You will need to store all security camera footage on-site for a minimum of 90-days, or more depending on regulations. You may need to store the data offsite for five years for future legal needs. Footage quality may need to be shot in 1080p minimum. An ASTM International Standard Guide for Video Surveillance System provides additional parameters to utilize.

Security Alarm: Monitoring

Security alarm needs to be monitored by a reputable company. A service level agreement (SLA) or similar to ensure there are redundancies in the event of a failure should be considered, and redundancy or a backup system might be necessary.

Odor Control: Exhaust Air Management

Odor mitigation is a crucial part of all operations. All exhaust airflow must be oxidized or ionized. You also need a fogger system and carbon filtration. Refer to local municipal bylaws and regulations for more information.

For interior odor control and non-cultivation areas, consider cascading air flows from non-cultivation areas to provide a common method of control for pressurization control. Plan to control air flow and exhaust.

Fire Sprinkler: Maximum Bench Sizing

Sprinklers are designed to cover a limited surface area. When installed on cultivation tabletops wider than 48”, additional sprinkler coverage may be required.

Flooring Type: Continuous

Cultivation floors shall have continuous resin or epoxy coating with at least a four-inch lip onto the adjacent wall.

Energy Incentives: Minimum HVAC/D Efficiency Rating

Air Conditioning (AC) units should be no less than 16 SEER, High Point (HP) units no less than 9 HSPF. Incentives for this vary by state. Please check with your local utility company and regulatory commission for all available rebates.

HVAC Validation Requirements:

Bi-Annual Third Party Controlled Environment Validation using required Trend Data Metrics is the validation and calibration of control sensors, including temperature, humidity, CO2, and other devices such as scales, flow meters, integral valves, PPM sensors, EC meters, TDS meters, HVAC dampers and other applicable devices that may drift from factory or initial installation specifications.

Good Agricultural and Collection or Manufacturing Practices (GACP/GMP): Ready Versus Complaint

Your operation should be designed with documentation to prepare for GACP or GMP requirements. Depending on final product types, specific food-based GMPs with appropriate risk assessment programs (such as HACCP, and others referenced within the Food Safety Modernization Act) will prepare you for any federal or international trade opportunities in a federally legalized framework.

Employee Locker Access

Plan for gender-specific, male and female locker rooms, with six square feet per employee per shift expected to arrive at the facility at any given time. Employee supplied flock for locker or lock provided by the employer is a business decision. Keep in mind how you will keep the environment of your production facility under control. You might consider having locker access adjacent to the growing area with a proper gowning area.

Locker Room Type

Make sure your locker room is correctly set up for employees to be able to change in a safe way. Specifications for Locker Room and Gowning/PPE Areas should allow access to faucets for washing hands as well as bathrooms. Note gowning areas should be separate from the bathrooms directly off the locker room area.

Employee Shower Access

Per International Building Code (IBC) and State Plumbing Codes, calculate the number of employees and determine the number of showers based on code requirements as well as business policies. Having gender-specific showers is a recommendation as well as a business decision.

Emergency Eye Wash- Shower

For safety and based on OSHA standards, Integrated Pest Management (IPM), fertigation, and extraction operations must-have emergency eye wash showers. Eyewash stations need to be placed throughout the facility so that they are within 10-15 seconds walking distance from employees. Check local requirements for additional needs.

Note: in a facility where corrosives and skin irritants could pose harm to employees and require immediate remediations, you should consider emergency showers.

First Aid Kit Distribution

First aid kits should be available in all rooms where sharp tools and other hazardous materials are intended to be used. These kits need to be within 10-15 seconds of employee walking distances. Per OSHA requirements, first aid kits should be located in all trim, extraction, flower hallway, and shredding areas. This is overall a must-have in your facility.

Safety and Injury Handling

We recommend that you ensure that you have enough first aid and burn kits available throughout your faculty, based on your activity and the number of employees.

Check Out These Related Articles for More Top Things to Consider When Planning:

Part 1 – Cannabis Cultivation Facilities
Part 2 – Cannabis Extraction Facilities
Part 3 – Cannabis Food Production Facilities
Part 4 –Cannabis Retail & Dispensary Facilities
Part 5 – Cannabis Facility Support Areas