Please create limited federal regulations that do not place additional requirements or burdens on farmers. We also encourage USDA to provide flexibility to states to regulate hemp production as they see fit as long as they are meeting the minimum requirements. Most of all we urge USDA to treat hemp like any other crop. Congress defined hemp broadly in the 2018 Farm Bill and we urge USDA to embrace and accept this definition. We are especially concerned about maintaining the Farm Bill definition

Given the previous attempt to modify and restate the 2014 Farm Bill definition of industrial hemp in the “Statement of Principles on Industrial Hemp.” We urge USDA to immediately begin certifying hemp crops and hemp products that meet all requirements as organic under the National Organic Program (NOP). This includes hemp crops grown for flower and hemp extracts which USDA previously stated it would not certify. Guidance in NOP 2040 treated American grown hemp differently than hemp grown outside the U.S. American farmers and manufacturers should be treated the same as those in other countries by the NOP. USDA supported the development of hemp varieties for American farmers from 1903 until 1935 under researcher Lyster Dewey. Those genetics have unfortunately been lost and there is an urgent need for high quality certified hemp varieties. It is critical that American breeders be empowered to develop hemp that will meet the needs of today’s manufacturers. We urge USDA to support and encourage private and university hemp research. Hemp research is now authorized under SEC. 7129 Supplemental and Alternative Crops and SEC. 7501 Critical Agricultural Materials Act and we urge USDA to prioritize hemp research funding. We also request that USDA welcome hemp germ plasm submissions at the National Center for Genetic Resources Preservation. We also request that USDA confirm that it will accept hemp submissions for Plant Variety Protection. This is critical to encourage breeders to invest the time in developing new and valuable hemp varieties. Another important area is the development of sampling procedures and testing requirements. We urge USDA to adopt a sampling procedure that collects samples from a minimum of 30 plants per distinct plant variety and collects significant portions of the top, middle and bottom of the plant. Sampling should begin 2-3 weeks after flowering in order to allow for harvest at the ideal time after receipt of the test results. USDA should allow states to utilize their preferred testing method as long as they can consistently reproduce accurate results. Requiring a specific testing method may place an unfair burden on states. The 2018 Farm Bill authorizes crop insurance for hemp crops. We encourage USDA Risk Management Agency (RMA) to seek input from farmers and the hemp industry prior to approval of a hemp crop insurance product. We also encourage RMA to encourage insurers to submit proposals to USDA for consideration. Vote Hemp has collected data from state departments of agriculture and published an annual Hemp Crop Report for the past 3 years (attached). We encourage USDA to require states to collect and report statistics on acreage licensed and planted as well as other useful data that USDA normally collects on crops. We also would like to share a 2018 Farm Bill Policy Guide and Model Hemp Production Plan (attached) that we developed along with the Vicente Sederberg law firm. This production plan has been shared with states regulators and legislators in order to encourage states to prepare to implement state hemp farming plans under the provisions of the 2018 Farm Bill. We thank USDA for hosting the session and welcoming feedback from the industry and farmers. I look forward to the USDA ensuring that regulations encourage the development of the market for hemp and hemp products.

Thank you.

--Mark M Giese

Wisconsin