Subject: Objection to cannabis CUP at 334 Purvine, UPC 17-0020
Date: September 19, 2019 at 9:43:03 AM MDT
To: Susan Gorin <Susan.Gorin@sonoma-county.org>, David Rabbitt <firstname.lastname@example.org>, Shirlee Zane <Shirlee.Zane@sonoma-county.org>, email@example.com, Lynda Hopkins <firstname.lastname@example.org>
Cc: Darin Bartow <Darin.Bartow@sonoma-county.org>, Pat Gilardi <Pat.Gilardi@sonoma-county.org>, Andrea Krout <email@example.com>, Tracy Cunha <Tracy.Cunha@sonoma-county.org>, Leo Chyi <Leo.Chyi@sonoma-county.org>, Stuart Tiffen <Stuart.Tiffen@sonoma-county.org>
Dear County Supervisors,
I urge the Board of Supervisors to deny this permit. The following analysis is based on the odor issue alone, although there are other major issues including traffic, noise, 24/7 operations, lights crime and safety that also are very problematic and should result in denial of this CUP application.
Odor is just one of the major issues that must be addressed before any outdoor cannabis grow can be properly and fairly be approved. Quantitative methods are available for determining how far cannabis terpenes travel depending on topography and meteorological data. An internet search found the consulting company Ortech [https://www.cannabisconsultingservices.ca] who has developed quantitative analytical methods for determining how far cannabis terpenes travel as a function of topography and meteorological data; they have also measured level of detection by the general public. They have been conducting odor analysis for 40 years for commercial farms as well as municipal and county governments including for cannabis cultivation.
Ortech has scientifically analyzed that planting trees does not mitigate cannabis odor. This agrees with our real life experience in Sonoma County that thick conifer cover did not prevent overpowering skunk-like odor at least 700 ft away from a 10,000 sf outdoor grow. Ortech states that the only mitigation for odor from outdoor cannabis cultivation is separation distance. To summarize from their experience with quantitative analysis of terpenes, the acceptable minimum setback for an outdoor cannabis grow would be at least 1000 meters (3281 ft) to prevent the odor from escaping to neighboring properties more than 2 days/year. Sonoma County needs to establish its own standards, with neighborhood input, of how many days people could be subjected to noxious odors to meet the health and safety requirements of 26-88-250(f) of the cannabis ordinance. If this operation were next to your home, how many days from July-Oct would you accept not being able to use your yard or open your windows?
Rather than recommending approval of a CUP for outdoor cultivation for a 2-year (or even 1-year) term to see how much it affects neighbors (ie, using the neighbors are the guinea pigs), a quantitative analysis should be performed prior to any planting, to determine an actual acceptable setback for each specific topographical and meteorological situation, that would meet the requirements of 26-88-250(f) including no odors. A preliminary result could be available in 2 weeks, with full results in 4-6 weeks. If such an analysis is not undertaken, a minimum setback of 1000 ft from an outdoor grow to neighbor’s property line should be required, with the understanding that such a setback may still not be sufficient to meet the requirements of 26-88-250(f). Knowing that a quantitative method for determining odor distance is available prior to planting an outdoor cannabis field, it would be irresponsible, arbitrary and negligent for Sonoma County to approve outdoor cannabis cultivation without previously confirming that this would not be likely to cause an odor problem for neighbors. When there are prior odor objections from neighbors as has occurred for 334 Purvine from a much smaller outdoor grow than is now proposed, to approve such an outdoor grow would be grossly negligent.
The 4 publications that Permit Sonoma has provided on odor analysis are largely irrelevant to cannabis odors, as they relate to odors from livestock. These odors are caused by very different molecules as well as particulates with different dispersion metrics. However, one of the publications, by Schauberger and Pringer (2012; Chemical Engineering Transactions, vol 30, p13-18), did utilize scientific methods to conclude that distances of 400 meters (1312 ft) were needed to remove nuisance from environmental noxious odors.
In addition to odor, many other issues associated with this proposed commercial cannabis operation negatively impact neighbors, including traffic, noise, security lights, crime and safety. It is a known fact in Sonoma County that cannabis operations attract crime, and police protection is not readily available here. I urge you to deny this CUP application as this is not an appropriate location for this type of large commercial operation of a controlled substance affecting near by residents.
If you want further information or wish to discuss any of these points concerning odor analysis, please let me know.