To: Colorado Department of Agriculture
Commissioner, Ms. Kate Greenberg. Kate.email@example.com, Director of Procurement, Mr. Daniel Huse firstname.lastname@example.org
July 23, 2020
Dear Colorado Department of Agriculture,
I am contacting you in my capacity as President of the Hemp Industries Association (HIA), the nation’s oldest and largest hemp centric trade association, serving greater than 1400 members nationally, and a resident of Colorado, which leads the nation in hemp research and cultivation with over 99% of our planted acreage harvested (51,851 acres in 2019).
As the foremost organization representing the interest of all sectors of the United States hemp economy, the HIA is dismayed that the Colorado Department of Agriculture would award a Hemp Center of Excellence contract to a group, the MPG Consulting, a consultancy firm for the marijuana industry. While MPG Consulting may be composed of skilled and accomplished professionals their expertise and experience has been narrowly focused on advising businesses on strategies to maximize profits within the marijuana industry. During the CHAMP stakeholder process, their lack of knowledge was evident as many discussion topics bordered on overly redundant regarding supply chain or regulatory issues that have been resolved years ago.
While the U.S.hemp and marijuana industries share some overlap, they each serve significantly different markets and operate within divergent regulatory environments, requiring leadership with expertise distinct to their respective needs. Whoever runs Colorado’s Hemp Center of Excellence must have a proven track record of the responsible regulation of hemp, a thorough understanding of the unique opportunities and issues distinct to hemp – from genetic research to testing to the wide variety of products and markets – and possess strong ties to the hemp community, public, private, not-for-profits and federal agencies such as the U.S. Department of Agriculture and Food & Drug Administration.
Hemp is an agricultural crop providing real economic benefit to our farmers, and the state. Since the cultivation of this crop is managed by our Department of Agriculture and has different stakeholders, hemp must not be confused with marijuana. Marijuana is a Department of Revenue, Marijuana Enforcement Division, regulated product and subject to DEA. Agriculture commodities such as hemp, industrial products made from hemp, and the enormous variety of down-line products derived from hemp, involve different leaders, different agencies on state and federal levels and profoundly different markets, and are 100% legal federally. The US hemp industry encompasses products including food, fiber, construction materials, bioeconomy, sustainable agriculture and much more – none of which are true of marijuana. Hemp farmers do not want association with marijuana.
Colorado, under the guidance of Governor Polis and Commissioner Kate Greenberg, should continue to show leadership in hemp cultivation, harvesting, processing, research and revenue. However, further conflating and confusing hemp and marijuana by awarding the Hemp Center of Excellence to a marijuana consultancy firm like MPG Consulting is a step in the wrong direction. We believe this confusion will limit long-term effectiveness of the Hemp Center for Excellence in serving the distinct needs of the hemp industry and agricultural sector. In fact, we worry that having a marijuana group provide a Center of Excellence proposal to USDA will jeopardize the approval as USDA is very hostile to marijuana.
The HIA would like to support the hemp center of excellence, as part of our mission to advance the hemp economy and educate the market. We are an organization flush with the right resources needed to make a Center of Excellence for hemp a success. However, we see an inherent conflict and disconnect with awarding this contract to a group fundamentally connected to the marijuana industry, with no experience in the agriculture of hemp or experience in creation of hemp derived products.
HIA extends an offer to suggest candidates who are proven leaders experienced in the hemp space and with expertise relevant to all aspects of the hemp industry to contribute to the success of the Hemp Center for Excellence. In fact, our members would value the opportunity to collaborate with you on any number of levels. Alternatively or in addition to any of these offers, while we understand the challenges, we recommend that you redo the proposal/awarding processes to rectify the appearance of any potential conflict of interest, and appropriately address the needs of a burgeoning hemp agricultural economy.
Thank you for your assistance and responsiveness.
President, Hemp Industries Association