Beginner’s Guide to Integrated Pest Management “IPM” – What is it and how to do it.

By David Perkins

Formulating a Plan 

In this article, you will learn how to control pests and improve the health of your cannabis plants using integrated pest management, commonly referred to as IPM. This involves a multi-point strategy – there is no quick fix, nor is there one solution that will wipe out all your pest problems. Proper pest management requires patience, consistency, and determination. 

It is important to understand that not all pesticides are bad. While many are incredibly harmful not only to pests, but also humans, in this article I will educate you about some of the safer alternatives to traditional pesticides. It is possible to safely control unwanted pests in your cannabis garden without harming yourself, your employees, or the natural habitat around you. 

Every cultivation facility should have a well thought out plan for their pest management program. This program should account for the prevention, and if necessary, eradication of: spider mites, russet mites, fungus gnats, root aphids, thrips and caterpillars. These are just a few of the more common pests you’ll find in a cannabis garden. There could also be many other less commonly known bugs, so you have to be vigilant in looking closely at your plants, and the soil, at all times. Complete eradication of a targeted pest can be difficult. Once a pest has established itself, decimating or decreasing the population will require an aggressive regimen that includes spraying daily to control populations and prevent other pests from getting established. 

Spraying or applying pesticides to the foliage of plants isn’t the only way to control or eradicate pest populations. There are many other ways that you can minimize the spread of pests without the use of pesticides. In greenhouse and outdoor grows, growing specific types of plants around the cultivation area will attract both beneficial and predator bugs that will naturally control pest populations. Some plants that attract these bugs are: mint, peppers, and marigold. Beneficial and predator bugs, such as ladybugs, predator wasps, and predator mites can control unwanted pest populations in the area before they even have a chance to become a problem in your garden. Plants and flowers that attract bees, birds and insects will also create helpful biodiversity, making it more difficult for the unwanted pests to thrive. 

For indoor cultivation, it is imperative that you have your cultivation facility set up for a proper workflow. If you have pests you need to make sure you are not contaminating the rest of your facility when going from one area to the next. Make sure that you only go to contaminated areas at the very end of your day, and when you’re done working in that area, you must immediately exit the building. Do not ever walk back through the uncontaminated parts of your facility or the pests will spread quickly. 

When most people think of pests in their cannabis garden they think of the more common varieties: spider mites, russet mites, aphids and thrips. However, there are also soil-dwelling pests that can exist, without your knowledge. These will decrease the health and vigor of your plants, without you even knowing they’re there, if you’re not careful to check for them. Some of the soil-dwelling pests that plague cannabis plants are: root aphids, fungus gnat larvae and grubs. It is just as important to control the pests below the soil, feeding on your roots, as it is to control the pests that feed above soil on your plants. 

Maintaining healthy plants is essential to controlling pest populations, both on the foliage and below the soil. Healthy plants will have an easier time fighting off pests than unhealthy plants. Plants have immune systems just like humans, and the stronger the plant’s immune system, the more likely it will be able to ward off pests and diseases. Allowing a plant to reach its full potential, by minimizing pests, means your plants will also have a better quality, smell and flavor, not to mention a bigger yield. 

Worker safety, Regulation and REI times 

The application of pesticides requires certification from the state agricultural department. In certain situations, depending on the type of pesticide and method of application, a license may even be required. The application of pesticides without proper certification is against the law. Applying pesticides in a manner that is not in accordance with the label and instructions is also a violation of law. 

The proper PPE or personal protective equipment is required for anybody handling, mixing, or applying pesticides. Employees can be a liability to your company if they are applying pesticides improperly. Make sure you and your entire staff are well educated about pesticide use requirements and limitations, prior to usage, and that only a person properly certified is handling the mixing and application at your facility. 

After a pesticide is applied, you must abide by the REI or re-entry interval. This is the required time period limiting all workers from re-entry into areas where pesticides have been applied. This time period will vary depending on the type of pesticide used and the method of application. In some instances, pesticides applied in the last 30 days may require employee training before work can be done in those areas. 

The misuse of or improper handling of pesticides is not only unlawful and dangerous to human health, but can also cause environmental damage to waterways and wildlife. The direct effects of pesticides on wildlife include acute poisoning, immunotoxicity, endocrine disruption, reproductive failure, altered morphology and growth rates, and changes in behavior. Pesticides can indirectly impact wildlife through reduction of food resources and refuses, starvation due to decreased prey availability, hypothermia, and secondary poisoning. Section 1602 of the California Fish and Game Code governs requirements for permitting of any project where pesticides will be used, and strictly regulates the disposition of all waste and run-off. It is imperative to know the regulations and to abide by them, or heavy fines will ensue! 

Using Pesticides in a Regulated Market 

Knowing which pesticides you can’t use, to avoid failing mandatory state testing, is just as important as knowing which ones you can use safely to pass required testing. Most states with regulated markets have strict limitations on the pesticides that can be used in cannabis cultivation. Pesticide use in the cultivation of cannabis is the most strictly regulated in the agriculture industry; the pesticides allowed for use in cannabis cultivation are far more limited than any other crop. 

Just because a product is certified organic, that does not mean that it can be used, or that it is safe to be consumed or ingested. Oftentimes when cannabis flower alone is tested it will not fail or a show or detectable amount of pesticides or heavy metals. However, when that flower is turned into concentrates, banned substances are then detected in testing, leading to test failures. 

Cannabis cultivation that is located on land that was previously used for conventional agriculture, or located near vineyards or other agricultural crops that are heavily sprayed with harmful pesticides, run a very high risk failing testing. This is because of either spray drift from nearby agriculture, or residual pesticides and heavy metals left in the soil from previous crops that were using pesticides banned for cannabis cultivation. Accordingly, if you’re going to be growing outdoors or in a greenhouse, it is imperative that you get a soil and water test prior to cultivation, so you can determine if there is any potential for test failures due to pesticide or heavy metals in the soil or water in that area. 

Proper Application – Using the Right Tools in the Right Way at the Right Time 

One of the most important factors in pest management is proper identification of pests and proper application and coverage of pesticides. It does not require an entomology degree to identify insects, these days there is a lot of information online that can help you identify cannabis pests. Proper identification of insects can make the difference between success and failure. With a good eye and a microscope, if you do your research, you can control most insects in your garden. 

In order to control pests in your garden you must get proper coverage of the foliage of the plant when you are applying pesticides. There are different types of equipment that are commonly used to apply pesticides in cannabis cultivation: backpack sprayers, foggers, and airless paint sprayers are the most common. An alternative method involves using an automated dosing system such as a dosatron, which injects fertilizer or pesticides at a specific ratio into you water lines, allowing you to use only the exact amount of pesticide you need. That way you avoid wasting money on unused pesticides. It is also safer for employees because it minimizes employee exposure, since there is no mixing required, and it allows for a large volume to be sprayed, without refilling a tank or a backpack sprayer. 

No matter what you are using you must ensure you get the proper coverage on your plants in order to control pests. The temperature and humidity of your cultivation area, and the PH and temperature of the pesticide solution, 

all factor into the success of your IPM. For example, PFR 97 needs to be applied at a higher humidity range, around 70% to be most effective. In some areas this is not possible so repeated applications may be required to ensure the application is effective. A high PH or alkaline PH can cause alkaline hydrolysis which will make your pesticide solution less effective and will dictate how long your pesticides remain effective after they are mixed. It is therefore important to use your pesticide solution as soon as you make it; don’t let it sit around for long periods of time before use or it will be less effective. 

In cannabis cultivation there are two different primary growth cycles, vegetative and flower. These cycles require different IPM strategies. In general, during the flowering cycle, pesticides should not be applied after the second week, with some limited exceptions i.e. for outdoor cultivation there is a longer window to spray since the flower set takes longer than a plant being grown inside, or in a light deprivation greenhouse, where there is a 12/12 flowering cycle. 

For the vegetative (non-flowering) cycle, a strict rotation of foliage spray applications targeting not only pests, but also molds and pathogens, will be necessary to avoid a quick onset of infestation. Starting with an immaculate vegetation room is crucial to maintaining pest and mold-free plants in the flowering cycle. Preventative sprays that are safe for use include: safer soap (contact kill) for soft-bodied chewing insects; Regalia (biological control) for powdery mildew; and PFR 97 (biological control) for soft-bodied chewing insects. It is also helpful to spray kelp, which strengthens the cell walls of plants making the plant healthier, and thus enabling the plant to better defend itself from pests and diseases. Also, bascillus thuringiensis (BT), is useful to prevent or kill caterpillars. 

The best way to control a pest infestation in the flowering cycle is at the very beginning on day one. You must start aggressively, with a three-way control consisting of a contact kill and preventative during days 1-14; preventative and biological control during days 10-18; and then release predator bugs on day 25, for optimal results. Knocking back the population with an effective contact kill pesticide early on is essential to ultimately lowering populations throughout the grow cycle, so that you can spray a biological control to preclude them from returning, before you release the predatory bugs at the end of the cycle. 

Biological controls can take anywhere from 3 to 10 days before they are effective. Biological pesticides are selected strains of bacteria or fungus. When the plant tissue is eaten by a targeted pest, the bacteria kills the pest from the inside providing control without having to spray pesticides repeatedly. Predator bugs are the last line of defense, used in late flowering. They can be used indoors, outdoors, and in greenhouses. An example of a common predator bug is Amblyseius Californicus used to control low populations of spider mites, but there are many different varieties and they are specific depending on the type of pest population you seek to control. 

A common concern with the use of predatory bugs, is whether they will be present when the flowers are harvested. However, if there is no food for the bugs (i.e. pests) the predator bugs will leave in search of food elsewhere. Further, indoor predator bugs are usually very small in size and difficult to see to an untrained eye. It is very unlikely to see any signs of predator bugs near the end of the flowering cycle, or in the finished flower product. Even when using bigger predator bugs, the bugs will leave the plants when harvested and dried. 

Having pests can be very stressful. It is not uncommon to have bugs, pests, rodents, animals and birds cause damage in cannabis gardens. Making an informed decision based on science and not on unproven assumptions can determine how successful you are at pest management. There are many factors that go into pest management and no one situation is the same. You must be dedicated and consistent; pest management never stops. You will always have something ready to invade your garden. Prepare, plan, prevent, and repeat! 

Read other articles by David Perkins:

Large Scale Cultivation Planning – Important Factors to Consider

Thinking of hiring a cultivation consultant? Here’s what you can expect.

Five Factors to Keep in Mind When Entering the Regulated Market

dave headshot photo

David Perkins is a cultivation manager and advisor with over 20 years of experience in the grow room. From build out to cultivation, cloning to processing, he has done it all. David can help you succeed in the grow room, and save you money along the way. If you are considering hiring a consultant, please reach out and discuss the ways in which he can help you achieve your goals. You can reach David at marleybrutusdave@gmail.com 

Addendum To Planning Commission Agenda of March 26, 2020

***This updated Agenda was put out by El Dorado County 3/20/20

ADDENDUM

County of El Dorado Public Meeting Protocol In Response to Coronavirus COVID-19
California Governor Gavin Newsom issued Executive Order N-29-20 on March 17, 2020,
relating to the convening of public meetings in light of the COVID-19 pandemic.
At this time, the County of El Dorado Planning Commission meetings will be limited to
hear only those items related to immediate public peace, health, and safety issues and
Permit Streamlining Act items that cannot be delayed by Tolling Agreement, as provided
in the publicly posted agenda notice and until further notice.

Accordingly, and as included in the attached staff memo, staff will be requesting
continuance of item No. 4 to hear the Central El Dorado Hills Specific Plan project to a
date certain of April 23, 2020.

Pursuant to the Executive Order and to maintain the orderly conduct of the meeting, the
County of El Dorado will allow Planning Commissioners to attend the meeting
telephonically and to participate in the meeting to the same extent as if they were
present.

In order to ensure compliance with federal and state guidance regarding large
gatherings and social distancing and in accordance with State of California Executive
Order N-29-20, to provide the public with the opportunity to provide comments to the
Commission, the Commission is providing a call in number (please see below). When
you hear the item called that you wish to comment on, please call the number and await
your opportunity to speak. Your call will be muted upon joining the meeting and, when
you are notified that your call has been unmuted, you may speak for three minutes or as
otherwise provided by the Commission Chair. While speaking, please reduce any
background noise to ensure that your comments can be heard.

Dial in line – 1-669-900-9128
Meeting ID – 393 945 785

You may also view the meeting through the Granicus livestream
http://eldorado.legistar.com/Calendar.aspx.

Members of the public who wish to participate may appear at the public meeting held in
the Board Chambers and are to maintain a minimum six-foot buffer between you and
others, as suggested by the State Department of Public Health. Additional seating for
the Commission meeting is available in the lobby of Building A.

Planning Commission audio recordings, Agendas, Staff Reports, Supplemental Materials and Minutes are available on the internet at:
http://eldorado.legistar.com/Calendar.aspx

To listen to open session portions of the meeting in real time, dial (530) 621-7603. This specialized dial-in number is programmed for listening only and is operable when the audio system inside the meeting room is activated. Please be advised that callers will experience silence anytime the Commission is not actively meeting, such as during a break period.

The County of El Dorado is committed to ensuring that persons with disabilities are provided the resources to participate in its public meetings. If you require accommodation, please contact the Clerk to the Planning Commission at 530-621-5355 or via e-mail, planning@edcgov.us.

All Planning Commission hearings are recorded. An audio recording of this meeting will be published to the website. Please note that due to technology limitations, the link will be labeled as “Video” although only audio will play. The meeting is not video recorded***.

***The Planning Commission meeting of March 26, 2020 will be video recorded and available for Live Web Streaming on the internet at: http://eldorado.legistar.com/Calendar.aspx

The Planning Commission is concerned that written information submitted to the Planning Commission the day of the Commission meeting may not receive the attention it deserves. Planning Services cannot guarantee that any FAX, email, or mail received the day of the meeting will be delivered to the Commission prior to action on the subject matter.

For purposes of the Brown Act, Section 54954.2(a), the numbered items on this agenda give a brief description of each item to be discussed. Recommendations of the staff, as shown, do not prevent the Commission from taking other action.

Staff materials related to an item on this agenda submitted to the Commission after distribution of the agenda packet are available for inspection during normal business hours in Planning Services located at 2850 Fairlane Court, Placerville, CA. Such documents are also available on the Commission’s Meeting Agenda webpage subject to staff’s ability to post the documents before the meeting.

El Dorado County Planning Commission

Response to Proposed Amendments To Zoning Ordinance Section 130.14.260

***This position statement has been submitted to the Planning Commission as a public comment. For information on how to submit your own public comment please see my recent post El Dorado County Call To Action:

Dear Sir/Madam,

These are very uncertain times with the COVID-19 virus lurking and there exists the possibility that the public hearing, on the above-referenced cannabis ordinance changes, will not go forward in the usual public forum. It is my hope that a way can be found to address the legitimate concerns of responsible medical cannabis patients in El Dorado County and allow enforcement to move forward. Please accept this letter as my public statement concerning the proposed changes to the county’s personal medical cultivation ordinance.

Medical cannabis patients have a longstanding and trusted relationship with the Board Of Supervisors. Responsible patients worked with prior Supervisors to craft what has been known as Ordinance 5,000. Under the current code sections concerning personal medical cannabis cultivation, patients with a physician recommendation, or a cannabis caregiver [1], are allowed to cultivate up to 200 square feet of flowering canopy. Further, two or three patients, or a caregiver, are allowed to cultivate 400 or 600 square feet respectively, on designated parcels. These code sections have been in place, and apparently working for responsible patients or caregivers, for years. The murder of Deputy Ishmael has changed all things cannabis in El Dorado County.

It is apparent from reading the proposed changes to the county cannabis cultivation code sections that simplicity is the goal. State law, as passed by Proposition 64 in 2016, allows six (6) cannabis plants to be cultivated by an adult 21 or over per residence. State medical cannabis laws, specifically Health & Safety Code section 11362.77 [2], provide for a medical cannabis patient to cultivate six (6) flowering OR twelve (12) immature plants per patient. Local jurisdictions are authorized to establish guidelines that exceed these numbers. Further, a physician can recommend an increase in these numbers, but ultimately, the patient’s needs are what would control. What is being proposed is an elimination of any distinction between adult and medical cultivation and restricting plant numbers to six (6) per residence. Although a set number of plants will make it easier for law enforcement to determine if a cannabis garden is in compliance, there are legitimate, responsible medical cannabis patients that require more plant numbers to meet their reasonable cannabis needs. A compromise would seem in order.

Requirements for state commercial licensing, where medical cannabis patients are concerned, are defined in Business and Professions Code 26033 [3] . It is clear that a qualified patient who is cultivating for their own personal medical needs are exempt from state commercial cannabis license requirements. Additionally, legitimate caregivers may provide for up to five (5) qualified medical patients and be exempt from the requirement of state commercial cannabis licensing. Further, H & S Code 11362.77, supra, gives counties and cities the legal right and power to enact local guidelines that exceed the 6 flowering plant limit outlined in that code section.   

It is my experience that many, if not most, legitimate medical cannabis patients are able to meet their needs with six (6) outdoor, full sun cannabis plants. However, there are patients that cultivate cannabis cultivars, or cultivation techniques, that do not produce enough cannabis flowers from six (6) plants to meet their needs and therefore, additional plants are grown, within the 200 square foot allowance. I would urge the Planning Commission to consider an alternative of six (6) plants OR 200 square feet of flowering canopy if additional plants are needed. Additionally, I would urge the Commission to consider allowing up to three (3) patients, or a caregiver, to cultivate on a parcel under the present parcel zones listed in the personal medical cannabis cultivation standards. I would also urge the Commission to consider a process to apply for a waiver of these cultivation requirements that would allow input from recommending physicians and advise any government personnel investigating a parcel where a waiver is in place. Because of the sensitive nature of cannabis cultivation, especially under federal law, the specifics of any parcel with a waiver could be exempted from official requests for public information.

The murder of Deputy Ishmael has hit our entire community very hard, but nothing compared to his family and the law enforcement community. The medical cannabis community is particularly troubled since Deputy Ishmael was led to believe he was investigating a theft from a legitimate medical cannabis garden. The criminal actions of the property owner and the cartel enforcers are being prosecuted and let’s hope the system effectively deals with all of them. The entire county is encouraging effective enforcement of ALL laws that are broken during the illegal cultivation of cannabis. The medical cannabis community would like to see enforcement that affords legitimate patients the cannabis they need for their medical conditions. It is hoped that an effective county code can be crafted that accomplishes both.

Respectively submitted:

 

Dale Schafer Esq

Attorney at Law

 

[1]Health and Safety Code Section 11362.7 

(d) “Primary caregiver” means the individual, designated by a qualified patient, who has consistently assumed responsibility for the housing, health, or safety of that patient, and may include any of the following:

(1) In a case in which a qualified patient or person with an identification card receives medical care or supportive services, or both, from a clinic licensed pursuant to Chapter 1 (commencing with Section 1200) of Division 2, a health care facility licensed pursuant to Chapter 2 (commencing with Section 1250) of Division 2, a residential care facility for persons with chronic life-threatening illness licensed pursuant to Chapter 3.01 (commencing with Section 1568.01) of Division 2, a residential care facility for the elderly licensed pursuant to Chapter 3.2 (commencing with Section 1569) of Division 2, a hospice, or a home health agency licensed pursuant to Chapter 8 (commencing with Section 1725) of Division 2, the owner or operator, or no more than three employees who are designated by the owner or operator, of the clinic, facility, hospice, or home health agency, if designated as a primary caregiver by that qualified patient or person with an identification card.

(2) An individual who has been designated as a primary caregiver by more than one qualified patient or person with an identification card, if every qualified patient or person with an identification card who has designated that individual as a primary caregiver resides in the same city or county as the primary caregiver.

(3) An individual who has been designated as a primary caregiver by a qualified patient or person with an identification card who resides in a city or county other than that of the primary caregiver, if the individual has not been designated as a primary caregiver by any other qualified patient or person with an identification card.

(e) A primary caregiver shall be at least 18 years of age, unless the primary caregiver is the parent of a minor child who is a qualified patient or a person with an identification card or the primary caregiver is a person otherwise entitled to make medical decisions under state law pursuant to Section 6922, 7002, 7050, or 7120 of the Family Code.

(f) “Qualified patient” means a person who is entitled to the protections of Section 11362.5, but who does not have an identification card issued pursuant to this article.

[2] Health and Safety Code Section 11362.77 

(a) A qualified patient or primary caregiver may possess no more than eight ounces of dried marijuana per qualified patient. In addition, a qualified patient or primary caregiver may also maintain no more than six mature or 12 immature marijuana plants per qualified patient

(b) If a qualified patient or primary caregiver has a doctor s recommendation that this quantity does not meet the qualified patient s medical needs, the qualified patient or primary caregiver may possess an amount of marijuana consistent with the patient s needs.

(c) Counties and cities may retain or enact medical marijuana guidelines allowing qualified patients or primary caregivers to exceed the state limits set forth in subdivision (a).

[3] Business and Professions Code 26033 

(a) A qualified patient, as defined in Section 11362.7 of the Health and Safety Code, who cultivates, possesses, stores, manufactures, or transports cannabis exclusively for his or her personal medical use but who does not provide, donate, sell, or distribute cannabis to any other person is not thereby engaged in commercial cannabis activity and is therefore exempt from the licensure requirements of this division.

(b) A primary caregiver who cultivates, possesses, stores, manufactures, transports, donates, or provides cannabis exclusively for the personal medical purposes of no more than five specified qualified patients for whom he or she is the primary caregiver within the meaning of Section 11362.7 of the Health and Safety Code, but who does not receive remuneration for these activities except for compensation in full compliance with subdivision (c) of Section 11362.765 of the Health and Safety Code, is exempt from the licensure requirements of this division.

ANNOUNCEMENT – El Dorado County Board of Supervisors Meeting to Certify Commercial Cannabis Measures and Direct Office of Administration

EDC BOARD OF SUPERVISORS MEETING 
12/4/18 @1:00pm
“Chief Administrative Office recommending the Board: 1) Receive and file a presentation outlining next steps and an estimated timeline for the development of the County’s Commercial Cannabis Program, pursuant to voter-approved Measures (pending certification), and; 2) Adopt and authorize the Chair to sign Resolution 243-2018, amending the Authorized Personnel Allocation Resolution 132-2018, thereby adding one Principal Management Analyst allocation to the Chief Administrative Office to allow staff to adequate time toward the development of the Commercial Cannabis Program, while continuing to address other County priorities as well as manage the budget and operational responsibilities within the CAO’s office. (Est. Time: 30 min.)”

SB 829 – The Compassion License

What Is SB 829?

SB 829 (as amended) Senator Scott Wiener’s Cannabis: compassion care license.

“(1) The Control, Regulate and Tax Adult Use of Marijuana Act of 2016 (AUMA), an initiative measure approved as Proposition 64 at the November 8, 2016, statewide general election, authorizes a person who obtains a state license under AUMA to engage in commercial adult-use cannabis activity pursuant to that license and applicable local ordinances. The Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA), among other things, consolidates the licensure and regulation of commercial medicinal and adult-use cannabis activities.

This bill would establish a compassion care license under the act issued to an M-licensee who, for no consideration, donates medicinal cannabis, or medicinal cannabis products, to qualified medicinal cannabis patients who possess a physician’s recommendation. The bill would require the Bureau of Cannabis Control to issue and regulate the compassion care licenses.

(2) Existing sales and use tax laws impose a tax on retailers measured by the gross receipts from the sale of tangible personal property sold at retail in this state, or on the storage, use, or other consumption in this state of tangible personal property purchased from a retailer for storage, use, or other consumption in this state. Those laws provide various exemptions from those taxes.

This bill, on and after January 1, 2019, would exempt from those taxes the gross receipts from the sale in this state of, and the storage, use, or other consumption in this state of, medicinal cannabis or medicinal cannabis products that will be donated, for no consideration, to a compassion care licensee.

(3) The Bradley-Burns Uniform Local Sales and Use Tax Law authorizes counties and cities to impose local sales and use taxes in conformity with the Sales and Use Tax Law, and existing laws authorize districts, as specified, to impose transactions and use taxes in accordance with the Transactions and Use Tax Law, which generally conforms to the Sales and Use Tax Law. Amendments to the Sales and Use Tax Law are automatically incorporated into the local tax laws.

Existing law requires the state to reimburse counties and cities for revenue losses caused by the enactment of sales and use tax exemptions.

This bill would provide that, notwithstanding Section 2230 of the Revenue and Taxation Code, no appropriation is made and the state shall not reimburse any local agencies for sales and use tax revenues lost by them pursuant to this bill.

(4) AUMA imposes an excise tax on the purchase of cannabis and cannabis products, as defined, at the rate of 15% of the average market price of any retail sale by a cannabis retailer.

The bill would require that these provisions not be construed to impose an excise tax upon medicinal cannabis, or medicinal cannabis products, donated for no consideration to a compassion care licensee, as defined.

(5) AUMA imposes a cultivation tax on all harvested cannabis that enters the commercial market upon all cultivators. Existing law defines entering the commercial market to mean cannabis or cannabis products, except for immature cannabis plants and seeds, that complete and comply with specified quality assurance review and testing.

This bill would redefine entering the commercial market to mean cannabis or cannabis products intended for sale, in any manner or by any means whatsoever, for consideration. The bill would require that the cultivation tax not be construed to be imposed upon medicinal cannabis, or medicinal cannabis products, donated for no consideration by a cultivator to a compassion care licensee or to a cannabis retailer for subsequent donation to a compassion care licensee.

(6) The Control, Regulate and Tax Adult Use of Marijuana Act, an initiative measure, authorizes the Legislature to amend the act to further the purposes and intent of the act with a 2/3 vote of the membership of both houses of the Legislature, except as provided.

This bill would declare that its provisions further specified purposes and intent of the Control, Regulate and Tax Adult Use of Marijuana Act.”

This Bill is supported by, in part, by the California Compassion Coalition

Who Is The California Compassion Coalition?

The California Compassion Coalition is comprised of a number of known compassion organizations who have functioned by giving donated cannabis medicine to indigent cannabis patients across the State of California. The organizations, who make up the California Compassion Coalition are as follows:

Weed For Warriors Project

Caladrius Network

WAMM

East Bay Canna Compassion

Sweetleaf Collective

Operation EVAC

Magnolia Wellness

How YOU Can Help

 

One battle has been won but we have many more to go. SB 829 was voted out of the Committee on Business and Professions, on Monday. It passed with and 11-1 vote. Next, we move onto the Committee on Revenue and Taxation and WE NEED ALL HANDS ON DECK.

Revenue and Taxation Committee

Monday, June 25, 2018

1430 hours (2:30pm)

California State Capitol – RM 126

Debriefing Video

URGENT CALL TO ACTION

Below you will find a sample letter of support for the Compassion Bill, SB 829. We need this post to not only go viral, but we need that exposure to be converted into emails to Senator Wiener’s office by 5pm today. Cannabis and non-cannabis companies carry the most weight with legislators but we should also encourage letters to be sent from those the most affected by the current lack of compassion embodied in the current regulations.
It will take a village to get this bill passed. We really need to step away from the circular firing squad at least until 5pm today. In order to ensure we all focus our energy here for the next 5 hours, we will not be allowing any other posts through. I hope we can lick our wounds and rise up so that the sickest of the sick, the neediest of the needy, are not the recipients of all of our industry’s current resentments. Please let our industry put all of our hurt feelings aside and rise up to honor what this movement has always been about, compassion.
*****THIS CONTENT BELOW NEEDS TO BE SENT IN A PRINTABLE DOCUMENT.
This means that the support needs to come in the form of a Word Doc, or a PDF. The sender will need to date the letter, add in a business logo (if one is available), a digital signature, and the supporter’s contact information.
****INSERT BUSINESS LOGO
June 11, 2018
Dear Senator Wiener,
On behalf of _______ I write to express our support for Senate Bill 829 (Wiener), which would exempt certified compassion care programs from paying excise and cultivation taxes on cannabis that they give away to compassion use patients, thereby allowing them to restart this service without facing prohibitive costs. Exempting the cultivation and excise taxes from the passage on to qualified compassion care programs will allow these organizations to resume donations of medical cannabis that vulnerable patients rely on to manage their debilitating symptoms.
In 1996, California passed Proposition 215, which allowed individuals with certain chronic medical conditions to procure medical cannabis. Following the enactment of Proposition 215, donation-based compassion care programs emerged to meet the needs of individuals who had a physician’s recommendation but also needed help accessing medical cannabis.
The enactment of Proposition 64 in 2018 placed new taxes on all recreational and medical cannabis. While compassion care programs do not operate in the commercial market since no cannabis is bought or sold, ambiguous drafting, unfortunately, does not explicitly exclude them from these taxes. These donation-based programs cannot afford the new taxes attached to cannabis and most have been forced to close their doors. While Proposition 64 did not intend to cut off medical cannabis to these compassion use patients, current policy has forced too many vulnerable people into the unregulated black market.
To rectify this situation, SB 829 would exempt qualifying compassion care programs from the cultivation and excise tax enacted by Proposition 64. After a compassion care program is certified by the state, they would receive a new license exempting them from the cultivation and excise taxes. Doing so will allow them to resume the donations of medical cannabis that compassion use patients rely on to manage their debilitating symptoms.
These programs are essential to the well-being, mental health, and overall quality of life for chronically ill patients. For these reasons, ______ supports SB 829 and requests an “AYE” vote on this important legislation.
Thank you,
****DIGITAL SIGNATURE.  ______________
****SENDER’S CONTACT INFORMATION
cc: Senator Scott Wiener, (11th District)”
COPY & PASTE the above text along with your business or personal name, sign and send to……

IS CBD LEGAL? DEPENDS ON WHO YOU ASK

IS CBD LEGAL? DEPENDS ON WHO YOU ASK

By: Dale Schafer, Esq.

One of the hottest dilemmas, in the cannabis industry, these days involves the relative legality of CBD. The answer involves the DEA, the Farm Bill of 2014, the myriad state laws, on the subject, and a history of ambiguity in America over jurisdiction, and control, over products that are consumed by humans for benefits to health.  Understanding this quagmire is helped by a glance back in history to see how we all got to this difficult place.

The 19th century was dominated by unrestricted capitalism in many commodities, including drugs. Opium had been known, for millennia, as a pain medication and pleasure producer, but it had a dark side. In 1805 the German pharmaceutical giant Merke isolated Morphine from opium. The British were very successful purveyors of opium and forced the poison onto the Chinese in several Opium Wars in the 1840’s. Opium tincture (laudanum) was a widely available medical, or whatever, product in stores across America. The Civil War brought widespread use of morphine, through hypodermic syringes, and it became a drug problem for many veterans of the conflict.

Coca wine was available circa the war, but it was refined to a crystalline product with cocaine hydrochloride. President Grant used the substance to help with the writing of his memoirs before he died from throat cancer. Doc Pemberton concocted Coca-Cola, from coca leaves, to help him treat his morphine addiction. It was labeled a “soft drink” because it contained no alcohol and was believed, in dry Atlanta, to be less harmful than liquor. By the time Sigmund Freud was treated for cocaine addiction, it was becoming apparent that cocaine had a dark side.

Indian hemp was introduced into European society when Napoleon’s troops returned from the near east with hashish. Dr. O’Shaughnessy brought Indian hemp medical products to England in the 1840’s. It’s medical benefits were widely spread through medical societies and products were developed, principally based on alcohol extraction. The second half of the 19th century saw a rapid expansion of cannabis preparations here in America.

Morphine, cocaine and cannabis were not the only substances that were put into “patent medicines”, but they were the big ones. Alcohol was the solvent, and an ingredient, in many of the medicines. As you probably recall, alcohol was becoming quite the moral dilemma as the end of the 19th century approached. Traveling “medicine men” mixed up their special elixirs and sold them to rural citizens. These medical products, along with many other commercially prepared products, eventually appeared in the Sears and Roebuck catalog to be shipped in plain wrapping to your home. When Bayer developed Heroin, in the late 1890’s, the nation was seemingly flooded with snake oil and “addiction” was part of the national discussion about safety in consumer products.

Not to be forgotten was the invention of nutritional products to bring people back to health. Health sanitariums popped up and inventors like Kellogg developed food products (I’m thinking breakfast cereals) to bring people to optimum health. The health claims of these food products were puffing on steroids and their safety was never guaranteed. The food supply was increasingly uncertain and there were few laws to protect consumers. This situation had gained the attention of Congress and when Upton Sinclair published “The Jungle”, about the meat packing industry, Congress passed the Pure Food and Drug Act of 1906 (PFDA). The act required truthful labeling of drugs (morphine, cocaine, chloral hydrate and cannabis) and alcohol and is still considered the beginning of the FDA. However, those products that were not considered drugs were not treated as harshly. This would turn out to be the beginnings of the modern battle between drugs and nutritional supplements.

Over the decade that followed the PFDA, morphine was criminalized. The International Convention of 1912 lead to the Harrison Anti-Narcotic Act of 1914 and federal drug prohibition was off and running. The Treaty of Versailles contained language to prohibit morphine and opium, as did the League of Nations in the 1920’s. States began to enact laws to control poisons and Boards of Pharmacy evolved in all states. As drugs were increasingly controlled, nutritional supplements fought hard to avoid the label of drug. Food, which included supplements, were under the control of the US Department of Food and Agriculture. Consumer safety for foods was viewed differently that the control mechanisms for drugs to protect medical consumers. In the 1930’s Congress added cosmetics to the FDA and today we operate under the FDCA.

America’s attack on cannabis took racial overtones as “marijuana” entered the lexicon of prohibition. When the Mexican Civil War sent refugees fleeing north after 1910, cities and states began to enact prohibitions against marijuana use, but medical use of cannabis was allowed. After alcohol prohibition ended in the administration of FDR, there was increasing pressure for national marijuana prohibition. In 1937, Congress nefariously passed the Marijuana Tax Act and even medical use was made effectively impossible. The Tax Act lasted until 1969 when Tim Leary got SCOTUS to find it unconstitutional. Congress took up the issue of drugs in the Omnibus Controlled Substances of 1970 (CSA). As you know, marijuana was placed in Schedule 1 of that Act and was completely outlawed, except with federal permission. An unfortunate situation that continues today.

In 1994, Congress passed the Dietary Supplement Health and Education Act. This act had jurisdiction over products taken orally for supplementing the health. Claims of health benefits were required to prove their claims or cease advertising the benefits. It also put the burden on the FDA to prove a product, or ingredient was to be treated as a drug rather than a supplement. Ingredients like ephedra lost the battle with the FDA and recently, kratom has fallen under such scrutiny. The industry that produces and markets food supplements is vast, politically connected and well funded. If there is a straight-faced argument to keep a supplement a food rather than a drug, massive political pressure can be brought to bear.

MARIJUANA AS A LEGAL TERM IS A PROBLEM

Prior to Dr. Machoulam’s discovery of THC in the early 1960’s, science did not know what was in cannabis that made it psychoactive. By that time, marijuana was the legal term, used by the federal and state governments, to describe the cannabis plant with psychoactive and medical benefits. Once this cannabinoid was discovered, definitions were developed to distinguish between “marijuana” and “hemp”. THC concentration defined the two terms and the figure of 0.3% THC was the line. Less was hemp and more was marijuana. When Congress enacted the CSA, marijuana was defined to include all parts of the cannabis plant, growing or not, seeds, resin extracted, all salts, compounds, derivatives and all the language thought to cover every possible product from the plant. The CSA also excluded the stalks, fiber, oil cakes made from seeds, but resin extracted from stalks was not excluded. (21 USC 802). The use of the term “resin” is a problem in today’s question about hemp derived CBD.

The cannabis plant produces cannabinoids. Prior to the scientific definition of THC, the term marijuana was all inclusive, even though the non-psychoactive phenotypes were defined as hemp for practical purposes. WWII brought hemp production back for a short period of time, but amnesia was imposed for several decades. Hemp and marijuana were treated effectively the same. They were illegal.

As research continued into the multitude of cannabinoids produced by the cannabis plant, it became possible to isolate the cannabinoids. CBD was able to be looked at separately and investigators began the process to identify which of the cannabinoids were responsible for the many medical effects described by patients. Research also proceeded into the health and nutritional benefits of hemp seeds and the oil derived from them. Dating back, to the 1937 Tax Act, whole seeds needed to be rendered sterile. Seed cake was the base for nutritional and health products. It was also determined that some varieties hemp had relatively more CBD than others. It was possible to extract, and isolate, CBD as a commercial by-product of hemp cultivation and processing. Herein lies the present reality that is creating today’s uproar.

The use of the term “resin” in the CSA demonstrates a desire to prohibit, and control, cannabinoids as a drug. The Farm Bill of 2014 was enacted to allow research projects, under state law, to develop agricultural products from hemp. Several states, most notably Kentucky, have moved forward with increasing commercial production of hemp products. As more acres of hemp are grown, increasing amounts of hemp flowers were available and CBD could be extracted commercially. Over the last two decades, CBD products have become increasingly popular and the source of CBD began to be hemp. Domestic hemp production was not enough to cheaply meet demand so international sources were sought out, think China. Many that were in the CBD trade began to believe that CBD was not a drug covered by the CSA, but an industrial hemp product or a nutritional supplement, outside federal criminal enforcement.

The DEA did not suffer from this belief. In early 2017, a statement was issued by the DEA that clarified, at least in their minds, that CBD was a schedule 1 drug under the CSA and that the Farm Bill did not allow CBD production since it was not an agricultural product, but a drug product. Litigation was started to fight this ruling, but the case was dismissed. In December of 2017, the DEA announced a new category of marijuana extract that covered CBD, and all cannabinoids. As far as the federal government is concerned, CBD is treated like THC, it’s all marijuana. It’s not that simple though.

Many states that have legalized cannabis specifically allow, or restrict patients to, CBD as a state legal medical product. If the CBD is produced within the lawful state, it is only the federal government that would take enforcement action. Unfortunately for the federal drug establishment, there aren’t enough enforcement officers to stop CBD as a medical product. CBD products are seemingly available everywhere and states appear to be inclined to not enforce. This creates a situation that defies understanding, logic or currently workable solutions.

To make matters even more difficult, hemp probably is not the best source of CBD for human consumption. The cannabis plant will extract many toxins from the soil and it takes acres of hemp to commercially produce CBD. The toxins can show up in the CBD and that is problematic for consumer safety because of a lack of testing. Additionally, the cannabis chemotypes that produce high concentrations of cannabinoids, traditionally called marijuana, include a fuller profile of cannabinoids and contain terpenes. Most cannabinoid experts, I’ve talked with, believe that full spectrum cannabinoid products are medicinally superior to hemp derived CBD. This particular topic cries out for research to determine the best source for medicinal products high in CBD.

Now that I’ve said all that, the central question remains difficult to answer. The DEA considers CBD to be prohibited as a schedule 1 drug and not allowed to be produced from hemp, since it’s not considered an agricultural product. If CBD is shipped through interstate commerce, the federal government may decide to take some enforcement actions to send a message. However, for all practical purposes, the feds can’t stop the CBD trade. If your state is allowing CBD production, odd are you’re safer, but not totally safe. How far one goes with CBD production and sales, depends on one’s willingness to accept the risk. Of course, that’s been the theme involved in cannabis production for many decades now. Welcome back to the wild west.  

El Dorado County – Seven Ad Hoc Cannabis Meetings Announced

Seven Ad Hoc Cannabis Meetings Announced

Seven Ad Hoc Cannabis Meetings Announced

Department:
CAO
Date:
3/5/2018
Contact:
Carla Hass
Phone:
(530) 621-4609

(PLACERVILLE, CA) – The following seven meetings of the El Dorado County ad hoc Cannabis Committee meeting are scheduled between today and May 14th.

WHAT: Ad hoc Cannabis Committee meetings

WHEN: All meetings are from 3:00 pm-5:00 pm

  • Monday, March 5th (Outdoor/Cottage)
  • Monday, March 12th (Indoor/Mixed Light/Cottage)
  • Monday, March 19th (Dispensaries/Deliveries/Distribution)
  • Monday, April 23rd (Microbusiness/Nurseries/Testing)
  • Monday, April 30th (Manufacturing)
  • Monday, May 7th (Tax Rates/Funding)
  • Monday, May 14th (Administering a Program/What does it look like?)

WHERE: All meetings will take place at the County Board of Supervisors Chambers 330 Fair Lane Placerville, CA

WHO: Members of the ad hoc Cannabis Committee, Supervisors Michael Ranalli and Sue Novasel
El Dorado County Staff
Members of the public are invited to attend

UPDATE – Successful Cannabis Business DIY Program

Cannabis Regulations

Workshop Overview

 

  1. Regulations Overview and Local Approval (Approx 3 hours)
  2. Temp. License Application Process – Includes information about all required elements of the temporary license application for the BCC, CDFA and/or CDPH (Approx 3 hours)
  3. Annual License Application 1 – Business Plan & Description, Business Formulation Documents, Fictitious Business Name Process (Approx 3 hours)
  4. Annual License Application 2 – Lists of Funds, Lists of Loans, Lists of Investments, Lists of Gifts, List of every individual with financial interest (approx 3 hours)
  5. Annual License Application 3 – List of every owner, Livescans, Evidence of Legal Right To Occupy, Evidence of Premises Compliance, Labor Peace Agreement (Approx 3 hours)
  6. Annual License Application 4 – Seller’s Permit, Proof of Bond, Standard Operating Procedures (Approx 3 hours)
  7. Annual License Application 5 – Cultivation Plan, Water Board Regs, Prohibited chemicals, heavy metals, etc. (Approx 3 hours)
  8. Annual License Application 6 – Track & Trace, Supply Chain, (Approx 3 hours)
  9. Maintaining Your License – Liability Issues, Potential hurdles, What to watch out for, Maintaining your License. (Approx 3 hours)
  10. Having a successful business – Your website, marketing your business, setting yourself apart in the industry, Branding, Trademarking (Approx 3 hours)

 

*** Between Workshops 2 & 3 there will be a week off to complete your TEMPORARY STATE APPLICATION and sit down with us to review before submitting

OR

Bank that 2-hour appointment for when you are ready to do so

AFTER WORKSHOP 10 THERE WILL BE ANOTHER OPPORTUNITY TO HAVE A 2-HOUR APPOINTMENT TO REVIEW YOUR ANNUAL APPLICATION 

OR

BANK THAT APPOINTMENT AS WELL

*** Program subject to change based on changes made by the State regulatory agencies

For more information go to Successful Cannabis Business DIY Program

6 Ways to Beat a Local Cannabis Ban

PREVIOUSLY PUBLISHED ON LEAFLY.COM

When California’s first adult-use cannabis stores opened on Jan. 1, many of the state’s residents realized they would be shut out. They weren’t happy. Residents of Orange County, where all but one city, Santa Ana, has banned retail sales, shook their heads in disgust. “Orange County will have no retail stores?” one Leafly reader wrote. “What a f joke OC is.”

If cannabis is legal statewide, how come you can’t buy it in your own county?

It’s not just Newport Beach turning its nose up. Retail cannabis may be legal statewide, but California law allows local municipalities to severely limit or ban cannabis companies. Cannabis is banned entirely, for example, in the cities of Redding, Pomona, Crescent City, and Santa Monica, as well as most of Orange, San Bernardino, and Ventura counties. That’s just the start of a long list.

These local bans aren’t entirely unusual—and they usually don’t last forever. During the early days of legalization in Colorado and Washington, many municipal councils enacted bans out of fear and ignorance. Suburban towns shut out retail storefronts, for example, nervous that legal sales could bring more trouble than good. Meanwhile, most local politicians voting on those bans knew very little about cannabis and the legal industry around it. Many bought into old stereotypes about weed, stoners, dealers, and crime.

When Oregon legalized, we saw the same thing. Today, California and Massachusetts are in the thick of it.

Here’s the rub: Many of the communities that initially enacted bans were themselves not anti-cannabis. Some voted overwhelmingly in favor of statewide legalization. In many cases, bans were the response to the vocal outcry of a relatively small number of concerned citizens. In others, local governments were simply unfamiliar with legal cannabis or felt unprepared to appropriately regulate it.

The good news is that bans can be reversed. But they don’t overturn themselves. Here are a few ways you can start opening minds and changing votes.

1. Work With an Advocacy Group (but Not Always)

You don’t need to reinvent the wheel. Connect with an advocacy organization, such as your state chapter of NORML, the National Organization to Reform Marijuana Laws. They have a deep well of knowledge, resources, and experience with the local political landscape. The Marijuana Policy Project (MPP) also has a “Block the Ban” initiative up and running; they’ve already successfully overturned the ban in one Massachusetts town.

Connecting with and joining NORML or another group doesn’t mean you become their official representative. Politicians sometimes tune out advocacy groups because they see them as “special interests.” That’s not entirely fair, but it is what it is. If you introduce yourself to a local elected official as a constituent and concerned citizen—or a concerned parent or business owner—you may get more traction.

2. Get Out and Meet the Man

It’s easy to protest The Man and his cannabis ban. But there is no Man. In most cases, there are well-meaning but fallible men and women who haven’t encountered a local constituent eager to talk with them as a cool-headed legalization advocate. (Okay, not all politicians are well-meaning. But you’d be surprised.) There are a number of entry points:

  • Sidle up to your local city council member before or after a weekly council meeting. Introduce yourself, give them your elevator pitch, and tell them you’d like to talk with them further about the issue.
  • Use the New Business or public comment period at the end of the council meeting to air your concern.
  • Write a letter to one or all of the council members.
  • Send a version of that letter to the local newspaper. Call out supporters and opponents of the ban by name.
  • Post about the issue on social media. Again, call out officeholders by name, and consider tagging them or creating a hashtag. You will get their attention.

Before you go: Have your clear, concise talking points ready to deliver. See #3 below.

3. Arm Yourself With Facts

“One of the biggest challenges we as a legislative body are going to face,” Indiana state Rep. Jim Lucas, a medical marijuana legalization supporter, recently told his colleagues, “is coming through all the smoke, all the fear-mongering, all the stigma, the ignorance.”

Luckily, there’s a lot of good evidence that a legal, regulated market works far better for everyone than prohibition.

There’s no shortage of misinformation when it comes to cannabis. Like with a lot of issues that people feel strongly about, it’s common for opportunists to seize on information that supports their preconceptions rather than digging deeper into the issues. Luckily, there’s a lot of good evidence that a legal, regulated market works far better for everyone than prohibition. So when you engage with elected officials, come armed with facts.

The reasons you support legal cannabis might not be reasons your neighbors or your council members find persuasive. If you’re talking to an elected official, learn about the issues that drive them customize your pitch. If you’re talking to a liberal Democrat, lead with social justice concerns. A conservative Republican may be more amenable to a pitch about personal freedom and the waste of taxpayer resources on nonsensical cannabis arrests. Centrists might appreciate the extra revenue to shore up budget holes. This article has a number of further tips.

4. Bring a Positive Proposal to the Table

Guess who writes a lot of the first drafts of legislation? Not the office holder! Seriously. Do some research. Find copies of the local cannabis ordinances adopted by towns and counties similar in size and culture to your own. Present the entire piece of legislation to your local office holder. They are busy, and they’re working on issues ranging from potholes to violent crime. The more work you can do for them, the more likely they’ll seriously consider introducing your measure.

5. Argue From a Position of Strength

Did your county, district, or town vote in favor of statewide cannabis legalization? Well then why is the local town council disrespecting the clearly expressed will of local voters? Do they think the voters are confused children?

70% of Marin County, CA, voters embraced legalization. And yet the county council banned it. That’s got to change.

When you approach an elected official, do so with the knowledge of how your district voted on the state’s ballot initiative. (If you’re working in a county that voted overwhelmingly against legalization, you will want to have an answer to the inevitable question. Often that’s where the experience of people from NORML and other groups comes in handy.)

For example, the map below shows how California counties voted on Proposition 64, the 2016 statewide measure to legalize the adult use of cannabis. Check out Marin County in the map below. Marin embraced legalization with 70% of the vote. Three months later the Marin County Board of Supervisors banned all cannabis-related business activity in unincorporated Marin. There’s your conversation starter, Concerned Marin Constituent.

6. Run Your Own “Beat the Ban” Initiative

When local elected officials won’t listen to your well-reasoned argument, you still have Option B: The local initiative. Find out how to get a local initiative on the ballot in your area, if it’s an option (different jurisdictions often have different rules). Reach out to groups like NORML and the Marijuana Policy Project, which have a lot of experience running and winning these “Beat the Ban” measures.

Local voters love to cast their ballots in favor of these initiatives, because they’re kind of like telling local politicians: “Yes, I did actually mean it when I voted for statewide legalization. It wasn’t a mistake.”

Often it’s just a matter of persistence. In Oregon, roughly a year after legal sales began, 15 municipalities that initially prohibited cannabis businesses voted to undo those bans. And in Massachusetts, which is readying for adult-use sales to begin this summer, a growing number of communities are voting to allow cannabis businesses, bucking an early trend of local bans.

“We got a lot of support from people who don’t use cannabis, but might want to someday,” Scott Winters, an Amesbury resident who spearheaded opposition to an anti-cannabis referendum that was defeated in November by a nearly 2-1 margin, told the Associated Press. “From users to non-users to just folks who want revenue for the city, we had a lot of support.

Bruce Barcott & Ben Adlin

Bruce Barcott is Leafly’s deputy editor. He is a Guggenheim Fellow and author of Weed the People: The Future of Legal Marijuana in America. Ben Adlin is an editor at Leafly who specializes in politics and the law. Together with editor Dave Schmader, they host Leafly’s weekly politics podcast, The Roll-Up.

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