con•tig•u•ous kən-tĭg′yoo͞-əs►
adj.Sharing an edge or boundary; touching.
adj. Neighboring; adjacent.
Contiguous should be neighboring parcels or adjacent APN's. The Planning Department or Cannabis Department routinely uses the most conservative and restrictive interpretation possible. Please buck the trend of adopting the most restrictive interpretation possible and work for the farmers survival, please.
Contiguous = Neighboring parcels or adjacent APN's.
Thank you,
Heidi Wordhouse/ Jackrabbit Ranch

Board of Supervisors,

I was contacted by a sales representative from Henry’s Originals today. I’ve been expecting the call; many of my neighbors and colleagues have also heard from them.

It has been suggested to me that this recent outreach by Henry’s Originals is an attempt to paint a picture of availability of cannabis flower in Mendocino County that will persuade the Board that there is not enough inventory and therefore that there is a need to increase cultivation in our county.

This is speculative on my part. There is no evidence that this is their strategy but I am asking you to consider the following:

I am in the process of selling the harvest of one of my farms to a distributor in Humboldt County. It is quality flower but it is not ‘top shelf’. I have been offered $1,100 per pound. Henry’s Originals quote for this grade of flower was $700-900.

Everyone I know in Round Valley has flower and I know more farmers than the average cultivator. If someone tries to purchase the sweat of my brow for less than the going rate, that doesn’t mean there is no inventory. It just means there is no inventory for sale at less than market value.

Many of my neighbors and colleagues believe that Henry’s Originals constitutes a threat to the small farmer. Maybe this is true. Maybe it isn’t. But just because a cultivator decides not to do business with a company because they believe the company does not have their best interests at heart does not mean that there is no inventory.

If Henry’s Originals truly believes that there can be a symbiotic relationship between their company and the small farmers of Mendocino County I would suggest that they pay their lobbyist to start forging actual relationships with them in the form of contracts paying fair market value.

In the meantime, there is enough flower in Round Valley alone to get the entire state of California rip roaring high.

Thank you for your time,

Gabriel Ferreira

* sent to bos@mendocinocounty.org yesterday but do not see it among the comments so doubling up:

Dear Honorable Supervisors,

We support the CCAG memo on all items today. We have attended the formal & informal cannabis related meetings over the past few weeks. For that matter, we have attended countless Mendocino County government sponsored cannabis infused meetings over the years & the information has been nothing short of overwhelmingly unclear with many plot twists.

As item 6A suggests, to clarify an interpretation of the MND that phase 1 is not “new cultivation” so it most likely does not need an additional SSHR from CDFW as it relates to CEQA is great step. To be able to have most of phase 1 permittees use appendix G would be a best of all possible worlds scenario. All phase 1 parcels had preexisting cultivation in order to qualify for participation in phase 1 so they are not new. Broadening the scope of legitimacy to one farm = one project = one system of contiguous growth works for many of these projects. We welcome the acknowledgement that there was, is & will be further site specific reviews that make sense for small farms. Interpreting the countywide environmental documents this way gives us a glimmer of hope after many months of being told phase 1 is too problematic, after years of being told otherwise. What Mendocino County has going for it is not “Big Ag” but an environmentally friendly cottage industry. As we continue onward, ANYTHING the County can do to alleviate the burden on the phase 1 cohort while streamlining a path toward Annual state licensure is appreciated.

We understand there are many points of view on the past, present & future of cannabis. On his own FB page, Supervisor Ted Williams recently commented “Legacy cultivation, essentially preexisting outlaw commercial cultivation in residential settings, does not meet the state framework.” Please consider that calling it “outlaw cultivation” disregards an actual medical market operating in California for over 20 years, as passed by the voters in 1996. And our County had a medical cultivation ordinance passed by the BOS known as the 9.31 program run by the Sheriff as far back as 2010. It was a voluntary plant tag permit program which many of the phase 1 farms were involved in, yes, many who stepped forward then are the very same people on the very same homesteads who stepped forward this time around. So, for many of us legacy cultivation, though a traditional market, was very real, very legal, & by the way, a thriving small business opportunity for tax paying citizens. It’s not all coming from illegal or illicit operations, although cartel grows which are the actual "outlaw cultivation" can still be clearly seen from the road today in Covelo, we respectfully request the BOS & MCSO please consider doing something about THAT problem!

On the subject of the sunset clause, by all means clear up language as needed. We feel lucky we were not directly affected by that particular process. But even as we have followed along for years, we do still wonder about the legality of the entire idea of these sunset parcels. We know the BOS did what it thought was best to “protect neighborhoods” & the County from liability, but just as the rest of phase 1 is a mess, this sunsetting of a decades long medically focused cottage industry can be seen as part of ongoing prohibition & it’s surprising that it has not yet been challenged in court. If we are really serious about ending prohibition, couldn’t an argument be made that small lots in all zones be able to apply as long as they are subject to the same appropriate site specific environmental reviews as the giant proposed corporate operations of phase 3?!

Mendocino County is synonymous with cannabis worldwide. Mendocino had always been the leader when it comes to forward thinking cannabis policies in the United States. We understand that times have changed. We mentioned Ted because he is the Supervisor who engages with the public most often on social media about many subjects, including cannabis. He uses the words prohibition & parity. We are concerned about prohibitive tactics under the guise of regulation. We are concerned about the still negated parity, even here in Mendocino among wine grapes, hemp & cannabis, among other crops. Maybe the State does not fully understand, but we as the original cannabis cultivation region have to help educate them, because throwing the heritage farms out in favor of supposed new improved corporate interests is the exact opposite of the legacy we can create together. Which lead to the 3rd point of this item, the letter of support for SB59 is necessary & appreciated! We were able to communicate directly with Senator McGuire’s office last week & we know the bill has his full support. We, also signed on to our local advocacy association's letter. After all the wrangling back & forth between the County & the State, time is running out on the phase 1 County program unless the State extends the expiration of the Provisional licenses. The County & State must allow phase 1 permittees / provisional license holders to continue to cultivate through the process of obtaining an Annual license.

Recently reported numbers by NORML – National Organization for the Reform of Marijuana Laws… In the U.S. “Customers purchased an estimated $17.9B in cannabis products from legal retailers in 2020 – up from $10.7B in 2019.” So, yes, a major potential economic boon for all who participate, but the point we are trying to make is that it seems like there is room enough for everyone in this industry. Bigger isn’t always better, better is better… we can do better, together. The County has been a major obstacle course for the entirety of the program, we know you want to give us & the 1000 other phase 1 farms a fair chance. Thank you for your consideration in support of this item & in support of phase 1 cultivators.

Sincerely, Laura & Marty Clein