To: Steve Marks, Executive Director

Recreational Producer Authority to Operate Business: while undergoing change in existing license.

According to ORS 845-025-1175 and 845-025-1160: While a licensee is undergoing changes in location, business structure, modifications that require additional security, or canopy size, that licensee must halt business operations until the commission has approved the change in structure.
Due to the delays experienced and Producer's lengthy wait for approval, we petition for an amendment to the current laws in place; allowing Temporary Authority to Operate while undergoing these changes.
Proposed Amendment: Granting Temporary Authority to Operate to Licensed Producers while undergoing changes in business structure, location, canopy size, and additions to site if the necessary paperwork is submitted 30 days before change and inspection of change is approved.

Why is this important?

In the production of any crop, time not cultivating has considerable costs and hinderance. It is therefore important to understand the difference between Producer's business than that of retail, extract, and cannabinoid. In production, if a licensee is unable to cultivate mothers and propagate for the upcoming season or indoor session, the halt of operation is not restricted to the time of delay, but an entire season or cultivation cycle. Timing is intrinsic to farming, and thus this should be given precedence to producers to ensure optimal production and consistency.

The current rule in place does not give producers beneficial allowance in times of change or business growth, which causes serious impediment to producers business cycles.

I personally have been affected by this rule for 60 days and counting, which carries considerable setbacks to the entire year of propagation.

It is my goal to draw attention to issues that licensees experience and to assist in changes that not only aid producers but the entire production towards a more consistent marketplace.