December 20, 2017

On November 21, 2017, Health Canada released their Proposed Approach to the Regulation of Cannabis for public consultation. The AAMDC has since drafted a submission in response to the proposed regulations that highlights the need for the Government of Canada regulations to include consider municipal land use plans and other considerations when reviewing applications for cannabis cultivation and processing facilities. As is, the proposed regulations lack meaningful reference to municipalities’ important role in recreational cannabis production and processing.

AAMDC Submission

The AAMDC submission aims to encourage Health Canada to include explicit reference to municipal plans, policies and bylaws in the regulations in order to facilitate positive relationships between licence holders and municipal governments, and to ensure that production and processing facilities do not have negative local impacts. The submission outlines the following key messages:

  • It should be required for municipal plans and priorities to be considered during the licencing process for all recreational cannabis activities;
  • Producers should be required to engage and consult with municipalities prior to licence approval to ensure the two entities are in agreement with the proposed activities;
  • Production facilities should be required to comply with provincial building codes and municipal bylaws;
  • Producers should notify and discuss the scale of the production activities with the hosting municipality to communicate of the level of municipal services producers will require (e.g. water);
  • The regulations should clarity whether each facility would be required to have its own licence, or if one licence allows multiple facilities;
  • Licence holders should be required to communicate with municipalities regarding all intended activities on the licenced site prior to the application process to allow municipalities to amend zoning and land use bylaws and to have the opportunity to discuss potential impacts to the community; and
  • Physical barriers around the perimeter of the cultivation site should be required to be planned in accordance and collaboration with municipal police and emergency response agencies.

The AAMDC is encouraging members to submit a response to Health Canada communicating the rural Alberta perspective and how Health Canada can better incorporate municipalities explicitly in the regulations. You are encouraged to use the AAMDC submission, found here, to inform and frame your response and to strengthen the rural Alberta voice. 

Full details of the regulatory proposal are available here, and a condensed backgrounder is available here.

You can submit your response to the proposed regulatory approach either through a written submission to cannabis@canada.ca or through an online questionnaire here. The deadline to submit is January 20, 2018.

 

Enquiries may be directed to:

Chelsea Parent
Policy Analyst
587.671.0124

Kim Heyman
Director, Advocacy & Communications
780.955.4079