Statement of the Flandreau Santee Sioux Tribe

-	The Tribe does not accept or believe that is must comply with the 2014 Farm Bill and that Section 297B specifically allows us to submit a plan that meets those provisions.  In fact they Farm Bill does NOT say Hemp Production must cease until USDA regs are in place.  This is contrary to congressional intent.

-	Tribes may often be not only the primary regulator of the hemp industry in Indian Country, and the primary market participant.  They could also be the ONLY market participant.  This is much different that the state models.

-	The growth in 2020 would result in lost land lease revenues because of cancelled leases for the 2019 summer, and possibly 2020 summer.

-	Tribes are fantastic at regulating based on federal guidance, and not direct regulation.  For instance, see Indian Gaming, Natural Resource Development, and Taxation.

-	Over-regulation will be incredibly costly to the Tribe, and the lack of strong guidance from the USDA will not give lending entities comfort when lending for commercial loans.

-	State Pre-emption guidance will need to be issued to states, ESPECIALLY a state like South Dakota that is not legalized.  The states must understand that this activity it completely pre-empted, and that they may not interfere with the Tribe’s operation.

-	When new tobacco regulation was to be instituted, FDA allowed for existing operations to continue to operate under specific guidance.  This is exactly what should happen here so as to not jeopardize existing operations.

Ben Fenner