Thank you to the county for considering my comment. This is in addition to the thorough requests made by the Mendocino Cannabis Alliance regarding state level issues with the cannabis regulatory program that impact Mendocino businesses. The request made by MCA to include the extension of provisional licenses in the 2021 platform is paramount to keeping those who have been working so hard to become licensed from falling out of the program completely. Without the extension of provisional licenses, upwards of 90% of Mendocino's cannabis businesses will no longer be legal at the end of 2021. However, the extension of provisional licenses is a bandage for real issue at hand, which is the way that CEQA is applied to cannabis businesses at the state level. Unlike other industries, all annual permits for cannabis are discretionary. This means that all cannabis projects REGARDLESS of local authority or regulations, are subject to site specific CEQA analysis. Every type of business, in every part of the state is subject to this. Not only does the locality become the lead agency for the site specific analysis, even if they bring in outside help for the inspections, the county is still responsible for the feedback loop with all agencies of interest stemming from that inspection. A potential solution to this problem, is to make the state annual license ministerial, which would allow the state to honor a local EIR or ruling on principally permitted activity. If the state were to make the annual permit ministerial, Mendocino would retain the right to deem an application CEQA exempt, and that designation would be honored by the state. Therefore, I urge the county to include amending how CEQA interacts with the cannabis industry at the state level to their 2021 platform. Thank you.
Thank you to the county for considering my comment. This is in addition to the thorough requests made by the Mendocino Cannabis Alliance regarding state level issues with the cannabis regulatory program that impact Mendocino businesses. The request made by MCA to include the extension of provisional licenses in the 2021 platform is paramount to keeping those who have been working so hard to become licensed from falling out of the program completely. Without the extension of provisional licenses, upwards of 90% of Mendocino's cannabis businesses will no longer be legal at the end of 2021. However, the extension of provisional licenses is a bandage for real issue at hand, which is the way that CEQA is applied to cannabis businesses at the state level. Unlike other industries, all annual permits for cannabis are discretionary. This means that all cannabis projects REGARDLESS of local authority or regulations, are subject to site specific CEQA analysis. Every type of business, in every part of the state is subject to this. Not only does the locality become the lead agency for the site specific analysis, even if they bring in outside help for the inspections, the county is still responsible for the feedback loop with all agencies of interest stemming from that inspection. A potential solution to this problem, is to make the state annual license ministerial, which would allow the state to honor a local EIR or ruling on principally permitted activity. If the state were to make the annual permit ministerial, Mendocino would retain the right to deem an application CEQA exempt, and that designation would be honored by the state. Therefore, I urge the county to include amending how CEQA interacts with the cannabis industry at the state level to their 2021 platform. Thank you.