Veronica Carpio founder of Grow Hemp Colorado (GHC) an open source hemp org in Colorado, hemp farmer, hemp seed breeder and MJ drug felon

6 main points to address

1. 2018 Farm bill gave allowance for States and Tribes to be MORE restrictive in their hemp program.... the discriminatory exclusion included in the hemp language in the farm bill, placed a 10 year ban on drug felons ONLY, this ban does not cover the worst kinds of felons like murders, rapist, child molesters and other violent felons which states and tribes may want to protect against and keep out

Industry stakeholders ask that USDA to please clarify in rule, that States/tribes are allowed to have additional restrictions on any type of felons not just drug felons?

2. There is currently a Pay-to-play hemp group called the US Hemp Roundtable, pushing and passing hemp legislative language in multiple states which includes the federal 10 year felon ban but intentionally leaves out the grandfather clause in the farm bill, which exempted drug felons from this discriminatory restriction if they were licensed or registered under the 2014 farm bill. When writing rules and regs, please clarify that States and Tribes are NOT allowed to be more restrictive regarding this provision, again please clarify in rule that grand fathered drug felons, like myself and many others, can operate in all states and tribal programs regardless if grandfather clause left out in state/tribal hemp language. 

3. Hemp Industry stakeholders request USDA clarification on weather CBD from industrial hemp is legal to both cultivate and sell in a retail market place regardless of the FDA's current position and authority

4. As mentioned, in 2015 Colorado became the first state to create a hemp seed certification program. As other states do the same it becomes important that domestic certified hemp seed is eligible for plant variety protection? please include this eligibility in the rules and regs. We also ask that USDA does not make a requirement which only allow certified hemp seed to be planted as the majority of the hemp industry does not support this agenda at this time. 

5. GHC stakeholders also support hemp testing standardization but would also request and strongly encourage that the USDA to please provide a testing variance allowance of at least 15% for the 0.3%thc delta 9 concentration total on a dry weight basis in the finial established rules. 

6.  A. Finally, please DO NOT required any further restriction on age for those who can grow hemp 

B. Please also clarify in rule that only the hemp applicants and or licensees will be the only ones required to be finger printed and back ground checked, NOT everyone who will be handling plants, especially minors or those who have access to hemp field as this makes zero sense and it is cost prohibitive. 

C. Last, please do not create any specific deadlines for hemp farming applications and allow the states to adopt them if they so choose to or not. 

Thank you again for your time, all efforts made for today’s webinar and future efforts by USDA to ensure we have a thriving us hemp industry which benefits the whole not just a select few.