West Virginia Department of Agriculture
1900 Kanawha Blvd. East
Charleston WV 25305
Standard Agriculture Ltd.
STAG
Don Smith II
COMMENTS CONCERNING PROPOSED RULES FOR
AGRICULTURAL HEMP
Commissioner,
I have developed Standard Agriculture Ltd. – STAG - to provide sales and services to
alternative agricultural crops and their associated industries in West Virginia. Industrial
Agricultural Hemp and Bamboo are my specialties. Over the years, I have compiled a
great amount of research and have performed my own experiments with tissue cultured
test plots of bamboo.
I have lectured the philosophy of starting this business with the concept of imagining a
completely satisfied and loyal customer, and then reverse engineering the policies all the
way back through the mills, factories, refineries and other associated businesses, then
back through the largest farms, plantations, and on back to the smallest garden plot.
To successfully develop the “farm to the fork” operations envisioned, millions of dollars
of capital will need to be raised to reopen shuttered industrial locations and to open new
facilities. Capital will flow to where it’s treated nicely. The financiers I have dealt with
are interested, but only if they have a high degree of “certainty” that their investments
will be protected. Of course, this same principal applies to the farmers and plantation
operators.
There are many opportunities that present themselves. We can develop Agricultural
Hemp Industries very quickly if we work towards a goal of providing that “certainty” to
all parties and develop a cooperative environment that will foster a new prosperity in
West Virginia.
Industrial Agricultural Hemp may provide the raw natural resource needed to begin
America’s Second Industrial Revolution.
At this time, the current legislation and these rules make raising the capital necessary to
develop these new industries, completely impossible to generate.
For now and until new and business friendly legislation is developed, I will offer the
following commentary on the proposed rules …
3.2.h and all of 5.1.c – 5.6.b - I fail to see the necessity – as I see it, if a person has repaid
their debt to society and choose agriculture as their vocation, then society has succeeded
in reforming a criminal – further punishment and exclusion from a legal activity and
vocation is draconian …
7.1 - I fail to see the necessity – as a matter of fact, this is the wrong way to proceed due
to several factors – One, every other exclusionary zone for alcohol, gambling, and other
vices is 1000 feet, not a mile. Two - As hemp seeds are scientifically proven to be one of
the “PERFECT FOODS”, providing all essential amino acids, every attempt should be
made to bring it into the classroom, school gardens, and other youth agricultural
enterprises. As this legislation dictates research under University Auspices, there will
obviously be many youth involved in research. Three - Approved cultivars of Industrial
Agricultural Hemp are NOT the plant that gets one intoxicated. This rule implies that it is
some form of high potency marijuana. The youth and students of West Virginia are our
future farmers and industrialists. They are the ones who will be taking over this new/old
enterprise and enjoying the prosperity it brings, far into the future.
7.2 – I fail to see the necessity – this rule implies we are dealing with a dangerous
substance, which is not the case. The security of the storage of Industrial Hemp should be
at the discretion of the farmer, operator, or industrialist, just as it is with any other crop.
7.3 – Ornamental Industrial Hemp Plants should be encouraged. They pose no threat.
9.1 through 9.5 – I would reconsider this entire section of the rules. Illegal marijuana
production throughout West Virginia is prolific and our number one cash crop. Therefore,
it is conceivable, cross - pollination could occur. If a registered farmer had a registered
cultivar that had suffered this cross – pollination, it would seem quite draconian and
ruinous to suspend and revoke that farm’s registration. This only takes away from the
“certainty” I had mentioned earlier. Perhaps we can conceive other “QULITY
ASSURANCE” measures that will make allowances and possibly provide regulated
markets for crops that exceed the THC limits …
61-29 – 12 FEES – I would recommend a complete reevaluation of the fee structure. At
this rate, only millionaire farmers and plantation operators could grow Industrial Hemp
with these fees. As I had mentioned earlier, Hemp Seeds are a perfect food. If a citizen of
West Virginia should choose to grow a small plot of Industrial Hemp for their own larder,
they should not have to pay such exorbitant fees. Likewise, should a cooperative of small
farmers decide to grow Industrial Hemp, accommodations should be made to provide
them with a cost competitive fee structure that will be fair. Perhaps a sliding scale of fees
would be far wiser. For example, sliding scale fees based on meters, hectares, square
footage, or other measures that accommodate small plot production would be preferable.
This would foster small farm production and self - sufficiency. American history is full of
stories of how small time operations soon develop into economic power - houses. Every
effort must be made to insure everyone who is involved with Industrial Hemp operations
are not faced with cost prohibitive and unfair fees.
OTHER RULES TO CONSIDER:
I.
GMO Industrial Hemp Production.
With the advent of GMO crop production, a whole series of unintended, unplanned, and
unmanageable consequences have occurred and ruined the production capacities and
businesses of many farmers who do not use GMO plants. This is another example of the
effects of cross – pollination having detrimental effects on approved Industrial Hemp
Cultivars. Yet, GMO crops are a viable business and it can be assumed some farmers and
plantation operators will proceed with their GMO crop operations. Therefore, it would
seem wise to restrict GMO Industrial Hemp production to enclosed, indoor, and
adequately filtered production facilities. This is apparently the only means to insure the
purity and viability of the Certified Industrial Hemp Cultivars we will be using.
II.
Seed Savers.
Saving one’s seeds is one of the oldest and wisest methods of developing and maintaining
a hardy stock of plants. This age old method of agriculture is wise and provides a natural
self - sufficiency. There are those of us now, who are searching for the old cultivars, that
grow wild in West Virginia to this day, that could be possibly traced back to the same
cultivars that were grown by Washington, Jefferson, and Adams. Every effort must be
made to insure the farmers who choose to practice this method of agriculture are
protected from undue and malicious legalities.
III.
Certifying Carbon Sequestration Rates.
The EPA is now allowing States to establish rates for carbon cap and trade. This offers
West Virginia a potential opportunity to allow for a more responsible and palatable
carbon fuels industry and provide Industrial Hemp Growers another source of income.
The going carbon rate and proposed tax levels are at $20.00 per ton. My research shows,
for every one ton of Industrial Hemp harvested, 1.67 tons of carbon is sequestered back
into the ground. That potentially equates to an additional value of $33.40 per ton of
Industrial Hemp, minus fees. This carbon sequestration industry is a whole new
opportunity as new financial markets and exchanges can be developed right here in West
Virginia. It is a win – win opportunity for our fossil fuels industry and the Industrial
Hemp Planters. In essence, we are paid to put carbon into the atmosphere and we are paid
to remove carbon from the atmosphere. A complete and scientific examination of this
opportunity should be started immediately and appropriate rules and policies should be
developed.
IV.
Using Industrial Hemp as a “MOP CROP”.
Across the world where people are FREE to use Industrial Hemp, it is being effectively
used as a “Mop Crop”. Industrial Hemp is a “hyper accumulator”. This means it will take
up and metabolize many pollutants, which are currently running straight into our West
Virginia waterways. In areas of West Virginia that are adversely affected by pollutants,
Industrial Hemp can be used as a natural pollution abatement system. Pollution hot spots
from municipalities, industrial sites, mines, drilling operations, chemical plants, waste water treatment facilities, farm – feedlot – field – poultry runoff, and a whole host of
other contaminating facilities could benefit from the phytoremediation properties of
Industrial Hemp. This represents a cost effective and natural means of controlling one of
the worst threats to our economy and humanity. A complete and scientific examination of
this opportunity should be started immediately and appropriate rules and policies should
be developed.
In closing, I will say we have been given an opportunity to prosper, redevelop, and to
reengage in an industry that is thousands of years old. This Cannabis Prohibition is
proving to be the most unwise and ruinous public policy in American History. Hemp has
a revered place in our lives and the thought of having it criminalized and demonized is
counterproductive. I recommend we proceed with a heightened sense of urgency to
quickly normalize all aspects of the Industrial Hemp Industry. We are in a unique
location, we have the manufacturing infrastructure, and we have the need to revitalize our
State’s economy as quickly as possible. Industrial Hemp can play a big part in West
Virginia’s future. Other State’s are proceeding with their Industrial Hemp tests and some
are even proceeding with actual production. At this time, with these new efforts
underway, we can write and develop the BEST INDUSTRIAL HEMP POLICIES and
bring about the BEST INDUSTRIAL HEMP OPERATIONS IN THE WORLD.
If I can be of any service, please feel free to contact me at your convenience.
Regards,
Don Smith II