The Cole Memo

Traditionally, the cultivation of cannabis in Illinois has been confined to indoor facilities, with strict regulations ensuring that the plant is grown in controlled environments.

In December 2023, after over a year of casual investigation, I released information suggesting that a select few cultivation centers in Illinois had been quietly granted permission to grow cannabis outdoors.

This stood out to me because growing outdoors is cost-effective, environmentally sustainable, and traditionally fits inside the norm for most of Illinois agriculture. As I stated in my last article, I believe that outdoor cultivation should be a right available to everyone—licensed cultivators, medical cannabis patients, and ideally all adults in Illinois. It should not remain an exclusive privilege granted to just two licensees in the state.

In discussions with several licensed craft cultivators, a recurring theme has emerged: outdoor cultivation presents a more accessible option for capital-constrained operators. These cultivators argue that being allowed to grow cannabis outdoors, specifically for producing infused or extracted products, could open new revenue streams that are currently out of reach due to delays in securing investors or the high costs of constructing heavily regulated indoor facilities.

To illustrate, imagine a visit to a hardware store: it involves purchasing some fencing, tent poles, netting, and security cameras. Compare this with the monumental task of building an indoor cultivation facility, and the appeal of outdoor cultivation becomes clear. It’s an opportunity to harness Illinois’ natural, agriculture-friendly soil and climate—advantages that many operators feel they are missing out on.

In my last article, I detailed my efforts to obtain information about lawsuits related to outdoor cannabis cultivation in Illinois, which had, until now, been unsuccessful. I also reaffirmed my commitment to providing accurate and timely updates as new information becomes available. By highlighting this issue, I hoped that others with more resources might help uncover the legal documents tied to these ongoing disputes.

I’m pleased to report that I have recently acquired a collection of documents related to outdoor cannabis cultivation in Illinois. I can now confirm that there were at least two active lawsuits involving Nature’s Grace and Wellness and Green Thumb Industries.

For the first time, I am revealing to the public the rescission letters issued to GTI and NGW, confirming that my initial findings were accurate: outdoor cannabis cultivation was indeed permitted in Illinois.

Up until now, I have been unable to get any state official to confirm the existence of such activity on the record, and I’m not aware of anyone else who has.

Rescission Letter for Green Thumb Industries

Rescission Letter for Nature’s Grace and Wellness

Despite the rescission letters, my understanding is that NGW and GTI are still permitted to use their outdoor growing areas while litigation is ongoing.

I plan to release more information on this topic in the future.

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#247 – What could rescheduling mean for cannabis policy? – The Cole Memo

I’ll be joined by a surprise guest to recap the latest developments in cannabis policy and what they could mean for both businesses and consumers. Read full show notes here: https://thecolememo.com/2025/12/22/e246/

1. #247 – What could rescheduling mean for cannabis policy? 54:03
2. #246 – Cannabis Is Legal in Illinois, So Why Are People Still Being Arrested 40:14
3. #245 – Live From the Oval Office: Trump Directs AG to Expedite Cannabis Rescheduling Process 39:06
4. #244 – Talking Cannabis Rescheduling With Its Harshest Critics 44:25
5. #243 – Social Equity, Transporters, Rescheduling, and the Future of Hemp With Ali Jubelirer 01:01:29