WWW Letter to Supervisors and Planning Commission

REMINDER: Supervisors Gore & Hopkins were the advisors and over sight of this group 

Regarding: Proposed  Cannabis Regulations

March 15, 2021

To: Sonoma County Planning Commissioners – Admin Record for March 18, 2021 Hearing








Wine and Water Watch is a local organization of over 250 citizens concerned with ethical land and water use. We oppose the industrialization of our neighborhoods for commercial cannabis cultivation, threat to our watersheds, groundwater depletion, water quality, cannabis tasting rooms and cannabis tourism that Sonoma County is allowing to continue despite numerous problems including out of compliance with state regulations.

WWW had numerous attendees at the “listening” workshops and were extremely disappointed at the format and questions that were asked as being totally biased to sway the public into acquiescence. Not one of members attending had questions discussed at either workshop. 30 days for review is NOT enough time. We request an extension. No public review is a nonstarter for county residents. 

We are in a megadrought! The proposed regulations do not address the millions of gallons of water that will be siphoned off for this new industry that uses 6 times more water than the already water thirsty vineyards? NOAA has declared our area in a drought in 2020.  The loopholes in the proposed cannabis regulations would allow for more deficit groundwater pumping as recycled water is only available to a small part of the county. Diversions will further the lack of water sources and increase the threat of more fires. With 24% of Sonoma County having already been burnt in the last few years, where is the current science to allow such poor judgement?

The state has declared by law that cannabis is NOT a crop and therefore a product. Is the County ready to litigate?  Right to farm does not apply to this crop and residents can file an appeal for 3 years. State laws overrule County laws.

We find:

  1. The Ag Commissioner was one year and 9 months releasing the 2019 Crop Report due to understaffing and underfunding so why would County give more responsibilities unless that is part of the strategy to accommodate the industry with lack enforcement and monitoring? State says cannabis is not a crop so move this over to Permit Sonoma as a use permit. “All decisions of the Agricultural Commissioner under this chapter are final, subject only to judicial review.” This is a setup for disaster and takes power away from private citizens to giving added benefits to the industry. 
  2. Weak enforcement giving growers a heads-up that the County is coming monitor lacks transparency and gives the public concern that the regulations are useless and will not be enforced.
  3. Public concerns. Why no public options that could revoke growers out of compliance and remove to have their license revoked?
  4.  Allowing water use in water scarce areas is negligence and a Public Trust issue. West County and Healdsburg areas are already trucking in water.
  5. Biological Resources in Chapter 38 qualified biologist will be at the discretion of county staffers who also regularly use 40-year-old drilling logs to issue new well permits and traffic studies 8 years old. Why the disdain for current science? A full EIR must be conducted before any regulations are authorized.
  6. According to ABAG our county has the least restrictions to commercial grows than any of the other 8 counties in the Bay Area. Napa (82-page report) has said no to commercial cultivation as has 4 other counties due to the myriad of problems exposed. San Mateo is allowing a short-term project before making any regulations as unintended consequences WILL occur. You are allowing a 5-year permit. Why are we not giving one-year permits, a public hearing before growers are allowed a full 5 year permit?
  7. What bonds for cleanup of environmental degradation have been set up? Figures show that Santa Barbara and Humboldt counties grow enough cannabis to supply the entire USA. There will be many failures, where is the clean up fund?
  8. Residents already are receiving buyout offers from out of state and area growers furthering unaffordability in the county. 65,000 acres of potential grow sites even with 19% coverage will make home affordability even further out of reach. We have the third highest homeless population in the nation. Why is this social issue not being part of the mitigation? This is another cumulative impact not addressed. You can’t have it both ways.
  9. Safety issues. Twenty-Two home invasions occurred from January 2018 to August 2018. This should raise alarm bells, where is the county on this?
  10. In February, the federal National Marine Fisheries Service within the Biden Administration wrote a letter to the County of Sonomalisting their concerns with the proposed cannabis ordinance. The letter stated that the current proposal “the current standards and requirements appear unlikely to adequately mitigate the potential impact of streamflow depletion, making a MND inappropriate”. As it is apparent the ordinance is inadequate, what is the county doing to prevent harm to endangered and threatened salmon species? Taxpayers subsidize these recovery efforts.
  11. The letter from NOAA expressing grave concern about the lack of studies and understanding about cumulative impacts that will occur unless exclusion zones for water scarce areas such as zones 3 and 4 are enacted. All hydrological tests must be done during low water times in September and October to determine sustainable levels for native fish to survive and done not more than 2 years prior to be trustworthy and scientific. There can be no exceptions.
  12. Reduced setbacks are only going to make more problems for people who live here. There have been so many complaints and yet the county wants to reduce setbacks? This is going to cause even more problems. Once again county officials are turning their backs on residents in favor of industry.

In summary, the County needs to extend the public review process and must have regulations that allow for public review and hearings at every juncture, so this industry does not overburden our dwindling resources and right to a reasonable quality of life for tax paying residents.  A 30-day review for such an impactful industry is not enough time for a thorough public review when urgent cumulative impacts and CEQA analysis has not been attempted. We must have a cumulative report countywide to make decisions that will impact so many lives and not put monetary considerations before the lives of future generations.

We remind the county that past crops include potatoes, hops, prunes, peaches, poultry, pears, hay, apples and others were not able to survive economic and environmental realities.  To quote David Keller, “We’ve harvested redwood, fir, salmon, eel, otters, seals, whales, murre eggs, ducks and egrets, mercury and gravel until resources were exhausted. Water is now subject to competing commercial, municipal, marijuana, wine and agricultural demands, all increasingly pitted against survival of native salmon.” And we would add, survival of the county residents. What will be left?


Wine & Water Watch Board Members:

CC:  district4@sonoma-county.org; ,