Primordia LLC Fights for all U.S. Hemp Farmers

— Primordia Team

By submitting comments to the USDA on revising the restrictive 15-day harvest window we aim to make hemp farming more achievable for America's new industry.

Brawley, CA (June 17th 2020) – PRESS RELEASE

With hemp regulations set to become final at the end of 2020, Primordia and it’s network of hemp farmers have decided to push back against the restrictive harvest window proposed by submitting comments to the USDA and the State of California that break down the arbitrary requirement that farmers are only allowed 15 days from the sampling date to harvest their entire crop.  You can read the full comments to the USDA here.

Primordia and the Primordia Collective have been executing a large-scale hemp program since the winter of 2019, successfully growing and harvesting over 2500 acres of hemp in the Imperial Valley of California.  With registered and research acreage, Primordia’s team has seen firsthand how requirements both proposed and established in the Farm Bill and California’s law pertaining to hemp put constraints on farmers ability to successfully harvest this new crop.  The hemp market is no longer in a gold rush phase and has commoditized rapidly over the last year with price declines as high as 90% year over year, this crash in pricing has made it extremely difficult for farmers to make a profit on their crop and with the new regulations being proposed, additional fees will be levied, harvesting compliance will not be met, and profit margins will evaporate.

The primary reason for this concern is the very tight timeline between the execution of the sampling and the proposed requirement to harvest a compliant field within 15 calendar days of the sampling date.  To understand why we are requesting this change, let’s start by looking at how the 15-day window poses a significant challenge to successfully harvest a crop within the proposed allotted time period.  As you can see, once a sample is taken, it can take up to one week before results are back in the hands of a farmer.

  • Breakdown of testing to harvest timeline 
    • Day 1 – Test ordered and pre-harvest report submitted
    • Day 4 – Lab and state liaison’s first available appointment time to sample field
    • Day 5 – Sample arrives at lab
    • Day 5-9 – Standard 3-5 day testing turnaround
    • Day 10 – Sample Tested
    • Day 11 – Sample results confirmed by lab and uploaded to farmer
    • Day 12 – Harvest Begins
    • Day 19 – Mandated harvest ending
  • Note* Labs are consistently backlogged and may require more than 3-5 days which can create an advantage or disadvantage based on a farmers’ geographic location and access to quality labs

This timeline would only allow eight days to harvest a field which, depending on harvest methodology, may not be possible for farmers.  With only eight days allotted, “Harvest plans must be drafted perfectly and executed without hiccups, if not, portions of the crop will have to be destroyed. The notion that a farmer can do everything right then have to destroy crop due to missing an arbitrary harvest window is not the way forward for hemp in California or the United States,” stated Mark Samuels, Co-Founder of Primordia.  The only real way to mitigate this is of course to extend the harvest window to 30 days, or, by breaking up a field into separate blocks, however, this methodology creates a severe cost burden as each block must be tested by laboratories that charge anywhere from $400-600 per test.  For a farmer growing significant acreage, these additional fees are not only prohibitive but may erase any profit that may have been achieved.

All told, we believe this restrictive 15-day window is an unfair burden considering the infant stage of the United States’ hemp industry, the myriad of idiosyncrasies the hemp plant produces, the inevitable delay of compliance sampling/testing timelines, and the difficulty in developing a complex crop production plan that must be executed perfectly in order to prevent destruction and a 100% loss. It is our opinion that if this rule is not revised there will be several consequences that will disproportionately effect US farmers and businesses:

  • Good, compliant hemp crops will be destroyed
  • Farmers and businesses will lose tens of millions of dollars due to the inability to harvest within the allotted window, reducing much needed revenue for this new industry
  • New investment will be placed in other countries where compliance standards make successful farming more achievable
  • The cost burden to sample and test hemp crops will be extremely high for mid to large scale farmers, making the US less competitive

We implore the USDA, State of California, the CDFA, and the OAL to reconsider the restrictive harvest window proposed and to revise the language of sections II:B, 4940 and 4946 to allow farmers 30 days from the sampling date to harvest their fields.  “This is a simple change that will lead to more farming jobs and successful, compliant hemp crops in the State of California and the US, a win for all involved,” stated Grant Mitchell, CEO of Primordia, “we are here to answer any additional questions and to further detail the points above.”  Primordia is looking forward to a positive response from the USDA and we ask all hemp farmers and businesses across the country to support this effort by sharing these comments to their network.

Sincerely,

The Primordia Team

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