Policy

MCA Memo Re: Re: Agenda Item 3b for 10/13/20 BoS Meeting

October 11, 2020

Mendocino County Board of Supervisors

Low Gap Road

Ukiah, CA 95482

 

Re: Agenda Item 3b for 10/13/20 BoS Meeting

 

Discussion and Possible Action Including Presentation on the Cannabis Local Equity Program, Adoption of a Resolution Approving a Revised Mendocino County Local Equity Program Manual and Authorizing the Chief Executive Officer to Execute the Grant Agreement and Related Documents Including Extensions or Amendments (Sponsor: Planning and Building Services)

 

Honorable Supervisors,

 

MCA applauds the imminent opening of the Equity Grant process which we anticipate will provide much needed assistance to members of the cannabis community still recovering from the effects of the War on Drugs. MCA stands ready, as always, to assist the County in crafting fair eligibility criteria consistent with the requirements of this grant, as outlined by GoBiz. However, we also implore the County to separate the tasks of aligning the program to the current funding source requirements, as required by GoBiz, from the task of reworking the LEP Manual to encompass the larger, and foundational parameters of our local Equity Program. The re-worked LEP Manual can and should be used to apply for additional sources of funding to meet any needs and goals that are beyond the scope of this specific grant.

It is worth noting that a number of local grant authorities are currently in the process of changing their LEP’s to more accurately meet state requirements as well as better serve their applicants by encompassing needs and goals that are broader than the current GoBiz grant.. .

 

Here are the specific revisions that MCA suggests¹ for the County’s Local Equity Program Manual:

1. Eligibility criteria should be written to encompass the maximum number of applicants in the County whom the war On Drugs has impeded or prevented from participating in the legal, regulated industry. So, for example, the changes proposed in the 10/0/7/20 LEP Manual to the eligibility requirements could unnecessarily limit the reach of the program. While GoBiz may require certain types of eligibility requirements that can be incorporated into the list, it is imperative that care is taken to not unnecessarily limit the LEP Manual if such requirements are not specifically mandated to.² Item number 5 is illustrative of the need to further adjust language in the LEP Manual to avoid unintentionally shutting out existing cultivation businesses from eligibility. Direct harm from the War On Drugs, as proven in a variety of ways as outlined below, should, and must, be the guiding principle regarding eligibility. Additional factors can then be utilized to determine the amount of the award each applicant is entitled to.
2. In line with the GoBiz recommendations for administering the current grant, MCA recommends that the County allow applicants to use these funds at their own discretion, for the purposes needed to recover from the effects of the War On Drugs on their new or existing businesses. An applicant’s identification of the use of funds and demonstration of use of those funds for that purpose will provide accountability and allow the applicant to be eligible for future
3. In order for the applicant to prove direct harm from the War On Drugs, the LEP Manual must include a provision that requires the County to cooperate and assist applicants in obtaining the needed documentation by giving access to relevant records needed to supply proof. For example, an applicant should be allowed to offer a notice from the District Attorney of a threatened asset forfeiture, as proof of w.o.d. impact. Likewise, proof that a raid was conducted, as provided by law enforcement, would be allowed as an illustration of direct harm, regardless of whether anyone was arrested. Types of proof should be listed as examples, but should not limit the proof required to prove the direct harm (i.e.., “Proof of direct harm may include, but is not limited to…”). Sensitivity to the unique disadvantage of providing proof that victims of the War On Drugs face must be incorporated into the
4. Enable County staff evaluating grant applications to use a matrix of eligibility criteria so that, when appropriate, an increase in the amount of funding awarded is possible. This flexibility allows the County to specify different amounts in its award system and provide greater awards for those most severely
5. Adjust the recommended Eligibility Criteria so that the stated databases concerning poverty levels account for the unique position that cannabis businesses are in with respect to federal prohibition and I.R.S. Rule 280E which prohibits the depiction of ordinary businesses expenses. Cannabis industry applicants must be evaluated based on the net income of the cannabis businesses. However, to avoid grants to businesses that pay the owners high salaries or compensation, any pay to an Owner or immediate household member should be added back into the net if otherwise deducted when reporting the net income of that
6. Applicants who have successfully used equity grant funds to bring their businesses into the legal marketplace, or who are able to demonstrate use of the grant to achieve the applicant’s stated purpose for the grant (i.e., install solar power for the business, or upgrade the culvert to CDFW standards, etc.) should be eligible for further funding through a later grant.

 

In closing, it is imperative to separate out the two parallel goals of adjusting the specific grant distribution requirements in response to GoBiz’s requests for this particular grant from the separate task of reworking our county’s LEP Manual and overarching Equity Program. The LEP Manual and Equity Program must be written and designed in a manner that achieves the overall vision and purpose of ANY equity funding.. It must stick to the principles intended of redressing the harm caused by the War On Drugs on those most impacted by it. The GoBiz grant and its requirements help fill a portion of those goals. Future grants from a variety of sources may be more broadly directed than this current grant, so it is important to have an LEP Manual that encompasses the broader vision and goals of the entire county Equity Program.

 

Thank you for your consideration.

Mendocino Cannabis Alliance

 

¹ On July 13, 2020, MCA provided the County with a detailed proposed program structure, including eligibility requirements and point matrix to determine award amounts based on extensive research and Equity Program comparisons. Staff was kind enough to meet with us but has not brought forward those suggested changes. At the time, Staff indicated it did not want to delay the roll-out of the program by changing the LEP Manual. However, now, 3 months later, Staff is recommending changes to the LEP Manual and GoBiz is still approving updated LEP Manuals in other jurisdictions,

² On 10/05/20, Staff emailed the Cannabis Ad Hoc a list of preferred avenues for addressing feedback from GoBiz regarding the eligibility requirements. However, Staff incorporated the most restrictive version into this draft LEP Manual dated 10/07/20, prior to getting feedback from the Ad Hoc or stakeholders.

MCA Memo Re: Agenda Item 3a for 10/13/20 BoS Meeting

 

October 11, 2020

Mendocino County Board of Supervisors

Low Gap Road

Ukiah, CA 95482

 

Re: Agenda Item 3a for 10/13/20 BoS Meeting

 

Discussion and Possible Direction to Staff Regarding the Mendocino Cannabis Cultivation Ordinance, Including Possible Changes to Phase Three

(Sponsor: Planning and Building Services)

 

Honorable Supervisors,

 

Thank you very much for allocating this special meeting to discuss possible changes to the Mendocino Cannabis Cultivation Ordinance. We believe that decisions regarding Phase 3 cannot be made without also considering the dynamic constellation of cannabis-related policy issues that are currently unresolved.

 

Additionally, this memo will address the specific Request for Direction in the Staff Memo dated 10/13/2020 provided by the Department of Planning and Building Services regarding Phase 3 – New Cultivation Sites. Therefore, we have organized our comments into two sections. Section 1 lays out our Recommendations on the Direction of the Cannabis Program and Section 2 is our Direct Response to the PBS Staff Memo and Request for Direction.

 

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Section 1 – Recommendations on the Direction of the Cannabis Program

 

As we enter these conversations it is imperative that we bear in mind the following:

• According to preliminary Tax Collector’s projections, as reported by Supervisor McCowen at the last BoS meeting, cannabis taxes are likely to bring in $5.8 million dollars this year and have consistently been the only revenue source that has outperformed expectations.
• Sheriff Kendall has reiterated that not one of the violent crimes associated with cannabis was related to a regulated cannabis business and that he believes that there should be a path forward to bring more people into the regulated system. He also believes the current regulations, including at the local level, are far too onerous and complicated. In fact, the Sheriff has stated that if more people get into the regulated system, the ability for law enforcement to effectively pursue criminals will be bolstered. Specifically, he has stated that regulated cannabis operators are more willing to report crimes that can then be investigated and prosecuted. Additionally, he hopes that if the permitting process was simplified, there would soon be a clear distinction between those that are lawfully permitted and those that are not.¹
• Mendocino County Board of Supervisors has, from the beginning of cannabis permitting, articulated clear foundations upon which such policy has been rooted: support for legacy cultivation. The Board’s recently stated commitment to follow through on the support for successful Phase 1 applicants, despite the revealed challenges to effectively process those applications into annual permits, indicates that the County continues to believe that legacy cultivation is a priority.
• Mendocino County continues to value environmental protections, and expects those who enter the regulated system to adhere to those values and regulations.
• All those who craft a path forward must acknowledge that the complex regulatory structures enacted for cannabis have created unnecessary bottlenecks, a complete lack of parity with other industries, including other agriculture crops, and a disincentive for cannabis businesses to enter or stay in the regulated system.

 

With those foundational issues in mind, it is imperative that the County refocus its discussions in a way that aligns with the County’s long stated goals. Specifically:

 

–      It is time to treat cannabis cultivation like all other agriculture.

• Hemp production recently allowed under a Pilot Program is not taxed.
• Hemp and all other row and field crops are qualifying income for Williamson Act contracts but cannabis is not.
• Cannabis has strict testing standards not applicable to other agriculture, including products consumed by humans.
• Cannabis cannot conduct fire safety efforts without fear of losing their local permits, while other agriculture business can.
• Cannabis is being targeted by and treated differently than other agriculture with respect to building permit policies by PBS (labeling building applications as cannabis, categorizing structures as greenhouses that require F1 occupancy instead of as Ag Exempt), local fire districts (distinguishing cannabis activities as more dangerous than other agriculture without any basis), and CalFire clearance (not allowing tree removal within 100’ of any cannabis structure despite 100’ clearance rule for fire safety).

 

–      We must effectively bring into regulation all legacy cultivation.

• The current cohort of permit holders and applicants MUST be prioritized and all efforts to get them to the finish line before the deadline for State provisional licenses must take precedence.
• Additional legacy cultivation MUST be afforded an immediate opportunity to be in the regulatory system, especially now that the Equity Grant is available.

 

–       Re-opening for legacy cultivation and tying proof of prior cultivation to the land and not to the person will NOT jeopardize the use of Appendix G.

• CalCannabis has specifically agreed that reopening permits for legacy cultivation under the existing ordinance would NOT jeopardize the use of Appendix G for site-specific reviews. CDFA also explicitly stated that as far as they were concerned, proof of prior cultivation was appropriate to run with the land and not be tied to a specific person and that changing the definition of “proof of prior cultivation” in that manner would be in line with CEQA and would not change the applicability of Appendix G.

 

–    We MUST WAIT to discuss whether Phase 3 or any discretionary permit process should proceed; if it should include only legacy cultivation that did not make it through the original process; and if it should include new cultivation but prioritize legacy cultivation, until AFTER we have received word on the final scope of work required by CDFA regarding Appendix G and the preliminary success of the new SSHR review process under the CDFW approved Pilot Program.

• In order for the conversations surrounding Phase 3 to happen effectively, we first must reaffirm our goals and vision for the county.
• In order for discussions regarding Phase 3 to happen, we must receive the final information from CDFA regarding the real possibility that the scope of work required to satisfactorily complete Appendix G is far less than was anticipated. Specific indications from CDFA suggest that while our first two sample cases failed to pass the Appendix G threshold, our next two test cases went well beyond what might be required. We must have a final determination from CDFA regarding the actual parameters of what will be required in order to know the scope of the work, the hours it will take, and therefore the costs and whether we could likely conduct all of the work in the required time frame.
• In order to effectively discuss Phase 3, we must see how the Pilot Program with CDFW is going for review of SSHRs. We believe that the ordinance should also be amended, to allow for the review to be conducted by professional biologists not hired or contracted with the county as well, but at the very least, we need to see if the current cohort is going to make it through and how long the reviews will take before we start discussing Phase 3 or a land use based discretionary permit program so that we include those left behind if the SSHR review holds things up.

 

In essence, it is important to examine County priorities, reaffirm or specifically reject long standing positions, assess the reality of the current situation with concrete data that will soon be available before embarking on discussions, whether truncated, as Staff suggests, or comprehensive, regarding Phase 3, zoning, and the use of the discretionary review process.

We believe it is worth calendaring the Phase 3 discussions for a time after the appropriate data is obtained, but in a timeframe that allows the County to take advantage of California Business and Professions Code Section 26055(h), enacted under MAUCRSA, which allows a local jurisdiction to avoid additional environmental reviews ordinarily required under CEQA, if it passes a discretionary permit process before July 1, 2021², especially if it turns out to be the only path forward for existing applicants. However, to discuss the issues before more data concerning the progress and scope of the work to be conducted for Phase 1 applicants is shortsighted and meaningless. To conduct a piecemeal discussion as Staff recommends, would likely land us right back where we are now, with an ordinance that did not have the benefit of all of the relevant information.

 

Section 2 – Direct Response to the PBS Staff Memo and Request for Direction

 

PBS Staff has requested/recommended that action on the following three critical topics be deferred to a later date:

1. Developing a Discretionary Permit Model for Phase One and Two applicants;
2. Inclusion of Rangeland in the Zoning Table for Phase Three;
3. Allowance for Expanded Cultivation in Phase

 

MCA prefers to defer the entire discussion until more data is received, perhaps to November, but urges that ANY discussions involve all relevant topics.

Phase 3 has been discussed as a potential Plan B or alternate pathway for existing Phase 1 & 2 operators to achieve eligibility for CDFA Annual Licenses should the Cannabis Ad Hoc be unable to resolve the CEQA issues facing our County’s 800+ Provisional Licensees.

We reiterate our support for Staff time to be allocated to Phase 3 ONLY if: 1) the primary focus is on creating a viable pathway to annual licensure for the existing cohort of legal operators, 2) the existing cohort receive priority processing if/when this permitting window opens, and 3) the development of Phase 3 does not further jeopardize the efforts to continue processing all Phase 1 & 2 permits under the existing ordinance, including those that apply during a reopening for legacy cultivation, and if the processing of those permits allow for applicants to be eligible for CDFA Annual Licenses before the expiration of all Provisional Licenses at the end of 2021.

We cannot support any decision to develop and launch Phase 3 that does not take into consideration the above listed priorities. The Staff recommendations ignore these considerations and effectively repeat the mistakes of the past: piecemeal enactments that do not further the value behind and a cohesive vision for a county cannabis program. We see this piecemeal approach to be negligent, at best, in regards to our existing legal operators and will not support this program as proposed.

 

Below are our responses to the 6 items listed in the Staff Memo that PBS Staff is requesting direction from the board on:

[Note: Requests in the PBS Staff Memo are italicized.]

 

1. Type of discretionary permit required (Use Permits or Administrative Permits) for each permit category and zoning district on the Draft Revised Table

• MCA is in favor of the proposed zoning table and requests that resource land zones (previously included in Phase 1 & 2) including Rangeland (RL), Forestland (FL), and Timber Production Zones (TPZ) be added to the table. 
• We recommend that all new cultivation sites within resource lands require a Minor Use Permit (Minor UP) and that all existing sites (with expansion allowed up to 10,000 SF of canopy) require an Administrative Permit (AP).
• MCA has attached a Zoning Chart of its recommendations.

 

2. Confirmation of the Board’s willingness to defer to a later date the potential inclusion of RL as part of Phase Three and expansion above 10,000 square-feet.

• MCA is not in favor of deferring the inclusion of additional zones for the reasons stated above.
• We are also not in favor of deferring the inclusion of expansion above 10,000 SF. We stand by our previous position on levels of expansion and reference the following from our memo on 02/01/2020:
  • Recommendation for Outdoor Cultivation: allow expansion up to 1 acre with AP over 10,000 sq. ft. if allowed.
  • Recommendation for Mixed Light Cultivation: allow expansion, with no specific recommendation for limit across the board, but instead case by case review of the request in each application bearing in mind the resources and impact in that instance. Require AP for expansion over 10,000 sq. ft. up to 22,000 sq.ft. and UP for any expansion above 22,000 sq.ft. if allowed.
  • Recommendation for Indoor Cultivation: allow expansion, with no specific recommendation for limit across the board, but instead case by case review of the request in each application bearing in mind the resources and impact in that instance. Except for Industrial zoning, which currently allows up to 10,000 sq. ft. of Indoor cultivation, require AP for expansion over 5,000 sq. ft. and UP for any expansion above 5,000 sq.ft. if allowed. For expansion for Indoor cultivation on Industrial property above 10,000 sq. ft. if allowed, require UP.

 

3. Allowance for scaling up to a larger cultivation size permit type given the acreage averages of surrounding parcels, similar to that allowed for existing cultivation sites. See

* 2 and * 3 on the Draft Revised Table 2.

• MCA is in favor of this recommendation and agrees with Staff that this practice has been beneficial with implementation of Phases 1 & 2 and parity between the existing system and Phase 3 for this issue would be appropriate and logical.

 

4. Aligning permit categories with the California Department of Food & Agriculture (CDFA). This should be reviewed in conjunction with items 5 and 6

• MCA is in favor of this recommendation and suggests that, in most cases, efforts to align with CDFA regulations, definitions, and nomenclature will be beneficial and create less confusion for applicants/permittees.
• MCA has prepared a comparison chart of CDFA license types and Mendocino County Permit Types so that the Board may better understand the differences.

 

5. If the Board of Supervisors directs Staff to allow Specialty Indoor permit type, which would allow 501-5,000 square feet of Cultivation area, then Staff recommends the Board of Supervisors also direct staff to make additional changes to either the Specialty Cottage Indoor permit type or the square footage allowance for a Specialty Indoor permit type.

• MCA is in favor of Option 1 as presented by PBS staff. This option is aligned exactly with CDFA permit types, whereas Option 2 creates discrepancy between the MCCO and CDFA permit types. We recommend avoiding this potential for confusion.

 

6. If the Board of Supervisors directs Staff to allow the Specialty Outdoor permit type, which would allow 501-5,000 square-feet of Cultivation area, then Staff recommends the Board of Supervisors also direct staff to make additional changes to either the square footage allowance for a Specialty Cottage Outdoor permit type or the square footage allowance for a Specialty Outdoor permit

•  MCA is not in favor of a 500 SF limit on the Specialty Cottage Outdoor license type. This does not align with the 2500 Sq. Ft. limit for the same license type with CDFA. As written, the Current Table 2 (Attachment A), Draft Table 2 (Attachment B) AND the CDFA license categories are all in alignment for the tiniest state license type and we strongly recommend keeping them aligned.

 

Thank you for your consideration.

Mendocino Cannabis Alliance

 

1 Sheriff Kendall was consulted and approved of the use of this accurate statement of his position.

2 CA B&P Code Section 26055(h): Without limiting any other statutory exemption or categorical exemption, Division 13 (commencing with Section 21000) of the Public Resources Code does not apply to the adoption of an ordinance, rule, or regulation by a local jurisdiction that requires discretionary review and approval of permits, licenses, or other authorizations to engage in commercial cannabis activity. To qualify for this exemption, the discretionary review in any such law, ordinance, rule, or regulation shall include any applicable environmental review pursuant to Division 13 (commencing with Section 21000) of the Public Resources Code. This subdivision shall become inoperative on July 1, 2021.

MCA’s RECOMMENDATIONS FOR THE COUNTY CANNABIS PROGRAM

October 11, 2020

Mendocino County Cannabis Community

 

Re: MCA Recommendations for the County Cannabis Program for the 10/13/2020 BoS Meeting

 

IF YOU AGREE WITH THE BELOW, LET YOUR SUPERVISORS KNOW!! EMAIL THE BOARD OF SUPERVISORS AT: BOS@MENDOCINOCOUNTY.ORG AND TELL THEM ‘I SUPPORT THE MCA RECOMMENDATIONS!’

 

1. DESIGNATE CANNABIS CULTIVATION AS AN AGRICULTURAL CROP AND TREAT IT WTH PARITY WITH OTHER FORMS OF AGRICULTURE: ALLOWING CANNABIS IN ALL ZONES WHERE ROW & FIELD CROPS ARE ALLOWED INCLUDING RANGELAND, FORESTLAND, AND TIMBER PRODUCTION ZONES, AND BY TREATING CANNABIS THE SAME WHEN IT COMES TO BUILDING PERMITS, LOCAL FIRE ORDINANCES, CALFIRE FIRE DEFENSIBLE SPACE, TAXES, AND BUSINESS REQUIREMENTS.

 

2. WE MUST PRIORITIZE OUR EXISTING LICENSED OPERATORS AND PROVIDE THEM A PATH TO ELIGIBILITY FOR STATE ANNUAL LICENSES.

 

3. ASSOCIATE PROOF OF PRIOR CULTIVATION WITH THE LAND, NOT THE PERSON.

 

4. DISCUSSIONS REGARDING PHASE 3 SHOULD BE RESCHEDULED FOR NOVEMBER WHEN MORE INFORMATION CONCERNING THE WORK REQUIRED TO GET PHASE 1 APPLICANTS TO THE FINISH LINE HAS BEEN PRESENTED BY THE CANNABIS AD HOC COMMITTEE.

 

5. RE-OPEN PERMITTING FOR THE LEGACY CULTIVATION COMMUNITY AND FOR LEGACY CULTIVATION SITES NOW THAT THE EQUITY GRANT PROGRAM IS NEARLY LAUNCHED.

 

6. CONTINUE TO VALUE ENVIRONMENTAL PROTECTIONS AND SUSTAINABILITY BY UTILIZING THE CURRENT ORDINANCE AS A METHOD TO ENSURE ALL LEGACY CULTIVATION IS INCLUDED IN THE REGULATED FRAMEWORK, WHICH HAS THOSE PROTECTIONS BUILT-IN.

 

7. PHASE THREE MUST BE DEVELOPED FIRST AND FOREMOST AS A ‘PLAN B’ FOR THE EXISTING COHORT OF LICENSED OPERATORS IF PHASE ONE PERMITS ARE NOT ELIGIBLE FOR STATE ANNUAL LICENSES.

 

8. ALLOW EXPANSION UP TO 1 ACRE FOR OUTDOOR AND ALLOW EXPANSION FOR MIXED LIGHT AND INDOOR BASED ON A SITE-SPECIFIC REVIEW OF THE IMPACT TO THE ENVIRONMENT AND NATURAL RESOURCES THROUGH A DISCRETIONARY PERMIT PROCESS.

 

9. FOR NEW OR EXPANDED CULTIVATION, USE ADMINISTRATIVE PERMITS (AP) AS THE METHOD OF DISCRETIONARY REVIEW IN ALL ZONES WHERE POSSIBLE, ONLY USING MINOR USE PERMITS WHEN ABSOLUTELY NECESSARY AND IN PARITY WITH OTHER AGRICULTURAL CROPS.

 

10. THE LOCAL EQUITY PROGRAM MANUAL (LEP) MUST BE REWRITTEN TO ENSURE THE MAXIMUM NUMBER OF PERSONS IMPACTED BY THE WAR ON DRUGS ARE SERVED BY THE PROGRAM. ELIGIBILITY CRITERIA MUST BE BASED ON DIRECT HARM BY THE WAR ON DRUGS WITH AN EXPANSIVE APPROACH TO HARM – THE COUNTY MUST ASSIST IN PROVIDING ACCESS TO RECORDS THAT PROVE DIRECT HARM (RAIDS, ). ADDITIONAL IMPACT FACTORS CAN AND SHOULD BE USED TO DETERMINE THE LEVEL OF AWARD TO EACH APPLICANT. AWARDEES MUST BE FREE TO DETERMINE WHAT THE MONEY WILL BE SPENT ON TO ADDRESS THE NEEDS OF THEIR CANNABIS BUSINESSES.

MCA County Cannabis Program Status Update

 

October 11, 2020

Mendocino County Cannabis Community

Re: MCA County Cannabis Program Status Update

 

In advance of the BoS meeting on October 13, 2020 focused on the County cannabis program, MCA has put together the following assessment of the current situation:

 

• Enforcement without opportunity is a broken paradigm. As long as our local permits (and annual state licenses) are inaccessible to existing unlicensed farmers, our friends and neighbors have no opportunity to participate in the regulated cannabis

 

• Sheriff Kendall has reiterated that none of the recent violent crimes have been associated with licensed farms. He agrees that there should be a path forward to bring more people into the regulated system. He also believes that current local and state regulations are far too onerous and

 

• Cannabis is an agricultural crop, cultivation is an agricultural activity, and MENDOCINO CANNABIS CULTIVATORS ARE FARMERS. Until the local and state regulations reflect this reality accurately, our cannabis farmers will continue to struggle to participate in the regulated system.

 

• Despite the challenges our licensed farmers continue to face, it looks like CANNABIS TAXES WILL BRING IN $5.8 MILLION THIS YEAR, AND HAVE CONSISTENTLY BEEN THE ONLY REVENUE SOURCE TO OUTPERFORM EXPECTATIONS. It is estimated that many of Mendocino’s existing cultivators are not yet licensed. When more of them can join the regulated industry, cannabis will become a truly thriving economic driver for our county. Cannabis has been deemed an essential business and if allowed to flourish, may be more insulated than other local industries that have been heavily impacted by the

 

• The Board of Supervisors has voiced support for the priority of legacy cultivation from the beginning of this regulatory process, and have recently reaffirmed their commitment to Phase One applicants. Resolving the issues facing existing licensed operators must remain the first priority in all changes to the County’s cannabis

 

• Licensed Cannabis Farms must adhere to strict environmental regulations. There are no environmental controls on unlicensed farms. The more existing farms that get licensed, the better the outcomes for our

 

 CLICK HERE to see MCA’s recommendations to the Board of Supervisors for the 10/13 meeting.