CAA Letter to Board of Supervisors in Support of C4

The Santa Cruz County Board of Supervisors held a meeting on Tuesday, December 8 regarding cannabis cultivation

The following is what Cannabis Advocates Alliance has submitted to the county in regards to the Board of Supervisors proposal.

1362 PACIFIC AVENUE, SUITE 219 SANTA CRUZ, CA 95060 (424) 262-1516
December 8, 2015


On Behalf of CAA

Re: County Counsel/C4 Presentation to BOS

Dear Board of Supervisors (BOS):

Cannabis Advocates Alliance (CAA) applauds your creation of the Cannabis Cultivation Choices Committee (C4). The BOS formed C4 for Santa Cruz community and local cannabis stakeholders to discuss, debate, and draft sensible local cannabis ordinance recommendations to the BOS.

The C4 is an historic opportunity to build trust and consensus across a broad and controversial spectrum of interests, and is particularly critical given sweeping new State cannabis laws that California recently passed with the Medical Marijuana Regulation and Safety Act 2015 (MMRSA).

After recent months of lengthy discovery and consensus-building, the C4 has marshalled a small, self-contained package of interim recommendations for the BOS, designed to function solely as a placeholder to allow Santa Cruz County to retain jurisdiction over cannabis cultivation licensing in advance of the MMRSA jurisdictional cutoff of March 2015 (soon to be extended, but has not yet).

It appears however that County Counsel is recommending that BOS go further than C4’s recommendations of a “symbolic” single-tier license ordinance. County Counsel appears to recommend a more functional and sweeping cannabis cultivation ordinance: 7.128. While C4 seems to have recently endorsed County Counsel’s approach in concept, it has not yet had the opportunity to form complete opinions on the proposed 7.128 ordinance, introduced only recently.

Thus, CAA concludes:

(1) BOS should give C4 more time to fully consider proposed 7.128;

(2) BOS should give C4 the opportunity to propose an ordinance that reflects sufficient interaction with County Counsel following their first draft of 7.128; and (3) at minimum, in the meantime, BOS should adopt in its entirety C4’s recommendations, arrived at unanimously, despite potentially clashing interests and concerns.

Irrespective of differences and potentially polarizing issues, the C4 members have continued to work together in good faith and to display tangible mutual trust. Similarly, we expect that when considering C4’s recommendations, County staff and supervisors will honor the same spirit that has kept the C4 together, and has allowed it to establish a foundation of community consensus.

The C4’s “package deal,” anticipated to be recommended to BOS on 12/8/15, represents the result of teamwork, trust-building, and compromise among a vast diversity of stakeholders representing the fullest spectrum of often divergent views in lengthy, rigorous, consensusoriented public debate.

CAA cannot emphasize greater how important and critical it is that BOS preserves and fosters the C4, as it is a community-representative coalition that the BOS itself created to build community consensus, among other things.

CAA recommends and urges to BOS the following interim placeholder ordinance, set to expire in approximately six months:

BOS should drop the 99-plant limit from 7.126.

BOS should drop the County Dispensary connection requirement in 7.126.

BOS should issue a placeholder, functionally symbolic,“micro-cultivation” ordinance for 100 s.f. (e.g., 10×10) commercial cannabis cultivation licenses.

No actual license shall issue until after BOS replaces the interim ordinance with a new functional ordinance that reflects broader, more developed consensus regarding a mature licensing system, zoning, environmental, and community concerns, among other issues.

The interim ordinance should expire in June 2016, in order to give both C4 and County Counsel time to develop a more fully operational ordinance that represents further analysis of recent State law changes, input from County Counsel, and further community building.

BOS should extend C4 by at least 6 months in order to more fully develop a multi-tiered commercial cultivation ordinance and a full spectrum of cannabis industry licenses.

These are the minimum elements that CAA believes BOS should adopt, as C4 consensus points, in their entirety, without any changes. The C4 arguably represents the largest consensus of the Santa Cruz community on cannabis cultivation issues to date. To not adopt each and every recommendation in full may threaten the validity of the C4 itself. We thus urge that you at least adopt these minimal basic points recommended by C4, and extend the life of the C4 by 6 months.

We will address our deeper concerns with the proposed County Counsel ordinance separately, as we cannot emphasize with more sincerity the need to implement the consensus of this community, as expressed by the work of the C4. Thank you for your public service and your support of C4.


Sasha Brodsky Attorney for CAA