Cover letter from the RBDA to the Santa Cruz County Supervisors:

The Rural Bonny Doon Association board is extremely concerned that commercial economic interests have trumped both community and environmental considerations in the Draft C4 recommendations. Our community members have expressed their concerns to us in general meetings, and many have written directly to the Supervisors and our representative.

We believe the unbalanced make-up of C4 toward commercial interests of a few has led to this result, which will have a long term damaging effect on residents and the environment. And in fact, MMRSA (including AB 243, AB 266, and SB 643) anticipated such situations where economic interests influence policy to the detriment of the public. 

The law states:

“19303. Protection of the public shall be the highest priority for the bureau in exercising its licensing, regulatory, and disciplinary functions under this chapter. Whenever the protection of the public is inconsistent with other interests sought to be promoted, the protection of the public shall be paramount.”

The RBDA urges the County Board of Supervisors to follow the intent of AB-266, to ignore the commercial “interests sought to be promoted” via C4, and implement regulations that actually protect our county’s families, neighborhoods and environment.

Our attached document provides the recommendations of the RBDA that are essential to help protect our local environment and neighborhoods.  Of the 12 items listed in the summary on pages 9-10, 4 key recommendations are:

(1) No Commercial cannabis cultivation or manufacturing on any RR or RA properties, as these properties are by definition first and foremost “residential.” Commercial interests should not supersede providing a safe and secure environment in our neighborhoods.

(2) Bonny Doon must have at least as much regulatory protection as other rural areas. Otherwise we are not being equally treated or represented. And, enforcement of county regulations will be significantly complicated.

3) Commercial operations must be within buildings with solid walls that provide security from theft and from rodents to minimize the need for rodenticides and to keep crops secure. Given the difficulty that our county has had in eliminating grows that are illegal, non-compliant with environmental regulations, we believe it will be impossible to stop destructive use of toxic chemicals at outdoor sites. Detecting chemical usage is much more difficult, which affects human health and wellbeing, and causes environmental degradation.

 (4) The county must rigorously enforce new and existing laws for commercial cannabis cultivation. The county must conduct a detailed economic analysis (with input from code-compliance and law-enforcement authorities) to determine in advance how much it will cost to protect neighborhoods and the environment from violators. And, the county must allocate budgets and resources prior to enacting new regulations. Allowing legal cannabis cultivation must be coupled with shutting down illegal operations. New license fees and taxes should be calculated to provide adequate funds for all enforcement.

The legalization of commercial cannabis will eventually lead to large-scale commercial production in agricultural regions and industrial warehouses outside of sensitive mountain regions (See The Sacramento Bee “Struggling California desert towns seek tax bonanza with pot farms” 3/12/16).  This will likely result in prices to drop such that it is no longer profitable to grow cannabis in the mountains of the Central Coast, a region with the greatest biodiversity in the 48 states, endangered fish, and severe wildfire threat.  However, in the meantime, we urge the Santa Cruz Supervisors focus on the long term impact of the short-term desires of a few commercial grower. And, we urge the supervisors to protect our neighborhoods and environment from growing operations.

The RBDA Board previously submitted the attached document with our recommendations.  C4 made few such recommendations, but world-renowned ecologist Dr. Mary Power (UC Berkeley) submitted a letter to C4 (attached) stating that our recommendations could serve as a “model for other groups seeking to protect people and watersheds against a surge in marijuana cultivation”.

Sincerely,

Dave Rubin

Vice Chair

Rural Bonny Doon Association