The Association for Standardized Cannabis

ASC Position on Proposed Cultivation Ordinance

Greetings ASC Members,

     There has been a lot of discussion as of late regarding the most recent, and very concerning, Cultivation Ordinance that members of the Santa Cruz County Board of Supervisors opted to consider in January of 2015.  The ASC has been working diligently to find solutions to this very challenging ordinance, and we hope to have a workable proposal for the Santa Cruz Board of Supervisors prepared soon.  As we work towards these solutions, however, we understand that there are also individuals in the County, particularly medical cannabis cultivators, who have been led to believe that the ASC is somehow responsible for Supervisor Neal Coonerty's motion to ban cultivation in the greater part of Santa Cruz County, but allow special conditions by which dispensaries may cultivate larger amounts.  This opinion is one that not accurate nor well informed, but rather targets an organization that is dedicated to stabilizing, enabling and enhancing the Medical Cannabis Industry in Santa Cruz.  

     The ASC has spent thousands of hours and countless resources fighting for the rights of Medical Cannabis Patients, cultivators, edible makers, and an entire industry in between.  One prime example of this was the December 10th, 2013 proposal by Supervisor Friend, which would have reduced the plant allowance in the county to 25 plants per parcel.  The ASC fought valiantly to prevent this from happening, and instead of it passing, an ordinance was passed that allowed for 1000 sf, 2000 sf, and 3000 sf in numerous parts of the County.  This would not have happened without the incessant work of the ASC.  Since that time, there have been numerous County Supervisor meetings where members of the ASC Board have stood and argued in favor of "Moms and Pops", defended the cannabis industry in Santa Cruz, and have been an instrumental voice in helping educate the Board of Supervisors on how to make informed decisions on County policy.  Again, the most recent proposal was not one of the ASC's, but rather one that was likely influenced by powers higher than that of our County officials.   

     In light of many concerns that may be circulating around the proposed ordinance that would alter zoning allowances in Santa Cruz County for the cultivation of cannabis, the ASC would like to dispel a few myths around it.  All members of the Board of Directors of the ASC were present during the public hearing, as were our attorneys, colleagues, friends and family.  In addition, several members of the ASC board, as well as local  attorney Ben Rice, recorded the proposals and have since digested much of the information.  Some of the concerns that the proposed ordinance presents are very real, however some of them are not.  The following are "interpretations" by the ASC Board and it’s attorneys, but are in no way intended to be perceived as actual policy that will be adopted; only time and continued hard work will clarify that.

1. "Criminalize ALL cannabis grows over 100 square feet."

The ASC does not believe that this statement accurately describes the proposal made by Supervisor Coonerty.  The proposal made by Supervisor Coonerty lays out specific parameters by which medical cannabis could be cultivated outdoors on a commercial scale in the County, including Agricultural and Commercial Agricultural zoned properties, and indoors on a commercial scale in Commercially and Industrially zoned parcels by medical cannabis "dispensaries".  Coonerty then goes on to indicate that all other cultivation sites within the County that are over 100 sf would be prohibited, with all other aspects of the current cultivation ordinance to remain in effect.  The ASC has taken a very strong stance AGAINST this measure, and has ALWAYS been advocating for "Mom and Pop" cultivators.  At this time, the ASC is reaching out to several  lobbyists to assist us in creating a proposal for the County, and potentially the State of California, that allows "Mom and Pop" cultivation to exist while simultaneously protecting the integrity of our neighborhoods and environment.  

2. "Ban patient providers from bringing cannabis products to any dispensary"

The Cultivation Ordinance that is currently in place (prior to Coonerty's proposal) includes verbiage that indicates that medicine being grown in Santa Cruz County should be providing to businesses within Santa Cruz County.  The ASC's interpretation of this is one that only reflects the current status of the cultivation ordinance, and is not a new policy being proposed by Coonerty. At this time, the ASC is working round the clock in order to find solutions to this challenge written into our current cultivation ordinance, and are requesting that the County Board of Supervisors remove it from their next version.  The ASC believes that "Mom and Pop" cultivators are a tremendous asset to not only the patients of Santa Cruz County, but the hundreds of thousands of patients across the State of California.  

3. "Dispensaries can grow large indoor and outdoor gardens with no plant limits"

Although Supervisor Coonerty's proposal would allow "dispensaries" to cultivate in larger indoor facilities, nothing indicated in it that cultivation by non-dispensaries was disallowed on outdoor parcels which were zoned Agricultural or Commercial Agricultural.  In addition, Supervisor Coonerty's proposal and his statement that "all other parts of the cultivation ordinance would remain unchanged" would indicate that Agricultural and Commercial Agricultural zoned parcels would still be allowed the privilege of cultivating 1,000 SF of canopy on parcels of 1 acre or more, 2,000 SF of canopy on parcels of 5 acres or more, and 3,000 sf on parcels of 10 acres or more.  In addition, through the diligent and incessant work of the ASC, Supervisor Coonerty made a motion to remove the "99 Plant Limit" from the ordinance, instead instructing the County to limit cultivation space by square footage. Although the ASC understands that many cultivators in Santa Cruz County are established in many areas of the County that do not fall under this zoning, the ASC also understands the need to strike balance between the needs of cultivators and patients, and the needs of neighborhoods and land owners who have become increasingly vocal in their frustrations. The ASC is taking a strong position with this proposed ordinance revision, and we are hoping to find common ground with the County Supervisors, cultivators, and property owners.  

     The ASC is very much in support of keeping "Mom and Pop" cultivation alive and thriving in Santa Cruz County.  We have been working since day one to support small-time farmers, edible producers, and the vast array of small cannabis businesses that our industry is comprised of.  We will continue to fight for these small operations, however we, being the cannabis industry as a whole, must be realistic in our expectations moving forward out of the darkness of prohibition and into the full light, and oversight, of legalization.

     The Medical cannabis industry in California may be at a precipice of recreational legalization, but our industry is fledgling compared to that of Colorado and Washington, and without proper organization early on, we can be easily overwhelmed by the financial and political potency of big Alcohol, Tobacco, Pharma and Gaming industries.  Protecting California's cannabis industry is a high priority for the ASC, and in order to do so, we must find common ground with our Legislators, community members, and our industry.  

     Thank you for your support, and we look forward to continuing work to help refine and grow our amazing, beautiful and vibrant plant and industry.  

The Board of Directors,

Association for Standardized Cannabis

The Association for Standardized Cannabis

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