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Regarding Vegetation Modification: I agree with the comments from Patrick Sellers, Jerry Munn, Michael Katz, and Hannah Nelson regarding vegetation modification and the arbitrary time frame.
Regarding property modifications: We've received unrealistic and senseless property "upgrade" requirements. For example, installing and replacing culverts on roads that have been existing for 50 years. It's dangerous. It disturbs the earth, wildlife, and homes of wildlife. The cannabis program talks about preservation, yet the requirements are the opposite of preservation.
Regarding a nursery license: Since the beginning, the BOS has said there shouldn't be a problem removing the county's arbitrary 10-acre requirement for a nursery license. This is negatively affecting the livelihoods of breeders. Farmers should be able to make their own seeds and sell their genetics.
Regarding R & D: R & D plants shouldn't be part of the total canopy calculations. The R & D plant might be an ounce. It might be a pound. These are too small of a batch size to go to market. This should be separate from the total canopy. The total canopy should only include flowers going to market, not the ones under research and development.
Regarding the cannabis program: Every single farmer that's in the Mendocino County cannabis program should be getting a permit, no matter what. Phase 1 was created to get farmers permitted. Some people refrained from applying because they wanted to see how the county was going to handle the program. Others applied with the expectation that they would receive a permit. The county staff was initially helpful in getting embossed receipts to applicants. But then the big roll of red tape came out. The county delayed and created obstacles, moving the goal posts constantly while taking tax revenue from applicants.
Now there are the people that didn't apply for permits laughing at the people that applied for permits. The people that applied feel duped. Legacy operators deserve to be 'grandfathered in' and receive a permit for doing the right thing by applying, The obstacles created by the county after the fact show a disingenuine attempt at permitting legacy operators. Instead of getting people with pre-existing operations permitted, the county has made it practically impossible to get permitted, threatening the livelihoods of small farmers, families, and county landholders. Cannabis is woven into the financial success or decline of small towns and communities.
The county should be doing everything it can to get applicants approved. The cannabis program has taken a new course of denying applicants and creating ways to not permit applicants when the cannabis program should be doing everything it can to approve legacy applicants.
I am writing on behalf of the Mendocino Cannabis Alliance to underscore the critical need to implement Hannah Nelson’s recommendations for Items 3a, 4a, and 4b. And to supplement her strong case with MCA’s specific recommendations.
Our legacy cultivators and medicine makers in the producer counties are in danger of extinction. And Mendocino County is in a most critically endangered position. The very distinguished craft products that have been developed here over decades, and that mark Mendocino’s unique added-value position in the California marketplace and beyond – THIS is what you are throwing away if you don’t start remediating the current ordinance and permitting process.
You’ve heard this from us for years but have continued to ignore the danger signs and create a system that will sell out our small farmers, our environment, and our potential role as a leader in creating a model of sustainability, along with notable quality, that will achieve state and global recognition, with all the economic value that will accompany it.
Here is a re-cap of Hannah Nelson’s and MCA’s recommendations to underscore what absolutely needs to happen in this 11th hour of attempting to save our legacy cannabis producers and products:
> ANY grading, tree removal or vegetation removal should be allowed under a modified policy;
> Create a sensible fallowing program that identifies a reasonable minimum tax and the ability to continue to sell product grown in the past. Cultivators can continue to file quarterly gross sales statements and be taxed for product sold while being exempt from the minimum tax for the time they are not actually cultivating;
> Create a long-overdue Appeals Process to support permit applicants that have been kept from obtaining a permit due to inconsistencies in how the standards have been applied by MCP staff; mistakes and misunderstandings in communications by and between staff and applicants; and staff-generated delays in approving applications with very minor and easily repaired deficiencies. This Appeals Process must be fair and explicit regarding reasons for denial and standards against which applications were judged. The cost of Appealing, especially the initial filing fee if any, must not be prohibitive so as to render the use of the appeal process meaningless.
We look forward to the Board of Supervisors’ re-commitment to supporting our cannabis farmers and medicine-makers in their good faith attempt to become part of the legal, regulated cannabis system.
Respectfully,
Jude Thilman, President
MCA
Jim Roberts
District #5
The Bohemian Chemist
The Madrones & The Brambles
Sugar Hill Farm, LLC
Philo, CA
www.themadrones.com
www.thebohemianchemist.com
Dear Honorable Supervisors,
As provisional state licensed cultivator and an annual state licensed micro-business, I adamantly oppose the current actions that are being exercised by MCP regarding vegetation notices as well as the lack of a process to file an appeal for a denied permit. There is no other department in the county that creates these types of barriers of entry and it is disturbing that these continuing obstacles are being put into place that target a marginalized part of our community that is trying so hard to comply with the regulation in our local municipality as well as our state. More disturbing is the lack of an appeal process. What other department under your guidance does this?
As a provisional licenses holder who has had a file in the county for five years, which has sat unreviewed and unassigned, I am well aware how it feels to be on the receiving end of this broken process. It is difficult for me to wrap my head around the reasoning we are continuing to see obstacles and barriers that go beyond what our state is requiring in a heavily regulated framework. Between our small cannabis business and our lodging establishment, we pay between $30,000 to $40,000 in collected taxes to the county each quarter. I am well aware of current lawsuits that are being filed regarding these draconian measures, as well as a possible class action lawsuit. It pains me to think that the money I am sending to our county could be used to fight these impending lawsuits instead of being utilized on much needed resources. I ask you to look for routes to lift barriers and search for avenues that will allow the citizens in our many communities to continue with their small farms. I would go one step further and have you look for ways to amend our current regulation, especially regarding the tree removal notice.
Our legacy cannabis farmers are the backbone of many regions in Mendocino County. They live in our communities, put their children through school here, spend their money here and work towards a better future. They are already battling and facing an extinction event from a collapsing market that may take several years to correct. They don’t need a local extermination event on top of that. To think that a filed application with fees paid towards it, which has sat unreviewed for five years, could be denied in 15 days is beyond my comprehension. I ask you to pay close attention to fact that prohibition is over and we need to stop penalizing our citizens that are navigating a very complicated path of compliance. There is a vibrant future economy ahead for the Mendocino craft cannabis market. Some of you may not think that is the case with the current landscape in our state, but I have followed this closely and know that this will happen. That golden ring will lack any authenticity if our legacy farmers and heritage farms are denied a seat at the table. I hope you will look for solutions to take as many barriers down for those who have the potential of creating much needed revenue for our county.
Mendocino county Board of Supervisors
501 Low Gap Road
Ukiah, Ca 95482
Dear Board of supervisors
As a permitted farmer since 2017, I have endured many changes to the program that have led me to no income during this process. It has been impossible to create and execute a business business plan in this ever changing environment. One day I am told I can never grow in a hoop house and must invest in substantial grading infrastructure, before a certain date, to proceed with commercial greenhouses. Then I am told I can use a hoop house but the infrastructure I was forced to install now puts me in jeopardy of CEQA compliance, due to vegetation removal, on land that has been in continual logging and grazing use since the mid 1800s. As a person on forest land with a managed timber harvest plan I was in a perfect position and started my CEQA in 2017. I was told to stop the process because I would not be allowed to include the information in my county file since the county had a mitigated negative declaration. We need a path to grandfather in legacy farmers on resource lands so they can move forward under phase 3 to do a full CEQA if deemed necessary.
I am told not to despair because the governor wants us to succeed and has made grant money available to get us through the process. I am then informed that since I am not up to date on county taxes due to no cannabis income, I will not be approved for grant funds even though I have a low income. This taxation is burdensome in a non functional industry. As farmers we need tax relief like 4 other counties and 9 cities are doing. We need relief from these taxes or at least an opportunity to utilize the grant money so we can proceed in the industry and make an income to pay the taxes. Without being able to cultivate, nor being able to sell products at a profit, how are we going to be able to pay these taxes? The cannabis bubble has burst. A system is being designed for well funded operators, yet the well funded operators have left the county and are exiting the industry due to market collapse. I do not foresee phase 3 enticing large operators and becoming a boom for our local economy.
We still have a valuable asset in our community in the form of legacy operators. We have the skills and the land. Essentially we have a dispersal of local wealth spread around the county combined with local talent that we can build a local industry on, we can increase the county income while dispersing the impact.
Also please give us a fallow system that is functional. Last year I had no crop nor a functional fallow system I could enter at the county level.
Kind regards
David King
I write to you today as a community member and proud resident of Mendocino County. My deep desire is to have the industry that I am passionately dedicated to (cannabis farming and agriculture in general) be able to thrive in our county. I thank you for holding this special meeting today to continue to discuss the complicated and new industry that you have the responsibility to regulate, commercial cannabis. It is my deepest wish that as you discuss these issues today that you put in the forefront of your mind the importance of the cannabis community in our local economy and culture and find ways to not make things more difficult for cultivators but to figure out ways (within the regulations) to make processes easier for cultivators. We are families and community members who contribute to the betterment of our communities. Not only do we contribute 6 Million Dollars in county taxes annually but we shop at our local super markets, support our local restaurants and businesses, do community service, serve on non-profit boards, our children go to our schools and much more. Please, please, please as you look at amending regulations today please remember that we care about the county as much as you do and please find solutions that will benefit us all.
It is my intention of this letter to show my support for the tireless work of MCA and Hannah Nelson and the direction given in the memos on the agenda items for the special cannabis meeting today on 3/2/22.
Thank you for your time and look forward to today's meeting.
Blaire AuClair
Regenerative Cannabis and Vegetable Farmer
Leadership Policy Committee of MCA
Board member of the Friends of the Round Valley Public Library
Regarding
Re : veg/ mod letter
I am one of the 40 applicants who portal access has recently been halted and sent a letter pertaining to vegitation modification. I feel as though the letter simply wanted information not in the ordinance, long after the established facts and as we are approaching the final countdown of issuance. Maybe I and the others issues the letter misunderstood the wording or intention. The letter had a threatening tone with no help offered. For the past 2 weeks I never never slept less or cried more worrying about the potential loss of permit status and my family i provide for.
I have had to contact pacific gas and electric multiple times and climb the later from inspector to arborist taking almost a week in its self . Providing lists of removed or trimmed vegitation since 2016 each year by a certified arborist from PGE.
I hired a 3rd party arborist to inspect the property and document the additional dead and dying debris, continuous maintenance we are required to perform , and testify to the truth of these statements.
I had local Legget fire cheif come to the site to perform a inspection and advise me on issues at hand. I included the letter from the chief in the documents.
I reached out to cal fire battalion chief Chris isham and caption Chris Vallerga who is the issuing officer in charge of my CAL FIRE condition of approval letter . All the fire agencies and officers listed above are open for dialog. I feel I have done my due diligence in maintaining my land, my safe fire definsible space according to my condition of approval. We are as cannabis farmers and full time residence of the property required to perform safe definsible zone around our home, livestock and permitted structures.
In my additional documents sent to MCO I also included pictures of down trees during storm blocking my driveway and access in and out of my property. In addition I show proof of dead and dying vegitation and uprooted for tree that fell down as well. All vegitation was used to heat our fulltime home and none was sold or taken off the property.
I want to add that the veg mod letter sent to me in BOLD stated" 15 days to respond", and ended with " if you would like to withdrawal contact the county "..... I feel this is disrespectful and ingenious to a family man waiting over one thousand eight hundred days to get to this point. If I would have not seen this letter or missed this letter I could have become homeless with my 2 kids and my wife within 30 days.
I'm asking that we build dialog with farmers and county on proper procedures moving forward, and our right to sensible fire safety be upheld by state and local level. We all have a right to safety and according to northern Mendocino fire agencies I have spoken with we are understanding that we are in a extremely high fire risk zone connecting 2 draws on a incline indicate a fast moving fire prone zone . I want to add that fire moves 7 times faster up hill than down, creating their own microclimate and climbing into the crows of trees. Fire fighters traditionally don't fight fire from the elevated uphill stance. In the last 4 years we have had 4 fires within a quarter mile of our property.
Even though I feel good about my situation it's stressful and time consuming. I want to thank you board members for listening to my story and considering adjustments for the better.
Please take time to rectify the the vegetation modification model and approach. The 15 day timeline is too short. The evidence being requested is unreasonable and not required under the ordinance.
We appreciate this special meeting. We are grateful to have John Hashchak as our District Supervisor as he hears the issues & works tirelessly toward solutions. Most of this Board seems to continue to say one thing & do another when it comes to cannabis. We hear you often state that you want to broaden the pathway, to get as many legacy farms into the regulated market, while your cannabis policy implementation does not reflect your words. To have a new Vegetation Modification system but not have it as part of this cannabis special meeting seems strange. Especially as there is such a drastic shift is process & documentation associated with it. The County's new system of the new vegetation modification assessments & the threats of denials for previously compliant situations is very concerning. Although we did not receive one of these letters at this time, in our case, we heard last week during the meeting Kristin define cultivation site as now including water storage and ponds (around 30:00 in the video). This changes everything yet again. And it goes beyond the definition provided in 10A.17, but if moving forward this is how the MCP defines what constitutes a cultivation site, then development of our ponds, which we planned to use grant money for, would constitute cancellation of our permit. Up until now we never considered the pond part of our cultivation site.In fact, 10A.17.020 "Cultivation site" means one (1) or more locations or facilities on one (1) legal parcel (or one (1) or more legal parcels if specifically allowed for by this Chapter 10A.17) subject to a single approved Permit for the cultivation of cannabis where cannabis is planted, grown, harvested, dried, cured, graded, trimmed, or processed, or that does all or any combination of those activities. One (1) or more areas of cannabis cultivation may exist on the legal parcel used for that purpose." Why & how is the County changing the definition of cultivation site or vegetation modification now? Why the continued narrowing of what is or isn't allowed. We strongly support Hannah Nelson, Patrick Sellers, & all the other farmers & consultants who have vehemently requested better ways to deal with the part of the ordinance re: tree removal. Thank you for your consideration, Laura & Marty Clein, Martyjuana™ Laura & Marty Clein, Martyjuana™
Good afternoon. I’m contacting you to ask for your much needed help. I have received a vegetation modification letter unfairly and I am not allowed to go through the correction portal.
When I moved to the property 51700 n hwy 101 Laytonville there were 3 existing bare stumps (I am completely unaware of the reason for the removal of the 3 tree’s as they were cut prior to me Purchasing the property). These stumps over time, started growing suckers and the stump started to resemble as bush, I then removed the stumps for fire mitigation purposes. If you were to look back at previous years some time prior to 2016 you will find that the tree had been chopped down to a stump years before I arrived to the property. The only thing I did was remove the stumps a few years after I arrived to the property for fire mitigation purposes.
My licensed arborist who has already inspected my property is an arborist teacher at Mendocino College
he is in Bakersfield right now doing a class and cannot get away until March 21st.
I’m pleading for your help to have Kristen Nevedal except my request for an extension until March 21st for my Letter from my arborist. And to let me through the correction portal for both my CULTIVATION AND NURSERY licenses.
I thank you so much for your time and look forward to hearing from you.
I support Hannah Nelson’s letter regarding the vegetation modification notice. Please read in full.
Patrick Sellers has some very important information/ideas and I urge you to listen to Scott Ward. These people are trying to help farmers who have been an asset to the local economy for years, if not decades.
Why does it look like the MCP program is trying to get rid of applicants in stead of working with them? A 15 day vegetation removal notice? Really? Why an arbitrary 15 days? I want to know the relevance of 15 days. We have to hire a licensed professional as well? Where is that listed in the 10A.17?
You will hear from other farmers regarding yet another flaw in the MCP program, the veg mod notice. Please listen to them as well.
The process that the Mendocino Cannabis Program (MCP) has developed to achieve compliance with the prohibition on tree removal in 10A.17 is unfair, unreasonable, and should be unlawful if it isn't.
Please consider halting the issuance of denials on the basis of this flawed 15-Day Vegetation Removal Notice process which imposes impossible requirements on cultivators who will lose everything because they can't comply.
Before I get into the specifics of what's currently happening, I'd like to state simply that a common-sense and environmentally beneficial approach would be to revise the prohibition on tree removal. Require that five trees be planted for every tree that was removed. Denying folks will just leave a scar on the land that will never be remediated.
That being said, what's being implemented by MCP now amounts to denials, not for actual tree removal but for a lack of documentation to disprove MCP's allegations that there MAY have been tree removal. I'll explain...
During last Friday's Weekly Public Meeting of the MCP, it was announced that if people removed vegetation in/around their cultivation sites in the last 6 years, they are going to deny those applications unless they can provide documentation from a licensed professional from the time that the vegetation modification took place to prove that no prohibited tree removal occurred. For those that don't know, cannabis cultivators may not remove certain, many tree species for the purposes of creating a cultivation site.
To be clear, there is no prohibition on vegetation removal in the ordinance, only tree removal. Nor is there any requirement in the ordinance to document vegetation removal in any specific way, with or without a licensed professional, at the time of the vegetation modification. Brush clearing, limbing/pruning of trees, etc., IS ALLOWED.
Despite this, MCP is saying that if you can't provide a list of modified species (again... from a licensed professional, produced at the time the vegetation modification occurred) then you will be denied. No after-the-fact analysis by a licensed professional will even be considered.
Let that sink in. Imagine that back in 2017 you cleared some brush and limbed up some trees, but you specifically did NOT remove any trees because you knew you were not allowed to. Now flash forward five years. It's early 2022 and you're starting to invest in your farm operation for the season and, lo and behold, all of a sudden you receive a 15-day notice to provide documentation (from five years prior!) proving that no tree removal occurred. And, I repeat, the only acceptable evidence must have been produced by a licensed professional at the time, even though this was not a requirement at the time you cleared the brush.
You either have that documentation from 5 years prior, or you don't. If you don't, then you're done, denied, out of business, can't pay your mortgage or rent, lose your land, your home, etc. For some folks receiving these notices, this isn't an exaggeration. This is their real-life predicament after tomorrow's 15-day deadline.
5+ years of investment in your farm down the drain because, well, you didn't think to (or couldn't afford to) hire a licensed professional, to document that you weren't doing something you weren't doing even though you weren't required to document it!
I've personally reviewed several projects who received these notices, some are clients of mine, others are friends in the program. They did not break the rules of the ordinance, and yet have no way of complying with this new documentation requirement, and will thus be denied unless something changes immediately.
This isn't the epitome of unreasonable regulation. Participating as a consultant in this industry feels more like the theater of the absurd than it does meaningful regulation. Even if someone did cut down a tree, we all know that it would be better for the environment to have them plant 5 more in its place than to shut down their farm forever. That's one way to be absolutely sure that the environment is negatively impacted...
To make matters worse, my experience of trying to get answers and clarity (from MCP and the Cannabis Ad Hoc Committee of the Board of Supervisors) on this whole vegetation removal notice and denial process has been challenging.
Below is a description of my experience attempting to address these 15-day notices during the 15 day period on behalf of 3 clients:
Day 0 - On Tuesday 2/15 at around 5 pm these 15-Day Notices went out. This was when we first found out what would be required. The notices left much open to interpretation.
Day 1 - On Wednesday 2/16 at around noon I submitted a list of eight questions regarding the notices. I asked what list of licenses or certifications would be acceptable types of 'licensed professionals'. I asked about the use of aerial imagery vs. on-the-ground surveys... whether they would allow extensions if it was impossible to get a licensed professional to the property within the 15 day period... if applicants could move their cultivation sites to prevent denial... etc.
Day 2 - On Thursday 2/17 at 6 pm, I received a response. To most of my questions, the answers were various forms of 'maybe'. (Examples: "We will consider this" or "This will need to be evaluated on a case by case basis" or "We will need to review the documentation provided before we can determine if it is adequate.") Obviously, my questions were aimed at getting clarity on what those considerations would be, what determines the adequacy of submission, what the criteria would be in those case-by-case evaluations. The answers I received provided none of the desired clarity. In fact, in response to my question regarding the types of licensed professionals, the answer I received was that a 'certified professional does not meet the requirement. ONLY a licensed forester, or licensed arborist' does. But there's no such thing as a licensed arborist. Arborists are certified professionals. The answer I received contradicted itself.
Day 3 - On Friday 2/18 at about 6 pm I responded back. I asked very specific follow-up questions and shared my concerns. I made specific requests and described how I had attempted to contact more than 22 tree service professionals to find folks with the appropriate licensing who would be able to assist within the 15-day timeframe with no luck.
Days 4 to 9 - I received no response at all from MCP during this time.
Day 9 - As requested by MCP, I submitted my questions as public comment by noon on Thursday for the Friday morning Weekly MCP meeting.
Day 10 - MCP hosted its meeting about vegetation modification during which only one of my questions submitted got answered. (See above.)
Day 13 - On Monday 2/28 I received a response to my email from ten days prior on Friday 2/18. In this response, MCP simply reiterated that "credible evidence regarding the species modified or removed must be from the entity that conducted the work or from when the work was conducted." They felt it unnecessary to answer several of my other questions, presumably because this new info (that any after-the-fact assessments would now be disallowed) rendered many of my other questions irrelevant, despite having received answers previously that those situations WOULD be considered.
Day 14 - Today, Tuesday 3/1, I'm writing this plea to the Board of Supervisors to seek a more reasonable approach than denial to as a means of reconciling 'vegetation modification' from years past.
Again, please consider halting the issuance of denials. This 15-Day Vegetation Removal Notice process is fatally flawed and imposes unreasonable and impossible requirements on cultivators who have will lose everything because they can't comply.
Respectfully,
Patrick Sellers
Headquarters Consulting
116 S. School St.
Ukiah, CA 95482
19236 tomki road resident since 2007
county wide tax reform is needed now to save 1000s of small businesses facing extinction due to overtaxation without proper representation or benefit.
And, please follow all Hannah Nelsons proposals and comments regarding all cannabis issues.
MCA fully supports the letter submitted by Hannah Nelson regarding Vegetation Modification.
The timeline for response (15 days from receipt of the letter), is completely unreasonable.
Additionally, the evidence being requested from recipients of the letter is not specifically called out in the ordinance (documentation from specifically licensed professionals) and is therefore both an onerous and unjustified burden of proof.
Additionally, by including information about Program Withdrawal to recipients of the letter, but not including alternatives to avoid a denial such as the Notice of Application Stay for applicants and the Notice of Non-Operation for Permit holders, it appears that the focus of MCP is to remove applicants from the process rather than try to help them maintain compliance.
We sincerely urge the Board to address these concerns with the MCP Director.
I support Hannah Nelson's letter regarding vegetation management the Cannabis Department's approach to applicant notification, unreasonable response deadlines and what appears to be an unequal enforcement of regulations and shifting of the burden of proof. In my experience, government regulators can get more compliance by taking a get to yes collaborative approach. I respectfully request that you provide the Canbabis Department firm direction to change their approach and work with the applicants and minimize the inconsistent application regulations and cease the overly subjective review.
Thank you,
Scott Ward
State provisional license issuance is at a stand still for Mendocino County Applicants. Many of the applicants that got caught in the extreme understaffing of CDFW did not receive a draft LSA agreement in time for the DCC modification to require draft LSA agreements prior to provisional license issuance - an obstacle to licensure. These applicants had to reapply for a state cultivation license due to their state provisional cultivation license application expiring. Currently, MCP is not responding to CEQA update requests by DCC, per the DCC in writing. This is again an obstacle to licensure. These state provisional license applicants will not be able to reapply for state provisioinal licenses if DCC application expires prior to MCP responding to DCC's CEQA update request. While I have compassion for the understaffing of MCP, that is not a valid reason for obstacles to licensure - MCP must respond to DCC in a timely manner in relation to DCC provisional licensure issuance. Our office may have to reapply for the 9 MCP applicants awaiting CEQA updates by MCP to DCC prior to provisional license issuance. This is a very serious matter that needs immediate attention. My understanding is MCP will be meeting with DCC this week regarding CEQA, but it is unclear as to what that meeting will entail. I want to thank MCP for the work they are doing, it is the most work that has been done since the original onset of the program, and for that, I am grateful. However, it may not be enough, as the "catch up" has a wide swath. Isn't the intent of 10A.17 to bring people into the regulated market? A program that is punative and restrictive does not accomplish that. Notices going out with comments on how to withdraw from the program does not accomplish that. Moving forward, any and all pathways forward should be adopted as an urgency ordinance in liue of promoting withdrawl and MCP must respond to DCC CEQA updates within the required timeframe. Provisional licenses have run out of time and no response to DCC inquiries is a county liability.
I am a resident of district 3. I'm in opposition to the process that the cannabis program has adopted regarding vegetation modification. It is unreasonable to require a 15 day response to the programs request for unreasonable evidence that is not specifically called out in the ordinance.
By including information about Program Withdrawal to recipients of the letter, but not including alternatives to avoid a denial such as the Notice of Application Stay for applicants and the Notice of Non-Operation for Permit holders, it appears that the focus of MCP is to remove applicants from the process rather than try to help them maintain compliance.
We have seen the incompetence of county staff and those running the cannabis program. It is a shame to see exactly how horribly wrong this system has been for those trying to get permitted for the last 5 years.
The Cannabis program did nothing for years for what should have been completed in timely manor.
Why is county staff not doing more to help applicants get threw this process?
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Regarding Vegetation Modification: I agree with the comments from Patrick Sellers, Jerry Munn, Michael Katz, and Hannah Nelson regarding vegetation modification and the arbitrary time frame.
Regarding property modifications: We've received unrealistic and senseless property "upgrade" requirements. For example, installing and replacing culverts on roads that have been existing for 50 years. It's dangerous. It disturbs the earth, wildlife, and homes of wildlife. The cannabis program talks about preservation, yet the requirements are the opposite of preservation.
Regarding a nursery license: Since the beginning, the BOS has said there shouldn't be a problem removing the county's arbitrary 10-acre requirement for a nursery license. This is negatively affecting the livelihoods of breeders. Farmers should be able to make their own seeds and sell their genetics.
Regarding R & D: R & D plants shouldn't be part of the total canopy calculations. The R & D plant might be an ounce. It might be a pound. These are too small of a batch size to go to market. This should be separate from the total canopy. The total canopy should only include flowers going to market, not the ones under research and development.
Regarding the cannabis program: Every single farmer that's in the Mendocino County cannabis program should be getting a permit, no matter what. Phase 1 was created to get farmers permitted. Some people refrained from applying because they wanted to see how the county was going to handle the program. Others applied with the expectation that they would receive a permit. The county staff was initially helpful in getting embossed receipts to applicants. But then the big roll of red tape came out. The county delayed and created obstacles, moving the goal posts constantly while taking tax revenue from applicants.
Now there are the people that didn't apply for permits laughing at the people that applied for permits. The people that applied feel duped. Legacy operators deserve to be 'grandfathered in' and receive a permit for doing the right thing by applying, The obstacles created by the county after the fact show a disingenuine attempt at permitting legacy operators. Instead of getting people with pre-existing operations permitted, the county has made it practically impossible to get permitted, threatening the livelihoods of small farmers, families, and county landholders. Cannabis is woven into the financial success or decline of small towns and communities.
The county should be doing everything it can to get applicants approved. The cannabis program has taken a new course of denying applicants and creating ways to not permit applicants when the cannabis program should be doing everything it can to approve legacy applicants.
Dear Honorable Supervisors:
Attached please find a memo with my comments for cannabis-related items not specifically on today's agenda.
- Lauren Mendelsohn, Esq.
Honorable Supervisors:
I am writing on behalf of the Mendocino Cannabis Alliance to underscore the critical need to implement Hannah Nelson’s recommendations for Items 3a, 4a, and 4b. And to supplement her strong case with MCA’s specific recommendations.
Our legacy cultivators and medicine makers in the producer counties are in danger of extinction. And Mendocino County is in a most critically endangered position. The very distinguished craft products that have been developed here over decades, and that mark Mendocino’s unique added-value position in the California marketplace and beyond – THIS is what you are throwing away if you don’t start remediating the current ordinance and permitting process.
You’ve heard this from us for years but have continued to ignore the danger signs and create a system that will sell out our small farmers, our environment, and our potential role as a leader in creating a model of sustainability, along with notable quality, that will achieve state and global recognition, with all the economic value that will accompany it.
Here is a re-cap of Hannah Nelson’s and MCA’s recommendations to underscore what absolutely needs to happen in this 11th hour of attempting to save our legacy cannabis producers and products:
> ANY grading, tree removal or vegetation removal should be allowed under a modified policy;
> Create a sensible fallowing program that identifies a reasonable minimum tax and the ability to continue to sell product grown in the past. Cultivators can continue to file quarterly gross sales statements and be taxed for product sold while being exempt from the minimum tax for the time they are not actually cultivating;
> Create a long-overdue Appeals Process to support permit applicants that have been kept from obtaining a permit due to inconsistencies in how the standards have been applied by MCP staff; mistakes and misunderstandings in communications by and between staff and applicants; and staff-generated delays in approving applications with very minor and easily repaired deficiencies. This Appeals Process must be fair and explicit regarding reasons for denial and standards against which applications were judged. The cost of Appealing, especially the initial filing fee if any, must not be prohibitive so as to render the use of the appeal process meaningless.
We look forward to the Board of Supervisors’ re-commitment to supporting our cannabis farmers and medicine-makers in their good faith attempt to become part of the legal, regulated cannabis system.
Respectfully,
Jude Thilman, President
MCA
Jim Roberts
District #5
The Bohemian Chemist
The Madrones & The Brambles
Sugar Hill Farm, LLC
Philo, CA
www.themadrones.com
www.thebohemianchemist.com
Dear Honorable Supervisors,
As provisional state licensed cultivator and an annual state licensed micro-business, I adamantly oppose the current actions that are being exercised by MCP regarding vegetation notices as well as the lack of a process to file an appeal for a denied permit. There is no other department in the county that creates these types of barriers of entry and it is disturbing that these continuing obstacles are being put into place that target a marginalized part of our community that is trying so hard to comply with the regulation in our local municipality as well as our state. More disturbing is the lack of an appeal process. What other department under your guidance does this?
As a provisional licenses holder who has had a file in the county for five years, which has sat unreviewed and unassigned, I am well aware how it feels to be on the receiving end of this broken process. It is difficult for me to wrap my head around the reasoning we are continuing to see obstacles and barriers that go beyond what our state is requiring in a heavily regulated framework. Between our small cannabis business and our lodging establishment, we pay between $30,000 to $40,000 in collected taxes to the county each quarter. I am well aware of current lawsuits that are being filed regarding these draconian measures, as well as a possible class action lawsuit. It pains me to think that the money I am sending to our county could be used to fight these impending lawsuits instead of being utilized on much needed resources. I ask you to look for routes to lift barriers and search for avenues that will allow the citizens in our many communities to continue with their small farms. I would go one step further and have you look for ways to amend our current regulation, especially regarding the tree removal notice.
Our legacy cannabis farmers are the backbone of many regions in Mendocino County. They live in our communities, put their children through school here, spend their money here and work towards a better future. They are already battling and facing an extinction event from a collapsing market that may take several years to correct. They don’t need a local extermination event on top of that. To think that a filed application with fees paid towards it, which has sat unreviewed for five years, could be denied in 15 days is beyond my comprehension. I ask you to pay close attention to fact that prohibition is over and we need to stop penalizing our citizens that are navigating a very complicated path of compliance. There is a vibrant future economy ahead for the Mendocino craft cannabis market. Some of you may not think that is the case with the current landscape in our state, but I have followed this closely and know that this will happen. That golden ring will lack any authenticity if our legacy farmers and heritage farms are denied a seat at the table. I hope you will look for solutions to take as many barriers down for those who have the potential of creating much needed revenue for our county.
Respectfully,
Jim Roberts
David King
P.O. Box 1866
Mendocino ca 95460
3/2/2022
Mendocino county Board of Supervisors
501 Low Gap Road
Ukiah, Ca 95482
Dear Board of supervisors
As a permitted farmer since 2017, I have endured many changes to the program that have led me to no income during this process. It has been impossible to create and execute a business business plan in this ever changing environment. One day I am told I can never grow in a hoop house and must invest in substantial grading infrastructure, before a certain date, to proceed with commercial greenhouses. Then I am told I can use a hoop house but the infrastructure I was forced to install now puts me in jeopardy of CEQA compliance, due to vegetation removal, on land that has been in continual logging and grazing use since the mid 1800s. As a person on forest land with a managed timber harvest plan I was in a perfect position and started my CEQA in 2017. I was told to stop the process because I would not be allowed to include the information in my county file since the county had a mitigated negative declaration. We need a path to grandfather in legacy farmers on resource lands so they can move forward under phase 3 to do a full CEQA if deemed necessary.
I am told not to despair because the governor wants us to succeed and has made grant money available to get us through the process. I am then informed that since I am not up to date on county taxes due to no cannabis income, I will not be approved for grant funds even though I have a low income. This taxation is burdensome in a non functional industry. As farmers we need tax relief like 4 other counties and 9 cities are doing. We need relief from these taxes or at least an opportunity to utilize the grant money so we can proceed in the industry and make an income to pay the taxes. Without being able to cultivate, nor being able to sell products at a profit, how are we going to be able to pay these taxes? The cannabis bubble has burst. A system is being designed for well funded operators, yet the well funded operators have left the county and are exiting the industry due to market collapse. I do not foresee phase 3 enticing large operators and becoming a boom for our local economy.
We still have a valuable asset in our community in the form of legacy operators. We have the skills and the land. Essentially we have a dispersal of local wealth spread around the county combined with local talent that we can build a local industry on, we can increase the county income while dispersing the impact.
Also please give us a fallow system that is functional. Last year I had no crop nor a functional fallow system I could enter at the county level.
Kind regards
David King
Dear Honorable Supervisors,
I write to you today as a community member and proud resident of Mendocino County. My deep desire is to have the industry that I am passionately dedicated to (cannabis farming and agriculture in general) be able to thrive in our county. I thank you for holding this special meeting today to continue to discuss the complicated and new industry that you have the responsibility to regulate, commercial cannabis. It is my deepest wish that as you discuss these issues today that you put in the forefront of your mind the importance of the cannabis community in our local economy and culture and find ways to not make things more difficult for cultivators but to figure out ways (within the regulations) to make processes easier for cultivators. We are families and community members who contribute to the betterment of our communities. Not only do we contribute 6 Million Dollars in county taxes annually but we shop at our local super markets, support our local restaurants and businesses, do community service, serve on non-profit boards, our children go to our schools and much more. Please, please, please as you look at amending regulations today please remember that we care about the county as much as you do and please find solutions that will benefit us all.
It is my intention of this letter to show my support for the tireless work of MCA and Hannah Nelson and the direction given in the memos on the agenda items for the special cannabis meeting today on 3/2/22.
Thank you for your time and look forward to today's meeting.
Blaire AuClair
Regenerative Cannabis and Vegetable Farmer
Leadership Policy Committee of MCA
Board member of the Friends of the Round Valley Public Library
Brandon Parker
3rd district
Bell springs Rd
Regarding
Re : veg/ mod letter
I am one of the 40 applicants who portal access has recently been halted and sent a letter pertaining to vegitation modification. I feel as though the letter simply wanted information not in the ordinance, long after the established facts and as we are approaching the final countdown of issuance. Maybe I and the others issues the letter misunderstood the wording or intention. The letter had a threatening tone with no help offered. For the past 2 weeks I never never slept less or cried more worrying about the potential loss of permit status and my family i provide for.
I have had to contact pacific gas and electric multiple times and climb the later from inspector to arborist taking almost a week in its self . Providing lists of removed or trimmed vegitation since 2016 each year by a certified arborist from PGE.
I hired a 3rd party arborist to inspect the property and document the additional dead and dying debris, continuous maintenance we are required to perform , and testify to the truth of these statements.
I had local Legget fire cheif come to the site to perform a inspection and advise me on issues at hand. I included the letter from the chief in the documents.
I reached out to cal fire battalion chief Chris isham and caption Chris Vallerga who is the issuing officer in charge of my CAL FIRE condition of approval letter . All the fire agencies and officers listed above are open for dialog. I feel I have done my due diligence in maintaining my land, my safe fire definsible space according to my condition of approval. We are as cannabis farmers and full time residence of the property required to perform safe definsible zone around our home, livestock and permitted structures.
In my additional documents sent to MCO I also included pictures of down trees during storm blocking my driveway and access in and out of my property. In addition I show proof of dead and dying vegitation and uprooted for tree that fell down as well. All vegitation was used to heat our fulltime home and none was sold or taken off the property.
I want to add that the veg mod letter sent to me in BOLD stated" 15 days to respond", and ended with " if you would like to withdrawal contact the county "..... I feel this is disrespectful and ingenious to a family man waiting over one thousand eight hundred days to get to this point. If I would have not seen this letter or missed this letter I could have become homeless with my 2 kids and my wife within 30 days.
I'm asking that we build dialog with farmers and county on proper procedures moving forward, and our right to sensible fire safety be upheld by state and local level. We all have a right to safety and according to northern Mendocino fire agencies I have spoken with we are understanding that we are in a extremely high fire risk zone connecting 2 draws on a incline indicate a fast moving fire prone zone . I want to add that fire moves 7 times faster up hill than down, creating their own microclimate and climbing into the crows of trees. Fire fighters traditionally don't fight fire from the elevated uphill stance. In the last 4 years we have had 4 fires within a quarter mile of our property.
Even though I feel good about my situation it's stressful and time consuming. I want to thank you board members for listening to my story and considering adjustments for the better.
Dear Honorable Supervisors,
Please take time to rectify the the vegetation modification model and approach. The 15 day timeline is too short. The evidence being requested is unreasonable and not required under the ordinance.
I fully supports the letter submitted by CCAG's tree removal letter and Hannah Nelson regarding Vegetation Modification.
Please find the attached public expression comment regarding tree removal.
Respectfully,
Monique Ramirez
For the Covelo Cannabis Advocacy Group
We appreciate this special meeting. We are grateful to have John Hashchak as our District Supervisor as he hears the issues & works tirelessly toward solutions. Most of this Board seems to continue to say one thing & do another when it comes to cannabis. We hear you often state that you want to broaden the pathway, to get as many legacy farms into the regulated market, while your cannabis policy implementation does not reflect your words. To have a new Vegetation Modification system but not have it as part of this cannabis special meeting seems strange. Especially as there is such a drastic shift is process & documentation associated with it. The County's new system of the new vegetation modification assessments & the threats of denials for previously compliant situations is very concerning. Although we did not receive one of these letters at this time, in our case, we heard last week during the meeting Kristin define cultivation site as now including water storage and ponds (around 30:00 in the video). This changes everything yet again. And it goes beyond the definition provided in 10A.17, but if moving forward this is how the MCP defines what constitutes a cultivation site, then development of our ponds, which we planned to use grant money for, would constitute cancellation of our permit. Up until now we never considered the pond part of our cultivation site.In fact, 10A.17.020 "Cultivation site" means one (1) or more locations or facilities on one (1) legal parcel (or one (1) or more legal parcels if specifically allowed for by this Chapter 10A.17) subject to a single approved Permit for the cultivation of cannabis where cannabis is planted, grown, harvested, dried, cured, graded, trimmed, or processed, or that does all or any combination of those activities. One (1) or more areas of cannabis cultivation may exist on the legal parcel used for that purpose." Why & how is the County changing the definition of cultivation site or vegetation modification now? Why the continued narrowing of what is or isn't allowed. We strongly support Hannah Nelson, Patrick Sellers, & all the other farmers & consultants who have vehemently requested better ways to deal with the part of the ordinance re: tree removal. Thank you for your consideration, Laura & Marty Clein, Martyjuana™ Laura & Marty Clein, Martyjuana™
Good afternoon. I’m contacting you to ask for your much needed help. I have received a vegetation modification letter unfairly and I am not allowed to go through the correction portal.
When I moved to the property 51700 n hwy 101 Laytonville there were 3 existing bare stumps (I am completely unaware of the reason for the removal of the 3 tree’s as they were cut prior to me Purchasing the property). These stumps over time, started growing suckers and the stump started to resemble as bush, I then removed the stumps for fire mitigation purposes. If you were to look back at previous years some time prior to 2016 you will find that the tree had been chopped down to a stump years before I arrived to the property. The only thing I did was remove the stumps a few years after I arrived to the property for fire mitigation purposes.
My licensed arborist who has already inspected my property is an arborist teacher at Mendocino College
𝙍. 𝗖𝗮𝗻𝗱𝗹𝗲𝗿 𝗦𝗲𝘄𝗮𝗿𝗱
𝗜.𝗦.𝗔 𝗔𝗿𝗯𝗼𝗿𝗶𝘀𝘁, 𝗨𝘁𝗶𝗹𝗶𝘆 𝗦𝗽𝗲𝗰𝗶𝗮𝗹𝗶𝘀𝘁
𝗪𝗘-𝟵𝟮𝟵𝟮𝗮𝘂
𝗧𝗿𝗲𝗲 𝗖𝗮𝗿𝗲 𝗜𝗻𝗱𝘂𝘀𝘁𝗿𝘆 𝗔𝘀𝘀𝗼𝗰𝗶𝗮𝘁𝗶𝗼𝗻
𝗖𝗧𝗦𝗣#𝟬𝟯𝟴𝟵𝟳
he is in Bakersfield right now doing a class and cannot get away until March 21st.
I’m pleading for your help to have Kristen Nevedal except my request for an extension until March 21st for my Letter from my arborist. And to let me through the correction portal for both my CULTIVATION AND NURSERY licenses.
I thank you so much for your time and look forward to hearing from you.
Sincerely,
JeNae Jellison
AG_2018-0079
AG_2018-0417
Honorable Board of Supervisors,
I support Hannah Nelson’s letter regarding the vegetation modification notice. Please read in full.
Patrick Sellers has some very important information/ideas and I urge you to listen to Scott Ward. These people are trying to help farmers who have been an asset to the local economy for years, if not decades.
Why does it look like the MCP program is trying to get rid of applicants in stead of working with them? A 15 day vegetation removal notice? Really? Why an arbitrary 15 days? I want to know the relevance of 15 days. We have to hire a licensed professional as well? Where is that listed in the 10A.17?
You will hear from other farmers regarding yet another flaw in the MCP program, the veg mod notice. Please listen to them as well.
Thank you for your time.
Honorable Board of Supervisors,
The process that the Mendocino Cannabis Program (MCP) has developed to achieve compliance with the prohibition on tree removal in 10A.17 is unfair, unreasonable, and should be unlawful if it isn't.
Please consider halting the issuance of denials on the basis of this flawed 15-Day Vegetation Removal Notice process which imposes impossible requirements on cultivators who will lose everything because they can't comply.
Before I get into the specifics of what's currently happening, I'd like to state simply that a common-sense and environmentally beneficial approach would be to revise the prohibition on tree removal. Require that five trees be planted for every tree that was removed. Denying folks will just leave a scar on the land that will never be remediated.
That being said, what's being implemented by MCP now amounts to denials, not for actual tree removal but for a lack of documentation to disprove MCP's allegations that there MAY have been tree removal. I'll explain...
During last Friday's Weekly Public Meeting of the MCP, it was announced that if people removed vegetation in/around their cultivation sites in the last 6 years, they are going to deny those applications unless they can provide documentation from a licensed professional from the time that the vegetation modification took place to prove that no prohibited tree removal occurred. For those that don't know, cannabis cultivators may not remove certain, many tree species for the purposes of creating a cultivation site.
To be clear, there is no prohibition on vegetation removal in the ordinance, only tree removal. Nor is there any requirement in the ordinance to document vegetation removal in any specific way, with or without a licensed professional, at the time of the vegetation modification. Brush clearing, limbing/pruning of trees, etc., IS ALLOWED.
Despite this, MCP is saying that if you can't provide a list of modified species (again... from a licensed professional, produced at the time the vegetation modification occurred) then you will be denied. No after-the-fact analysis by a licensed professional will even be considered.
Let that sink in. Imagine that back in 2017 you cleared some brush and limbed up some trees, but you specifically did NOT remove any trees because you knew you were not allowed to. Now flash forward five years. It's early 2022 and you're starting to invest in your farm operation for the season and, lo and behold, all of a sudden you receive a 15-day notice to provide documentation (from five years prior!) proving that no tree removal occurred. And, I repeat, the only acceptable evidence must have been produced by a licensed professional at the time, even though this was not a requirement at the time you cleared the brush.
You either have that documentation from 5 years prior, or you don't. If you don't, then you're done, denied, out of business, can't pay your mortgage or rent, lose your land, your home, etc. For some folks receiving these notices, this isn't an exaggeration. This is their real-life predicament after tomorrow's 15-day deadline.
5+ years of investment in your farm down the drain because, well, you didn't think to (or couldn't afford to) hire a licensed professional, to document that you weren't doing something you weren't doing even though you weren't required to document it!
I've personally reviewed several projects who received these notices, some are clients of mine, others are friends in the program. They did not break the rules of the ordinance, and yet have no way of complying with this new documentation requirement, and will thus be denied unless something changes immediately.
This isn't the epitome of unreasonable regulation. Participating as a consultant in this industry feels more like the theater of the absurd than it does meaningful regulation. Even if someone did cut down a tree, we all know that it would be better for the environment to have them plant 5 more in its place than to shut down their farm forever. That's one way to be absolutely sure that the environment is negatively impacted...
To make matters worse, my experience of trying to get answers and clarity (from MCP and the Cannabis Ad Hoc Committee of the Board of Supervisors) on this whole vegetation removal notice and denial process has been challenging.
Below is a description of my experience attempting to address these 15-day notices during the 15 day period on behalf of 3 clients:
Day 0 - On Tuesday 2/15 at around 5 pm these 15-Day Notices went out. This was when we first found out what would be required. The notices left much open to interpretation.
Day 1 - On Wednesday 2/16 at around noon I submitted a list of eight questions regarding the notices. I asked what list of licenses or certifications would be acceptable types of 'licensed professionals'. I asked about the use of aerial imagery vs. on-the-ground surveys... whether they would allow extensions if it was impossible to get a licensed professional to the property within the 15 day period... if applicants could move their cultivation sites to prevent denial... etc.
Day 2 - On Thursday 2/17 at 6 pm, I received a response. To most of my questions, the answers were various forms of 'maybe'. (Examples: "We will consider this" or "This will need to be evaluated on a case by case basis" or "We will need to review the documentation provided before we can determine if it is adequate.") Obviously, my questions were aimed at getting clarity on what those considerations would be, what determines the adequacy of submission, what the criteria would be in those case-by-case evaluations. The answers I received provided none of the desired clarity. In fact, in response to my question regarding the types of licensed professionals, the answer I received was that a 'certified professional does not meet the requirement. ONLY a licensed forester, or licensed arborist' does. But there's no such thing as a licensed arborist. Arborists are certified professionals. The answer I received contradicted itself.
Day 3 - On Friday 2/18 at about 6 pm I responded back. I asked very specific follow-up questions and shared my concerns. I made specific requests and described how I had attempted to contact more than 22 tree service professionals to find folks with the appropriate licensing who would be able to assist within the 15-day timeframe with no luck.
Days 4 to 9 - I received no response at all from MCP during this time.
Day 9 - As requested by MCP, I submitted my questions as public comment by noon on Thursday for the Friday morning Weekly MCP meeting.
Day 10 - MCP hosted its meeting about vegetation modification during which only one of my questions submitted got answered. (See above.)
Day 13 - On Monday 2/28 I received a response to my email from ten days prior on Friday 2/18. In this response, MCP simply reiterated that "credible evidence regarding the species modified or removed must be from the entity that conducted the work or from when the work was conducted." They felt it unnecessary to answer several of my other questions, presumably because this new info (that any after-the-fact assessments would now be disallowed) rendered many of my other questions irrelevant, despite having received answers previously that those situations WOULD be considered.
Day 14 - Today, Tuesday 3/1, I'm writing this plea to the Board of Supervisors to seek a more reasonable approach than denial to as a means of reconciling 'vegetation modification' from years past.
Again, please consider halting the issuance of denials. This 15-Day Vegetation Removal Notice process is fatally flawed and imposes unreasonable and impossible requirements on cultivators who have will lose everything because they can't comply.
Respectfully,
Patrick Sellers
Headquarters Consulting
116 S. School St.
Ukiah, CA 95482
19236 tomki road resident since 2007
county wide tax reform is needed now to save 1000s of small businesses facing extinction due to overtaxation without proper representation or benefit.
And, please follow all Hannah Nelsons proposals and comments regarding all cannabis issues.
MCA fully supports the letter submitted by Hannah Nelson regarding Vegetation Modification.
The timeline for response (15 days from receipt of the letter), is completely unreasonable.
Additionally, the evidence being requested from recipients of the letter is not specifically called out in the ordinance (documentation from specifically licensed professionals) and is therefore both an onerous and unjustified burden of proof.
Additionally, by including information about Program Withdrawal to recipients of the letter, but not including alternatives to avoid a denial such as the Notice of Application Stay for applicants and the Notice of Non-Operation for Permit holders, it appears that the focus of MCP is to remove applicants from the process rather than try to help them maintain compliance.
We sincerely urge the Board to address these concerns with the MCP Director.
Sincerely,
Mendocino Cannabis Alliance
e: info@mendocannabis.com
I support Hannah Nelson's letter regarding vegetation management the Cannabis Department's approach to applicant notification, unreasonable response deadlines and what appears to be an unequal enforcement of regulations and shifting of the burden of proof. In my experience, government regulators can get more compliance by taking a get to yes collaborative approach. I respectfully request that you provide the Canbabis Department firm direction to change their approach and work with the applicants and minimize the inconsistent application regulations and cease the overly subjective review.
Thank you,
Scott Ward
State provisional license issuance is at a stand still for Mendocino County Applicants. Many of the applicants that got caught in the extreme understaffing of CDFW did not receive a draft LSA agreement in time for the DCC modification to require draft LSA agreements prior to provisional license issuance - an obstacle to licensure. These applicants had to reapply for a state cultivation license due to their state provisional cultivation license application expiring. Currently, MCP is not responding to CEQA update requests by DCC, per the DCC in writing. This is again an obstacle to licensure. These state provisional license applicants will not be able to reapply for state provisioinal licenses if DCC application expires prior to MCP responding to DCC's CEQA update request. While I have compassion for the understaffing of MCP, that is not a valid reason for obstacles to licensure - MCP must respond to DCC in a timely manner in relation to DCC provisional licensure issuance. Our office may have to reapply for the 9 MCP applicants awaiting CEQA updates by MCP to DCC prior to provisional license issuance. This is a very serious matter that needs immediate attention. My understanding is MCP will be meeting with DCC this week regarding CEQA, but it is unclear as to what that meeting will entail. I want to thank MCP for the work they are doing, it is the most work that has been done since the original onset of the program, and for that, I am grateful. However, it may not be enough, as the "catch up" has a wide swath. Isn't the intent of 10A.17 to bring people into the regulated market? A program that is punative and restrictive does not accomplish that. Notices going out with comments on how to withdraw from the program does not accomplish that. Moving forward, any and all pathways forward should be adopted as an urgency ordinance in liue of promoting withdrawl and MCP must respond to DCC CEQA updates within the required timeframe. Provisional licenses have run out of time and no response to DCC inquiries is a county liability.
I am a resident of district 3. I'm in opposition to the process that the cannabis program has adopted regarding vegetation modification. It is unreasonable to require a 15 day response to the programs request for unreasonable evidence that is not specifically called out in the ordinance.
By including information about Program Withdrawal to recipients of the letter, but not including alternatives to avoid a denial such as the Notice of Application Stay for applicants and the Notice of Non-Operation for Permit holders, it appears that the focus of MCP is to remove applicants from the process rather than try to help them maintain compliance.
We have seen the incompetence of county staff and those running the cannabis program. It is a shame to see exactly how horribly wrong this system has been for those trying to get permitted for the last 5 years.
The Cannabis program did nothing for years for what should have been completed in timely manor.
Why is county staff not doing more to help applicants get threw this process?