Recent Notice of Violations Sent to Cannabis Community Often Issued Erroneously, Says Letter to the Editor

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Remember opinions expressed do not necessarily reflect that of Redheaded Blackbelt nor have we checked the letters for accuracy.Letter to the Editor

Dear State Water Board Division of Water Rights and Humboldt County Community,

I am writing to share with you a concern I have about the current widespread issuance of Notice of Violations (NOVs) from the State Water Board’s Division of Water Rights Enforcement program for Failure to Obtain Cannabis Cultivation Regulatory Coverage.

Thus far, I have assisted 5 Humboldt County land owners to handle such NOVs. Of those 5 recipients, 3 contained false allegations of cultivation of cannabis without the required Small Irrigation Use Registration (SIUR), Waste Discharge Waiver, or Humboldt County permit. For those 3, all required permits are in place.

I have heard (and am observing) that these NOVs were sent widely across the Redwood Creek and Salmon Creek watersheds of southern Humboldt county. I am sure that we can agree, Notice of Violations are serious statements that ought to be issued only when a factual basis for violations exist.  Here in Humboldt County many farmers, consultants, and government personnel work very hard to achieve compliance. These erroneous violations press thin the already worn pocket books, calendars and emotional well-being of a community hard at work to comply with emerging commercial cannabis cultivation regulations.  

I am writing with suggestions for both the Water Board and the Humboldt County community that if implemented will reduce the burden of erroneous NOVs.

First, the process leading up to the issuance of NOVs ought to be changed. Prior to issuance of the NOV, a review of up to [date] permitting date data must be reviewed to confirm potential violations. The existing, publicly available sources of data summarizing compliance status include:

  1. The State Water Board’s CIWQS database.
  2. The Humboldt County Planning Department’s Monthly Cannabis Reports.
  3. The CalCannabis Cultivation Licensing Information email list serve.

Second, water diversion and cannabis cultivation permit holders ought to be ready to prove compliance. This can be done by:

  1. Understanding the permits that you have and what they permit you to do.
  2. Having digital copies of permits in a known location to be easily emailed to government personnel in response to inquiry or NOV.

I am eager to experience a reality in which our compliant community members receive the peace of mind deserving their position and am happy to further facilitate solution development.


Hollie Hall, PhD

Humboldt County Community Member



  • I was the first round in may and they cited me for illegal grading. I had a permit from timberland resource for a less than 3 acre conversion that was signed of by cal fire. The county had no record of this so I emailed the proof to them.. they said the proof was insufficient and made me drive to eureka with a hard copy of the permit which I did. We took down all of our infrastructure in 8 days and called for inspection. About a month later they scheduled an inspection and never showed. 2 months after that I called to see the status and they said they had lost the paperwork I brought months previous. So I copied and pasted the original email resent it and low and behold they finally cleared us. Well supposedly lol because I still have not received the resend letter which was supposed to come in two weeks and that was beginning of September.. land has been locked by county can’t sell can’t get permits.. can’t make a living…what a shit show

  • Sorry but the writing is on the wall, it’s a wrap we are done. This thing has been mishandled out the gate. And now that the state/county arnt getting their way we will see lots of temper tantrums in all different forms. Time to turn the page and see what the rest of life will bring.

    • Who is “we”?

      • Me and your mother Who do you think? Of course I am referring to the pot growers of Humboldt county and any of the ancillary business’ that serviced said growers.

    • I think everyone is wrong.
      I run a legal cannabis company we just made a legal sale for 20k.
      Its actually not that hard to comply i was able to do it all for about 30k on my 10k sqft grow.
      I did my own paperwork, read all the laws and was able to navigate the system just fine.
      I currently have a state license and final county permit.
      The system does work and i know other farms who are also being successful.
      All this complaining is just unfounded. sure some people don’t have what it takes to be professional.

      • You’re smart: “I did my own paperwork, read all the laws and was able to navigate the system just fine.”
        You’re rich: “Its actually not that hard to comply i was able to do it all for about 30k”
        You’re boastful: “…some people don’t have what it takes”.

        What’s your point?

        • Shrekengostnutz

        • Some people always win.

          It’s like the fine furniture guy who hired me in my 20s. He asked if I wanted to be under the table or not. “Under”. 12$/hour making his designer furniture. After 6 months, he 1099s me, and says he never remembered the conversation that way.

          Some people always win.

      • insufferable is the only word.

        always a know it all.

        Rly happy to hear your dads property was easy to get into compliance. throw yourself a party.

        a legal sale for 20k. also being successful. and w little to no syntax needed. amazing!!!

      • I think you may be on another planet..

      • Because you have sold 20k in product, you are now successful? Don’t spend it all in one place. Everybody is making sells right now.

      • In my 1911 I trust

        Hmm, spent 30k to get in compliance, just did your first 20k deal. Sounds to me like you are still 10k in the hole. Only in [edit] are you successful when you’re still in debt.

      • What’s your piece of property like? Some pieces of property are easily permitted, some would cost a million dollars to bring up to code. I’ve heard of people literally going hungry trying to get their permits.

        The only people I know who have state permits are guys with deep pockets and nice pieces of property.

  • The system was designed to fail

  • Yep, humboldt drop the ball again. The only way this community had any kind of chance to be competitive in the marijuana market after legalization, was to have things put together in a timely fashion making it reasonable for people to produce. Instead our County went the opposite direction and screwed things up as usual. Almost like it was planned that way. Even if all the regulations were dropped right now and people were allowed to grow all they want it’s too late, the rest of the state has already outpaced us. Now there’s just too much Supply and not enough demand. And with the entire country a Canada coming online, things are not going to change anytime soon, even if it goes Industrial.

    • Thc is out of touch. If his comments were true, then why are the permitted growers from HUmboldt currently getting $1200.00 per lb and more. That’s cuz people want Humboldt weed .

      • The xarrit is still on the stick. It’s rarely a sudden death. It’s usually a long drawn out affair. Death from disease or sickness. Changing landscapes, and market consolidation. People always struggle to persevere, and over come. Against the most challenging odds. You can almost look at it from a fundamentally economic point. The ones who adapt and learn how to instill the blow and go mentality will at least make it to market.

        Whether the cost of logistics will make this worth the effort.

        Stay tuned.

      • In my 1911 I trust

        Hmm, sounds like you are quoting the gross product price. That was how growers on the black market do it, that don’t pay taxes. Care to do the math and quote the net product price?

      • Yeah and less than 10 years ago it was still gone for almost 4000 a pound, just wait and see…

  • Growers are such sensetive flowers

    First off, the dope growers have made more than enough to pay for permits , just because they were foolish with their money doesnt mean they are exempt from the permit fees.If you own a business, permits are expected and simply part of doing biz as are taxes, fact is growers have been paying neither until now. Growers generally have a huge amount of free time compared to the average taxpaying worker, and other than being busted , lead a fairly stress free existence leaving plenty of time and money for trips to South America, heli skiing, surfing, eating out every night, yoga, gambling, hunting, shopping for lobster at wildberries with food stamps and other assorted dbag grower activities.

    • Rednecks are such sensitive flowers.

    • you have no idea what you are talking about.

    • This is such a stereotype!
      Sure maybe 12 years ago some grower in Arcata fit that description and was eating sushi and watering there small 10 lighter and making a ton of money!

      Those days are OVER!

      The average grower is working harder and harder with smaller and smaller profits. If you are still producing in this market it is because you are working 24/7. Growers i know work 7 days a week do not take any time off, dont have any money to spend. They were wise with there money never went on vacation and they had to spend a ton of money on compliance all while getting close to costs or nothing for there last years crop! Grower have it very hard right now! Also i think you are confused about people you assume are grower. Folks who go on vacation and are on welfare / food stamps are usually traveling hippy types. They mooch off the system and use benefits while sleeping at growers houses rent free all to save up trim money that will last then 4x months in Thailand. These are not growers they are trimmers and they have a very different way of running there life’s. Real growers don’t have this type of lifestyle because they are always working, trying to setup a legal business and operate it 7 days a week with no breaks till harvest comes!

  • Dear Hollie,

    I am eager to experience a reality in which our criminal community members receive the peace of mind deserving their position – going out of business. Can you say missed the boat?


    Taxpayers who are not criminals

  • Have to agree with this letter to the editor. The whole process of sending these out needs to be re thought. People already in the process should not be receiving these. Typical government work, the lazy route. They just sent them to everyone in a huge area. Did zero background checking into anything and now even people that aren’t even growing have to spend time to prove there innocence. Beyond F’d up!

    • I am actually happy these folks are getting notices!
      The rest of us that don’t have money right now have spent it on waterboard and other fees.
      How come i have to spend all this money and be compliant while others just continue to break the rules and complain and whine about not being about to break the law and get away with whatever they want.
      The Humboldt growers are acting like little children. Grow up pay to play if you cant you never had a right to use cannabis to print money!

      • Just because your called legal by state and county doesn’t mean the Feds won’t come bust you at any given time.

      • Your right you do sound like a child.

      • When federal legalization happens you will be left out in the cold with your 10k sq ft grow. But enjoy your little period of being a smug a-hole

      • No, the children are the ones finding happiness in other peoples struggles. The children are the ones “happy these folks are getting notices”. The adults realize most of us came from the same place, we are responsible for our own actions and we don’t find happiness in someone else’s suffering because they didn’t get signed up. These permits are really making peoples true color fly. Typed by someone with multiple permits. If you are so proud of your permit and other people getting busted, tell us your company name so we can either support you or not.

      • soon to be legal grobrough

        Whaaaaat……do you mean one cannot expect the county to look the other way while growers crap all over county, state and federal laws? What next! All these legal consultants that took money from desperate scenes should be ashamed of themselves. How can you be a legal expert money taking consultant when you they have no fucking clue what to do next.

      • Lol.. leave it to this lil white lady to call the cops on everyone she doesn’t agree with.. typical..🙄

        • Leave it to a greedy pot grower to equate public control of their destruction for dollars lifestyle with being the victim of racism. Seems likely arrogantly screwing the environment for profit makes a person more like the racist than the victim of racism.

          • Lol.. leave it to an Internet Troll to assume every ‘pot grower’ is ‘greedy’, and ‘destroying the environment’. Sounds arrogantly biased and judgmental to me.
            Instead of ‘Permit Patty’ it’s Petty permit Jojo.

      • Just remember that ‘permits’ were used to stop civil rights movements.

      • LOL, so are you involved in one of those “local” “Humboldt roots” companies who’s family registered here in 2016 from LA, Nevada or Jersey and bought land in 2017 and then quickly in 2018 registered 4 – 8 companies in Humboldt county with corporate agents in Delaware? I think I might have seen you. Or at least a bit of your footprint.

        You have carpetbagger troll written all over your responses. How do you treat your workers? Do they like you?

        Oh wait! I could be wrong. You might be fronting for someone else…

    • but you just made a 20k legal sale. and spent 30 on compliance. You lack humility and you are still complaining

  • Well said
    Compliance is supposed to be beneficial for both parties.
    If you act responsible, you should receive help, not hindrance.
    Make it easy, everyone will sign
    Make it hard, well… Here we are.

  • I spoke to Water Board Reps on Tuesday at their ‘Enrollment’, AKA, ENTRAPMENT WORKSHOP at the Mateel. One ‘Enforcement’ official gave me these stats:
    They chose to serve 2 ‘sensitive’ watershed communities with warning letters: Redwood Creek (RC) and Salmon Creek (SC).
    They first issued ‘general notice’ letters to ALL members of those communities. On August 24, they sent 299 letters to RC. On September 27 to 270 households in SC. Then they say that waited 30 days…. Of course the math doesn’t quite work for SC…. till they sent follow up warning and demand letters to parcel owners they believed were being grown on, 174 in SC, and “about the same” number in RC. They cross checked state, county and agency compliance, issued notices of (potential) violations to find that, only 4 in SC and 6 in RC were regarded to be ‘in compliance’ with all their agency criteria!
    So. At this point you might think they would offer more info and help growers to know how to conform. But ‘Noooooo! (Lol). They hold a “workshop”, with only officials and computers set up where they could get your information, to draw you into their web!
    SC and RC are being used as guinea pigs in the Water Board’s new program of asserting their authority.
    BEWARE! ‘First they came for the growers of Redwood and Salmon Creek, but I did not object because I did not live in either Salmon or redwood Creek…….’ (That paraphrased line is admittedly used as dark humor and to inject a sense of reality).

    • “They cross checked state, county and agency compliance, issued notices of (potential) violations to find that, only 4 in SC and 6 in RC were regarded to be ‘in compliance’ with all their agency criteria!”

      In light of the ongoing research by the investigative researchers WW, I can’t help but wonder if a part of the “agency criteria” consists of which political party they are signed up with.
      I could be wrong though.

  • The basic problem with the county abatement notices and the waterboard violation notices is that they are based on faulty assumptions, and not real evidence. The county does not send people out to check and see if cannabis is being grown in a greenhouse, they just send the Notice of Violation and Threat of Enormous Penalties to anyone who has, or has had, a greenhouse. In the county system you are guilty until proven innocent, so they can just send out notices more or less at random. It appears to me that the State Water Board just gets a list from the County Code Enforcement Unit and mails out it’s notices to everyone the County has attacked. . Every innocent owner who gets a notice has to take immediate action, no matter what is going on in their life, and often spend thousands on legal fees, or “compliance agreements”, or at the least hundreds on the “administrative costs” of the County’s bringing baseless charges against them. There is no incentive for the County or the State to act justly, and so they don’t. If the individuals who sent these notices had to pay the costs of accusing an innocent property owner of violations, they would be doing due diligence and investigating before accusing. We need administrative law to be overhauled so that it protects the accused with the same standard as criminal law; and so that those who misuse their authority to make baseless accusations can be individually sued for abuse of process.

    • the county has a technology called lidar that can penetrate the roof of a greenhouse it can determin if there is cannabis growing with very high accuracy, they do not need a permit they can detect that you are growing even inside metal warehouses.

      • In my 1911 I trust

        Lidar is used to strip away forest and ground layers to view topographical imagery. They can’t use that to see what is in a greenhouse.

      • “…..they do not need a permit”. Really? Can you site the court precedent that allows the government this type of surveillance and to presume the greenhouse owners as guilty, without a warrant?

  • Also, could I ask, where is the Board of Supervisors on all this. They passed the ordinances which are now being misused. They have heard from victims of the county’s process. And they do nothing to fix the problems they have created. They do nothing to reign in the country bureaucrats who are running amok, and piling up huge surpluses in the country treasury. Over 1.4 million in Abatement penalties, said Director Ford, several weeks ago.

    • Sounds like a racket to me. History has shown that we are all susceptible to the, “do as we say, not as we do”, philosophy. The power in the hands of the government is simply staggering.
      Sobering to think …death by government, aka democide, is the number one historical cause of death in the world. Match that with 10 million dollars and hour spent by the Military over the last 10 years, and you begin to see how this works. Hang together…hang apart. What a choice.

      Break the left right ,black white, have have not. rich poor, paradigm.

      This is a wealthy multi national corporate fascist game.

      The grand chessboard.
      Tragedy and hope.
      Lords of the rings.


  • I like the how the rules aren’t the same for all the players. As someone who has multiple structures and greenhouses and has permits, I’ve never once been told I need to permit my structures. However, I have a friend that received an abatement notice, no cannabis being grown and is getting fined. Right next door to him is 3 temp permit holders that suck water straight form a creek, have zero track and trace, do not have temp state, trash the properties and have greenhouse without permits. Something is wrong and the county better damn start taking responsibility. FYI, it only cost $150 to permit a greenhouse. Get the permits now and tell the county to shove it!

  • Hollie, thank you for writing and sharing the letter. I hope they answer soon and with clarity. You’ve outlined important inquiries.

  • The water board is also violating court law, if you have a spring, and it doesn’t leave your property, or it enters a creek where you have a reparian right to.. you do not have to report to the water board, or pay them. This desision has been handed down by the courts.. and is the law.. but the water board is violating this.
    It is also ridiculous that legalization actually means criminalization. Guilty by assumption. If some one was to say grow any other agricultural products on thier property.. they would not be subject to such insane amount of regulation? Why water board people to death??

    • Try running a pig or chicken farm for regulation. And they stink less.

      • Well.. there is probably a lot less regulation and red tape to run a pig or chicken farm. Lol.
        But this is not Iowa.. or even Petaluma. And actually a properly run hog or egg farm can be quite sustainable. But.. sorry a huge industry pig or chicken farm is NOT less environmentally destructive or smelly than a cannabis farm.

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