Rachel's Public Hearing Comment

PUBLIC HEARING COMMENT – PART 1200 INDUSTRIAL HEMP ACT

Support establishing a better regulatory framework for Illinois hemp including:

1. Single year licenses, graduated initial fee structure

2. Less restrictions for people with criminal backgrounds

3. Allowing land to be used for hemp that doesn’t classify a farm per the tax code, introducing urban agricultural zones

4. Broadly inclusive language recommended by the Director of the IDOA for approved sample testing entities and equipment

5. Alternatives to destruction of hemp that tests higher than 0.3% THC

INTRODUCTION

My name is Rachel Berry. I am a small farmer and representative of the Illinois Hemp Grower’s Association. Here is my perspective and my suggestions for the proposed rules and regulations.

FEES

Only issuing licenses for three years at a time can create a challenging initial cost-barrier to entry for small farmers and researchers.

IDOA should allow growers and processors to purchase a license for one year at a time, at the proposed rate of just over $333 dollars a year.

IDOA should also adopt a graduated scale of $2 per acre for the initial application fee with a max of $200 the at the top for growers with over 100 acres.

DENIAL OF ELIGIBILITY

Included in the language of these proposed rules is the denial of eligibility to people convicted of any felony, drug-related misdemeanor or crime of dishonesty. Who does this benefit?

It discriminates against people who may have limited access to good paying jobs.

It will deny people eligibility further than what is established in federal law, people who need the opportunity to participate in this new and fast-growing industry.

We should bring the Illinois rules in line with the federal rules which only deny eligibility to people with controlled substance related felonies.

RESTRICTION ON LAND USE

Another restriction that only serves to discourage potential growers is the requirement that any land used to grow hemp be classified as a farm per the Property Tax Code.

This excludes large portions of the population that would otherwise happily grow and use hemp for many purposes including food and soil remediation. It excludes community gardens, urban farmers, and suburban gardeners.

Illinois should allow qualified urban agricultural zones as well as farms the rights to grow hemp.

TESTING COST

Farmers are going to be responsible to pay for lab tests that can cost between $75 and $300 per sample based on my research. Kentucky is $250 per sample payable to the state treasury.

The IDOA Director should recommend broadly inclusive language allowing any third party entities and forms of equipment that meet accuracy standards to perform sample tests to help keep costs and delays to producers low.

ALTERNATIVE TO DESTROYING >0.3% THC HEMP

North Carolina’s rules and regulations provide an economic alternative to destroying fiber and seed crops that test higher than 0.3% THC.

Kentucky and Wisconsin rules say all hemp testing >0.3% THC must be destroyed.

IDOA proposes all hemp testing >0.3% THC must be destroyed.

North Carolina’s economic alternative is a fantastic example of protecting hemp farmers while growing the industry. IDOA should not follow Kentucky or Wisconsin’s example on this issue.

CONCLUSION

The proposed rules create a multi-layered financial and bureaucratic gateway between farmers and hemp profits while offering the farmer nothing but delays and possible penalties in return. Let’s make a better regulatory framework to help protect our farmers and help hemp’s benefits reach even more people.

Rachel Berry, CEO

Illinois Hemp Grower’s Association

IHGA@tutamail.com

815-719-3928