We know it can seem daunting to write a letter around issues like this. We’ll provide various samples for you to get you started or provide inspiration. Feel free to use anything below for/in your own letters. We also have a “links” page and an “arguments” page that might give you some ideas.
Letters should be sent to the clerk of the Board: email@example.com and cc’d to all the Board of Supervisors:
Sample Letter 1
Dear Board of Supervisors,
As your constituent, I am writing to express my opposition to Arcata Land Company’s proposed Commercial Cannabis Outdoor Light Deprivation and Mixed-Light Cultivation Project Application # 12255. This project, at 8 plus acres, does not belong on the edges of the City of Arcata close to homes, neighborhoods, parks, schools, etc. It’s also an absurd location to grow weed! The project claims that it mitigates for air quality and for greenhouse gas emissions but by the County’s own Environmental Impact Review (EIR), this is not possible:
Air Quality and Greenhouse Gas Emissions: Operation of new commercial cannabis operations under the proposed ordinance would result in the increase in particulate matter (PM10) emissions during the harvest season that would exceed North Coast Unified Air Quality Management District (NCUAQMD) thresholds and contribute to the
nonattainment status of the North Coast Air Basin for PM10. No feasible mitigation is available to reduce this impact. Therefore, the impact would be significant and unavoidable (Impact 3.3-2). The project’s contribution to cumulative air quality impacts involving particulate matter (PM10) emissions would be cumulatively considerable and significant and unavoidable.
Operation of new commercial cannabis operations under the proposed ordinance could generate objectionable odors to nearby residents. Mitigation has been recommended to reduce this impact. However, this mitigation measure would not completely offset the odor impact. Therefore, the impact would be significant and unavoidable (Impact 3.3-4).
The project’s contribution to cumulative impacts from exposure of people to objectionable odors would be cumulatively considerable and significant and unavoidable.
The neighborhood and other residents in Humboldt are very concerned about the impacts on air quality, the noise impacts from 8 acres of hoop houses with fans, the potential increase in crime related to this high-value crop, the potential impact on wells, and the impact on the viewshed. All these things will negatively affect the quality of life. Why is this being allowed so close to homes and neighborhoods? Please do not allow this project to move forward. This is not the future we want for Humboldt. Much smaller grows in more appropriate climates are what we as a community should look at.
Sincerely, Jane Doe, Eureka
Sample Letter 2
To: Board of Supervisors
From: John Doe, Cutten, CA
Regarding: Sun Valley’s project to locate an over-sized industrial cannabis growing operation in the Arcata Bottoms next to people’s homes: ARCATA LAND CO APPLICATION # 12255
As a home-owner and a 30-year county resident, I am strongly opposed to this project. Locating a large industrial cannabis operation with industrial-sized noise, odor, and other negative impacts next to people’s homes and neighborhoods is poor planning and unacceptable. Impacts to the residents would include: health impacts due to noxious odors and emissions, reduced property values, reduced ground water availability; unacceptable noise levels; increased traffic; and heavy negative impacts on the viewshed, the land, and the water.
If the Board of Supervisors allows this project to move forward, it will set a terrible precedent and be a threat to all Humboldt county residents in the unincorporated areas, knowing that our leaders find it acceptable to locate enormous cannabis grows – with all the accompanying negative impacts – next to people’s homes.
PLEASE DO NOT ALLOW THIS PROJECT TO MOVE FORWARD.
Sample Letter 3
We are writing to ask you to recommend a limited, phased in grow for the Arcata Land Company’s proposal to grow cannabis in the Arcata Bottom next to neighborhoods, homes, and schools. The Initial Study/Mitigated Negative Declaration is inadequate and rife with errors. A phased in approach, starting at 10,000 square feet would allow an opportunity to address the numerous shortcomings in the Initial Study. It should be limited to 1 acre at full build-out after all the issues have been addressed, including odor, noise, cumulative impacts, etc.
Sue and Sid Smith
Sample Letter 4
As your constituents, we are asking you to stop this huge cannabis grow next to neighborhoods. Sun Valley’s project is far too large and will be harmful and impactful to people’s quality of life, bringing with it a wide array of problems, including air, noise and light pollution, damage to aesthetics, harm to public health and safety, and potential impacts to wells and water quality. It also increases the carbon footprint of the cannabis industry by growing the plants in a locale ill-suited to growing cannabis, which will require an enormous amount of energy.
Protect the residents’ quality of life and keep this grow at 1 acre or less.
Cap and JJ Jones
The letter below is an actual letter that was sent in to the BOS on 7/9/21
Dear Supervisor Bushnell,
As Appellants, we want to thank you for the concern you expressed for the health and well-being of the Arcata Bottom residents during the last supervisors meeting and for requesting additional information regarding odor control before making a decision on the future of our neighborhood as it relates to the proposed cannabis cultivation for Arcata Land Company.
There are so many unknowns. The proposed odor management technology is new and even in earlier iterations it has not been used in climate conditions like the Arcata Bottom. Will it effectively deal with odor? Will it eliminate problems with noise? We do not know. As so well-acknowledged by you at the meeting on 6/22, consideration of the human and social costs needs to be considered as does the potential that things may not go as well as the Applicants want. Ensuring this is good for the neighborhoods in the Arcata Bottom and good for Humboldt County is vital. Phasing in, starting at one acre or less, would allow real-time data collection for this new, unproven technology and would allow for changes to be made if problems arise. The phased-in approach with a 2-acre cap (per the general Plan designation), while not our first choice, is one we could live with.
We, the Appellants, would also welcome the opportunity to work with the Applicants through the initial phase of the project. We want to make an effort to join together to take care of our community and neighborhood. We would welcome the opportunity to work with them for a year to find solutions to any problems.
We thought it might be helpful for you to read four quotes from an interview with Melinda Burns on 7/2/21. Burns is an award-winning environmental reporter who has covered Santa Barbara since 1985. “People on the ground are left to fend for themselves,” in the face of life-altering changes to their health, safety and economic well-being, inflicted by the politically-wired pot industry, Burns said in the interview with Newsmakers. In this interview, she talks about how the controversial and much-criticized Santa Barbara cannabis ordinance has disrupted life for thousands of locals and is a huge and ongoing news story that is hiding in plain sight.
Time markers from the interview in minutes and seconds are indicated by the ( ) at the start of each quote from the interview. The four quotes are:
Quote 1 (11:55)- “[it’s a] system that emits a kind of a thin mist…of vapor into the air that neutralizes the cannabis smell and instead you smell something like supposedly citrus or pine. Many people say it smells like a laundromat…some people say it irritates their lungs worse than the cannabis.”
Quote 2 (12:38)-“The newest technology that has come in starting late last year are the carbon filters or scrubbers that are placed inside the greenhouses…that technology is being tested, I think, right now in some of the greenhouses.”
Quote 3 (25:50)-“Will the carbon filters work? We don’t know.”
Quote 4 (26:50)-“It’s like we’re having to invent controls on the industry as we go and we already know that the people, yes, the quality of their lives is being affected.”
The link to the full 35-minute interview is here: https://www.newsmakerswithjr.com/post/press-clips-people-on-the-ground-left-to-fend-for-themselves-under-sb-s-pro-industry-pot-law?fbclid=IwAR0WyQ1yZya8kQw0LGzbmwsUgmJjBZYRP-QWuNUYshV6oMBceRrK9CjmonE
At the conclusion of the June 22 Humboldt County BOS meeting, it was apparent that the BOS is not going to deny the CUP but is considering a phased approach with an acreage cap on the cultivation. While 1-2 acres are not something the Appellants fully embrace, the phasing approach, with a cap of 2 acres maximum (per the General Plan designation for the two parcels) as proposed by Supervisors Wilson and Madrone would be acceptable to the Appellants providing it protects the health, safety, and well-being of our community. This process would allow for modification of the various systems should problems be encountered and it would also serve to help improve relationships between the applicants and appellants.
After our research of Ecosorb (see below) we feel that it would be important to start the phasing system with a non-chemical approach to odor management. From the literature we have reviewed, we think that the use of carbon scrubbers inside the greenhouses may be the best technology for odor management and should be tried prior to using Ecosorb or any other chemicals. Should this fail, then other options could be explored together.
What we found after investigating the odor control methods being used in Santa Barbara County revealed that while the Byers Vapor Phasing system may be useful in the elimination of odors from solid waste facilities, it remains unproven in safely eliminating odors from cannabis greenhouses emissions. The only case study using Ecosorb CNB 100 for cannabis (the proposed odor control product for the Arcata Land Company cannabis grow) we were able to find was from the Ecosorb web site which was for a 4,000 sq. ft. facility that also utilized internal recirculated air with carbon scrubbers and UV technology. (https://ecosorbindustrial.com/resources/case-studies/cannabis-enterprise/) Because the proposed ALC 8 acres grow is 80 times larger than this case study, the results may not be comparable due to the increased canopy size. This study does, however, lend some credence to the use of internal carbon scrubber technology.
Perhaps the biggest unknown in using the Byers system is its effectiveness in a windy environment such as the Arcata Bottom. This system depends on the liquid Ecosorb CNB 100 that is vaporized and dispersed around the greenhouses via external piping. According to The Ecosorb Engineering Manual, (https://mail.google.com/mail/u/0?ui=2&ik=8632b61907&attid=0.1&permmsgid=msg-a:r-6945066724686598691&th=17a723ba2413b93a&view=att&disp=inline&realattid=17a71eef355c018d23a1): the efficiency/effectiveness of Ecosorb in controlling odors can be changed by manipulating the following variables:
1. Increasing the concentration of Ecosorb® [CONC] (dosage rate)
2. Decreasing the size of the atomized droplet [SIZE]
3. Increasing the contact between malodor and droplet [TIME]
4. Increasing the velocity of droplets and therefore impact velocity [VEL]
5. Changing the polarity of the droplet [POL] (we usually have little control here)
The amount of time that Ecosorb will be in contact with the air exhausted from the greenhouses is a function of the wind speed. The average mean wind speed in the Arcata Bottom, which is somewhat comparable to the data collected at our airport, varies throughout the year ranging from 6.9 to 9.2 mph (and sustained winds are often in excess of 20 mph in the Bottom, with gusts often exceeding 25-30 mph) (https://weatherspark.com/y/145167/Average-Weather-at-Arcata-Eureka-Airport-California-United-States-Year-Round. At these wind speeds, Ecosorb will have little time to mix with the odors so the dosage rate of Ecosorb might have to be increased in order to achieve the desired effect.
OMI, the manufacturers of Ecosorb, had CPF Associates (an LLC that provides consulting and project management services in environmental science and public health) conduct an assessment of Ecosorb. On January 8, 2020 CPF Associates sent a memo to OMI discussing their assessment, “Screening Health Assessment of Odor Control at Cannabis Greenhouses.” The potential for health concerns related to Ecosorb was evaluated by comparing the calculated air concentrations to the health criteria. If the calculated air concentration for a compound or odor control product is lower than the corresponding inhalation health criterion, adverse public health effects would not be expected to occur under the assumed odor control application scenario. If an air concentration exceeds its criterion, this does not mean that adverse effects would occur among the general public because of the conservative assumptions included in both the derivation of the criterion and the calculation of air concentrations. Rather, it indicates that further investigation may be warranted, using more refined and realistic assumptions, to help determine whether or not levels in air may present a potential public health concern.
Additionally, the memorandum states that “ECOSORB CNB 107, which is the newest iteration of the product:
12.2 Persistence and degradability Bio degradability in water: ‘no data available.’
12.3. Bio accumulative potential: ‘Not established.’
12.4. Mobility in soil: The product is predicted to have high mobility in soil. Soluble in water.”
The above information, coupled with the fact that there has also been no analysis of the surfactant used with this product, suggests that questions regarding impact on the environment remain unresolved and this product should not be used in this application until further studies can be undertaken.
The most troubling aspect of the odor control systems for the Appellants is the unknown health risk of using a product such as Ecosorb. There were many letters submitted to the Santa Barbara Board of Supervisors regarding the effects of Ecosorb on neighbors living near grows (these letters are included as an attachment to this document). To date, there are no long-term studies on the health impacts on humans. There is some evidence, per the letter from Greg Gandrud (see attached letters), that Ecosorb also inhibits some forms of plant growth.
Given the suspected health implications and the unknown effectiveness of Ecosorb combined with the uncertainty of new technologies such as scrubbers on our environment, the phasing-in of the ALC cannabis cultivation is the most logical approach in providing protection for our residents and neighborhoods. Again, starting small with phasing allows opportunities for dealing with issues that arise in a timely manner thereby reducing tensions between the Applicant and Appellants.
One thing we’d like to ask to be considered: associated with the sealed greenhouses and odor control equipment are interior fans for the scrubbing process as well as exhaust fans. We are concerned about the amount of noise that will be generated and, given this concern, have initiated monitoring noise levels at the property line with an approved decimeter we purchased in order to establish base line data. If the grow is allowed, should decibel reading surpass 60 decibels, we will notify the County Planning Department/code enforcement division of the violation. The IS/MND did not have a maximum limit to the time that the applicant had to correct a violation. The county should add a maximum time to correct any violation after which penalties would be assessed.
In addition to the phasing in process and a cap of 2 acres, we respectfully request a detailed Odor Management Plan be submitted by the Applicant. We have attached an example of an Odor Control Plan from Santa Barbara titled “SANTA BARBARA COUNTY PLANNING COMMISSION Staff Report for the Appeal of Creek Property LLC. Mixed-Light Cannabis Cultivation Hearing Date: May 26, 2021 Staff Report Date: May 19, 2021 Odor Abatement Plan” which may be a useful template for the applicant to follow.
In the long run, doing a phased-in approach saves time and money for all parties (the County, the Applicant, and the Appellants). Capping the grow at two acres, per the General Plan designation, is an opportunity most growers in Humboldt would be thrilled to have.
We’d like to extend our thanks once again, to the Supervisors for their consideration and concern for the health and well-being of our neighborhood.
James Cotton and other Appellants