Please accept these as our preliminary comments on your 1/22/20 hearing regarding changes to the Cannabis Ordinance. We believe this item as inextricably linked to the “Ag Working Group” report, which has not been posted as of 2 p.m. today [January 17, 2020], so it is impossible for us to comment on that. A Coalition Board member will address your Commission at public comment at the hearing, once we’ve had a chance to review the Ag Working group report.

In summary, the
Coalition has submitted numerous comments over the past year to the
Planning Commission, and to the Board of Supervisors, pleading with you to
recommend and the board to adopt significant changes to the County Cannabis
Ordinance, as well as to the manner in which so-called “legal
non-conforming” cultivation sites have been allowed to obtain state
license, and expand.

We believe it is well
within your powers, if not your obligation, to urge the Board of Supervisors
(BOS) to cease authorizing State Provisional Licenses, or the extension
of those licenses, as state law relies on local jurisdictions to advise if a
grower is “in compliance with local law.” (See Business and
Professions Code 26055 (a), (f) and (g)
.) It is absurd for staff to claim
no ability to enforce county codes, while other county staff have authorized over
1,000 provisional licenses for industrial cannabis operations that have not
been permitted and that far exceed the 100 square feet exempted in
January 2016.

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