April 11, 2022
It is with great urgency that we write to you again, following up on our letter of January 31, 2022, on Metro Vancouver’s proposed emission regulation changes. We understand from conversations with Metro Vancouver staff that Metro Vancouver would seek to put these regulations in place before the summer. We attach for your reference our response, dated January 31, 2022, to the proposed potential regulations.
We respectfully urge Metro Vancouver to abandon the proposed regulations.
As a start, any proposed regulations should be based on established science and evidence. Metro Vancouver needs to better understand the impacts (if any) of cannabis volatile organic compound (VOC) emissions. There is no agreed upon scientific evidence to demonstrate that VOC emissions cause, or have the potential to cause, any measurable human health impacts. Inclusive of further scientific studies becoming available, we strongly support the need for further analysis.
Furthermore, as regulations linking VOCs to odour impacts, it is important to note that cultivators in the region already implement best-in-class odour mitigation technologies and there has been a material drop in the number of odour complaints and complainants related to our operations over the last year.
Metro Vancouver is the only jurisdiction in Canada considering implementing these changes. These revised regulations put the region at a disadvantage and create serious impediments to cultivation, making it more attractive to operate elsewhere. BC is already marred with consolidation and insolvency. Remaining producers already face tremendous challenges, and these proposals will put a serious chokehold on the industry in this province.
Cannabis Cultivators of British Columbia (CCBC) members contribute well over $158M in annual revenue, over $52M in excise taxes, and more than 1,000 jobs to the region.
You may not be aware that cannabis production contributes more to Canada’s agricultural GDP than animal production, meat product manufacturing, dairy product manufacturing and breweries. It is value greater to the country’s GDP than the pipeline transportation of natural gas and crude oil. It is bigger in BC’s story than forestry, logging, paper, and paper mills. Cannabis is already more important in BC than the secondary wood industry vision proposed for engineered wood products like laminate timber.
Furthermore, four years into regulation, senior levels of governments are still grappling with the challenges of bringing illicit growers into the legal regime. The proposed regulation will impact the operations of legal growers only; it will discourage illicit growers from forming legal operations and put a complete chokehold on the cultivation industry’s ability to grow and contribute to BC’s economy.
Implementing the proposed regulations as they stand would have real consequences for the viability of growers in the region, destroy any possibility of bringing (or converting) new legal growers into the fold, and thereby allowing illegal growers to flourish.
We reiterate our offer to collaborate with Metro Vancouver on policies that will support cannabis as an emerging economic driver and agricultural commodity as we work to support the BC and federal government’s objectives of protecting public health and safety by eliminating the significant illicit market in British Columbia.
Metro Vancouver needs to attend to this matter with the attention it deserves, these regulations have far-reaching impacts for the over-all cannabis sector and other agricultural stakeholders. We do not believe Metro Vancouver has the grounds to execute or enforce these kinds of regulations, unseen elsewhere in Canada.
We respectfully ask for Metro Vancouver to brief the Agricultural Advisory Committee, the Economic Prosperity Committee (Invest Vancouver), and Climate Action Committee on this issue and abandon proposed regulations.
We welcome an opportunity to present to these committees and answer any questions they may have.
Sincerely,
Cannabis Cultivators of British Columbia