The State of Michigan’s Department of Licensing and Regulatory Affairs (LARA) today released an Advisory Bulletin stating its intent that medical marihuana businesses will be allowed to hold multiple Class C grow licenses, and do so in the same facility.

As we previously reported, last week LARA announced that it intends to allow the co-location of different license types (growers, processors, and retail provisioning centers) in the same building. Co-located licenses, however, will require separate entrances and exits and separate, distinct working areas. Left unaddressed in last week’s Advisory Bulletin was whether those separation requirements would apply to multiple grow licenses.

Today’s Advisory Bulletin answers the question about locating multiple grow licenses together. The State does intend to allow multiple or “stacked” grow licenses for Class C (1,500 plant) grow licenses only. Stacked licenses must be issued to the same applicant/licensee (i.e., no difference in ownership composition), and the license fee and regulatory assessment must be paid for each license. Separation of the licenses then will only be “virtual” in nature. That is, the licenses can occupy the same working area, but information entered into the State’s seed-to-sale monitoring system will need to be tracked to the each specific, individual license. Finally, stacking must be in compliance with any local ordinances and zoning.

This latest announcement by LARA continues a trend of the Department being responsive to industry concerns, and providing helpful information in advance of the release of emergency rules, still expected for early November. Per public announcements by LARA’s Director, we do expect further guidance to be issued in the relatively near future, including the financial requirements for various license types.

In addition to these Advisory Bulletins, LARA has also released the Confidentiality and User Agreement for interfacing inventory control systems with the State’s METRC seed-to-sale tracking software. Per the terms of that agreement, the State expects METRC to be tracking transactions in real time, and allow provisioning centers to check whether a customer has reached a daily purchase limit.