HomeMy WebLinkAboutPC PACKET 12.12.2024If you need accommodations for the Planning Commission meeting please contact
Rachel Juba at (651) 762-6304 or rjuba@ci.hugo.mn.us, thank you.
Agenda
Hugo Planning Commission
Thursday, December 12, 2024
Hugo City Hall
7:00 PM
A. ROLL CALL: Andress, Arcand, Derr, Granger, Kelly, Kleissler, Lessard, Petty
B. PLEDGE OF ALLEGIANCE
C. APPROVAL OF MINUTES
1. September 26, 2024
D. PUBLIC HEARING
1. Cannabis Ordinance – An ordinance adding to and amending Chapter 90, Article I,
Section 90-1. – Definitions, Chapter 90, Article II. Section 90-37.2. – Special Event
Permits, Chapter 90, Article IV – Zoning District Regulations, and Chapter 90, Article
VI – Requirements for Specific Uses and Performance Standards to regulate cannabis
businesses within the City of Hugo.
E. NEW BUSINESS
F. OLD BUSINESS
G. ADJOURNMENT
Minutes for the Planning Commission Meeting of Thursday, September 26, 2024
Acting Chair Derr called the meeting to order at 7:00 pm.
PRESENT: Andress, Arcand, Derr, Granger, Kelly, Lessard, Petty
ABSENT: Kleissler
STAFF: Rachel Juba, Community Development Director
Max Gort, Associate Planner
Pledge of Allegiance.
Approval of Minutes for the Planning Commission Meeting of August 8, 2024
Commissioner Petty made a motion, seconded by Commissioner Lessard, to approve the minutes for
the Planning Commission meeting of August 8, 2024.
All ayes.
Motion carried.
Public Hearing: Craig Anderson – Minor subdivision request to create two 10-acre parcels from a 20-
acre parcel located on Jeffrey Avenue North.
Associate Planner Max Gort presented background on the minor subdivision request. [FILL IN]
The applicant, Craig Anderson, introduced himself to the Planning Commission.
Acting Chair Derr opened the Public Hearing at 7:05 PM
No one spoke.
Acting Chair Derr closed the Public Hearing at 7:05 PM
Commissioner Petty made a motion, seconded by Commissioner Granger, to approve the minor
subdivision request subject to conditions in the resolution.
All ayes.
Motion carried.
The Minor Subdivision request will be reviewed by the City Council at its October 7 th, 2024 meeting.
September 26, 2024 PC Minutes
Page 2
Public Hearing: Scott and LeAnn Neamy – Conditional Use Permit (CUP) request to construct a 900
square foot building addition to be used as an accessory apartment
Gort presented background on the CUP request to construct a 900 square foot accessory apartment as
building addition at 17220 Keystone Ave N. The applicant has stated that the purpose of the accessory
apartment is to provide care for a family member. When reviewing the application, staff found that the
request met the spirit and intent of the ordinance requirement, and the requirements necessary to
approve a CUP. Staff recommended approval of the CUP request subject to conditions in the
resolution.
Commissioner Petty asked if the proposed building addition will be two stories, and if there was a
requirement for an accessory apartment to be a single story. Juba responded that this would be two
stories, and that accessory apartments are not required to be one story.
Commissioner Arcand asked about the need for the accessory apartment to be owner -occupied, what
would make the accessory apartment different from a regular building addition, and if there’s an
inspection timeline attached to the CUP. Juba said that the intention of the accessory apartment is to
prevent the single-family home property from being split through the building, and that there likely
wouldn’t be a reason to re-inspect the CUP after the building permit is issued.
Commissioner Petty stated that she thinks that Accessory Dwelling Units (ADUs) should not be limited
to the Agricultural (AG) zoning district. Juba stated that this proposal is an accessory apartment, which
is allowed in more zoning districts, rather than an ADU.
Rebecca Neamy, a representative for the applicant, introduced herself to the Planning Commission.
Acting Chair Derr opened the Public Hearing at 7:16 PM
No one spoke.
Acting Chair Derr closed the Public Hearing at 7:16 PM
Commissioner Andress asked if the access was only through the garage, Juba said there would be
access through an exterior door and through the garage.
Commissioner Petty made a motion, seconded by Commissioner Arcand, to approve the CUP request
subject to conditions in the draft CUP and resolution.
All ayes.
Motion carried.
The CUP request will be reviewed by the City Council at its October 7 th, 2024 meeting.
September 26, 2024 PC Minutes
Page 3
Public Hearing: Ordinance Amendment – amending Sec. 90-103(b) to allow tobacco shops as a
permitted use in the Central Business (C-1) zoning district
Juba gave background on the request from an individual who purchased the former Premier Banks and
Speedway gas station location, and found that tobacco shops are not technically allowed as a
permitted use in the C-1 zoning district. Tobacco shops are allowed as a permitted use in the C-2
district, and the C-1 district already permits many comparable uses. Staff is of the opinion that it would
be appropriate to amend the permitted uses in the C-1 zoning district to allow tobacco shops as a
permitted use.
Commissioner Granger asked if the omission of tobacco shops from the C-1 zoning district is
considered by staff to be an oversight, Juba says that it likely was an oversight.
Commissioner Petty asked if there would be enough parking for a tobacco shop at the proposed
location. Juba said that there would be enough parking, and mentioned the shared parking and cross -
access easements shared by surrounding businesses. Petty asked if vaping products could be sold at
the tobacco shop, Juba said that they are subject to the terms of their tobacco license. Petty asked if
the tobacco shop would have video surveillance, Juba said yes.
Chair Kleissler opened the Public Hearing at 7:22 PM
Rebecca Neamy, who stated she lives on Skillman Avenue in Maplewood, asked if the tobacco shop
would sell CBD products. Juba stated that the owner would be suited to answer that question and that
staff can provide contact information. Juba mentioned that there will be a separate discussion on
cannabis items coming later.
No one else spoke.
Chair Kleissler closed the Public Hearing at 7:24 PM
Commissioner Petty stated that she’d be reluctant to approve the text amendment because of the
concern that minors could be able to purchase cannabis products at the store. Juba stated that the
tobacco shop wouldn’t be permitted to sell cannabis products, and that there’s a separate licensing
process coming from the state.
Commissioner Lessard made a motion, seconded by Commissioner Arcand, to recommend approval of
the text amendment to allow tobacco shops as a permitted use in the C-1 zoning district.
All ayes. Motion carried.
The text amendment will be considered by the City Council at their October 7, 2024 meeting.
New Business – Citywide Bus Tour
September 26, 2024 PC Minutes
Page 4
Gort briefly reminded the Planning Commission of the citywide bus tour on Saturday, October 5 th, 2024
at 9:30 AM beginning at North Star Elementary, and invited the Planning Commission members to
attend.
Old Business
None.
Adjournment
Commissioner Arcand made a motion, seconded by Commissioner Lessard, to adjourn at 7:27 PM.
All ayes.
Motion carried.
Respectfully Submitted,
Max Gort, Associate Planner
Memorandum
To: Hugo Planning Commission
From: Max Gort, Associate Planner
Date: December 9, 2024, for the Planning Commission Meeting of December 12, 2024
Re: Public Hearing – Creation of an ordinance relating to and regulating cannabis b usinesses
1. BACKGROUND AND MEETING UPDATES:
By enacting Minnesota Statutes 2023, Chapter 342, the Minnesota Legislature has provided a
regulatory framework for the sale and manufacturing of cannabis and hemp products, the
licensing of cannabis and hemp businesses, and establishes a State Agency known as the Office
of Cannabis Management (OCM). Section 342.13 of the act allows a local unit of government to
adopt “reasonable restrictions on the time, place, and manner” of the operation of cannabis
businesses. On July 10, 2023, the City Council enacted a 12-month moratorium on the sale,
testing, manufacturing, and distribution of cannabinoid products within the city, that was
extended on August 5th, 2024 until January 1, 2025. The City Council gave some high-level
direction to staff at a workshop on April 22, 2024 which included not prohibiting use of
cannabis in public places, not to consider a municipal cannabis store, and not to increase the
limit of retail registrations beyond the minimum required by state statute. At that time, the
OCM had not published any additional guidance for local governments.
On September 3, 2024, the OCM released its most recent guide for local governments as well
as a model cannabis ordinance. Staff began to draft an ordinance relating to and regulating
cannabis businesses within the City of Hugo, which would include definitions of cannabis
businesses, a procedure for registering cannabis businesses within the city, zoning and land use
designations for cannabis businesses, performance standards for cannabis businesses, and
processes related to temporary cannabis events.
At its meeting of November 18, 2024, the City Council gave some high-level direction to staff
on a number of items to be included within the draft ordinance. After some discussion, the City
Council recommended that staff proceed to draft an ordinance with the zoning districts
proposed, no buffers in place for cannabis businesses, and for temporary cannabis e vents to be
included in the special event permitting process.
At its meeting of November 19, 2024, the EDA heard a presentation f rom staff asking for
similar comments on the direction of the cannabis ordinance. The EDA had some debate about
whether to require buffers to limit the ability to advertise to minors, but they agreed that this
concern could be addressed through regulating signage specifically for cannabis business.
Generally, the EDA was comfortable with staff’s recommendation for zoning districts, buffers,
and the inclusion of cannabis events within the special event permitting process.
At its meeting of December 2, 2024, the Ordinance Review Committee (ORC) discussed the
D.1
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direction of the cannabis ordinance and some questions that were raised during the previous
City Council and EDA meetings. In general, the ORC recommended that staff proceed with the
proposed zoning districts, not requiring any buffers, an d including cannabis events under
special event permits in the draft cannabis ordinance.
2. SUMMARY OF ORDINANCE:
A. Cannabis Ordinance
State statute allows local governments to adopt reasonable restrictions on the time,
place, and manner in which cannabis businesses can operate. While drafting an
ordinance, staff considered whether to recommend buffer requirements for cannabis
businesses. Based on findings related to existing zoning and separation of
noncompatible uses, staff is recommending buffers not be included in the ordinance.
Staff has drafted proposed zoning districts where certain cannabis business types would
be allowed. Generally, staff found that cannabis retailers, and other business types that
include retail sales, were land uses comparable to those allowed in commercial zoning
districts. Meanwhile, all other cannabis business types were found to be more
compatible with land uses allowed in industrial zoning districts. Additionally, the city is
required by state statute to allow temporary cannabis events in some form, and can
place restrictions on their operation. Staff is recommending adding standards for
cannabis events into the existing special event permit process.
B. Types of Cannabis Businesses
The Minnesota Office of Cannabis Management (OCM) is setting up to issue licenses to
13 cannabis business types:
• Cannabis cultivators
• Cannabis manufacturers
• Cannabis retailers
• Cannabis wholesalers
• Cannabis transporters
• Cannabis testing facilities
• Cannabis event organizers
• Cannabis delivery services
• Cannabis microbusinesses
• Cannabis mezzobusinesses
• Lower-potency hemp edible manufacturers
• Lower-potency hemp edible retailers
• Medical cannabis combination businesses.
Each of these represent a specific license issued by the OCM to business owners, and
each have specific requirements for approval. The OCM requires that license
applications receive a certificate of local compliance from the local government where
the license is being proposed for. Cannabis microbusinesses and cannabis
mezzobusinesses are businesses that can apply for endorsements on their state license
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to perform multiple business activities, such as cultivation, manufacturing, and/or retail
sales but on a smaller scale than general cultivators, manufacturers, and retail ers.
C. General Standards for all Cannabis Businesses
The OCM’s Guide for Local Governments on Adult-Use Cannabis provides some context
for how different cannabis business types may fit into a city’s existing zoning
framework. Based on this context, staff has developed some general standards for all
cannabis businesses. These general standards must be met in addition to applicable
performance standards for each business type. In general, cannabis businesses may
conduct the operations of multiple cannabis business types, provided that they receive
the required license from the OCM for each business type, which includes local zoning
approval for each business type. The City shall conduct annual age-verification
compliance checks for every cannabis business that conducts retail sales. Signage for
cannabis businesses must remain minimal, with two on-site exterior signs permitted
that can not advertise cannabis products, and can not be a temporary sign, portable
sign, neon sign, window-mounted sign, or a sign lit with static LED, blinking, moving, or
flashing lights. All interior signage must not be visible from the exterior of the business.
Additionally, all cannabis businesses are required to register with the city after receiving
state license approval.
D. Registration of Cannabis Businesses
State statute requires that cannabis businesses that operate retail sales to customers or
patients register with the local government in which the retail establishment is located.
Staff is proposing that the city require registration of all cannabis businesses, including
retailers. Since the state issues and controls cannabis business licenses, requiring local
registration allows the city to have an extra review of each business seeking to locate
within the city.
Section 90-280(c) of the draft ordinance outlines the procedure by which cannabis
businesses will register with the city, including: the initial registration application and
fees, process for city council review, approval, and basis for denial, the process for
renewal of a registration, the process by which the city addresses violations and
grounds for suspension of a registration. State statute sets a limit on how much local
governments can charge for registration of cannabis businesses based on the business
type. The proposed registration fees are:
Business Type City Initial Fee City Renewal Fee
Microbusiness $0 $1,000
Mezzobusiness $500 $1,000
Cultivator $500 $1,000
Manufacturer $500 $1,000
Retailer $500 $1,000
Wholesaler $500 $1,000
Transporter $250 $500
Testing Facility $500 $1,000
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Delivery Service $250 $500
Event Organizer $375 N/A
LPHE Mfr. $500 $500
LPHE Retailer $125 $125
Med. Comb. $500 $1,000
*The above fees are proposals and are subject to change.
Registration applications may be denied by the City Council if the application does not
meet ordinance requirements, or the applicant does not have a valid state-issued
license. Additionally, registration applications for retailers are limited to one
registration per 12,500 residents, which would allow a maximum of two retailers to
locate and register within the City of Hugo. The City Council is not obligated to approve
a retail registration application if the number of registered retailers across Washington
County exceeds one registration per 12,500 residents.
E. Proposed Zoning
Staff reviewed the types of businesses for which OCM will be issuing licenses, and
following OCM guidance, considered how each business type compares to existing uses
within the zoning code.
When considering cannabis cultivation, staff reviewed the state statute requirements
and draft rules for cannabis cultivator operations, and determined that several factors
will guide the type of land use and impact that cultivators will generate. Key factors
include requirements for security and exterior lighting, the desire to control
environmental factors within cultivation area, and the requirement to control odor,
staff is recommending that cultivation activity be restricted to occur indoors. Staff
found that cannabis cultivators will likely generate an impact that is more consistent
with uses allowed in industrial zoning districts than those typically found in agricultural
zoning districts.
Staff is proposing that the zoning code be amended to add the following permitted (P),
accessory (AC), and conditional (CUP) uses to each applicable zoning district:
Neighborhood
Service (NS)
Central
Business
(C-1)
General
Business
(C-2)
Business
Park (BP)
General
Industrial
(I-3)
Cannabis
Cultivator
P P
Cannabis
Manufacturer
P P
Cannabis
Retailer
P P P
Cannabis
Wholesaler
P P
Cannabis
Transporter
P P
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Cannabis
Testing
Facilities
P P
Cannabis
Delivery
Services
AC AC
Lower-Potency
Hemp Edible
Manufacturers
P P
Lower-Potency
Hemp Edible
Retailers
AC AC AC
Medical
Cannabis
Combination
Businesses
CUP CUP
Cannabis
Microbusiness
P P
Retail Location
of a Cannabis
Microbusiness
P P P AC AC
Cannabis
Mezzobusiness
P P
Retail Location
of a Cannabis
Mezzobusiness
P P P AC AC
F. Buffers
While drafting an ordinance, staff considered whether to recommend adoption of
buffer requirements for cannabis businesses. State statute allows local governments to
require cannabis businesses be buffered up to 1,000 feet fro m a school, or up to 500
feet from a daycare, residential treatment facility, or an attraction within a public park
frequently utilized by minors, such as playgrounds and athletic fields. Local
governments are encouraged to follow precedent for comparable uses within existing
city code. The City of Hugo requires that liquor stores to be 200 feet from schools and
churches, and that sexually oriented businesses be 300 feet from several sensitive uses.
Staff created maps of the city showing where cannabis businesses would be permitted
and different buffer scenarios: the maximum buffer allowed by state statute, a 300-foot
buffer from sensitive uses following city code precedent, and a scenario with no buffers
in place. Staff found that the existing zoning districts separate noncompatible uses, and
that problems were created where adjacent parcels within the same zoning district can
suddenly have different permissions. Staff is currently recommending that the cannabis
ordinance not include buffers.
G. Performance Standards
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The draft cannabis ordinance has performance standards in place for each cannabis
business type, intended to ensure that any cannabis business application coming to the
City of Hugo is compatible with the vision of the City Code and Comprehensive Plan.
Performance standards are a tool that cities can use to restrict the time, place, and
manner in which cannabis businesses may operate. In addition to the performance
standards listed in the draft ordinance, each cannabis business shall be subject to
applicable performance standards of the land use more generally, and zoning district
regulations where the business is located.
H. Cannabis Events
While drafting the cannabis ordinance, staff has been finding ways to incorporate
cannabis-related items into existing processes. Section 90-37.2 of City Code outlines
requirements for special event permits, including standards for specific events and a
process for review and approval at the administrative and City Council levels. Staff is
proposing that the special event permit section of city code be amended to require that
cannabis events be included as a special event that requires City Council approval.
Cannabis events are proposed to be limited to operating between the hours of 10:00
AM and 10:00 PM, and may not permit on-site consumption of any cannabis products
except lower-potency hemp edible products. Additionally, an applicant for a cannabis
event special event permit will be required to obtain their state-issued cannabis event
organizer license prior to the event taking place.
3. STAFF RECOMMENDATION
Staff recommends the Planning Commission hold the public hearing and take all comments.
Staff recommends that the Planning Commission have a discussion based on the public
comments received.
Staff recommends that the Planning Commission recommend approval of the draft cannabis,
subject to any recommendations from the Planning Commission, to the City Council.
Attachments:
1. Draft Cannabis Ordinance
2. Minnesota OCM Guide for Local Governments on Adult-Use Cannabis
3. Comments received from the public
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CITY OF HUGO,
COUNTY OF WASHINGTON
ORDINANCE NO. 2024-___
AN ORDINANCE RELATING TO AND REGULATING CANNABIS AND CANNABIS
BUSINESSES WITHIN THE CITY OF HUGO
TITLE:
An ordinance adding to and amending Chapter 90, Article I, Section 90-1. – Definitions, Chapter 90,
Article II. Section 90-37.2. – Special Event Permits, Chapter 90, Article IV – Zoning District
Regulations, and Chapter 90, Article VI – Requirements for Specific Uses and Performance Standards.
NOW, THEREFORE, the City Council of the City of Hugo does ordain:
The City Council of the City of Hugo does hereby amend Chapter 90, Article I In General for the
addition of the following Sections:
Chapter 90, Article I, Section 90-1. -- Definitions
Cannabis Business means any business that receives a license from the Minnesota Office of
Cannabis Management.
Cannabis Cultivator means cannabis business licensed to grow cannabis plants within the
approved amount of space from seed or immature plant to mature plant, harvest cannabis
flower from mature plant, package and label immature plants and seedlings and cannabis
flower for sale to other cannabis businesses, transport cannabis flower to a cannabis
manufacturer located on the same premises, and perform other actions approved by the
office.
Cannabis Event means an event that serves, sells, or is otherwise related to cannabis or
cannabis products, and conducts operations pursuant to Minn. Stat. 342.40.
Cannabis Event Organizer means an individual or entity licensed to plan and host events
featuring cannabis, and receives a license under Minn. Stat. 342.39.
Cannabis Delivery Service means a cannabis business that can purchase cannabis and lower-
potency hemp products from specific cannabis businesses, and sells and delivers those
products directly to consumers, and is licensed under Minn. Stat. 342.41 and conducts
operations pursuant to Minn. Stat. 342.42.
Cannabis Manufacturer means a cannabis business that manufactures cannabis products and
is licensed to conduct operations pursuant to Minn. Stat. 342.31.
Cannabis Mezzobusiness means a cannabis business that conducts operations pursuant to
Minn. Stat. 342.29.
Cannabis Microbusiness means a cannabis business that conducts operations pursuant to
Minn. Stat. 342.28.
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Cannabis Retailer means any person, partnership, firm, corporation, or association, foreign or
domestic, selling cannabis product to a consumer and not for the purpose of resale in any
form, and conducts operations pursuant to Minn. Stat. 342.32.
Cannabis Testing Facility means a cannabis business that receives cannabis products and
lower-potency hemp products from manufacturers and cultivators, and tests them to ensure
the products meet safety standards, and conducts operations pursuant to Minn. Stat. 342.37
and Minn. Stat. 342.38.
Cannabis Transporter means a cannabis business that conducts operations pursuant to Minn.
Stat. 342.35 and Minn. Stat. 342.36.
Cannabis Wholesaler means a cannabis business that conducts operations pursuant to Minn.
Stat. 342.33 and Minn. Stat. 342.34
Edible Cannabis Product means a product as defined under Minn. Stat. 342.01 Subd. 31.
Lower-Potency Hemp Edible means a product as defined under Minn. Stat. 342.01 subd. 50.
Lower-Potency Hemp Edible Manufacturer means a cannabis business that conducts
operations pursuant to Minn. Stat. 342.45.
Lower-Potency Hemp Edible Retailer means a retail business that receives a state-issued
license pursuant to Minn. Stat. 342.46.
Medical cannabis combination business means a cannabis business that can grow,
manufacture, package, label, and sell cannabis products to both medical patients and adult
consumers, and conducts operations pursuant to Minn. Stat. 342.515.
Office of Cannabis Management means the state agency known as the Minnesota Office of
Cannabis Management.
Plant Canopy means the surface area within a cultivation facility that is used at any time to
cultivate mature, flowering cannabis plants. For multiple tier cultivation, each tier of
cultivation surface area contributes to the total plant canopy calculation, Calculation of the
area of the plant canopy does not include the surface area within the cultivation facility that is
used to cultivate immature cannabis plants and seedlings.
Retail Registration means an approved registration issued by the City of Hugo to a state-
licensed cannabis retail business.
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The City Council of the City of Hugo does hereby amend Chapter 90, Article II Administration and
Enforcement for the amendment of the following Sections:
Section 90-37.2 Special Event Permits
Amend subsection (2)(m) to read:
m. Whether food, alcohol, or cannabis will be served or sold at the event.
Amend subsection (5) Special events subject to City Council approval to add the following:
f. Cannabis events, subject to the following additional standards:
1. On-site consumption during events receiving a special event permit is limited to
lower-potency hemp edible cannabis products.
2. Cannabis events shall only take place between the hours of 10:00 AM and 10:00 PM.
3. Cannabis event operations shall be consistent with requirements listed in Minn. Stat.
342.40, as well as any other applicable rule or law.
4. Any special event permit for a cannabis event shall have a condition requiring that a
copy of a state-issued cannabis event organizer license, as licensed under Minn. Stat.
342.39, be provided to the City Clerk prior to the event taking place.
5. Proof of insurance, and a cash escrow payment to the city for damages.
Amend subsection (7) Basis for denial to add the following:
h. A cannabis event application that does not meet the standards under section 90-37.2(5)(f)
of this ordinance.
Amend subsection (9) Suspension and revocation to add the following:
b. An approved special event permit for a cannabis event that does not receive state approval
of a cannabis event organizer license shall be revoked.
The City Council of the City of Hugo does hereby amend Chapter 90, Article IV Zoning District
Regulations to add of the following Sections:
Sec. 90-102. - Neighborhood service district (NS).
(b) Permitted uses.
(11) Cannabis retailers (refer to section 90-280(h)).
(c) Accessory uses.
(6) Lower-potency hemp edible retailers (refer to section 90-280(m)).
Sec. 90-103. - Central business district (C-1).
(b) Permitted uses.
(27) Cannabis retailers (refer to section 90-290(h)).
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(c) Accessory uses.
(6) Lower-potency hemp edible retailers (refer to section 90-280(m)).
Sec. 90-104. – General business district (C-2).
(b) Permitted uses.
(20) Cannabis retailers (refer to section 90-280(h)).
(c) Accessory uses.
(6) Lower-potency hemp edible retailers (refer to section 90-280(m)).
Sec. 90-106. – Business park (BP).
(b) Permitted uses.
(13) Cannabis microbusinesses (refer to section 90-280(d)).
(14) Cannabis mezzobusinesses (refer to section 90-280(e)).
(15) Cannabis cultivators (refer to section 90-280(f)).
(16) Cannabis manufacturers refer to section 90-280(g)).
(17) Cannabis wholesalers (refer to section 90-280(i)).
(18) Cannabis transporters (refer to section 90-280(j)).
(19) Cannabis testing facilities (refer to section 90-280(k)).
(20) Lower-potency hemp edible manufacturers (refer to section 90-280(l)).
(c) Accessory uses.
(6) Retail sales of cannabis products within a cannabis microbusiness or cannabis
mezzobusiness, subject to applicable performance standards under Section 90-280 of this
ordinance, as well as any other applicable rule or law.
(7) Cannabis delivery service (refer to section 90-280(o)).
(d) Conditional uses.
(15) Medical cannabis combination businesses (refer to section 90-280(n)).
Sec. 90-107. – General industrial district (I-3).
(b) Permitted uses.
(16) Cannabis microbusinesses (refer to section 90-280(d)).
(17) Cannabis mezzobusinesses (refer to section 90-280(e)).
(18) Cannabis cultivators (refer to section 90-280(f)).
(19) Cannabis manufacturers refer to section 90-280(g)).
(20) Cannabis wholesalers (refer to section 90-280(i)).
(21) Cannabis transporters (refer to section 90-280(j)).
(22) Cannabis testing facilities (refer to section 90-280(k)).
(23) Lower-potency hemp edible manufacturers (refer to section 90-280(l)).
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(c) Accessory uses.
(6) Retail sales of cannabis products within a cannabis microbusiness or cannabis
mezzobusiness, subject to applicable performance standards under section 90-280 of this
ordinance, as well as any other applicable rule or law.
(7) Cannabis delivery service (refer to section 90-280(o)).
(d) Conditional uses.
(23) Medical cannabis combination businesses (refer to section 90-280(n)).
The City Council of the City of Hugo does hereby amend Chapter 90, Article VI Requirements for
Specific Uses and Performance Standards for the addition of the following Section:
Sec. 90-280. – Cannabis businesses.
(a) Findings and purpose – The purpose of this ordinance is to implement the provisions of
Minnesota Statutes, Chapter 342, which authorizes the City of Hugo to protect the health,
safety, and welfare of residents by regulating cannabis businesses within the boundaries of
the city.
1. Authority and Jurisdiction -- The City of Hugo has the authority to adopt this
ordinance applicable to the legal boundaries of the city, pursuant to:
a) Minn. Stat. 342.13(c) regarding the authority of a local unit of
government to adopt reasonable restrictions of the time, place, and manner
of the operation of a cannabis business provided that such restrictions do not
prohibit the establishment or operation of cannabis businesses.
b) Minn. Stat. 342.22, regarding the local registration and enforcement
requirements of state-licensed cannabis retail cannabis businesses and
lower-potency hemp edible retail businesses.
c) Minn. Stat. 152.0263, Subd. 5, regarding the use of cannabis in public
places.
d) Minn. Stat. 462.357, regarding the authority of a local authority to
adopt zoning ordinances.
2. Severability – If any section, clause, provision, or portion of this ordinance is
adjudged unconstitutional or invalid by a court of competent jurisdiction, the
remainder of this ordinance shall not be affected thereby.
3. Enforcement – The City of Hugo is responsible for the administration and
enforcement of this ordinance. Any violation of the provisions of this ordinance or
failure to comply with any of its requirements constitutes a misdemeanor and is
punishable as defined by law. Violations of this ordinance can occur regardless of
whether or not a permit is required for a regulated activity listed in this ordinance.
(b) Unlawful unless conditions met. It shall be unlawful for any person or entity to operate a
cannabis business within the city, except in conformance with this section.
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(c) General standards for all cannabis businesses.
1. Compliance verification prior to state license approval - Pursuant to Minn.
Stat. 342.13 (g), within 30 days of receiving a copy of a state license application
from the state office of cannabis management, the City of Hugo shall certify
whether a proposed cannabis business complies with local zoning ordinances and,
if applicable, whether the proposed business complies with the state fire code and
building code.
2. Registration of Cannabis Businesses
a) Consent to registering of cannabis businesses – No person or entity
may operate a state-licensed cannabis business within the City of Hugo
without first registering with the city. Any state-licensed cannabis business
that operates within the city without a valid municipal registration shall
incur a civil penalty of up to $2,000 for each violation.
b) Registration Application Procedure
1. Registration terms and fees – The City of Hugo shall charge a
registration fee to applicants depending on the type of cannabis
business, as established in the city fee schedule.
a. Each cannabis business registration shall be issued for a
period of one calendar year.
b. The first fee payment shall include the initial registration
fee and first renewal fee.
c. Any registration renewal fee shall be charged at the time
of the second renewal, and each subsequent annual
renewal thereafter.
2. Application Submittal – An applicant for a cannabis business
registration shall submit:
a. A completed application form provided by the city.
b. The required registration fee(s).
c. A copy of a valid state license.
d. A written statement of approval from the property owner.
e. Any additional materials requested at the discretion of
city staff.
3. City Council Review and Approval:
a. City staff shall accept applications for cannabis business
registrations on a first-come, first-served basis.
b. City staff will review cannabis business registration
applications for completeness and respond to the
applicant within 30 calendar days. If an application is
considered incomplete, staff shall promptly notify the
applicant of the incomplete status and the remaining
items needed to make the application complete.
c. Once a registration application is considered complete,
city staff shall inform the applicant as such, and forward
7
the application to the City Council for approval or denial.
4. Basis for Denial – the City Council may deny an application for a
cannabis business registration if the city finds that:
a. The application does not meet the requirements of this
ordinance or any other applicable rule or law.
b. The applicant does not have a valid state-issued cannabis
business license.
c. The registration application is for a cannabis retailer, the
retail location of a cannabis microbusiness with a retail
operations endorsement, or a retail location of a cannabis
mezzobusiness with a retail operations endorsement, and:
1. The registration of the retail business would
exceed the maximum number of cannabis retail
business registrations permitted under Section 90-
280(c)(2)(f) of this ordinance.
2. The total number of registered cannabis retailers,
retail locations of cannabis microbusinesses with
a retail operations endorsement, and retail
locations of cannabis mezzobusinesses with a
retail operations endorsement within Washington
County meets or exceeds one registration per
12,500 residents within the county, pursuant to
Minn. Stat. 342.13 Subd. j.
c) Location Change – If a state-licensed cannabis business registered
with the city seeks to move to a new location still within the legal
boundaries of the City of Hugo, the license holder must receive an updated
certification of zoning approval and apply for a new cannabis business
registration.
d) Renewal of Registration – the City of Hugo shall renew an annual
registration of a state-licensed cannabis business at the same time the state
renews the cannabis business’ license. A cannabis business registration
issued under this ordinance shall not be transferred.
1. An applicant for renewal of a cannabis business registration sha ll
submit a renewal fee annually, beginning at the application for the
second renewal.
2. The application for a cannabis business registration renewal shall
include all items for an initial registration as required under
section 90-280(c)(2)(b) of this ordinance.
3. Basis for denial – an application for renewal of a cannabis
business registration may be denied if:
a. Any of the conditions for basis of denial of an initial
registration listed under section 90-280(c)(2)(b)(4) of this
ordinance are met.
b. The registration is currently suspended by the city.
c. The cannabis business no longer holds a valid license
issued by the state office of cannabis management.
8
d. The renewal application does not meet the requirements
of this ordinance, or any other applicable rule or law.
e) Suspension of Registration
1. Violations – Any violation of this ordinance, or any applicable
rule or law, shall be deemed to be an administrative offense of the
registration holder, and the registration holder shall be subject to
the administrative penalties set forth in the city fee schedule for
cannabis businesses.
2. When Suspension is Warranted – The City of Hugo may suspend
a cannabis business registration, after notice and an opportunity
for hearing where reasonably available, if it violates a city
ordinance or poses an immediate threat to the health or safety of
the public. The city shall promptly notify the cannabis business in
writing the grounds for the suspension.
3. Notification to the state – The City of Hugo shall immediately
notify the state office of cannabis management in writing the
grounds for the suspension, who shall in turn provide the city and
cannabis business a response to the complaint within seven
calendar days, and perform any necessary inspections within 30
calendar days.
4. Length of suspension – The suspension of a cannabis business
registration may be up to 30 calendar days, unless the state office
of cannabis management suspends the license for a longer period.
The business may not make sales to customers if their registration
is suspended. The city may reinstate a registration if it determines
that the violation(s) have been resolved. The city shall reinstate a
registration if the state office of cannabis management determines
that the violation(s) have been resolved.
5. Subject to Minn. Stat. 342.22 Subd. 5(e), the city may impose a
civil penalty, as specified in the city fee schedule, for registration
violations. The penalty shall not exceed $2,000.
f) Limiting of Retail Registrations -- the City of Hugo shall limit the
number of cannabis retail business registrations to one registration for every
12,500 residents. This limit shall include registrations for cannabis retail
businesses as licensed under Minn. Stat. 342.32, cannabis microbusinesses
with a retail operations endorsement as licensed under Minn. Stat. 342.28,
and cannabis mezzobusinesses with a retail operations endorsement as
licensed under Minn. Stat. 342.29. This limit shall not extend to lower-
potency hemp edible retailers, as licensed under Minn. Stat. 342.46, and
medical cannabis retailers, as licensed under Minn. Stat. 342.51.
3. Annual Compliance Checks – The City of Hugo shall complete at minimum one
compliance check per calendar year of every registered cannabis business that
conducts retail sales of products to customers or patients, to assess if the business
meets age verification requirements, as required under Minn. Stat. 342.22 Subd.
4(b) and Minn. Stat. 342.24.
4. Multiple license types – Subject to all applicable state law, and cannabis
licensing rules under Minn. Stat. Chapter 342, a cannabis business that holds more
than one license type can perform all activities for which they are granted a state -
9
issued license, provided that the business meets all applicable conditions in this
ordinance and any other applicable rule or law.
5. Signs
a) Cannabis businesses are limited to two exterior, on-site signs with the
name and logo of the business only.
b) Signage for cannabis business shall not be a temporary sign, portable
sign, neon sign, window-mounted sign, or a sign lit with static LED,
blinking, moving, or flashing lights.
c) Exterior advertisement of cannabis products is prohibited.
d) Interior signs shall not be visible from the exterior of the building.
e) Special event signs are prohibited for cannabis business.
(d) Cannabis microbusinesses.
1. Performance Standards
a) All cultivation activity shall be consistent with the standards for
cannabis cultivation under section 90-280(f) of this ordinance section,
except that cultivation area shall be limited to 5,000 square feet of plant
canopy.
b) All manufacturing activity shall be consistent with the standards for
cannabis manufacturing under section 90-280(g) of this ordinance section.
c) Cannabis microbusinesses with a retail operations endorsement may
operate a retail location within the city that meets the performance standards
for cannabis retailers under section 90-280(h) of this ordinance. A cannabis
microbusiness may operate a retail location within a building that also has
spaces for cultivation and manufacturing of cannabis products, provided that
the retail location does not exceed more than 2,500 square feet of gross floor
area.
d) The registration of the retail location of a cannabis microbusiness in the
City of Hugo shall count towards the limit of cannabis retail registrations
under section 90-280(c)(2)(f) of this ordinance.
e) City staff shall review applications for cannabis microbusiness
licenses and verify that the application meets local ordinance requirements
prior to state license approval. In order to verify that an application meets
local ordinance requirements, the application must include the following to
be reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. Demonstration that all light and glare from interior lighting will
be confined to the interior of the building.
4. An exterior lighting plan that includes all lighting be downcast,
and is otherwise consistent with outdoor lighting requirements
under Section 90-239 of City Code.
10
5. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(e) Cannabis mezzobusinesses.
1. Performance Standards
a) All cultivation activity shall be consistent with the standards for
cannabis cultivation under section 90-280(f) of this ordinance section,
except that cultivation area shall be limited to 15,000 square feet of plant
canopy.
b) Cannabis mezzobusinesses with a production of customer products
endorsement, pursuant to Minn. Stat. 342.29 Subd. 7, may manufacture
cannabis products indoors subject to performance standards for cannabis
manufacturers under section 90-280(g) of this ordinance.
c) Cannabis mezzobusinesses with a retail operations endorsement may
operate a retail location within the city that meets the performance standards
for cannabis retailers under section 90-280(h) of this ordinance. A cannabis
mezzobusiness may operate a retail location within a building that also has
spaces for cultivation and manufacturing of cannabis products, provided that
the retail location does not exceed more than 2,500 square feet of gross floor
area.
d) The registration of the retail location of a cannabis microbusiness in the
City of Hugo shall count towards the limit of cannabis retail registrations
under section 90-280(c)(2)(f) of this ordinance.
e) City staff shall review applications for cannabis mezzobusiness
licenses and verify that the application meets local ordinance requirements
prior to state license approval. In order to verify that an application meets
local ordinance requirements, the application must include the following to
be reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. Demonstration that all light and glare from interior lighting will
be confined to the interior of the building.
4. An exterior lighting plan that includes all lighting be downcast,
and is otherwise consistent with outdoor lighting requirements
under Section 90-239 of City Code.
5. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(f) Cannabis cultivators.
1. Performance Standards
a) All cultivation of cannabis must occur indoors and may not occur in
greenhouses, hoop houses, tents, or similar mixed-light structures. The
building(s) for a cannabis cultivator must be constructed to the standards for
commercial and industrial construction under Section 90-272 of City Code.
11
b) Cannabis cultivators are limited to a gross plant canopy area of 30,000
square feet.
c) Cannabis cultivators may utilize a portion of their building area for
post-harvest processing and packaging for transportation.
d) City staff shall review applications for cannabis cultivator licenses and
verify that the application meets local ordinance requirements prior to state
license approval. In order to verify that an application meets local ordinance
requirements, the application must include the following to be reviewed and
approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. An interior floor plan with dimensions of each room, and a
description of the stage of cannabis cultivation taking place in
each room.
4. Demonstration that all light and glare from interior lighting will
be confined to the interior of the building.
5. An exterior lighting plan that includes all lighting be downcast,
and is otherwise consistent with outdoor lighting requirements
under Section 90-239 of City Code.
6. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(g) Cannabis manufacturers.
1. Performance Standards.
a) All manufacturing of cannabis products must occur in an enclosed building
that is constructed to the standards for commercial and industrial
construction under Section 90-272 of City Code, and the standards for light
manufacturing under Section 90-240 of City Code.
b) City staff shall review applications for cannabis manufacturer licenses
and verify that the application meets local ordinance requirements prior to
state license approval. In order to verify that an application meets local
ordinance requirements, the application must include the following to be
reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. Demonstration that all light and glare from interior lighting will
be confined to the interior of the building.
4. An exterior lighting plan that includes all lighting be downcast,
and is otherwise consistent with outdoor lighting requirements
under Section 90-239 of City Code.
5. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
12
(h) Cannabis retailers.
1. Performance Standards
a) Hours of Operation – No cannabis retail business with a retail
registration issued by the city shall operate retail sales of cannabis
products, except between the hours of 10:00 AM and 10:00 PM.
b) City staff shall review applications for cannabis retailer licenses and
verify that the application meets local ordinance requirements prior to state
license approval. In order to verify that an application meets local
ordinance requirements, the application must include the following to be
reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. Plans for signage.
(i) Cannabis wholesalers.
1. Performance Standards
a) A cannabis wholesaler shall be subject to the performance standards
for warehousing and distribution under Section 90-269 of city code, except
that retail sales of cannabis products stored on site is prohibited.
b) A cannabis wholesaler that operates a motor freight terminal shall be
subject to all applicable performance standards under Section 90-248 of city
code, and shall require approval of a conditional use permit.
c) City staff shall review applications for cannabis wholesaler licenses
and verify that the application meets local ordinance requirements prior to
state license approval. In order to verify that an application meets local
ordinance requirements, the application must include the following to be
reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. An exterior lighting plan that includes all lighting be downcast,
and otherwise consistent with outdoor lighting requirements under
Section 90-239 of City Code.
4. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(j) Cannabis transporters.
1. Performance Standards
a) A cannabis transporter that operates a motor freight terminal shall be
subject to all applicable performance standards under Section 90-248 of city
code, and shall require approval of a conditional use permit.
b) City staff shall review applications for cannabis transporter licenses
and verify that the application meets local ordinance requirements prior to
13
state license approval. In order to verify that an application meets local
ordinance requirements, the application must include the following to be
reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. A plan for fleet management and storage, as applicable.
4. An exterior lighting plan that includes all lighting be downcast,
and otherwise consistent with outdoor lighting requirements under
Section 90-239 of City Code.
5. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(k) Cannabis testing facilities.
1. Performance Standards
a) Cannabis testing facilities shall meet the standards for cannabis
manufacturers under Section 90-280(g) of this ordinance, as well as any
other applicable rule or law.
b) City staff shall review applications for cannabis testing facility
licenses and verify that the application meets local ordinance requirements
prior to state license approval. In order to verify that an application meets
local ordinance requirements, the application must include the following to
be reviewed and approved by staff:
1. A security plan consistent with all state requirements.
2. A waste management plan consistent with all state requirements.
3. An exterior lighting plan that includes all lighting be downcast,
and otherwise consistent with outdoor lighting requirements under
Section 90-239 of City Code.
4. An odor control plan that is consistent with all standards adopted
by the state office of cannabis management and the state pollution
control agency.
(l) Lower-potency hemp edible manufacturers.
1. Performance Standards
a) Lower-potency hemp edible manufacturers shall meet the standards
for cannabis manufacturers under section 90-280(g) of this ordinance, as
well as any other applicable rule or law.
(m) Lower potency hemp edible retailers.
1. Performance Standards
a) Retail sales of lower-potency hemp edibles, in conjunction with a
state-issued license under Minn. Stat. 342.46, may only occur in an
establishment that:
14
1. Holds an alcohol license under Chapter 6, Article II of City Code,
except that the license shall not be a one-day permit.
2. Holds a tobacco license under Chapter 38, Article III, Division 2
of City Code.
3. Operates a cannabis retail location, subject to performance
standards under section 90-280(h) of this ordinance.
b) The registration of the retail location of a medical cannabis
combination business in the City of Hugo shall not count towards the limit
of cannabis retail registrations under section 90-280(c)(2)(f) of this
ordinance.
(n) Medical cannabis combination businesses.
1. Performance Standards
a) Medical cannabis combination businesses shall be conditional uses
within the I-3 and BP zoning districts
b) All cultivation of cannabis must occur indoors and may not occur in
greenhouses, hoop houses, tents, or similar mixed-light structures. The
building(s) for a cannabis cultivator must be constructed to the standards for
commercial and industrial construction under Section 90-272 of City Code.
c) All manufacturing of cannabis products must occur in an enclosed
building that is constructed to the standards for commercial and industrial
construction under Section 90-272 of City Code.
d) A medical cannabis combination business with appropriate
endorsements may operate a retail location within a building that also has
spaces for cultivation and manufacturing of cannabis products, provided that
the retail location does not exceed more than 2,500 square feet of gross floor
area.
e) The registration of the retail location of a medical cannabis
combination business in the City of Hugo shall not count towards the limit
of cannabis retail registrations under section 90-280(c)(2)(f) of this
ordinance.
f) A medical cannabis combination business that operates a warehouse
shall be subject to the performance standards for warehousing and
distribution under Section 90-269 of city code, except that retail sales of
cannabis products stored on site is prohibited. If the medical cannabis
combination business operates a motor freight terminal shall be subject to
all applicable performance standards under Section 90-248 of city code, and
include the motor freight terminal request in their conditional use permit
request.
15
(o) Cannabis delivery services.
1. Performance Standards
a) Cannabis delivery services licensed under Minn. Stat. 342.41 are
allowed as accessory uses if the primary use of the property is a cannabis
wholesaler, cannabis transporter, or medical cannabis combination business
operating a retail location, subject to all applicable performance standards
under section 90-280 of this ordinance.
b) Cannabis delivery services may operate between the hours of 10:00
AM and 10:00 PM, seven days per week.
EFFECTIVE DATE. This Ordinance shall be in full force and effect from and after its passage
by the City Council.
ADOPTED by the City Council this ____________________.
______________________________
Tom Weidt, Mayor
ATTEST:
_____________________________
Michele Lindau, City Clerk
A Guide for Local Governments
on Adult-Use Cannabis
Version 2.0 | Updated November 21, 2024
Page 2
Table of Contents
Introduction ................................................................................................ 3
About OCM ................................................................................................. 4
Cannabis License Types ................................................................................ 5
Adult-Use Cannabis Law .............................................................................. 7
Cannabis Licensing Process .......................................................................... 8
General Authorities ................................................................................... 13
Zoning and Land Use .................................................................................. 15
Local Approval Process .............................................................................. 18
Inspections and Compliance Checks ........................................................... 23
Municipal Cannabis Stores ......................................................................... 24
Creating Your Local Ordinance ................................................................... 25
Additional Information – Tobacco Sales ....................................................... 26
Additional Resources ................................................................................. 27
Page 3
Introduction
This guide serves as a general overview of Minnesota’s new adult-use cannabis law, and
how local governments can expect to be involved. The guide also provides important
information about Minnesota’s new Office of Cannabis Management (OCM), and the
office’s structure, roles, and responsibilities. While medical cannabis continues to play an
important role in the state’s cannabis environment, this guide is primarily focused on the
adult-use cannabis law and marketplace.
The following pages outline the variety of cannabis business licenses that will be issued,
provide a broad summary of important aspects of the adult-use cannabis law, and cover
a wide range of expectations and authorities that relate to local governments. This guide
also provides best practices and important requirements for developing a local
cannabis ordinance.
Chapter 342 of Minnesota law was established by the
State Legislature in 2023 and was updated in 2024.
Mentions of “adult-use cannabis law” or “the law”
throughout this guide refer to Chapter 342 and the
changes made to it.
As of this guide's date of publication, final state
regulations governing the adult-use cannabis market
have not yet been published. A draft of the rules is
available on our Rulemaking webpage
(https://mn.gov/ocm/laws/rulemaking.jsp).
The first draft of rules is based on substantial input OCM has received through surveys,
meetings, and conversations that took place since fall 2023, as well as OCM’s review of
Minnesota’s cannabis statute and cannabis rules in other states.
OCM will publish in the State Register a notice of intent to adopt rules, which will prompt
a 30-day formal comment period. Watch the OCM website for updates.
This guide is not a substitute for legal advice, nor does it seek to provide legal advice. Local governments and
municipal officials seeking legal advice should consult an attorney.
Page 4
About OCM
Minnesota’s Office of Cannabis Management is the state regulatory office created to
oversee the implementation and regulation of the adult-use cannabis market, the medical
cannabis market, and the consumer hemp industry. Housed within OCM are the Division
of Medical Cannabis (effective July 1, 2024), which operates the medical cannabis
program, and the Division of Social Equity, which promotes development, stability, and
safety in communities that have experienced a disproportionate, negative impact from
cannabis prohibition and usage.
OCM, through Chapter 342, is tasked with establishing rules and policy and exercising its
regulatory authority over the Minnesota cannabis industry. In its duties, OCM is
mandated to:
• Promote public health and welfare.
• Protect public safety.
• Eliminate the illicit market for cannabis flower and cannabis products.
• Meet the market demand for cannabis flower and cannabis products.
• Promote a craft industry for cannabis flower and cannabis products.
• Prioritize growth and recovery in communities that have experienced a
disproportionate, negative impact from cannabis prohibition.
OCM governs the application and licensing process for cannabis and hemp businesses,
specific requirements for each type of license and their respective business activities
and conducts enforcement and inspection activities across the Minnesota cannabis and
hemp industries.
Page 5
License Types
Minnesota law allows for 13 different types of business licenses, each fulfilling a unique
role in the cannabis and hemp supply chain. In addition to license types below, OCM will
also issue endorsements to license holders to engage in specific activities, including
producing, manufacturing, and sale of medical cannabis for patients.
Microbusiness
Microbusinesses may cultivate cannabis and manufacture cannabis products and hemp
products, and package such products for sale to customers or another licensed cannabis
business. Microbusiness may also operate a single retail location.
Mezzobusiness
Mezzobusinesses may cultivate cannabis and manufacture cannabis products and hemp
products, and package such products for sale to customers or another licensed cannabis
business. Mezzobusiness may also operate up to three retail locations.
Cultivator
Cultivators may cultivate cannabis and package such cannabis for sale to another licensed
cannabis business.
Manufacturer
Manufacturers may manufacture cannabis products and hemp products, and package
such products for sale to a licensed cannabis retailer.
Retailer
Retailers may sell immature cannabis plants and seedlings, cannabis, cannabis products,
hemp products, and other products authorized by law to customers and patients.
Wholesaler
Wholesalers may purchase and/or sell immature cannabis plants and seedlings,
cannabis, cannabis products, and hemp products from another licensed cannabis
business. Wholesalers may also import hemp-derived consumer products and lower-
potency hemp edibles.
Page 6
License Types (continued)
Transporter
Transporters may transport immature cannabis plants and seedlings, cannabis, cannabis
products, and hemp products to licensed cannabis businesses.
Testing Facility
Testing facilities may obtain and test immature cannabis plants and seedlings, cannabis,
cannabis products, and hemp products from licensed cannabis businesses.
Event Organizer
Event organizers may organize a temporary cannabis event lasting no more than four days.
Delivery Service
Delivery services may purchase cannabis, cannabis products, and hemp products from
retailers or cannabis business with retail endorsements for transport and delivery to
customers.
Medical Cannabis Combination Business
Medical cannabis combination businesses may cultivate cannabis and manufacture
cannabis and hemp products, and package such products for sale to customers, patients,
or another licensed cannabis business. Medical cannabis combination businesses may
operate up to one retail location in each congressional district.
Lower-Potency Hemp Edible Manufacturer
Lower-potency hemp edible manufacturers may manufacture and package lower-potency
hemp edibles for consumer sale, and sell hemp concentrate and lower-potency hemp
edibles to other cannabis and hemp businesses.
Lower-Potency Hemp Edible Retailer
Lower-potency hemp edible retailers may sell lower-potency hemp edibles to customers.
Each license is subject to further restrictions on allowable activities. Maximum cultivation area and manufacturing
allowances vary by license type. Allowable product purchase, transfer, and sale between licensees are subject to
restrictions in the law.
Page 7
The Adult-Use Cannabis Law
Minnesota’s new adult-use cannabis law permits the personal use, possession, and
transportation of cannabis by those 21 years of age and older, and allows licensed
businesses to conduct cultivation, manufacturing, transport, delivery, and sale of cannabis
and cannabis products.
For Individuals
• Possession limits:
o Flower - 2 oz. in public, 2 lbs. in private residence
o Concentrate - 8 g
o Edibles (including lower-potency hemp) - 800 mg THC
• Consumption only allowed on private property or at licensed
businesses with on-site consumption endorsements.
Consumption not allowed in public.
• Gifting cannabis to another individual over 21 years old is
allowed, subject to possession limits.
• Home cultivation is limited to four mature and four
immature plants (eight total) in a single residence. Plants must be in an enclosed
and locked space.
• Home extraction using volatile substances (e.g., butane, ethanol) is not allowed.
• Unlicensed sales are not allowed.
For Businesses
• Advertising:
o May not include or appeal to those under 21 years old.
o Must include proper warning statements.
o May not include misleading claims or false statements.
o Billboards are not allowed.
• The flow of all products through the supply chain must be
tracked by the state-authorized tracking system.
• All products sold to consumers and patients must be tested
for contaminants.
• Home delivery is allowed by licensed businesses.
Page 8
The Cannabis Licensing Process
An applicant will take the following steps to proceed from application to active licensure.
As described, processes vary depending on social equity status and/or whether the type
of license being sought is capped or uncapped in the general licensing process.
License Preapproval: Early Mover Process for Social Equity
Applicants
The license preapproval process is a one-time application process available for verified
social equity applicants. State law required OCM to open the application window on July
24, 2024, and close the window on August 12, 2024.
The preapproval process was available for the following license types, and all are capped
in this process: microbusiness, mezzobusiness, cultivator, manufacturer, retailer,
wholesaler, transporter, testing facility, and delivery service.
High-Level Pathway to License Preapproval and Conversion to Business Licensure
1. Applicant’s social equity applicant (SEA) status verified.
2. Applicant completes license preapproval application and submits application fees.
3. Application vetted for minimum requirements by OCM.
4. Application (if qualified) entered into lottery drawing.
5. If selected in lottery, applicant completes background check process and submits
attestation of labor-peace agreement.
6. If applicant successfully completes Step 5, OCM issues license preapproval to
applicant.
7. Applicants with license preapproval work with local governments to discuss zoning
compliance, secure property, raise capital, etc., pursuant to Minnesota Session Laws
2024, Chapter 121, Article 2, section 148.*
8. Once rules are adopted and applicant is ready to move to next step in conversion,
applicant with license preapproval* submits business location to OCM and updates
application accordingly.
9. OCM forwards completed application to local government.
Page 9
The Cannabis Licensing Process (cont.)
10. Local government completes zoning certification of whether a proposed cannabis
business complies with local zoning ordinances, and if applicable, whether the
proposed business complies with state fire code and building code. (This is distinct
from the retail registration approval process.)
11. OCM conducts site inspection.
12. If applicant successfully passes site inspection, OCM issues license, operations may
commence except for retail activity.
Continued High-Level Pathway for Licensees Seeking to Conduct Retail Sales: Process for
Required Local Retail Registration from Local Governments (Retailer, Microbusiness,
Mezzobusiness)
13. Licensed business seeks local retail registration from local government.
14. Local government approves applicant for retail registration through means
determined by ordinance (see page 19 for more information about the retail
registration process).
15. Applicant pays retail registration fee to the local government (see appendix for
relevant fees in accordance with Minn. Stat., section 342.22).
16. Local government conducts compliance check for any applicable local ordinance
established pursuant to Minn. Stat., section 342.13, if desired.
17. Local government ensures tax compliance, if applicable.
18. Local government issues retail registration to licensee.
19. Licensee is able to conduct retail sales now that they have received a state license
and a local retail registration.
*Social equity applicants with license preapproval for microbusiness, mezzobusiness, or cultivator licenses may
begin growing cannabis plants prior to the adoption of rules if OCM receives both a signed and completed Local
Approval of Early Cultivation Form from the local government, and also a signed and completed Applicant Notice of
Intent for Early Cultivation Form. “The Local Approval of Early Cultivation" form is available now and linked in the
appendix.
This is only applicable to cultivation and does not authorize retail sales or other endorsed activities of the licenses
prior to the adoption of rules. OCM will share additional guidance related to the early cultivation opportunity and
local governments’ role in this distinct process.
Page 10
The Cannabis Licensing Process (cont.)
The general licensing process will align with the adoption of rules and OCM will share
more information about the timing of general licensing process. The general licensing
process includes social equity applicants and non-social equity applicants.
General Licensing: Cultivator, Manufacturer, Retailer,
Mezzobusiness
1. Applicant completes application and submit application fees. If applicable, an
applicant’s social equity applicant status may be verified.
2. Application vetted for minimum requirements by OCM.
3. Application (if qualified) entered into lottery drawing.
4. If selected in lottery, applicant completes background check process and submits
attestation of labor-peace agreement.
5. If applicant successfully completes Step 5, OCM issues preliminary approval to
applicant.
6. Once prepared for final licensure, applicant with preliminary approval submits
business location and updates application accordingly.
7. OCM forwards completed application to local government.
8. Local government completes zoning certification of whether a proposed cannabis
business complies with local zoning ordinances, and if applicable, whether the
proposed business complies with state fire code and building code. (This is distinct
from the retail registration approval process.)
9. OCM conducts site inspection.
10. If applicant successfully passes site inspection, OCM issues license, operations may
commence except for retail activity.*
Continued High-Level Pathway for Licensees Seeking to Conduct Retail Sales: Process for
Required Local Retail Registration from Local Governments (Retailer, Mezzobusiness)
11. Licensed business seeks local retail registration from local government.
12. Local government approves applicant for retail registration through means
determined by ordinance (see Page 19 for more information about the retail
registration process).
Page 11
The Cannabis Licensing Process (cont.)
13. Applicant pays retail registration fee to the local government (see appendix for
relevant fees in accordance with Minn. Stat., section 342.22).
14. Local government conducts compliance check for any applicable local ordinance
established pursuant to Minn. Stat., section 342.13, if desired.
15. Local government ensures tax compliance, if applicable.
16. Local government issues retail registration to licensee.
17. Licensee is able to conduct retail sales now that they have received a state license
and a local retail registration.
*For businesses seeking a retail endorsement (microbusiness, mezzobusiness, and retailer), a valid local retail
registration is required prior to the business commencing any retail sales. See Page 19 for information on the local
retail registration process.
General Licensing: Microbusiness, Wholesaler, Transporter, Testing
Facility, Medical Cannabis Combination Business
1. Applicant complete application and submit application fees. If applicable, an
applicant’s social equity applicant status may be verified.
2. Application vetted for minimum requirements by OCM.
3. For qualified applicants, applicant completes background check process and submits
attestation of labor-peace agreement.
4. If applicant successfully completes Step 3, OCM issues preliminary approval to
applicant.
5. Once prepared for final licensure, selected applicant submits business location and
amends application accordingly.
6. OCM forwards completed application to local government.
7. Local government completes zoning certification of whether a proposed cannabis
business complies with local zoning ordinances, and if applicable, whether the
proposed business complies with state fire code and building code. (This is distinct
from the retail registration approval process.)
8. OCM conducts site inspection.
9. If applicant successfully passes site inspection, OCM issues license, operations may
commence except for retail activity.*
Page 12
The Cannabis Licensing Process (cont.)
Continued High-Level Pathway for Licensees Seeking to Conduct Retail Sales: Process for
Required Local Retail Registration from Local Governments (Microbusiness, Medical
Cannabis Combination Businesses)
10. Licensed business seeks local retail registration from local government.
11. Local government approves applicant for retail registration through means
determined by ordinance (see Page 19 for more information about the retail
registration process).
12. Applicant pays retail registration fee to the local government (see appendix for
relevant fees in accordance with Minn. Stat., section 342.22).
13. Local government conducts compliance check for any applicable local ordinance
established pursuant to Minn. Stat., section 342.13, if desired.
14. Local government ensures tax compliance, if applicable.
15. Local government issues retail registration to licensee.
16. Licensee is able to conduct retail sales now that they have received a state license
and a local retail registration.
*For businesses seeking a retail endorsement (microbusiness, mezzobusiness, and retailer), a valid local retail
registration is required prior to the business commencing any retail sales. See Page 19 for information on the local
retail registration process.
Applicant Responsibility
All applicants and licensees are responsible for working with their local government to
ensure their success in the zoning certification and, if applicable based on license type,
the local retail registration process. This includes reviewing local ordinances and
understanding how the local government will be selecting applicants for a retail
registration (including if retail registrations will be limited). Local units of government
have the statutory authority to limit retail registrations if they desire, and applicants
should understand this prior to making decisions about site locations.
OCM will not facilitate communication between applicants and units of local government,
nor can it mediate disputes as they relate to local zoning compliance or retail registration.
OCM is required to ask each local unit of government where an applicant intends to
locate a business if that business has met all zoning and use requirements.
Page 13
General Authorities
Local governments in Minnesota have various means of oversight over the cannabis
market, as provided by the adult-use cannabis law. Local governments may not issue
outright bans on cannabis business, or limit operations in a manner beyond what is
provided by state law.
Cannabis Retail Restrictions (342.13)
Local governments may limit the number of retailers and microbusiness/mezzobusinesses
with retail endorsements allowed within their locality, as long as there is at least one
retail location per 12,500 residents. Local units of government are not obligated to seek
out a business to register as cannabis business if they have not been approached by any
potential applicants but cannot prohibit the establishment of a business if this population
requirement is not met. Local units of government may also issue more than the
minimum number of registrations. Per statutory direction, a municipal cannabis store
(Page 24) cannot be included in the minimum number of registrations required. For
population counts, the state demographer estimates will likely be utilized.
Tribal Governments (342.13)
OCM is prohibited from and will not issue state licenses to businesses in Indian Country
without consent from a tribal nation. Tribal nations hold the authority to license tribal
cannabis businesses on tribal lands – this process is separate than OCM’s licensing
process and authority. Subject to compacting, Tribal nations may operate cannabis
businesses off tribal lands. There will be more information available once the compacting
processes are complete.
Taxes (295.81; 295.82)
Retail sales of taxable cannabis products are subject to the state and local sales and use
tax and a 10% gross receipts tax. Cannabis gross receipts tax proceeds are allocated as
follows: 20% to the local government cannabis aid account and 80% to the state general
fund. Local taxes imposed solely on sale of cannabis products are prohibited.
Cannabis retailers will be subject to the same real property tax classification as all other
retail businesses. Real property used for raising, cultivating, processing, or storing
cannabis plants, cannabis flower, or cannabis products for sale will be classified as
commercial and industrial property.
Page 14
General Authorities (cont.)
Retail Timing Restrictions (342.13)
Local governments may prohibit retail sales of cannabis between the hours of 8 a.m. and
10 a.m. Monday-Saturday, and 9 p.m. and 2 a.m. the following day.
Operating Multiple Locations with One License
Certain cannabis licenses allow for multiple retail locations to be operated under a single
license, with the following limitations:
• Retailers: up to five retail locations.
• Mezzobusinesses: up to three retail locations.
• Microbusinesses: up to one retail location.
• Medical cannabis combination businesses: one retail location per congressional
district. Additionally, medical cannabis combination businesses may cultivate at
more than one location within other limitations on cultivation.
For all other license types, one license permits the operation of one location. Each retail
location requires local certification and/or registration.
Page 15
Zoning and Land Use
Buffer Guidelines (342.13)
State law does not restrict how a local government conducts its zoning designations for
cannabis businesses, except that they may prohibit the operation of a cannabis business
within 1,000 feet of a school, or 500 feet of a day care, residential treatment facility, or an
attraction within a public park that is regularly used by minors, including playgrounds and
athletic fields.
Zoning Guidelines
While each locality conducts its zoning differently, a few themes have emerged across the
country. For example, cannabis manufacturing facilities are often placed in industrial
zones, while cannabis retailers are typically found in commercial/retail zones. Cannabis
retail facilities align with general retail establishments and are prohibited from allowing
consumption or use onsite and are also required to have plans to prevent the visibility of
cannabis and hemp-derived products to individuals outside the retail location. Industrial
hemp is an agricultural product and should be zoned as such.
Cannabis businesses should be zoned under existing zoning ordinances in accordance
with the license type or endorsed activities held by the cannabis business. Note that
certain types of licenses may be able to perform multiple activities which may have
different zoning analogues. In the same way municipalities may zone a microbrewery that
predominately sells directly to onsite consumers differently than a microbrewery that
sells packaged beer to retailers and restaurants, so too might a municipality wish to zone
two microbusinesses based on the actual activities that each business is undertaking.
Table 1, included on Pages 16 and 17, explains the types of activities that cannabis
businesses might undertake, as well as some recommended existing zoning categories.
Page 16
Zoning and Land Use (cont.)
Table 1: Cannabis and Hemp Business Activities
Endorsed
Activity
License Type
Eligible to Do
Endorsed Activity
Description of Activity Comparable
Districts
Municipal
Considerations
Cultivation
• Cultivator
• Mezzobusiness
• Microbusiness
• Medical
Cannabis
• Combination
“Cultivation” means any
activity involving the
planting, growing,
harvesting, drying,
curing, grading, or
trimming of cannabis
plants, cannabis flower,
hemp plants, or hemp
plant parts.
Indoor:
Industrial,
Commercial,
Production
Outdoor:
Agricultural
• Odor
• Potential need for
transportation from
facility
• Waste, water, and
energy usage
• Security
Cannabis
Manufacturing,
Processing,
Extraction
• Manufacturer
• Mezzobusiness
• Medical
Cannabis
• Combination
This group of endorsed
activities turn raw, dried
cannabis and cannabis
parts into other types of
cannabis products, e.g.
edibles or topicals.
Indoor:
Industrial,
Commercial,
Production
• Odor
• Potential need for
transportation from
facility
• Waste, water, and
energy usage
• Security
Hemp
Manufacturing
• Lower-Potency
Hemp Edible
(LPHE)
Manufacturing
These businesses
convert hemp into LPHE
edible products.
Indoor:
Industrial,
Commercial,
Production
• Odor
• Waste, water, and
energy
Wholesale
• Wholesale
• Cultivator
• Manufacturer
• Mezzobusiness
• Microbusiness
• Medical
Cannabis
• Combination
This activity and license
type allows a business
to purchase from a
business growing or
manufacturing cannabis
or cannabis products
and sell to a cannabis
business engaged in
retail.
Indoor:
Industrial,
Commercial,
Production
• Need for
transportation from
facility
• Security
Page 17
Zoning and Land Use (cont.)
Table 1: Cannabis and Hemp Business Activities (continued)
Endorsed
Activity
License Type
Eligible to Do
Endorsed Activity
Description of
Activity
Comparable
Districts
Municipal
Considerations
Cannabis Retail
• Retailer
• Mezzobusiness
• Microbusiness
• Medical
Cannabis
• Combination
This endorsed
activity and
license type
allow a business
to sell cannabis
products directly
to consumers.
Indoor: Retail,
Neighborhood
Shopping Districts,
Light Industrial,
Existing districts
where off-sale
liquor or tobacco
sales are allowed.
• Micros may offer
onsite consumption,
similar to breweries.
• Micros and Mezzos
may include multiple
activities: cultivation,
manufacture, and/or
retail.
Transportation • Cannabis
Transporter
This license type
allows a
company to
transport
products from
one license type
to another.
-
• Fleet based
businesses that will
own multiple
vehicles, but not
necessarily hold a
substantial amount
of cannabis or
cannabis products.
Delivery • Cannabis
Delivery
This license type
allows for
transportation to
the end
consumer.
-
• Fleet based business
that will own
multiple vehicles,
but not necessarily
hold a substantial
amount of cannabis
or cannabis
products.
Events • Event Organizer
This license
entitles license
holder to
organize a
temporary event
lasting no more
than four days.
Anywhere that the
city permits events
to occur, subject to
other restrictions
related to cannabis
use.
• On site
consumption.
• Retail sales by a
licensed or endorsed
retail business
possible.
Page 18
Local Approval Process
Local governments play a critical role in the licensing process,
serving as a near-final approval check on cannabis businesses
nearing the awarding of a state license for operations. Once an
applicant has been vetted by OCM and is selected for
proceeding in the verification process, they are then required to
receive the local government’s certification of zoning
compliance and/or local retail registration before operations
may commence.
Local Certification of Zoning Compliance (342.13; 342.14)
Following OCM’s vetting process, local governments must certify that the applicant with
preliminary approval has achieved compliance with local zoning ordinances prior to the
licensee receiving final approval from OCM to commence operations.
During the application and licensing process for cannabis businesses, OCM will notify a
local government when an applicant intends to operate within their jurisdiction and
request a certification as to whether a proposed cannabis business complies with local
zoning ordinances, and if applicable, whether the proposed business complies with state
fire code and building code.
According to Minnesota’s cannabis law, a local unit of government has 30 days to respond
to this request for certification of compliance. If a local government does not respond to
OCM’s request for certification of compliance within the 30 days, the cannabis law allows
OCM to issue a license. OCM may not issue the final approval for a license if the local
government has indicated they are not in compliance.
OCM will work with local governments to access the licensing software system to
complete this zoning certification process.
Page 19
Local Approval Process (cont.)
Local Retail Registration Process (342.22)
Once the licensing process begins, local government registration applies to licensed
cannabis retailers or other cannabis/hemp businesses seeking to conduct retail sales.
Several license types are authorized to conduct retail sales if they receive a retail
endorsement from OCM. Prior to conducting retail sales under their business license,
state law also requires the business receive a local retail registration.
There are five license types that are eligible to conduct cannabis retail activity and will
seek a retail registration from local governments:
• Cannabis retailers
• Microbusinesses
• Mezzobusinesses
• Medical cannabis combination businesses
• Lower-potency hemp edible retailers
Local governments must issue a retail registration after verifying that:
• The business has a valid license or license preapproval issued by OCM.
• The business has paid a registration fee or renewal fee to the local government.
o Initial registration fees collected by a local government may be $500 or half
the amount of the applicable initial license fee, whichever is less, and
renewal registration fees may be $1,000 or half the amount of the applicable
renewal license fee, whichever is less.
• The business is found to be in compliance with Chapter 342 and local ordinances.
• If applicable, the business is current on all property taxes and assessments for the
proposed retail location.
Local registrations may also be issued by counties if the respective local government
transfers such authorities to the county.
Page 20
Local Approval Process (cont.)
Option to Limit Retail Registrations for Cannabis Businesses:
Determining a Process
State law allows the option for a local government to place a limitation on the number of
cannabis retailers, microbusiness, and mezzobusinesses with retail endorsements allowed
within their locality via ordinance, as long as there is at least one retail location per 12,500
residents. Please see Page 13. Retail registrations for lower-potency hemp edible retailers
and medical cannabis combination businesses are required but may NOT be limited in
number by a local government.
If a local government wishes to limit the number of cannabis retailers, microbusinesses,
or mezzobusinesses via ordinance, state law does not define the process for a local
government’s selection if there are more applicants than registrations available.
Local units of government issuing retail registrations should consider how they will issue
retail registrations. Local units of government may wish to consider whether they will
accept applications during a specified application window or on a rolling basis. Local
governments may wish to consider how to accommodate to the timing of accepting
applications for retail registration as to not allocate all registrations at once. This may also
include timelines that coincide with state licensing timelines as to limit bottlenecks.
Additionally, local units of government should consider the process by which they will
determine who gets a registration, e.g., through the use of a lottery, on a first-come/first-
serve model, through a merit-based scoring system, etc. It is highly recommended that
local governments work with an attorney to determine their specific process for selection
if they wish to limit the number of retail registrations per section 342.13.
It is also important to note that local governments are not required to limit the number of
licensed cannabis retailers, microbusinesses, or mezzobusinesses, and instead local
governments can determine a process that reviews requests/applications for retail
registrations as they are received.
Page 21
Local Approval Process (cont.)
Other Considerations
Existing retail locations. Retailers in Minnesota’s medical cannabis program and lower-
potency hemp edible program may currently be operating in a local government’s
jurisdiction under active registrations. In the future, these active businesses will be
required to obtain a license from OCM and will need a local retail registration to continue
their operations. Local governments may wish to consider how businesses currently
operating will be issued retail registrations when determining if and how to limit retail
registrations.
Local zoning approval does not guarantee retail registration. Zoning certification from
local governments does not guarantee a local retail registration. This is a distinctly
separate approval process. All applicants seeking retail activity will be required to obtain a
zoning certification from the local government to be issued a state license. Local
governments may wish to monitor the number of zoning certifications they provide to
OCM to inform the likely volume of retail registration applicants.
Page 22
Local Approval Process (cont.)
Local governments are permitted specific authorities for registration refusal and
registration suspension, in addition to—and not in conflict with—OCM authorities.
Registration and Renewal Refusals
Local governments may refuse the registration and/or
certification of a license renewal if the license is associated
with an individual or business who no longer holds a valid
license, has failed to pay the local registration or renewal
fee, or has been found in noncompliance in connection with
a preliminary or renewal compliance check.
Local Registration Suspension (342.22)
Local governments may suspend the local retail registration of a cannabis business or
hemp business if the business is determined to not be operating in compliance with a
local ordinance authorized by section 342.13 or if the operation of the business poses an
immediate threat to the health and safety of the public. The local government must
immediately notify OCM of the suspension if it occurs. OCM will review the suspension
and may reinstate the registration or take enforcement action.
Expedited Complaint Process (342.13)
Per state law, OCM will establish an expedited complaint process during the rulemaking
process to receive, review, read, and respond to complaints made by a local unit of
government about a cannabis business. Upon promulgation of rules, OCM will publish the
complaint process.
At a minimum, the expedited complaint process shall require the office to provide an
initial response to the complaint within seven days and perform any necessary
inspections within 30 days. Within this process, if a local government notifies OCM that a
cannabis business poses an immediate threat to the health or safety of the public, the
office must respond within one business day.
Page 23
Inspections & Compliance Checks
Local governments are permitted specific business inspection and compliance check
authorities, in addition to—and not in conflict with—OCM authorities.
Inspections and Compliance Checks (342.22)
Local governments must conduct compliance
checks for cannabis and hemp businesses holding
retail registration at least once per calendar year.
These compliance checks must verify compliance
with age verification procedures and compliance
with any applicable local ordinance established
pursuant to section 342.13. OCM maintains
inspection authorities for all cannabis licenses to
verify compliance with operation requirements,
product limits, and other applicable requirements
of Chapter 342.
Page 24
Municipal Cannabis Stores
As authorized in section 342.32, local governments are
permitted to apply for a cannabis retail license to establish
and operate a municipal cannabis store.
State law requires OCM issue a license to a city or county
seeking to operate a single municipal cannabis store if the
city or county:
• Submits required application information to OCM,
• Meets minimum requirements for licensure, and
• Pays applicable application and license fee.
A municipal cannabis store will not be included in the total count of retail licenses issued
by the state under Chapter 342.
A municipal cannabis store cannot be counted as retail registration for purposes of
determining whether a municipality’s cap on retail registrations imposed by ordinance.
Page 25
Creating Your Local Ordinance
As authorized in section 342.13, a local government may adopt a local ordinance
regarding cannabis businesses. Establishing local governments’ ordinances on cannabis
businesses in a timely manner is critical for the ability for local cities or towns to establish
local control as described in the law and is necessary for the success of the statewide
industry and the ability of local governments to protect public health and safety. The
cannabis market’s potential to create jobs, generate revenue, and contribute to economic
development at the local and state level is supported through local ordinance work. The
issuance of local certifications and registrations to prospective cannabis businesses is also
dependent on local ordinances.
• Local governments may not prohibit the possession,
transportation, or use of cannabis, or the establishment or
operation of a cannabis business licensed under state law.
• Local governments may adopt reasonable restrictions on the
time, place, and manner of cannabis business operations (see
Page 14).
• Local governments may adopt interim ordinances to protect
public safety and welfare, as any studies and/or further
considerations on local cannabis activities are being
conducted, until January 1, 2025. A public hearing must be
held prior to adoption of an interim ordinance.
• If your local government wishes to operate a municipal
cannabis store, the establishment and operation of such a
facility must be considered in a local ordinance.
Model Ordinance
For additional guidance regarding the creation of a cannabis related ordinance, please
reference the additional resources on page 27.
Page 26
Additional Information – Tobacco Sales
Penalties Related to a Revocation or
Suspension of Tobacco License
A cannabis or hemp business license holder may also hold a
tobacco license under Minnesota Statutes Chapter 461.
However, tobacco cannot be sold in the cannabis retail
location. Under section 461.12, Minnesota law allows a
licensee’s authority to sell tobacco and related products
under the section to be suspended and possibly revoked if
the licensee also holds a cannabis or hemp business license
under Chapter 342 or is a registrant under section 151.72
and that license or registration is revoked. This penalty also
applies if the license holder is convicted of an offense under
section 151.72 or has been convicted under any other
statute for illegal sale of cannabis products.
Clarifying Cannabis Businesses Authority
Cannabis businesses will be able to sell vaporizers without
a tobacco license. Under Minnesota Statutes, section
342.27, subd. 3(a), retail licensees are permitted to sell
cannabis paraphernalia. Cannabis paraphernalia includes
“all equipment, products, and materials of any kind that
are knowingly or intentionally used primarily in ...
ingesting, inhaling, or otherwise introducing cannabis
products into the human body” [Minnesota Statutes,
section 342.01, subd. 18(2)]. Therefore, Minnesota
Statutes, section 342.27, subd. 3(a) specifically authorizes
retail licensees to sell cannabis paraphernalia, which in
this instance includes vaporizers.
Page 27
Additional Resources
OCM Toolkit for Local Partners
Please visit the OCM webpage (mn.gov/ocm/local-governments/) for additional
information, including a toolkit of resources developed specifically for local government
partners. The webpage will be updated as additional information becomes available and
as state regulations are adopted.
Toolkit resources include:
• Appendix A: Cannabis Model Ordinance (mn.gov/ocm/lgg-appendix-a)
• Appendix B: Retail Registration Form and Checklist (mn.gov/ocm/lgg-appendix-b)
• Appendix C: Cannabis Flower and Hemp-Derived Cannabinoid Products
Inspection Checklist (mn.gov/ocm/lgg-appendix-c)
• Appendix D: Enforcement Notice from the Office of Cannabis Management
(mn.gov/ocm/lgg-appendix-d)
• Appendix E: Notice to Unlawful Cannabis Sellers (mn.gov/ocm/lgg-appendix-e)
• Appendix F: Model Guidelines on Age Verification Compliance Checks Policy and
Procedures (mn.gov/ocm/lgg-appendix-f)
• Appendix G: Cannabis and Hemp Age Compliance Check Form (mn.gov/ocm/lgg-
appendix-g)
• Appendix H: Local Unit of Government Cannabis Licensing Contact, Delegation
Form, and Accela Registration Instructions Guide (mn.gov/ocm/local-
governments/contactform.jsp)
• Appendix J: Local Approval for Early Cultivation (mn.gov/ocm/lgg-appendix-j)
Local Organizations
There are several organizations who also have developed resources to support local
governments regarding the cannabis industry. Please feel free to contact the following for
additional resources:
• League of Minnesota Cities
• Association of Minnesota Counties
• Minnesota Public Health Law Center
From:Dean Anderson
To:Tom Weidt; Becky Petryk; Phil Klein; Dave Strub; Mike Miron; Michele Lindau; Bryan Bear; Max Gort; Rachel Juba
Cc:Reece Geel; Isabeau Ryan
Subject:Hugo"s Future - Cannabis Zoning
Date:Monday, December 2, 2024 11:08:38 AM
You don't often get email from dean@uffda.cc. Learn why this is important
Caution: This email originated outside our organization; please use caution.
The decisions you are about to make over the next few weeks on where and how cannabis cultivation can occur are not just
policy—they are a defining moment for Hugo’s future. These choices will ripple through our community, affecting not only
businesses like ours but also the very character and legacy of our city. This is an opportunity to lead, to shape Hugo into a
place where tradition and innovation coexist, and where small farms and new ideas thrive together.
It is imperative that cannabis cultivation be considered an agricultural activity. The world around us is changing, and farming
as we know it is under threat. Small farms are disappearing, swallowed up by corporations that prioritize profit over
stewardship. Traditional crops like corn, soybeans, and dairy have become increasingly difficult to grow and sell profitably,
especially for independent farmers. The dream of owning a farm and being a full-time farmer is slipping away for many,
unless they can operate at an industrial scale.
We can see the writing on the wall. The aging hands that have tilled Hugo’s soil for decades are slowly retiring, and their
farms—those patches of land that hold generations of blood, sweat, and dreams—are at a crossroads. What will become of
them?
Without innovation, their futures are bleak. These small, family-owned farms will either be swallowed whole by faceless Big
Ag corporations, stripping them of their soul and connection to the community, or flattened and sold off to developers, paving
over the legacy of Hugo’s agricultural roots.
But it doesn’t have to be this way. We have an opportunity—a responsibility—to ensure that these farms not only survive but
thrive. By embracing innovation, like incorporating cannabis cultivation as a modern cash crop, we can give the next
generation of farmers the tools to succeed. We can preserve the heart of Hugo while paving the way for a future where
farming is once again a livelihood to aspire to.
Cannabis offers an opportunity to revitalize farming. As a cash crop, it has the potential to make homesteading and small-
scale farming tangible again, giving new farmers a viable path to succeed without relying on massive volumes.
We moved to Hugo with a vision of escaping the city, purchasing land, and building a homestead where we could grow
cannabis. We were drawn to Hugo for its vibrant community of modern farmers—people like Niemczyk Gardens, T and
Nae’s Flower Farm, and Applecrest Orchard—just to name a few who exemplify the harmony of agriculture and community.
Restricting cannabis cultivation to industrial zones would miss the chance to treat this crop as part of our agricultural heritage
and risks framing a vibrant opportunity as something disconnected from the land.
Cannabis is not just a crop; it is a symbol of innovation and resilience in farming. It has the power to preserve Hugo’s
agricultural roots while supporting sustainable growth. The choice of how to zone cannabis cultivation belongs to this council
and this community—not distant bureaucrats who don’t know the heart of Hugo. This is your moment to lead, to protect the
values and character of our city, and to ensure that the decisions made today honor the legacy of those who built Hugo while
securing a future where the next generation can thrive and the promise of the American Dream endures.
Thank you for your time and thoughtful consideration.
Dean, Beau, and Reece
Some people who received this message don't often get email from lyndabarry760@gmail.com. Learn why this is
important
From:Michele Lindau
To:Max Gort; Rachel Juba
Subject:FW: Hugo Cannabis - Important Distinction in the Population Rule
Date:Thursday, December 5, 2024 10:25:55 AM
Attachments:image001.png
Michele Lindau
Hugo City Clerk
651-762-6315
From: Lynda Barry <lyndabarry760@gmail.com>
Sent: Thursday, December 5, 2024 10:13 AM
To: Tom Weidt <mayortom@ci.hugo.mn.us>; Becky Petryk <jdpetryk@gmail.com>; Phil Klein
<philklein7@msn.com>; Dave Strub <dstrub@ci.hugo.mn.us>; Mike Miron
<mmiron@ci.hugo.mn.us>
Cc: Hugo Info <info@ci.hugo.mn.us>; Bryan Bear <bbear@ci.hugo.mn.us>; Michele Lindau
<mlindau@ci.hugo.mn.us>
Subject: Hugo Cannabis - Important Distinction in the Population Rule
Caution: This email originated outside our organization; please use
caution.
Dear Mayor Weidt and City Council Members ~
In reading the Nov 27 news article titled Hugo City Council sets public hearing for
cannabis, I noticed that a very important nuance is missing in the following quote:
" ...Per state statute, the city of Hugo would be required to allow a minimum of two
cannabis businesses due to its population of 17,000. (One retail license is required
per 12,500 residents.)" ... "Mayor Tom Weidt said that was a “big roundup,” but Gort
explained that is the way the law is written."
Having not attended the meeting, I don't know if Mr. Gort failed to mention - or if
the reporter failed to include in the article - that under section
342.13 subsection (j) If a county has one active registration for every 12,500
residents, a city or town within the county is not obligated to register a
cannabis business.
In other words, if other cities within Washington county wish to exceed their
population requirement, Hugo may not be required to issue any cannabis licenses at
all ... or possibly issue just one license. [(k) Nothing in this section shall prohibit a
local government unit from allowing licensed cannabis retailers in excess of the
minimums set in paragraph (i).]
I do not personally have a strong position on this topic one way or another - except
for the fact that as 7-year residents of Hugo, my husband and I are both STRONG
proponents of Hugo keeping the "small town/rural" feel we fell in love with (and the
reason we happily left our St. Paul home of 30 years). Sadly, over the past 3 or 4
years we feel this rapidly slipping away and caution against any further actions
(cannabis or otherwise) which might further deteriorate the unique treasure that is
Hugo, MN.
Thank you for your time and for your service to our beautiful community.
Lynda (and Jeff) Barry
165th Street N, Hugo