CAA Letter to Board of Supervisors, County of Santa Cruz - January 2015

Cannabis Advocates Alliance
www.cannabisadvocatesalliance.org
January, 2015

County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Re: Participation in County Medical Cannabis Ordinance Changes

Dear Board of Supervisors:

I am writing as a member of the newly formed Cannabis Advocates Alliance (CAA).

We share the Board of Supervisors' concerns regarding environmental violations and nuisance complaints that affect quality of life in this County. However, we seek more effective, more sensible, and more just solutions than those we believe are currently being considered by the Board.

Among other things, we are requesting: 1) that local patients be given a greater voice in re-drafting the County cannabis ordinances; 2) that the County draft clearer and more environmentally-friendly paths to compliance for patient-cultivators, and 3) that in re-drafting the existing ordinances the County preserve the minimal diversity of choice required for patients to have proper access to quality cannabis medicine.

To further these goals, and prevent unfair penalization of patients, we are asking the County to postpone modifying the current cannabis ordinances by at least 90 days or more, to make the process more transparent and participatory, and for the County to more fairly represent patients and their needs.

A Significantly Improved Third Party Compliance Program is Key to the Solution

We encourage a far more developed, uniform and rigorous 3rd-party compliance program aimed not only at the quality of the cannabis itself, but also at making patient growers comply with environmental law. Among other things, the County should maintain an index of all legitimate patient growers and subject them to similar standards as those of licensing requirements that exist for every other agricultural product produced in this County. The intended effect would be to better empower the County to keep track of growers rather than force them underground, which is less environmentally conscious.

Cannabis Patients Require A Minimum Degree of Access to and Diversity of Medicine

Allowing only three grow sites per dispensary, abolishing collective gardening rights, and making other forms of distribution illegal, such as mobile delivery, destroys the current diversity that County patients currently enjoy. Restricting the spectrum of choices of medicine available decreases the likelihood that these patients will have the type and quality of medicine needed to address their particular ailments.

Limiting Grows to Ag and Commercial Ag Areas Penalizes Compliant Patient Providers

Requiring all non-personal grows to be in Commercial Agriculture and Agriculture zones will unfairly abolish the protections of limited immunity for most Santa Cruz cannabis patients, patient-providers, and collective patient growers. This will leave most of the patients and patient-providers to bear the brunt of the County’s enforcement divisions, while giving only a handful of growers the protections of State law. Rather than arbitrarily revoking limited immunity for local patient growers, the County must protect patients and patient-providers who cultivate in a safe and sustainable manner.

Medical Cannabis Patients Rely on a Variety of Medical Cannabis Distribution Models

The County must permit indoor cultivation in C-4 and Light Industrial zoning to all medical cannabis collectives, regardless of whether they maintain a brick and mortar location. Brick and mortar dispensaries are only one model of medical cannabis distribution, and this model should not be favored over others. This the only approach that ensures all patients have access to safe, quality and effective medicine.

While the foregoing is an overview of our proposals, there is far more detail that the County must consider. It is imperative that local cannabis patients participate in the development of these regulations.

We thus ask that the County: 1) continue the hearings for modifying the current Santa Cruz Medical Cannabis Ordinances for at least another 90 days; 2) agree to hold regular, announced meetings sufficient to include and consider more evidence, solutions, and dialogue; and 3) seriously revisit the County’s current approach and consider significantly more proactive and progressive solutions

I thank you for your time today,

Name: ___________________________________________

Signature: ________________________________________

Cannabis Advocates Alliance