I am currently and have been Chief Science Officer at Leef Holdings in Willits for the last three years. In my position, I have been tasked with analyzing the economic landscape of cannabis cultivation and the market for manufactured products in California. What I have come to understand is that unless cultivation of cannabis in Mendocino county is allowed to expand, the economic viability and therefore the long term health of Mendocino county’s economy is threatened.

After years of adjustment, the price points for cannabis products in the California marketplace are well established and the economic success of both cultivation and manufacturing enterprise is determined by the ability of businesses to meet those price points. Manufacturing requires a large capital investment in equipment, in infrastructure and skilled jobs to succeed in a competitive market. It is also clear that sale of manufactured cannabis products operates on narrow margins that require price control of cultivated inputs and I personally understand how difficult it is to operate within those limits and still remain viable.

Leef is a vertically integrated Mendocino county business that in 2020 paid out over 1.5 million dollars in salaries and wages to employees living in Mendocino county. As of December 31, 2020, Leef employed 34 people at its Cannapark facility. Leef’s 2021 budget plan is to double this employment number with a mixture of high salary positions and hourly, well above minimum wage and benefited, earners. In 2020, Leef paid approximately $275,000 to the City of Willits in city taxes. Without a vertically integrated cultivation operation, this expansion is in jeopardy.

For a proposed cultivation operation of ten acres that supports its manufacturing business, Leef will employ an additional 10 full time employees. Leef further intends supporting other large scale cultivators in the area to supply us with additional biomass for manufacturing.

It is Leef’s intention to remain in Mendocino county but for our business to succeed, continue to expand and continue to keep jobs in Mendocino, we need to scale production. In the current regulatory framework, responsible, environmentally conscious operators are zoned out of legal cultivation that is allowed in other parts of the state. County limits on cultivation prevent reasonable expansion as in every other agriculture crop such as the wine industry. That is why Leef advocates for allowing expansion to ten percent of parcel size. Furthermore, allowing this expansion will make it possible for currently non-compliant growers to enter the market with a reasonable business model that will promote new tax revenue and additional employment in the county.

I strongly support moving forward with Chapter 22.18, particularly expansion and new permits in Rangeland subject to the Use Permit process. Also, please allow current Phase 1 applicants to apply for permits pursuant to Chapter 22.18 regardless of their current zoning or parcel size. This can easily be accomplished by a simple text change and by adding one or more asterisks/footnotes to the Zoning Table. This does not open the process up to new applicants or subject neighbors to new impacts. It does keep faith with those Phase 1 applicants who are seeking a path to legality. The Use Permit process will determine if they have the appropriate site characteristics and can satisfy proof of water and other environmental concerns.

Dear Board if Supervisors,

Please support the CCAG recommendations.

I support personal medical and adult use, not requiring 10 acres to cultivate medicine outdoors. Please separate personal use from commercial canopy allowances.

We need a workable path for those in Phase 1 that will not meet the CEQA challenges under a ministerial process. Please write in allowances for those operators when finalizing the phase 3 table.

Do NOT allow 10% acreage expansion! This is absolutely not the direction we should go in. Furthermore it only allows those with the approved zoningto have this kind of opportunity, meanwhile leaving everyone else in the dust. We need opportunities for everyone. Not just a few. Allow everyone that currently holds a county embossed recipe or county permit in phase the option to scale to 22,000 sq ft. Allow this for those in phase 3 as well.

If expansion will be allowed, please require regenerative growing practices. When will we put ecology over economy?

Change the 25 plants for specialty cottage outdoor to allow up to 2500 sq ft just as the state allows for this size license type.

Phase 3 should be allowing phase 1 operators to turn in applications first for a window of time, then open phase 4 which will be for all those not currently in our program. This is the right approach.

The state has set up the licensing tier structure to hold off on unlimited grows until 2023 and we should not fear delaying the start of phase 3 as currently proposed especially if some operators that come forward will expand if the board approves it.

Honor the 1100 applicants that came forward in 2017 to be licensed. Who have paid thousands of dollars in permit fees and yearly sales taxes amounting to nearly $6 million dollars!

Stand up for small farms! We need you desperately to hear us. We need your support.

Thank you!

Dear Board of Supervisers,
After reading the proposed changes to the cannabis ordinance, I can’t help but wonder why such extensive changes to the code would be proposed on a Friday for a vote on the following Monday. This is not a public policy process designed to inspire confidence that our elected officials are working for the best interests of all Mendocino County residents. What gives, Misters Haschak and Williams? It sure seems like an attempt to limit broad consideration and discussion. These issues are important and demand detailed and nuanced examination.

To the members of the Board of Supervisors of Mendocino County,
I would like to make a comment of opposition to item 3b on todays agenda. This issue been fought for by numerous residents over the past few years and seemingly put to rest for the more residential neighborhoods.

As a lifelong resident of Mendocino county with my roots tracing back five generations in Potter Valley, I am concerned with the changes and expansion this will create for all unincorporated areas of the county. I agree with fellow commenters that phase 1 has all but imploded already and many growers are still hanging out in limbo and increasingly frustrated with the counties inability to efficiently process these permits. So why are we moving on to another phase? Why can't we finish one thought before we move to another?
Aside from this my main fear is that we will see even more expansion and conversion of rich and diverse agricultural land within the county. Many of the conversions that have happened in prime ag land are irreplaceable. Fields and range land that at one time housed numerous cattle, sheep, horses etc, are now large swathes of compacted base rock with the equivalent of an industrial complex on top of them. Cannabis is being grown in light, humidity and temperature controlled facilities and being justified as an "agricultural" product. Sorry, but that is a scientific lab not agriculture and can be done in industrial complexes without the destruction of agricultural land, which also happens to be a major industry in this county. Many growers are growing outdoor at the whims of mother nature like traditional agriculture which I am fine with. These growers are typically concerned with building their soil and regenerative farming and often times have additional crops growing on their properties. The conversion of properties and expansion that will come with phase 3 will only benefit large corporate companies from outside of our county and will continually undermine the long time families and rural livelihood that at one point made our county a little slice of heaven.

Please take all of these comments into consideration for todays meeting.

John March
Langdon Day Farms
Potter Valley

Jan. 25, 2021
Respected Members of Mendocino County Board of Supervisors.
I would like to speak in favor of allowing the growing of 6 cannabis plants for personal use by everyone in Mendocino County. This is what is allowed in the California law and what should be allowed by our ordinance. Most people who need to grow some cannabis do not have access to 10 acres in which to grow and only want to grow a few plants in their yard for their own medicinal and personal use. To deny the ability to grow outside is restrictive and discriminatory. This personal 6 should not be subject to setbacks and zoning, but if it becomes a nuisance to neighbors, can be subject to the same complaint process as any other ordinance violation. To deny this to medical users of cannabis is to violate the spirit of the state law.
I think that allowing this amount, and not restricting the area in which personal cannabis can be grown is a very good idea.
I also think that permitted cannabis growers should be allowed to grow their personal 6, in space outside of their legal canopy area in addition to their permitted amount. To do otherwise is to further penalize legal growers for stepping forward to pay you taxes.

Sincerely, Tekla Broz
Covelo, CA 95428
(707) 983 8198

Dear Honorable Supervisors,

My husband and I own a diversified farm called Radicle Herbs which is a regenerative cannabis farm with a 5k outdoor and 5k mixed light in Covelo. I would first like to say that I am in support of the MCA memo, Hannah Nelson’s memo and CCAG’s memo. In addition, I would like to support allowing individuals to grow 6 plants outdoors under the sun for their personal or medical needs which are in line with the passing of Prop 64.

Hello Board, Since we are looking at the CFBL ordinance will you edit it in such a way that allows Kure to keep it's drive thru on a permanent basis and be allowed our nursery back? Or order staff to just approve it? County staff could have just approved it but chose not to. These historical uses on the property are clearly needed and the county staff isn't acknowledging that those uses were included with the continued operation clause at our flagship, original store. I am working hard attempting to create tax base here and it would be helpful if I had all the tools. I have offered to upgrade the drive thru infrastructure to standards that would apply to any other drive thru but was rebuffed by county staff. Please Help.

I support the 10% of cultivation space regardless of zoning, relaxed regulations regarding fencing, public view, and tree cutting. No f1 for drying or trimming space. I support self distro and manufacturing uses on cultivation sites so that they can see their product all the way to retail ready. I support 25 plants per parcel as adult use with no permit required and ideally being able to sell excess into licensed supply line. In order to fix the negative issues with prohibition we need as inclusive a program as possible.

Also please support and build value into the original licenses that sacrificed so much to go on this wild ride that was legalization with you, we've been drug thru the mud and it would be real nice if the big expansions were limited to those original applicants. So far many haven't even been rewarded with a viable business out of this and many are hanging on hoping to have something to sell at the end, give them something worth selling please, we don't want to feel like the right decision was to stay in the shadows.

Also I'd like to mention that some letters of opposition are likely confusing city limits issues with unincorporated county issues

Thank you for reading.
Russ

It upsets me that cannabis on many occasions is associated with crime. There are many various aspects of crime activity in this county. Some of it has to do with drug use and or abuse, other parts of it with mental health, yes, some of it comes from cannabis, but to say that all cannabis falls into a crime infested reality is a hard pill for me, and I can only hope, for all of you, to swallow.

Now, I don’t know if I am 100% clear on the full aspect of what will be discussed and agreed upon, but I think that those of us that have given everything we’ve got to see this reality of cannabis legalization succeed, believe that there is yet so very much work to be done to see that all of us get through the finish line, if there is such a thing.

My wife and I entered into the county program back in the end of 2016, after having been involved in the 9.31 program that Sheriff Allman had created, but have also been a part of the prop 215 program as well, working with medical patients throughout the state. So we have been in this business, working and doing our best to stay positive with all the twists and turns and trials and tribulations. That being said, we strongly urge you, our Board of Supervisors, to please not forget the Phase 1 applicants. We have worked tirelessly, we have done our very best to give you the county, as well as the state, everything you have asked for at the drop of a dime. We personally have been in great standing with both the county and the state. But we are fearing the worst. We don’t know what the solutions are. We hope that this discussion will help address those issues.
In regards to changing the regs on the allowed 6 plants within city limits or in neighborhoods. All I can say is the discussion has to be based around the idea of quality of life. It’s a hard conversation. Because quality of life in this goes both ways. Those in favor and those against. Those against could potentially have a prejudice and so will find any idea to grab onto to complain. Or they could have a valid concern. Personally, I can’t say I’ve heard a valid concern. That doesn’t mean there are any any. I just haven’t heard them. I have heard some cockamamie ones though. On the pro side, There could be a medical patient who needs to grow their own medicine because they can’t afford it elsewhere. They should have that right. One question I would ask, how does California code express cannabis for a medical patient. Do they have rights under some sort of health guideline that states they can’t be denied their medicine? If this is the case, then I would take a hard look at why we deny some of these patients their rights handed down by the state.

I know you all have a hard road ahead. We all do. But I have trust and faith in the ingenuity of our thoughts and will, and our systems that have been put in place to be able to make those decisions that can propel a peoples forward into the future. I hope that we can have the vision and the strength and the ingenuity to make those decisions, the ones that might look frightening now, but what we can only hope will bring good fortunes and well being for our county and all its people on a whole. I thank you all for doing the hard work and for taking the time to read my message. Wishing you all the best.

Dear Honorable Supervisors,

We appreciate the ongoing re-visioning of the cannabis policy locally as the County, as well as the country & the entire world, continue to evolve their opinions of this medicinal plant. We support the Covelo Cannabis Advocacy Group & the Round Valley MAC recommendations. We are in agreement that various options need to be in place for the commercial cannabis industry & specifically for the Annual cultivation licenses from the State to be attainable here in Mendocino. We have attended many meetings, participated in working groups, offered up public comments, written letters to the BOS… & we want to reiterate again, even if Phase 3 becomes the answer to the Phase 1 dilemma, please prioritize Phase 1 applicants & permit holders.

When we stepped forward in the cannabis program, we were told that obtaining a County permit would be the equivalent of the State license. While that may have been the intent, that is simply not true. As a farm who has had an actual County permit for cannabis cultivation since 2017 & a State provisional license since 2018, we are still waiting for the County & the State to work out the CEQA issues. It was clear from the start that the regulations did not line up yet it was expressed all along in BOS meetings & by various iterations of cannabis staff in both the Agriculture & Building & Planning Depts for cultivators not to worry about it, they were going to find a compromise… 3+ years in we are all still waiting! Only to learn recently at the time of our third County renewal, that we are among the group that were approved but do not have the SSHR or air quality, & now the County wants a site plan & other information far & beyond what the State requires, etc. To top it off, there is not enough staff to get even Phase 1 through this process. We are still jumping through all of those hoops with the hope of attaining an Annual license from the State, but truth is, it is a more than ever assumed risk at this point for our farm & most of the phase 1 farms, with no clear path to bridge the gaps from the County to State. Therefore, we are still unclear why the 10% expansion idea for a few seems fair or doable while leaving so many behind.

We acknowledge the difference between commercial ventures & personal gardens. We believe strongly that people should have the right to grow their organic herbal medicines next to their heirloom tomatoes. A commercial Hemp pilot program was approved by the BOS in this county late last year for any zone. That hemp will be grown for smokeable CBD flower, not textiles, since there is nowhere near enough room in this county to grow enough hemp for paper, fabric, rope. Hemp enjoys the favor of being decriminalized due to the 2018 farm bill. We wonder why it is OK to grow hemp in any backyard anywhere in the county, yet the main complaint we have seen online about backyard cannabis is related to the is the scent. Hemp is the same plant as cannabis & therefore it carries the same terpene profiles in other words, it smells the same!! As for crime, no thief will be able to tell the difference between hemp & cannabis. The discussion we have seen online over the weekend amounts to nothing more than reefer madness. Cannabis is legal for adult use in California. Hemp has a different commercial agricultural designation federally right now, that’s it. There is much work being done to sort out the need for parity between these two varieties of the same plant species.

Did you all know that while Mendocino County is looking at adopting a land use permit system today instead of the ministerial permit in place now, Sonoma County is at the same time switching from a use permit to a ministerial permit system. So, which way is the way forward for the 1200+ family farms already in the process???!!! We agree with the CCAG stance to allow everyone with a commercial permit (or county embossed receipt) to apply to expand to a half acre at this time. The Phase 3 10% plan as it stands right now only seems to engage well-funded corporate interests & that seems like the opposite of what our county has been working on all this time, which is a sustainable path saving the small farms.

Sincerely, Laura & Marty Clein

No decisions should be made on this item as the proposal changed at the last minute, depriving constituents and stakeholders adequate time to study the proposal and prepare a response (or even know this is happening). To throw out nearly all the restrictions, including the requirement that cannabis growers reside on the property, would seem to send a message that anyone can use our land and our water and not even live here or contribute to the community or the economy (since many of these harvests will be sold on the black market). This would be a loss for everyone in our county including commercial growers who are working hard to meet the requirements and pass CEQA. This important topic which affects future livability in our county deserves a robust public conversation, not a last minute run around public process.

I am vehemently opposed to any additional changes to cannabis facilities within residential areas. I currently have a huge nine hoop house grow across from my front yard. There are additional trailers on the property, several people staying there, large trucks in and out from 6am - 8pm, strong odors and questionable visitors.
I agree with Ms. Yarbrough and Mr. Green below. The representatives are not representing the residents of this county. We are opposed to new zoning and additional facilities within Mendocino county near residential areas. This board is notorious for spending exorbitant amounts of time on cannabis and having very little to show for it. This is, at best, an altering of the previously agreed course, and at worst a betrayal, and outright REVERSAL of action that had strong support. Please leave the residential protections alone.

It is unbelievable that this is even a conversation when the explicit wishes of the community are known, have been known, and oppose these changes. Furthermore, the short window of time allocated to the public to study the matter and respond, and the backhanded way supervisors introduced these changes creates mistrust in the reliability of our representatives.

The protections for rural residential neighborhoods from commercial and personal cannabis grows took significant time and effort to establish with major public input. After debate, wrangling and public input spanning untold hours and meetings with the BOS, these said protections were established. This wasn’t decades ago. These have been fought for and constantly defended since at least 2016 and even last year. Why are we here now? These residential protections were established not because people like or dislike cannabis as a whole, but because constituents want their neighborhoods to be less contaminated with the odor, peaceful enjoyment of the neighborhood and your own property, and less chance of crime. Is that so bad? I think we can all agree that cannabis isn’t apples or grapes or some other benign crop. It has a pungent odor. And yes, whether its 6 plants, 12 plants or more, there will be an illegal market element, and therefore, cash, and an invite for crime.
This board is notorious for spending exorbitant amounts of time on cannabis and having very little to show for it. This is, at best, an altering of the previously agreed course, and at worst a betrayal, and outright REVERSAL of action that had strong support. Please leave the residential protections alone.