In case you were wondering what Supervisor Gore’s sister in law thought about the cannabis ordinance…

No, he didn’t recuse himself

3/13/21
Erin Gore
Old River Road Inc dba Garden Society
C12-0000062-LIC

840 N Cloverdale Blvd,
Cloverdale, CA 95425

Dear Planning Commissioners,

Thank you for the opportunity to have an open discussion with you all about the recently proposed regulations from the County of Sonoma with regards to their proposed changes for cannabis cultivation across the county. Clearly, the County’s first attempt to regulate cannabis cultivation failed because of onerous regulations and a convoluted permitting process. I support the efforts of the county to move cannabis cultivation out of Permit Sonoma and have it administered by the Ag Commissioner. While the proposed changes are a good start, they do not address some of the most pressing items needed to allow traditionally agricultural farms to enter the market and maximize their potential.

As a board member of the Cannabis Business Association of Sonoma County and licensed operator in Cloverdale, I believe that the ability for adults to safely experience the benefits of legalized cannabis is both important to the overall implementation of California’s legalization of cannabis and a potentially critical revenue generator for the County, both for its tourism industry and its economic workforce development. As has been proven with wine, the ability for people to come to Sonoma County and experience its natural beauty while meeting the producers of that product and consuming it in that setting enables the County to effectively monetize the collective reputations of artisanal producers to the tune of hundreds of millions of dollars.

Cannabis provides a similar opportunity and is arguably of more interest to changing demographics who are focused on consuming less alcohol and living a health-conscious lifestyle. There are few other industries which have the potential to provide this type of economic opportunity to the County while also preserving our rural heritage. There are already laws at the State that protect and promote cannabis appellations due to consumer recognition of the importance of terroir.
Therefore, I have the following requests for immediate incorporation into the County’s cannabis updates:

1) Land Use and Zoning Amendments for Retail- Zoning categories which allow for retail uses should be expanded to include the 4 types of agricultural zoning (LIA, LEA, RRD, DA) which currently allow for commercial cultivation. This would allow cultivators to create a “Direct to Consumer” retail experience with a conditional use permit. Currently retail in AG zones is unnecessarily prohibited.

2) On-Site Consumption- Already allowed under California law by Business and Professions Code §26200(g) at a licensed retail with a conditional use permit to create a “tasting room experience”. Currently on-site consumption is unnecessarily prohibited entirely in the County.
3) Lift Dispensary Caps- Outdated limitation of 9 dispensaries imposed by the County prior to legalization. We request that the County lift the cap on retail facilities and regulate retail as land use issue exclusively.

Second, as a current licensed operator and multi-generational farming family here in Sonoma County, I have a unique understanding of the impact onerous cannabis regulations have on practical farming practices. With this experience, and in consultation of many industry peers and work teams, I request the following changes be made to the proposed regulations as outlined on the recent public forums.

4) Remove Senseless Setbacks and align to State Law – Removing setback requirements when both parcels in question are commonly owned is another way to encourage thoughtful, environmentally responsible cultivation on larger agricultural properties. Many large farmlands are made up of multiple parcels and requiring setbacks to property lines in these cases achieves nothing other than inefficiencies. Cultivators should be encouraged to locate their cultivation sites in the areas of their property that are the least environmentally sensitive, present the best growing conditions, and are setback from real neighbors, and should not be limited by arbitrary setbacks when the adjoining parcels are commonly owned.

5) Remove Cultural Resource Survey – Delete this section completely. This regulation is onerous and will delay and possibly prevent cannabis cultivation. No other agriculture crop is required to do a Cultural Resource Survey. By including the words “involving ground disturbance” all forms of planting and soil preparation could be deemed ground disturbance. Under CEQA, any site development that requires a building permit will be tasked with doing a cultural survey. This process would be managed through Permit Sonoma who has staff versed on CEQA.

6) Energy Use – Delete this section completely. The requirement to have all 100% renewable energy source and the inability to use a generator will make it infeasible to have a cultivation site in the more remote areas of our County. Isn’t this counterintuitive to what the NIMBYs and county officials want? Until the County has developed their Climate Action Plan and provided the infrastructure needed to have an on-grid 100% renewable energy source, there should be no requirements put on any small business to meet these demands. The inability to use generators for day-to-day operations as needed again flies against the desire to have cannabis grows in the unpopulated areas of our county. Many agriculture crops depend on generators for frost protection, irrigation, and other farming practices. An option could be to require whisper generators, noise reducing housing structures and/or propane generators depending on the concern with this power source.

7) Water Use – Delete this section completely. There are already local and state regulatory agencies that manage water use in our County. The California Sustainable Groundwater Management Act (SGMA) protects ground water and the State Water Board, through their regional offices have control over surface water use including streams, rivers, reservoirs, and ponds. Permit Sonoma has determined water scarce areas within our County and has regulations in place for these areas. The requirements from these water-centric regulatory agencies supersede anything the Ag Commissioner believes he can regulate.

Cannabis is having a national moment, with 36 states having some form of state cannabis legalization and full federal legalization on the horizon. California is the largest cannabis market in the world, with the reputation of growing the best cannabis in the world because of incredible genetics, the terroir of the land, and culture of cutting edge, modern products.

Cannabis will never replace the diversity of agriculture across Sonoma County that makes this one of the most beautiful terroirs in the world. Cannabis can, however, provide diversified revenue streams for farmers who have been severely impacted by droughts, fires, floods, freezes, and the pandemic. We see cannabis thriving in our ecosystem by bringing diversity, opportunity, and legacy for generations to come. Thank you for supporting sensible regulations in the County and taking a formal position against these items.

Warmest Regards,

Erin Gore

On Fri, Mar 12, 2021, at 9:47 AM, Erin Gore wrote:

Hi Commissioner Davis!

My name is Erin Gore. I’m a local elected official here in Sonoma County (chair of Healdsburg district hospital) and also a cannabis operator (vertically licensed in Cloverdale) and female founder of Garden Society!
I’d love to have a call or coffee with you to discuss the pending cannabis ordinance discussion. I’ve done a lot of work with our industry on this policy and would love to make you aware of some of our concerns, the impact to the industry, and some viable solutions that are win/win for the community and the industry. I’d also be happy to answer any questions you have that would be helpful prior to the discussion at the planning commision.
Would you have time on Monday for a call? Please let me know what works well for you and I can adjust!
Thank you so much and enjoy the weekend ahead!

Erin

Erin Gore
Founder, CEO
email: erin@thegardensociety.com
website: www.thegardensociety.com

Garden Society is a California-based, cannabis-focused benefit corporation serving women in search of new, more holistic ways to renew and restore from the chaos of their daily lives. Garden Society creates artisanal edibles and sun-grown pre-rolls, made with uncompromising quality, that connect responsible farming, sustainable ingredients and strain-specific cannabis. Every product is lab tested all the way through the process—providing an expected experience, from the farm to your home.