The State of Michigan’s Department of Licensing and Regulatory Affairs (LARA) today issued an advisory bulletin confirming that the State will allow growers, processors, and provisioning centers to operate in the same location.

LARA’s Advisory Bulletin is not a final statement of the Department’s position, which will be solidified in emergency rules that are expected to be promulgated in early November. Nevertheless, it provides helpful guidance for those engaged in business planning and preparing to submit license applications. Per the Advisory Bulletin, LARA intends to allow co-location upon satisfaction of the following conditions:

  • Each licensed entity operates, and posts its license, in distinct and separate working areas.
  • Each licensed entity has separate entrances and exits, point of sale, and record systems.
  • The host municipality doesn’t prohibit co-location.
  • Compliance with health standards and building and fire codes.

Additionally, each grow license, processing license, and provisioning center license will require separate applications (and application fees), regulatory assessments, and license.

Left somewhat open for interpretation is how the above requirements might apply to stacked grow licenses. In other words, if one business holds multiple grow licenses for the same facility, will each grow license need to be wholly separated from one another? We anticipate that these issues will be more comprehensively addressed in the emergency rules.