The Department of Cannabis Control posted proposed revisions to its cultivation regulations Wednesday, opening a 45-day public comment period that runs through May 9. The proposed rule package (DCC-2026-03-CR, 187 pages) covers canopy size thresholds, environmental compliance requirements, Metrc reporting protocols, and the expansion of large-scale cultivation licenses that has been the single most contentious issue in California cannabis since 2023.

The comment period will include two public hearings: one in Sacramento on April 16 and one in Eureka on April 23. The Eureka hearing is notable. It’s the first time the DCC has held a formal regulatory hearing in Humboldt County since the agency was created in 2021.

What’s in the proposal

The big items, briefly:

Canopy limits. The DCC is proposing to maintain the current Type 5 (large outdoor, no size cap) and Type 5A (large indoor, no size cap) license categories. These were authorized by AB 195 in 2022 but have been subject to ongoing legal challenges. The proposed rules would set minimum environmental review requirements for operations over 50,000 square feet, including mandatory CEQA analysis at the project level rather than the programmatic level most large operations have relied on.

Environmental compliance. New requirements for water use reporting (quarterly instead of annual), pesticide management plans reviewed by CDFA, and a stormwater management provision that would apply to any operation with more than 2,500 square feet of impervious surface. That last one hits mixed-light greenhouses particularly hard, since greenhouse plastic counts as impervious.

Metrc changes. The proposal would reduce the mandatory track-and-trace tagging threshold from individual plants to harvest batches for outdoor and mixed-light operations under 10,000 square feet. This has been a longstanding ask from small growers who spend hundreds of hours per season tagging individual plants. The change would save an estimated 40 to 60 labor hours per harvest cycle for a typical small farm.

Testing. The proposal includes a provision allowing the DCC to establish “reduced testing protocols” for licensees with three consecutive years of clean CoA results. Details are vague. The regulatory text says the DCC “may, by order” reduce required analytes for qualifying operations, but doesn’t specify which analytes or what the reduced panel would look like.

Industry reaction

Reaction is split along the same lines that have defined California cannabis politics for the past four years: big vs. small, north vs. south, legacy vs. new money.

The Humboldt County Growers Alliance issued a statement calling the Metrc batch-tagging change “overdue by three years” but criticized the overall package as “a regulatory framework designed to accommodate industrial-scale operations while offering small farms cosmetic relief.”

“They’re giving us batch tags with one hand and keeping uncapped large licenses with the other,” said Natalynne DeLapp, the Alliance’s executive director. “The tagging fix is real and we appreciate it. But it doesn’t change the market dynamics that are killing small farms.”

The California Cannabis Industry Association, which represents many of the state’s larger operators, called the proposal “a balanced approach” and praised the environmental compliance provisions as “raising the bar for all participants.”

The stormwater requirement is getting pushback from mixed-light growers specifically. A typical 10,000-square-foot dep greenhouse generates approximately 62,000 gallons of runoff annually. The proposed regulation would require a stormwater management plan, retention infrastructure, and annual reporting for any operation exceeding the 2,500-square-foot impervious surface threshold.

“That’s basically every greenhouse in the county,” said a licensed grower near Willow Creek who asked not to be named. “I already have a water board permit. Now I need a stormwater plan too? Who’s paying for the engineer to design that?”

The Eureka hearing

The April 23 hearing in Eureka will be held at the Adorni Center, 6 to 9 p.m. Written comments can also be submitted through the DCC’s online portal at cannabis.ca.gov through May 9.

For Humboldt County growers, the Eureka hearing is the opportunity to get on the record. The DCC is required to respond to every substantive comment in its final statement of reasons when adopting the regulations. That process typically takes three to six months after the comment period closes.

“Show up or shut up, basically,” DeLapp said. “This is how it works. You put your comment on the record, or it doesn’t exist.”

The DCC expects to finalize the revised cultivation regulations by Q4 2026, with an effective date of January 1, 2027.