August 16, 2020

Mendocino County Board of Supervisors

501 Low Gap Road

Ukiah, CA 95482

 

Re: agenda Item 4ae – DEA Grant Funding for Illegal Cannabis Enforcement

 

Honorable Supervisors,

MCA continues to be on record as supporting enforcement on public lands and for egregious environmental violations. We also continue to register concern about militarized enforcement and to restate the reality that enforcement without the opportunity to apply for and participate in the permit program is a broken paradigm.

Federal Prohibition is a vast failure on all levels of society and it is important that local government and law enforcement keep in mind that monies for enforcement are a bandaid for a gunshot wound. Until legalization occurs at the federal level, our county will continue to encounter trespass and public lands cultivation sites.

The permitting program has been complicated and expensive, with many changes to the procedures and requirements, as well as multiple changes to the program’s management, inspectors, and administrative staff. Many farmers find themselves in limbo with the county and state, uncertain whether the program they signed up for will ultimately allow them to continue their legal operation beyond next year. Currently, it is unclear what they should be doing to  meet all of the requirements of the many agencies with oversight of different aspects of the legal cannabis industry. Given this reality, it is crucial to remember that the majority of state licensed operators have only provisional licenses, and the majority of legal county operators only have embossed application receipts at this time. Most of these people have been trying their best to comply and to navigate the constantly changing landscape, and we ask that the county acknowledge that full compliance with all requirements of all agencies is practically impossible for most operators at this time.

Additionally, our county was only recently awarded equity grant funding intended to benefit those legacy operators most impacted by the war on drugs, many of whom have been locked out of the permitted cultivation program due to financial hardship, etc. Until this program opens, and permitted cultivation is actually a possibility for these folks, enforcement on these members of our community should not take place.

In closing, for all of the reasons stated above, MCA continues to stand by our position that enforcement priorities should be focused on public lands and egregious environmental violations only. We also request that the official narrative recognize that far more than the 275 annual permit holders that are referenced in the Grant application are in good standing with the County.

 

Thank you for your consideration.

Mendocino Cannabis Alliance