I would like to submit the following comments for consideration by the USDA as it promulgates regulations for hemp.

I strongly agree with the observation made by Secretary Perdue about the nascent problems that could [*are* developing] when producers move too quickly, especially without well-defined and well-understood markets, let alone a lack of processing infrastructure and growing/varietal protocols required to serve those markets. His statement is as follows:

'Perdue stated "we would love to think that the potential for hemp agriculture is as great as the anticipation is but that remains to be seen. We want to proceed slowly to make sure we don't have another situation where our productive farmers overcompensate and blow out a market before it gets going."

Concerns about speculative growing of a new crop like hemp are legitimate. Hemp is not yet a commodity and there are limited processing facilities. We strongly recommend that farmers start small in their first year and secure a contract with a vetted buyer. There is a learning curve to grow hemp and you also may need to try several varieties to determine which one works best in your specific conditions.' 

Hemp represents myriad challenges as well as opportunities, given the broad potential uses for the plant and its numerous parts. However, most of those end uses dictate that particular seed varieties, varying growing conditions, and further processing be rigorously followed in order for the crop to be suitable/acceptable and pass tests for those sought after constituents/characteristics. 

I am very interested in assisting with the development of varietal, growing and harvest/handling protocols, as well as commercial availability of agricultural and processing equipment unique to the handling of hemp to facilitate its cultivation; and lastly, organizing and matching growers with market sector players. I am willing to collaborate with the USDA to share those findings as it could inform regulatory matters. 

I'm beginning discussions with the State of Montana Department of Agriculture, in particular, out of personal interest and since the 2018 growing season has demonstrated that its farmers are aggressively cultivating hemp regardless of stable market outlets. However, it is also recognized that approved seed varieties are limited under the 2014 Farm Bill protocols and do not necessarily align with the crop characteristics needed to supply/respond to current market trends and opportunities. This is just one of many examples of issues that need to be addressed through market study and experience. 

There is great advantage in having a period of time in 2019 for states to formulate future-looking regulatory procedures that anticipate scenarios of varietal testing (and possibly exceeding the the limits for THC content inadvertently), as well as taking into account that the chemical constituency of this plant enables those very same constituents to be further processed in order to become compliant compounds/products.

One example of this is if a hemp crop contains excessive THC, it is economically advantageous to follow further process protocols instead of the state or governing body proceeding to confiscate and destroy the crop. There are relatively inexpensive and simple steps that the producer can take to harvest or separate and expose the flower portion of the plant to UV light for a reasonable period of time to allow the oxidation of the THC in order to chemically convert it to the non-psychoactive cannabinoid CBN. 

CBN is currently being tested/studied in the medical community for its many potential medicinal properties (particularly for sleep disorders, antibiotic properties, hormone-regulating and analgesic properties to name just a few) that function distinctly differently from THC or CBD and could prove to be of equal or greater market value than that of CBD at present. Additionally, the other parts of the plant (not containing excessive THC) can be sold or processed for other market outlets.

Thus, instead of a financial loss to the producer and regulatory enforcement cost to the governing body, the crop could be re-tested at producer expense, cleared, and then marketed at potentially greater value. 

It would be prudent to build in some mechanism for the expedient modification of regulatory procedures as these sorts of situations become known, understood, and remedied to have positive impacts rather than negative while ensuring that this burgeoning industry can become established with as few setbacks as possible. 

I want to sincerely thank the USDA for its commitment to re-introducing industrial hemp back into US agriculture and allowing it to be a strong contributor to the emerging bio-economy.

Loraine Green, Principal

Regenerative Systems Design/Development