Lansing, Michigan Municipal Ordinance §1300.05: Security Camera System Requirements for Cannabis Farms and Dispensaries

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Lansing, Michigan Municipal Ordinance §1300.05: Security Camera System Requirements for Cannabis Farms and Dispensaries

Here's the basic problems on what the law says.

1. Continuously "Monitor"

So, many states have a requirement to continuous record - not monitor - the cameras. Based on previous clients in the area, regulators in Lansing seem to approve camera systems with motion or AI alert based monitoring rather than continuous monitoring, as long as they are continuous recording - despite the fact that the law requires "continuous monitoring" but not "continuous recording." The word "monitor" here is most likely a typo and is regulators seem to act as if the word is "record;" this would be consistent with most other states' regulators (and how the systems work), but is actually not what the law actually says.

"Continuous Monitoring" is an industry term that means someone is actively watching the cameras at all time. However, we have not yet seen a regulator requires this. Regulator seem content if the camera system has a way to watch live video at all times, and alerting mechanism (such as audible alarms, push notifications, and emails), and do not seem to require someone to be paid to actively watch all the cameras at all times. If you find a regulator that requires the law to be enforced as written, we do have a Remote Guarding Professional Camera Monitoring service that would meet this requirement.

2. "Entire Premises on which they are operated with security cameras."

This is a very unclear requirement (and poor grammar in general). It just basically says "the whole facility needs cameras" but it doesn't spell out where in the facility they are needed and what level of clarity you need from those cameras. The text seems to require a camera in every room positioned in such a way as to have no blind spots, but this is probably overkill for several reasons (Most states do not require cameras in staff offices. Cameras in bathrooms would be illegal.) We've found the best way to comply with this section of the law is to lean on other states regulations that detail out what is meant by the coverage area and "entire premises." Here's an example of a more clear regulation.

(a) All controlled access areas, security rooms/areas and all points of ingress/egress to limited access areas, all points of ingress/egress to the exterior of the licensed premises, and all point-of-sale (POS) areas must have fixed camera coverage capable of identifying activity occurring within a minimum of twenty feet of all entry and exit points.

(b) Camera placement shall allow for the clear and certain identification of any individual on the licensed premises.

(c) All entrances and exits to the facility shall be recorded from both indoor and outdoor vantage points, and capable of clearly identifying any activities occurring within the facility or within the grow rooms in low light conditions. The surveillance system storage device must be secured on-site in a lock box, cabinet, closet, or secured in another manner to protect from employee tampering or criminal theft.

(d) All perimeter fencing and gates enclosing an outdoor grow operation must have full video surveillance capable of clearly identifying any activities occurring within twenty feet of the exterior of the perimeter. Any gate or other entry point that is part of the enclosure for an outdoor growing operation must have fixed camera coverage capable of identifying activity occurring within a minimum of twenty feet of the exterior, twenty-four hours a day. A motion detection lighting system may be employed to illuminate the gate area in low light conditions.

(e) Areas where marijuana is grown, cured or manufactured including destroying waste, shall have a camera placement in the room facing the primary entry door, and in adequate fixed positions, at a height which will provide a clear, unobstructed view of the regular activity without a sight blockage from lighting hoods, fixtures, or other equipment, allowing for the clear and certain identification of persons and activities at all times

Following this roadmap is much wiser and easier to understand than trying to comply with the "entire premises" rule that was actually written down. We suggest following this roadmap and checking with your inspector to see if they require additional coverage areas.

3. Off Site

The second sentence of the regulation similarly requires an impossible standard when it says "recordings shall be maintained in a secure, off-site location for a period of 14 days," and we similarly see regulators approving things that meet the "spirit" of the law and not its written words.

The problem with off-site storage is your internet upload speed. The speed of the average internet upload speed of a US internet connection is about 5Mbps. A single 1080P camera creates 2Mbps of video footage a second, and a 4K camera creates nearly 5Mbps. The average cannabis system is thirty to sixty cameras. This makes the Lansing, Michigan regulation, as written, close to impossible to upload all cameras to the cloud for most internet connections where a grow opp could operate. The data being created by sixty or so HD continuously recorded security cameras is about 1000x greater than the average rural internet upload speeds. because most locations do not have the ability to send all the data that simultaneously recorded to the cloud at the same time.

The authors of this regulator are largely confusing commercial grade solutions with consumer grade ones. Cloud cameras, like Google Nest, Samsung Arlo, or Ring doorbells, do provide off-site storage in the cloud. However, they are primarily used by consumers with small camera counts. The don't have to deal with this network speed problem because most people don't use more than one or two cameras on their home, usually on their front door. A consumer cloud camera usually record video clips (not continuous video, as your regulator requires) when a motion sensor is triggered. Their user interfaces usually allow you to watch only one camera live at a time, unlike a commercial grade system. Often you cannot watch live video at all - and can only see the last event.

Modern Commercial grade camera solutions solve the "creating more data that I can upload at once" problem by using P2P to send data to whoever is watching the cameras, based upon what they are actively watching. In other words, when you want to remotely watch cameras 4, 16, and 51 and 62, the only data leaving your network is for those cameras - not all 70 cameras. P2P means that the system send video on demand to whoever is watching the system with no central server in the way (cloud means multiple redundant central servers). P2P send a full HD video stream when watching a single camera full screen and low-resolution streams when watching the cameras on a grid. When you are not remote, you can watch all the cameras all at once without having to upload and video at all.

Most regulators approve at-your-location storage in a secure locked sever room as long as you have remote access to the footage.

*We're not lawyers and laws do change. We try our best to keep this page updated with changes to the law, but you should always do your own research or hire your own lawyer to guarantee compliance with the law.