In part 1 and part 2 of this series we discussed how to find the perfect location for your Oregon recreational grow op, and how to let the OLCC know that your property, your company, and your owners are up to par. You now have a perfect location and the local planning department is working towards approving your Land Use Compatibility Statement. Everyone involved with your company has filled out their Information History forms. Next you need to prove to the OLCC that you have adequate security to prevent your crop from joining the illegal market, rights to enough water to nourish your plants, and enough power to operate your lights and fans (you do have adequate around-the-clock ventilation to prevent mold, right?).
The OLCC wants to know some basic details about your business, such as when you will be open, your cultivation process, and your security setup. Fortunately, the OLCC has recently simplified the producer application, so these requirements are all clearly laid out.
Hours of Operation. As part of the producer application packet you will need to provide your hours of operation for each day of the week, as well as any anticipated variations for seasonal or other reasons. This requirement helps OLCC inspectors know whether they can enter your property on a whim (while you are open) or whether they must first have a reason to believe a violation has occurred (while you are closed).
Cultivation Plan. The application has a short essay question where you will need to describe your grow op in depth. The OLCC wants to know your growing medium, the specialized equipment you will be using, and whether your crop will be indoor or outdoor (or both for mixed producers). You will also need to explain whether you will be using seeds, clones, or a mix and detail how you will be handling your immature cannabis plants. Since you will ultimately need to submit a cultivation plan to the OLCC, you should create one as part of your initial business plan. Savvy investors will likely want to know this information anyway.
Electricity & Water Use. When you initially apply for an Oregon cannabis grow license you will need to provide month-by-month electricity and water usage estimates and you will need to prove you have a legal source of sufficient water. This proof can take the form of 1) a copy of a water use authorization, permit, or certificate from the Oregon Water Resources Department, 2) a statement with the name and contact information of a public or private water provider that will be providing water to your site, or 3) a Marijuana Producer Exempt Water Form from the Oregon Water Resources Department showing that your water does not require a water right. You should contact the Water Resources Department to determine which option will work for your site.
Security. The OLCC is understandably concerned about licensed cannabis flowing into the black market, so all growers must meet strict security requirements. Generally, you will need to do the following:
- Keep all exterior access points locked with commercial grade locks outside of business hours;
- Store all usable cannabis, harvested plants, and finished products within a secure, indoor steel-framed room (outside of business hours). This requirement should be on your mind as you search for a location;
- Have an alarm system that covers all potential entry points, can detect movement within any area housing mature plants or usable product, and automatically notifies authorized personnel in the event of a breach (you can ignore this requirement if you will have at least one person in the premises at all times outside of business hours);
- Have at least two operational “panic buttons” inside the premises that will immediately notify a security company and law enforcement, or have mobile “panic buttons” carried by all of your employees and representatives, or have a landline telephone present in all limited access areas.
One of your more significant up-front costs will be designing and installing a compliant video surveillance system. Your 24-hour a day system must satisfy the following:
- Cover all areas where cannabis items or waste will be present or in transit;
- Cover all areas within 15 feet of all entry points in all directions;
- Record at a minimum resolution of 1280 x 720 pixels in all lighting conditions;
- Record at a minimum of 10 frames per second (5 frames per second for exterior non-restricted areas);
- Be contained in a dedicated room containing a list of all personnel authorized to access the surveillance system;
- Have a backup battery that can independently power the system for at least an hour;
- Provide automatic notification in the event of a failure of a security camera or other portion of the system;
- Include a monitor for viewing video from any camera, a digital archiving system, and a printer; and
- Maintain recordings for 90 days both on-site and continuously backed up to a secure off-site location.
You will also need to keep a log of all maintenance activity on the system.
Now you have your surveillance and alarm systems set up, you’ve let the OLCC know when and how you will be growing, and you have satisfied the OLCC that you have enough water and power. Check back next week for part 4 where we will discuss your requirements to keep the public, and particularly minors, out of your licensed area as well as the various site diagrams the OLCC will want to see.