Small Marijuana Grower Advocates Urge Reforms to Humboldt County Supervisors and Planning Department

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Hummap Humboldt Mendocino Marijuana Advocacy ProjectThe following letter was sent to the Humboldt County Planning Commissioners and Supervisors from HUMMAP (Humboldt-Mendocino Marijuana Advocacy Project):

Dear Planning Commissioners and Supervisors:

These are the initial comments of the Humboldt-Mendocino Marijuana Advocacy Project (HUMMAP) on the proposed commercial marijuana ordinance. We are pleased to see some thoughtful new changes in the proposal. These suggest that you as decision makers are concerned to develop a healthy marijuana industry in our county, and with that we are pleased. But what we are hearing from our members and others is that the regulations thus far have been so ineffective as to be widely viewed as a disaster, and we think it is very telling that in the recent ordinance deliberations by both the Trinity and the Mendocino Supervisors it was strongly stated that a goal was to avoid being like Humboldt. You are grasping neither the magnitude nor the seriousness of the destruction that is occurring. Please adopt the improvements we here suggest.

1) The Artisanal Program (55.4.13). This innovative program pays due honor to the people, the history, and the motives underlying this industry by assuring its fitting future. The persons who helped to develop this program include the one who in the 1970s imported to the US the seeds that provided key genetics to the marijuana now grown in North America and Europe, and two others who were the first to stabilize the CBD clones now so strongly sought for dramatic health benefits, especially for pediatric seizures. The ideals driving these spectacular accomplishments never revolved around money, but were primarily founded on a deep belief in the special significance of marijuana.

Artisans, then, are focused primarily on the quality of the product, using the knowledge that quality finally lies well beyond industrial manipulations. Accordingly, we must object strongly that the change proposed to this program misunderstands what it is about. The proposed change to which we object is the inclusion of the use of artificial lights in artisanal cultivation, where the prior ordinance (55.4.15) specified natural light only. We strongly request this new feature be dropped, and sun-grown only be retained! The use of lights merely facilitates the commercialization of an otherwise ethics-based product. It has no place in this wholesome history.

2) Timberland (;;; etc.). In several places the proposed ordinance refers to timberland, but the usages appear to be confused, misleading, and inaccurate. The ordinance variously cites the included definition “Timberland”, “TPZ zones”, and “General Plan Land Use Designation of Timberland”; and Public Resources Code 4526 is also mentioned. Most timberland as defined by PRC 4526 is not in TPZ and U, as the ordinance repeatedly suggests. These zones are not the only timberlands requiring the protections of the ordinance. It remains a common myth that TPZ is all, or nearly all, forest lands.

If you consult your institutional memory, you may recall receiving a letter on this topic, dated November 2, 2015, from Unit Chief Hugh Scanlon of the Department of Forestry and Fire Protection. I quote from that letter: “It should be noted that the Department’s authority is not limited to timberland production zone (TPZ) land, but any land that is considered timberland. Timberland is defined as “non-federal land which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees (PRC § 4526).”” These all are lands for which the Department must issue the three-acre exemptions, and thus all such lands should be addressed in the various relevant ordinance provisions. For example, CalFire found numerous violations of the exemption requirement within the Forest Recreation (FR) zone, yet that important zone is not addressed regarding generator restrictions, among other matters.

Chief Hugh Scanlon continued: “The Humboldt-Del Norte Unit evaluated illegal timberland conversion in Humboldt County, which has increased dramatically due to cannabis cultivation. The Department concluded that approximately 88% of timberland conversions have been completed without CAL FIRE compliance.[…] These illegal operations were found on timberland, regardless of zoning.”

When the TPZ law passed, many residents opted not to include their timberlands. This means among other things that there is a patchwork of these zoning categories, which may result in neighbor impacts. Some of these parcels also contain unrecorded wildlife such as Spotted Owls, as evidenced by the Humboldt Breeding Bird Atlas, and that wildlife remains seriously vulnerable to impacts such as generator noise and expansion of pre-existing cultivation sites. Differences in zoning do not equate to differences in significant adverse habitat impacts. We request all forest lands be treated in a uniform protective manner.

3) Building Code Compliance for existing residences ( An issue strongly discussed in the fora leading up to the passage of the current ordinance was whether to require inspections and compliance upgrades for non-commercial structures on an applicant’s parcel, and it was clearly concluded by decision makers that only the structures and facilities used in the commercial operation needed inspection and compliance. Planning and Building is again attempting to provoke unnecessary social controversy by imposing the inspections requirement.

We restate again that it is important to keep in view here the history. The homes now once again targeted by Planning and Building were built decades ago and have been quite satisfactorily occupied all the while. The reason they were not permitted when built is because the Planning Department at that time attempted social genocide against the back-to-the-land people by refusing or obstructing to issue permits. Contrary again to popular myth, not all of these homesteaders became wealthy from marijuana. In fact, most came here specifically to avoid materialistic lifestyles. Therefore, many of them cannot today afford the hugely expensive upgrades that likely would be required, septic systems being a premier example. By rights, the County should pay for these as damages. These homes when not actively a part of any commercial operation should continue to stand aside from relevance to this process. This should not be another kick at homesteaders. They have a right to continue living here. We request the limited compliance policy of the current ordinance be retained.

4) Roads ( This provision requires virtually all commercial growers on private roads to join or establish road associations. It is highly controversial not least because it is yet another attempt by county government to impose social engineering on rural residents.

By law, or so we are informed, road associations must comply with standard constitutional guarantees of rights. For example, they must be governed democratically by direct vote by, or representation of, all affected parties, and, given the length and interconnections of remote rural road systems, this organization alone presumes a large bureaucratic effort. That is but the small matter. You should understand that our rural communities have long ceased to be uniform populations (if they ever were), and they contain strongly diverse attitudes. The proposal before you favors those bent upon resource extraction over those whose long-established interest is to reside in a rural setting. This road proposal is a key part of the effort to industrialize the entire county by piecemeal changes. It seems the most basic concepts of zoning are being pushed aside.

In this instance the inevitable domination of road associations by industrial interests plausibly will result in flat taxes that spread their high impact costs to low impact residents — this already has been repeatedly attempted. This is bound to generate serious conflicts. It amounts to a de facto conspiracy to engage in takings, as some residents may be forced from their homes by inability or unwillingness to subsidize the heavy users. Therefore you have an affirmative responsibility to foresee these matters. Traffic has increased on private roads by a probable factor of more than twelve, including far more heavy trucks, which are the big damagers, and essentially all that increase is related to industrial marijuana use.

Road association costs established pursuant to this proposal should be borne by commercial users only as their cost of business in a secondary zone, and should be graded by impact such as square footage of cultivation and measures of traffic. Alternatively, the County should deal with these issues based on each individual application, soliciting the input of road co-users, and the County certainly should establish effective enforcement mechanisms. Also, Director Ford mentioned on a radio program that rural road usage could be subject to an entirely separate use application permit, and it seems likely this may be the best suggestion of all.

5) Hearing ( When a Hearing is held, the Hearing Officer should have the discretion to deny the application based on significant adverse effects on the natural environment, in addition to the other listed causes.

6) Permit Approvals. We join with others in shouting the horror that is happening so widely and intensely now throughout our wildlands. Inappropriately sited and irresponsibly conducted grows are nothing but exploitation of the community, the environment, and the future. They also strongly damage the credibility and good will of the industry. County officials repeatedly have told of their awareness of the ineffectiveness of enforcement. You cannot continue ignoring this ugly reality, and we request you cease contributing to it. We request that no new applications be accepted, including indoor, outdoor, or mixed, until all the pending ones are responsibly completed and approved, and that expansions of grows likewise be entirely restrained. Until we are working with a regulated and accountable industry, we shouldn’t be thinking of expanding it.[Edit: Bold format added]

Thank you for considering our suggestions. We recognize the weight that is on your shoulders, and admire every instance of doing the right thing. Hopefully this time around the Board will give the Commission at least as much consideration as the Commission has shown to us.

Robert Sutherland

Humboldt-Mendocino Marijuana Advocacy Project (HUMMAP)



  • Love #1. It is true and I back that fully! Well heck #2 and #3 are excellent points also!! Not all back-to-the-landers have left or “sold out” and became mass consumers. I know a couple dozen at least that came here 70s into mid-80s and grew a little just to be able to stay….extra funds went to forest rehab or Sally Bell Grove fight or later on Headwaters, stuff like that. The Man Who walks in the Woods speaks for us. This shitshow is hammering down on all the wrong people.

    • Yep. I agree completely.

    • Thirded.

      • “We request that no new applications be accepted, including indoor, outdoor, or mixed, until all the pending ones are responsibly completed and approved, and that expansions of grows likewise be entirely restrained. Until we are working with a regulated and accountable industry, we shouldn’t be thinking of expanding ”

        While I agree with most of this letters points this final point above makes me question the sound reasoning before it . when in my opinion it would be logical to allow new permitted grows on prime ag ,with slopes less than 5%. Let the agriculture lands in our county be used provided the corporation applying show they can store proper water supply before allowing permit approval.

  • What I think would have been great is to allow everyone to have 100 plants per homestead. Following all environmental concerns of course. As usual the big money always wins just like Maxxam.

    • Could you even imagine if “everyone” in SoHum was legally allowed to grow 100 plants per homestead? There would be no more water in the river, but I guess water is not an environmental concern? The biggest difference between SoHum and NoHum, NoHum has so much more water, it doesn’t know what to do with it all, and SoHum can only dream about it, as they call for another truck load of water from NoHum…

      • Dam near everyone is growing 100 plants in sohum lol. And for the people that arent there’s people growing 10,000 plants to make up for them. How clueless are you??

      • Yes I can imagine it and it’s a beautiful continuation of a disappearing lifestyle. And it’s exactly what should be happening. Not just in Humboldt but state wide. 100 plants maximum. And with no tolerance for further timber zone conversion. And no nonsense about code enforcement. But 100% expectation of water forbearance outside the mad River watershed.

        • So how do you insure compliance to “forbearance”, storage? You cannot store or impound water with riparian water rights. Yes or No answer, would the Eel or Mattole river watersheds be as low as they are right now, if cannabis was not being grown in those areas?

          • Yes. Audits of uninhabited, but previously logged, watersheds show the water is going as fast to those mid age stands of trees as it is where people live. Ergo, yes.

            • Ernestine, is there something documented I can read that confirms your assertion?

              “Audits of uninhabited, but previously logged, watersheds show the water is going as fast to those mid age stands of trees as it is where people live.”

              The reason I ask, I have heard other people that represent growers organizations say and use the same assertion and I cannot find a single documented study or report for that same opinion or conclusion? Maybe you could provide the name of the study you are referencing?

        • Anyone remember that the state wants to grab back water from the Mad River reservoir because not enough was getting used. Two of the proposals being considered a few years back were building a pipeline to send it to the Sacramento Valley, and one was to pipeline it south to Sohum. Wonder what the HBMWD has been contemplating?

      • Lordy. I grow 12-15 plants and do just fine.

      • But “everyone” wouldn’t, couldn’t, can’t, won’t grow that many.
        Imagine how nice it would be to have full control of your own private property again. Rain water cachements everywhere useful, ponds, beautiful happy neighbors selling extra water when needed, dredging of the little creeks so they hold more water, adding gravel and sand and charcoal where needed for purifying the water…

      • Reread it Ed, I said “following all environmental concerns”.

      • ed why can’t we get an agricultural pipeline from ruth lake/eureka to sohum.. ?

        • Cost, its only money!

          I still don’t understand why the Garberville Sanitary District doesn’t sell their treated recycled wastewater and the same for the Redway Community Services District? They could both provide millions and millions of gallons of clean ag water per year. Farmers and agriculture have been using treated recycled wastewater in California for decades, why not for cannabis?

          BTW, it seems the Community Park has enough water, since they planted those 10 acres of privately
          owned wine grapes last year…

          And what about that rain water catchment farm in Garberville, what ever happened to that scheme?

  • Can't plant spaghetti

    Best seed starts happen UNDER LIGHTS. The folks that have been breeding and stablizing strains have been employing a shop flourescent or t5 and a warmed space since forever. The spring in Humboldt is too cold, long and gray to pump out decent starts on natural light alone..

    • I don’t think you k ow what you’re talking Bout. If you know what you’re doing with good genetics… Pop em on Valentine’s day in a greenhouse or sheltered space and no worries. Head high by the 4th of….. June. Take your lights and plug em into yer own head

      • Can't plant spaghetti

        Head high ,4 inchez wide and slow to sex . Haha . Hack. You don’t know how much better u could be doing. Pop em Feb 14 under t5 u get 5foot tall 3foot wide FEMALES mid…MAY!

        • Already sexed four weeks from being popped.and as wide as your corolla. Don’t need your lights. Some of us are natty brah. But you probably don’t get that dog. Hack. Whatever have a good season with your gigantic plants
          . Pic?

    • They sunk themselves and every small grower with too many demands and micromanaging. By dividing small innies and outies, would restrict permissible small grows to those who are able to own larger parcels of land or work as a share cropper. Owning land is no longer a small undertaking, especially for those who are not in the baby boomer generation.

  • The Hermit of Grizzly Mountain

    In America, first-movers rarely are the ones to profit from their innovations. The exception that proves this rule is Apple. IBM’s PC was in large part a response to the Apple ][, Microsoft Windows to capitalize on the superiority of Macintosh, Android was to be a BlackBerry clone until the iPhone was released. But Apple is the exception; 20 years ago few expected the company to survive, let alone become the world’s largest corporation.

    More common are those entrepreneurs who never profited much from their inventions. Dan Bricklin invented the spreadsheet, but failed to capitalize on it. Ted Nelson pioneered web links & micrpayments, etc and never became wealthy, let alone filthy rich. Uber has eclipsed Lyft. The examples are endless, and certainly not limited to Silicon Valley tech nor are they all recent.

    My point is, like it or not (fair or not), American Capitalism rarely favors the first movers. The real profiteers move in after the hard work has been done. It is niave to assume otherwise.

    That being said, good luck! (Sincerely)

  • Timothy McVeigh's ghost

    You want to help fix the environment? Then fix your outdated unpermitted septic!
    Says the man who recently spent $18,000 getting his septic code compliant. I mean completely replaced….

  • Honeydew Bridge C.H.U.M.P.

    I’d rather see absolutely no marijuana grown, anywhere.

    Getting the druggies to move on to create positive communities should be the plan.

    Central Valley will be growing all the dope and we all know of the terror desperate marijuana growers are capable of.

    We should use this to rid the scourge from the area.

    One marihuana plant growing is one too many, one doper growing a plant is one too many.

    No permits should be issued so the dopers move someplace else.

    • I ran into the fortune-teller
      Who said beware of lightning that might strike
      I haven’t known peace and quiet
      For so long I can’t remember what it’s like
      There’s a lone soldier on the cross
      Smoke pourin’ out of a boxcar door
      You didn’t know it, you didn’t think it could be done
      In the final end he won the wars
      After losin’ every battle
      I woke up on the roadside
      Daydreamin’ ’bout the way things sometimes are
      Visions of your chestnut mare
      Shoot through my head and are makin’ me see stars
      You hurt the ones that I love best
      And cover up the truth with lies
      One day you’ll be in the ditch
      Flies buzzin’ around your eyes
      Blood on your saddle
      Idiot wind
      Blowing through the flowers on your tomb
      Blowing through the curtains in your room
      Idiot wind
      Blowing every time you move your teeth
      You’re an idiot, babe
      It’s a wonder that you still know how to breathe

  • Just like there is no point in talking about immigration reform without first securing your borders, there is no point in discussing marijuana regulations without first having a thorough and consistent enforcement at the ready.

  • Sounds nice, but Honeydew Bridge Drumpf’s gonna have his way. Who’s gonna be running 10k+ plant operations here? Who’s gonna truck water dirt, tanks, land movers, lumber, trailers, amendments, building materials, greenhouses, etc to the end of Salmon Creek, Titlow Hill or The Gap with all this readily available–along with the buyers–all over the rest of the state. The commissioners got paid… a couple times already… and even extended the deadline (again) for yet another paycheck….

    But only small operators will be left to cater to a still fully neglected by these county planners ‘budding’ tourist economy. All such a sh*t show…. Still, Now, Today: Where is the restaurants with infused edibles in Garberville? Where’s the permits?? Where’s the Wake and Bake Bed and Breakfasts? The storefronts? The Canna Specialized Docs? The Garden Tours? The Playhouse/ CR site was for sale… why is the Cannabis college not HERE? Oakland’s economy is more stable. What a joke.

    A sad farce this “legalization”… maybe a couple three of the ‘legal’ (meaning bought out) farms with the best locations will last. Then you can work out all the track and trace forms and try to find buyers who don’t live next to a 300 acre canna farm in LA County.

    The opportunities being wasted here while the commissioners create new boards (paychecks) is unreal.

    7 Generations….. We can’t even leave nice things for the NEXT generation!

    • Honeydew Bridge C.H.U.M.P.

      Marijuana leaving is a positive thing, just read this blog and read story after story of marijuana crime.
      Dope growers are all criminal minded, you don’t want your children growing up surrounded by criminals.
      The sooner the last dope grower moves on the better.

      • And yet you are still here bumping your gums. Skidaddle!

      • There are no stories of “marijuana” crime. In every story there is a capitalist incentive, same thing that motives nearly all crime.

      • Diesel Chump Fell Off the Bridge

        My Husband and I Keep on meditating that you will slip and fall off your pedestal of bigotry, jealousy and hate [edit]… I am more worried about my kids being exposed to mentally ill delusional funda-mental christian perverts and their insanity about some make believe man above who knows when u are sleeping or awake than I would ever be concerned about them being exposed to a plant… ridiculous! Your a delusional individual Diesel Chump who spreads nothing but hate and trouble. [edit]

  • What Road Assoation

    Road assoations are not necessary the state supreme court already set the standard ,If you are one of 8 people on the road you owe 1/8 of the maintenance .This is without any signed road agreement.

  • Diesel DRW - Curb Weight 7762 lbs

    Eeeeek!! You guys are in the wrong county, you should be growing your pretentious crop down in Napa Valley… This article is enough to send someone out to the forest to grow “slash and burn weed” in the thousands of plants…

    If Humboldt County could enact law, enforce, anything at all, or collect revenue on weed, it would have many years ago. All your rules and regulations will not save you from the fact that pot is passe, and the fact that the forces of economics will render your gentleman farms barren.

    What you should be doing is shutting up before the permits and regulations you seek financially break you entirely.

    Wow. It’s pot. Best served to stupid people at room temperature, and lit with an oaken brand…

    You dopers make me sick, but you are entertaining…

    • Diesel DRW - Curb Weight 7762 lbs

      AND, chant after me:

      Brand, market, cache, packaging, tourists. Figure out how to band together and sell this crap with some class…

      Stop being so snooty and elitist, and you may survive as some kind of producer… Other than that, NOBODY needs 100 plants, and “enough to get by” should be “enough for me and my people”.

      I do enjoy the smell of wake and bake, but I am WAY past needing to do it myself….

  • I thoroughly agree, no more permits application until you take care of what you have and get some of the money from the greedy Stupervisors for more code enforcement officers. As far as building permits I have seen truckloads of lumber go past my house and I bet there are no building permits for places up the hill but we have to have them for our home. We live on a forest service road that is not maintained and the growers and their delivery people are tearing it up. Most of them do not know the meaning of slow down or be courteous to the neighbors. Also register your vehicles in California or go back where you came from!

  • mom and pop is done…
    big grows are approved…
    the county finds it easier to tax a bunch of big grows…
    rather than multitudes of small ones…
    it’s fucked for the little guy, in both Humboldt and
    should we have seen this coming?…
    (Estelle why didn’t you care?)

  • This is the County Bureaucracy turning back the gains made by United Stand back in the 80’s. This situation should be of extreme interest to everybody in the county, whatever your politics or lifestyle. Today they say they are going after that other fellow but your turn will come, no matter who or what you are. Possible $10,000 per day for code violations will eventually take land and homes from many. That is where this is going. Wake up. The move behind the move, behind the move. F & G and State Water people are in on it too.

  • The premise of the artisanal program is deeply flawed and based on an erroneous narrative. Artisan cannabis is currently, and has been primarily grown indoors.

  • Not a single one of these points supports small growers. Limits on crop size and use of light dep support small growers.

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