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HomeMy WebLinkAboutbocc.ord.024.2016 AN ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF PITKIN COUNTY AUTHORIZING AMENDMENTS TO SECTIONS 6.48 AND 6.49 OF THE PITKIN COUNTY CODE REGULATING RETAIL AND MEDICAL MARIJUANA LICENSING ORDINANCE NO.D ti -2016 RECITALS 1. The purpose of Pitkin County's retail and medical marijuana regulations is to authorize licensing in unincorporated Pitkin County as provided by state statute by establishing specific standards and procedures for local licensing of retail marijuana establishments and of medical marijuana centers,medical marijuana infused products manufacturers,and optional premises medical marijuana cultivation operations. 2. The Board of County Commissioners ("Board") is authorized to amend Pitkin County's Retail and Medical Marijuana Licensing Regulations from time to time as necessary to protect the health safety, and welfare of the residents of Pitkin County. 3. The following amendments are hereby made to Section 6.48 and 6.49 of the Pitkin County Code regulating retail and medical marijuana licensing: a. Section 6.48.070(C)(16) and Section 6.49.070(C)(17) shall be amended to reflect that in addition to an application for any type of retail or medical marijuana establishment being referred for recommendation and comment to the caucus in which the proposed licensed facility is located, such applications shall also be referred to any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. b. Section 6.49.100(H) shall be amended to permit the sale of marijuana accessories at medical marijuana centers,limited exclusively to those accessories needed for ingesting, inhaling,or otherwise introducing marijuana into the human body,as defined by Section 16, Article XVIII of the Colorado Constitution. c. Section 6.49.140 shall be amended to reflect an initial medical marijuana licensing application fee of$2,500. d. Section 6.48.140 shall be amended to reflect that retail marijuana operating fees are fees in addition to application fees. e. Sections 6.48.140 and 6.49.140 shall be amended to reflect that all additional costs over the amount of applicable application fees (and operating fees in the case of retail medical marijuana),to investigate,remediate, process referrals or otherwise respond to applications or violations of State or County laws or license conditions shall be the responsibility ORDINANCE 7 2016 PAGE 2 of the licensee and shall be remitted to Pitkin County at a rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all license issued to the licensee. 7. The BOCC finds that adoption of this ordinance is necessary for the immediate preservation of the public health, safety and welfare of the citizens of Pitkin County and therefore declares this ordinance and legislation to be effective immediately. NOW THEREFORE, BE IT ORDAINED by the Board of County Commissioners of Pitkin County, Colorado that Sections 6.48.070(C)(16), 6.49.070(C)(17), 6.49.100(H), 6.48.140 and 6.49.140 of the Pitkin County Code regulating retail and medical marijuana licensing are hereby amended as set forth above and depicted in redline on Exhibit 1 attached hereto. INTRODUCED AND FIRST READ ON THE 26TH DAY OF SEPTEMBER 2016 AND SET FOR SECOND READING AND PUBLIC HEARING ON THE 2ND DAY OF NOVEMBER 2016. NOTICE OF PUBLIC HEARING AND TITLE AND SHORT SUMMARY OF THF, ORD CE PUBLISHED IN THE ASPEN TIMES WEEKLY ON THE alt DAY OF h,e✓ 2016. NOTICE OF PUBLIC HEARING AND THE FULL TEXT OF THE ORDINANCE POSTED ii ON THE OFIgj-IAL PITKIN COUNTY WEBSITE( www.pitkincounty.com )ON THE C/ DAY OF 12,e Y 2016. A Gal ADIOPTED AFTER FINAL READING AND PUBLIC HEARING ON THE DAY OF ) I Gt/L-lA/Lbu2.r 2016. PUBLISHED BY TITLE AND SHORT SUMM4RY,AFTER ADOPTION, IN THE ASPEN TIMES WEEKLY ON THE Mk DAY OF 2016. POSTED BY TITLE AND SHORT SUMMARY ON THE OFF, ICIAL PITKIN COUNTY WEBSITE (www.pitkincounty.com) ON THE DAY OF/Ioci-e_ixkev,2016. THIS ORDINANCE IS EI}FECTIVE ON //-2 - , 2016. T: BOARD OF COUNTY COMMISSIONERS ,/ B} if .r, iL' By: . Je. ette Jones Rachel Richards, Chair D Duty County Cl-rk Date: //-9- APPROVED /-9-APPROVED AS TO FORM: MANAGER APPROVAL: 2 ORDINANCE# .,/V'2„016 PAGE PAGE2 �. John Ely,C•. orney Jon Pea ck, County Manager 3 EXHIBIT 1 Amendments to the Pitkin County Code Regulating Retail and Medical Marijuana Licensing(Depicted in Redline) RETAIL MARIJUANA LICENSING REGULATIONS 6.48.070(C)(16): REVIEW CRITERIA 16. A license will not be issued for any type of retail marijuana establishment in the following Caucus Areas: Snowmass-Capitol, Frying Pan, Woody Creek and Emma. A license for a retail marijuana store will not be issued within the Town of Redstone (Village Commercial District) in the Crystal River Caucus. The prohibition on the issuance of licenses described in this paragraph shall remain in place until February 15, 2018. All applications for any type of retail marijuana establishment shall be referred for recommendation and comment to the apprepfiate-caucus of the proposed licensed facility and any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. awl-comme#- 6.48.140: OPERATING FEES Operating Fees are fees in addition to application fees. All additional costs over the amount of applicable application and operating fees to investigate, remediate, process referrals or otherwise respond to applications or violations of State and County laws or license conditions shall be the responsibility of the licensee and shall be remitted to Pitkin County at the rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all licenses issues to the licensee. Operating Fees Applicable to: Initial License Renewal License Retail marijuana store $3,000 $1,500 Retail marijuana cultivation facility $3,000 $1,500 Retail marijuana products manufacturing facility $3,000 $1,500 Retail marijuana testing facility $3,000 $1,500 Modification of Premises $ 150 Payments shall be made payable to the Pitkin County Treasurer. All fees are nonrefundable and must be paid at or before the time of any license issuance. All fees associated with these regulations shall be used as general funds of Pitkin County. MEDICAL MARIJUANA LICENSING REGULATIONS 6.49.070(C)(17): 17. All applications for any type of medical marijuana establishment shall be referred for recommendation and comment to applicable-the caucus of the proposed licensed facility areas and to any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license; . - ••• . . --- - ; 6.49.100: FACILITY REQUIREMENTS H. No products other than marijuana or products containing marijuana and marijuana accessories, limited exclusively to those accessories needed for ingesting, inhaling, or otherwise introducing marijuana into the human body as defined by Section 16, Article XVIII of the Colorado Constitution, shall be available for sale at medical marijuana centers. 6.49.140: APPLICATION FEES The application fee for any type of initial medical marijuana license is$44400$2,500.The application fee for a modification of premises application is$150. The fee to renew any type of medical marijuana license is$1,000. All additional costs over the amount of applicable application fees to investigate, remediate, process referrals or otherwise respond to applications or violations of State and County laws or license conditions shall be the responsibility of the licensee and shall be remitted to Pitkin County at the rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all licenses issues to the licensee. Payments shall be made payable to the Pitkin County Treasurer. All fees are nonrefundable and must be paid at or before the time of any license issuance. All fees associated with these regulations shall be used as general funds of Pitkin County. 5 1W3r2016 FOCUS-1 Result-Section 16 PERSONAL USE AND REGULATION OF MARIJUANA • (c) "Department" means the department of revenue or its successor agency. (d) "Industrial hemp" means the plant of the genus cannabis and any part of such plant, whether growing or not, with a delta-9 tetrahydrocannabinol concentration that does not exceed three-tenths percent on a dry weight basis. (e) "Locality" means a county, municipality, or city and county. (f) "Marijuana" or "marihuana" means all parts of the plant of the genus cannabis whether growing or not, the seeds thereof, the resin extracted from any part of the plant, and every compound, manufacture, salt, derivative, mixture, or preparation of the plant, its seeds, or its resin, including marihuana concentrate. "Marijuana" or "marihuana" does not include industrial hemp, nor does it include fiber produced from the stalks, oil, or cake made from the seeds of the plant, sterilized seed of the plant which is incapable of germination, or the weight of any other ingredient combined with marijuana to prepare topical or oral administrations, food, drink, or other product. (g) "Marijuana accessories" means any equipment, products, or materials of any kind which are used, intended for use, or designed for use in planting, propagating, cultivating, growing, harvesting, composting, manufacturing, compounding, converting, producing, processing, preparing, testing, analyzing, packaging, repackaging, storing, vaporizing, or containing marijuana, or for ingesting, inhaling, or otherwise introducing marijuana into the human body. (h) "Marijuana cultivation facility" means an entity licensed to cultivate, prepare, and package marijuana and sell marijuana to retail marijuana stores, to marijuana product manufacturing facilities, and to other marijuana cultivation facilities, but not to consumers. (i) "Marijuana establishment" means a marijuana cultivation facility, a marijuana testing facility, a marijuana product manufacturing facility, or a retail marijuana store. (j) "Marijuana product manufacturing facility" means an entity licensed to purchase marijuana; manufacture, p-epare, and package marijuana products; and sel: marijuana and marijuana products to other marijuana product manufacturing facilities and to retail marijuana stores, but not to consumers. (k) "Marijuana products" means concentrated marijuana products and marijuana products that are comprised of marijuana and other ingredients and are intended for use or consumption, such as, but not limited to, edib'e products, ointments, and tinctures. (I) "Marijuana testing facility" means an entity licensed to analyze and certify the safety and potency of marijuana. (m) "Medical marijuana center" means an entity licensed by a state agency to sell marijuana and marijuana prodacts pursuant to section 14 of this article and the Colorado Medical Marijuana Code. (n) "Retail marijuana store" means an entity licensed to purchase marijuana from marijuana cultivation facilities and marijuana and marijuana products from marijuana product manufacturing facilities and to sell marijuana and marijuana products to consumers. (o) "Unreasonably impracticable" means that the measures necessary to comply with the regulations require such a high investment of risk, money, time, or any other resource or asset that the operation of a marijuana establishment is not worthy of being carried out in practice by a reasonably prudent businessperson. (3) PERSONAL USE OF MARIJUANA. Notwithstanding any other provision of law, the following acts are not unlawful and shall not be an offense under Colorado law or the law of any locality within Colorado or be a basis for seizure or forfeiture of assets under Colorado law for persons twenty-one years of age or older: (a) Possessing, using, displaying, purchasing, or transporting marijuana accessories or one ounce or less of marijuana. (b) Possessing, growing, processing, or transporting no more than six marijuana plants, with three or http/Aveb.lexisnexis.com/reseerchretrieve?_m=cOf357f7d9e734c4bc7eac13d350efcbScsvc=fodcform=seerchFormS WO.=FULLBAocrrm=l3_startdoc=1.. 2/8 1 AGENDA ITEM SUMMARY REGULAR MEETING DATE: November 2, 2016 AGENDA ITEM TITLE: Amendments to Sections 6.48 and 6.49 of the Pitkin County Code Regulating Retail and Medical Marijuana Licensing STAFF RESPONSIBLE: Jeanette Jones—John Ely ISSUE STATEMENT: Shall the Board of County Commissioners (BOCC) amend Title 6, Sections 6.48 and 6.49 of the Pitkin County Code regulating retail and medical marijuana licensing. •BACKGROUND: 1) The current initial application fee for a medical marijuana license is $1,000. Staff recommends that this be raised to $2500 to make it more consistent with the retail marijuana application fee and more fully cover the costs of processing an application. 2) At a work session on August 2nd, the BOCC heard a presentation and a request from a licensee to reconsider the medical marijuana regulations to allow the selling of certain paraphernalia in medical marijuana centers. At that meeting staff was asked to bring back an amendment to the regulations to allow for certain accessories to be sold in medical establishments so clients are able to purchase the accessory they need for their individual health purposes. 3) County staff has experienced a significant increase in staff time processing referrals, responding to applicant's questions,inspections,etc., which includes not only the clerk but other departments such as environmental health and the building department. 4) This item was a topic of discussion at the October 11th work session at which time the board asked staff to bring an ordinance forward with an additional amendment as follows: All applications for any type of retail marijuana establishment shall be referred for recommendation and comment to the caucus of the proposed licensed facility and any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. The BOCC approved this Ordinance on first reading on October 26th and its before you at this time for a second reading and public hearing. KEY DISCUSSION ITEMS: Staff is recommending the following amendments to Section 6.48 and 6.49 of the code: Section 6.49.140 of the Pitkin County Code amended to reflect an initial medical marijuana licensing application fee of$2,500. Section 6.49.100(H)of the Pitkin County Code amended to include marijuana accessories, as defined by Section 16, Article XVIII of the Colorado Constitution, as allowable for sale at medical marijuana centers. Sections 6.48.140 and 6.49.140 to be amended to reflect that all additional costs over the amount of applicable application fees (and in the case of retail medical marijuana, operating fees), to investigate, remediate,process referrals, or otherwise respond to applications of violations of State or County laws or license conditions shall be the responsibility of the licensee and shall be remitted to Pitkin County at a rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all license issued to the licensee. Section 6.48.070(c)(16); to be amended to state: All applications for any type of retail marijuana establishment shall be referred for recommendation and comment to the caucus of the proposed licensed facility and any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. RECOMMENDED BOCC ACTION: Open the public hearing and approve the Ordinance on second reading. ATTACHMENTS: 1) Proposed Ordinance Amending Title 6.48 and 6.49 of the Code 2) Definition of Marijuana Accessories (Section 16, Article XVIII) 45,e 3 nwat (4 nia al I AN ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF PITKIN COUNTY AUTHORIZING AMENDMENTS TO SECTIONS 6.48 AND 6.49 OF THE PITKIN COUNTY CODE REGULATING RETAIL AND MEDICAL MARIJUANA LICENSING ORDINANCE NO. -2016 RECITALS 1. The purpose of Pitkin County's retail and medical marijuana regulations is to authorize licensing in unincorporated Pitkin County as provided by state statute by establishing specific standards and procedures for local licensing of retail marijuana establishments and of medical marijuana centers, medical marijuana infused products manufacturers, and optional premises medical marijuana cultivation operations. 2. The Board of County Commissioners ("Board") is authorized to amend Pitkin County's Retail and Medical Marijuana Licensing Regulations from time to time as necessary to protect the health safety, and welfare of the residents of Pitkin County. 3. The following amendments are hereby made to Section 6.48 and 6.49 of the Pitkin County Code regulating retail and medical marijuana licensing: a. Section 6.48.070(C)(16) and Section 6.49.070(C)(17) shall be amended to reflect that in addition to an application for any type of retail or medical marijuana establishment being referred for recommendation and comment to the caucus in which the proposed licensed facility is located, such applications shall also be referred to any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. b. Section 6.49.100(H) shall be amended to permit the sale of marijuana accessories at medical marijuana centers, limited exclusively to those accessories needed for ingesting, inhaling, or otherwise introducing marijuana into the human body, as defined by Section 16, Article XVIII of the Colorado Constitution. c. Section 6.49.140 shall be amended to reflect an initial medical marijuana licensing application fee of$2,500. d. Section 6.48.140 shall be amended to reflect that retail marijuana operating fees are fees in addition to application fees. e. Sections 6.48.140 and 6.49.140 shall be amended to reflect that all additional costs over the amount of applicable application fees (and operating fees in the case of retail medical marijuana),to investigate, remediate,process referrals or otherwise respond to applications or violations of State or County laws or license conditions shall be the responsibility rcL5 L( ORDINANCE# 2016 PAGE 2 of the licensee and shall be remitted to Pitkin County at a rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all license issued to the licensee. 7. The BOCC finds that adoption of this ordinance is necessary for the immediate preservation of the public health, safety and welfare of the citizens of Pitkin County and therefore declares this ordinance and legislation to be effective immediately. NOW THEREFORE, BE IT ORDAINED by the Board of County Commissioners of Pitkin County, Colorado that Sections 6.48.070(C)(16), 6.49.070(C)(17), 6.49.100(H), 6.48.140 and 6.49.140 of the Pitkin County Code regulating retail and medical marijuana licensing are hereby amended as set forth above and depicted in redline on Exhibit 1 attached hereto. INTRODUCED AND FIRST READ ON THE 26TH DAY OF SEPTEMBER 2016 AND SET FOR SECOND READING AND PUBLIC HEARING.ON THE 2ND DAY OF NOVEMBER 2016. NOTICE OF PUBLIC HEARING AND TITLE AND SHORT SUMMARY OF THE ORDINANCE PUBLISHED IN THE ASPEN TIMES WEEKLY ON THE DAY OF 2016. NOTICE OF PUBLIC HEARING AND THE FULL TEXT OF THE ORDINANCE POSTED ON THE OFFICIAL PITKIN COUNTY WEBSITE( www.pitkincounty.com) ON THE DAY OF 2016. ADOPTED AFTER FINAL READING AND PUBLIC HEARING ON THE DAY OF 2016. PUBLISHED BY TITLE AND SHORT SUMMARY, AFTER ADOPTION,IN THE ASPEN TIMES WEEKLY ON THE DAY OF 2016. POSTED BY TITLE AND SHORT SUMMARY ON THE OFFICIAL PITKIN COUNTY WEBSITE (www.pitkincounty.com) ON THE DAY OF , 2016. THIS ORDINANCE IS EFFECTIVE ON , 2016. ATTEST: BOARD OF COUNTY COMMISSIONERS By By: Jeanette Jones Rachel E Richards, Chair Deputy County Clerk Date: APPROVED AS TO FORM: MANAGER APPROVAL: 2 /-*P4..s ORDINANCE# 2016 PAGE 2 John Ely, County Attorney Jon Peacock, County Manager 3 EXHIBIT 1 Amendments to the Pitkin County Code Regulating Retail and Medical Marijuana Licensing(Depicted in Redline) RETAIL MARIJUANA LICENSING REGULATIONS 6.48.070(C)(16): REVIEW CRITERIA 16. A license will not be issued for any type of retail marijuana establishment in the following Caucus Areas: Snowmass-Capitol,Frying Pan,Woody Creek and Emma. A license for a retail marijuana store will not be issued within the Town of Redstone (Village Commercial District) in the Crystal River Caucus. The prohibition on the issuance of licenses described in this paragraph shall remain in place until February 15, 2018. All applications for any type of retail marijuana establishment shall be referred for recommendation and comment to the appropriate-caucus of the proposed licensed facility and any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license. ander 6.48.140: OPERATING FEES Operating Fees are fees in addition to application fees. All additional costs over the amount of applicable application and operating fees to investigate, remediate,process referrals or otherwise respond to applications or violations of State and County laws or license conditions shall be the responsibility of the licensee and shall be remitted to Pitkin County at the rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all licenses issues to the licensee. Operating Fees Applicable to: Initial License Renewal License Retail marijuana store $3,000 $1,500 Retail marijuana cultivation facility $3,000 $1,500 Retail marijuana products manufacturing facility $3,000 $1,500 Retail marijuana testing facility $3,000 $1,500 Modification of Premises $ 150 Payments shall be made payable to the Pitkin County Treasurer. All fees are nonrefundable and must be paid at or before the time of any license issuance. All fees associated with these regulations shall be used as general funds of Pitkin County. MEDICAL MARIJUANA LICENSING REGULATIONS 6.49.070(C)(17): 17. All applications for any type of medical marijuana establishment shall be referred for recommendation and comment to awe-the caucus of the proposed licensed facility areas and to any other caucus that has a reasonable expectation of experiencing impacts related to the issuance of the license; . . . -- . . - •-- - ; 6.49.100: FACILITY REQUIREMENTS H. No products other than marijuana or products containing marijuana and marijuana accessories, limited exclusively to those accessories needed for ingesting, inhaling, or otherwise • introducing marijuana into the human body as defined by Section 16, Article XVIII of the Colorado Constitution, shall be available for sale at medical marijuana centers. 6.49.140: APPLICATION FEES The application fee for any type of initial medical marijuana license is X000$2,500. The application fee for a modification of premises application is $150. The fee to renew any type of medical marijuana license is $1,000. All additional costs over the amount of applicable application fees to investigate, remediate, process referrals or otherwise respond to applications or violations of State and County laws or license conditions shall be the responsibility of the licensee and shall be remitted to Pitkin County at the rate of$350 per hour of staff time. Failure to pay these costs are grounds for revocation of all licenses issues to the licensee. Payments shall be made payable to the Pitkin County Treasurer. All fees are nonrefundable and must be paid at or before the time of any license issuance. All fees associated with these regulations shall be used as general funds of Pitkin County. 5 1Q''3'2016 FOCUS-1 Result-Sectim 16 PERSONAL USE AND REGULATION OF MARIJUANA I (c) "Department" means the department of revenue or its successor agency. /1-14-(4101(401 (d) "Industrial hemp" means the plant of the genus cannabis and any part of such plant, whether growing or not, with a delta-9 tetrahydrocannabinol concentration that does not exceed three-tenths percent on a dry weight basis. (e) "Locality" means a county, municipality, or city and county. (f) "Marijuana" or "marihuana" means all parts of the plant of the genus cannabis whether growing or not, the seeds thereof, the resin extracted from any part of the plant, and every compound, manufacture, salt, derivative, mixture, or preparation of the plant, its seeds, or its resin, including marihuana concentrate. "Marijuana" or "marihuana" does not include industrial hemp, nor does it include fiber produced from the stalks, oil, or cake made from the seeds of the plant, sterilized seed of the plant which is incapable of germination, or the weight of any other ingredient combined with marijuana to prepare topical or oral administrations, food, drink, or other product. (g) "Marijuana accessories" means any equipment, products, or materials of any kind which are used, intended for use, or designed for use in planting, propagating, cultivating, growing, harvesting, composting, manufacturing, compounding, converting, producing, processing, preparing, testing, analyzing, packaging, repackaging, storing, vaporizing, or containing marijuana, or for ingesting, inhaling, or otherwise introducing marijuana into the human body. (h) "Marijuana cultivation facility" means an entity licensed to cultivate, prepare, and package marijuana and sell marijuana to retail marijuana stores, to marijuana product manufacturing facilities, and to other marijuana cultivation facilities, but not to consumers. (i) "Marijuana establishment" means a marijuana cultivation faci'ity, a marijuana testing facility, a marijuana product manufacturing facility, or a retail marijuana store. (j) "Marijuana product manufacturing facility" means an entity licensed to purchase marijuana; manufacture, prepare, and package marijuana products; and sel: marijuana and marijuana products to other marijuana product manufacturing facilities and to retail marijuana stores, but not to consumers. (k) "Marijuana products" means concentrated marijuana products and marijuana products that are comprised of marijuana and other ingredients and are intended for use or consumption, such as, but not limited to, edible products, ointments, and tinctures. (I) "Marijuana testing facility" means an entity licensed to analyze and certify the safety and potency of marijuana. (m) "Medical marijuana center" means an entity licensed by a state agency to sell marijuana and marijuana products pursuant to section 14 of this article and the Colorado Medical Marijuana Code. (n) "Retail marijuana store" means an entity licensed to purchase marijuana from marijuana cultivation facilities and marijuana and marijuana products from marijuana product manufacturing facilities and to sell marijuana and marijuana products to consumers. (o) "Unreasonably impracticable" means that the measures necessary to comply with the regulations require such a high investment of risk, money, time, or any other resource or asset that the operation of a marijuana establishment is not worthy of being carried out in practice by a reasonably prudent businessperson. (3) PERSONAL USE OF MARIJUANA. Notwithstanding any other provision of law, the following acts are not unlawful and shall not be an offense under Colorado law or the law of any locality within Colorado or be a basis for seizure or forfeiture of assets under Colorado law for persons twenty-one years of age or older: (a) Possessing, using, displaying, purchasing, or transporting marijuana accessories or one ounce or less of marijuana. (b) Possessing, growing, processing, or transporting no more than six marijuana plants, with three or http:/1web.lexisnexis.com/researchiretrieve?_m=c0f357f7d9e734c4bc7eac13d350efcb&csvc=facform=searchFormB fmtstr=FULLBdocnum=1&_startdoc=1.. 218