PO Box 5817 Banff, Alberta T1L 1G7 bllha.ca

August 1, 2017

Minister Kathleen Ganley 424 Legislature Building 10800 – 97 Avenue Edmonton, Alberta T5K 2B6 Dear Minister Ganley: RE: CANABIS LEGALIZATION IN ALBERTA Thank you for the opportunity to provide input as the Province of Alberta creates legislation around something that is much more complicated than it may appear at first glance. While the overarching approach that our members deemed appropriate is to align the legislation very closely with liquor controls; there are some very clear directives that our members have provided. These directives are as follows: Age: We acknowledge that research indicates use of cannabis products may lead to higher incidences of mental health conditions such as depression if there is regular use prior to the age of 25. However, we also recognize that instituting a higher legal age than the age for liquor and tobacco use will likely lead to more of an illegal market for cannabis products. Therefore, it is important to align the legal age for purchase and consumption of cannabis products with the purchase and use of tobacco and alcohol; 18 years old. It is vital to ensure there are strong educational campaigns around the use of cannabis products and a specific campaign to those under age 25. Distribution: While we are not in favour of the Government of Alberta operating Cannabis retail outlets; it is important that the Government of Alberta maintain the control of sales, distribution and consumption as it does with liquor. Consumption: Discussion around consumption was perhaps the most robust. One message that our membership was very clear on was that at no time should individuals be exposed to second hand smoke or any other residual effects from others engaging in the consumption of cannabis products. In terms of retail opportunities; retail should be very specific to cannabis products; including edible products and by- products such as baked goods and paraphernalia. Again, retail should operate under the same guidelines as liquor retail outlets; with the exception being that only products that do not produce second hand smoke are available for sampling. The topic of “where” use should be permitted brought various answers but the themes

were edibles should be treated more like liquor while smoking should be treated more like tobacco. In other words consumers should be able to consume edible products without being subject to second hand smoke. Smoking or vaping should only be permitted in designated, signed areas specific to the consumption of cannabis again without non-smokers or children and youth under the age of 18 being subject to second hand smoke. Further to that, respondents deemed minors should not be permitted anywhere that consumption is allowed. Additional Regulations for Multi-Family Housing: Our members did not agree as strongly with additional regulations for multi-family housing although it was deemed appropriate that there should be some allowance for condominium boards and landlords to create policies both around consumption and number/location of plants. Employee Housing Provided by Employers: It is vital that employers are permitted to create policies around both consumption of cannabis products and allowing plants within accommodation when the employee and employer have entered into tenancy agreements for employer owned housing. Overall, the members of Banff & Lake Louise Hospitality Association believe that legislation created for the consumption, sale and distribution of cannabis products must be focused on health and safety, prevention of crime and training and education. It is very likely that similar to liquor, as markets for products and distribution of such become clearer it will be determined that the cannabis industry will become an integral part of tourism and hospitality. As such, it is important that our industry leaders are involved in all discussions regarding the training, education and legal responsibilities of those that provide service to customers. We look forward to contributing to these discussions further in the future. Sincerely,

Darren Reeder Executive Director