Sample letters

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: cob@co.humboldt.ca.us and cc’d to all the Board of Supervisors:

rbohn@co.humboldt.ca.us

mbushnell@co.humboldt.ca.us

mike.wilson@co.humboldt.ca.us

vbass@co.humboldt.ca.us

smadrone@co.humboldt.ca.us

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

Dear Supervisor: 

We are writing to ask you to recommend a full Environmental Impact Report (EIR)for 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. At a minimum, this needs a full EIR to address the numerous shortcomings in the Initial Study, such as inadequate energy calculations (only the mixed light was included, did not include ancillary support equipment such as dehumidifiers, fans, filtration equipment, etc.), an inadequate biological assessment ( for example, no bat study, which is required by CEQA, was done), cumulative impacts were missing from all sections of the study), inadequate water calculations (no data on number of plants and number of rotations are provided which are necessary for an accurate assessment of water usage), etc. Throughout the study, statements are made without any supporting evidence or data. An EIR would address the gross shortcomings in the Initial Study. Please require a full EIR for this project.

Sue and Sid Smith

Arcata, CA

Sample Letter 4

Dear Supervisors: 

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 do not allow this project to move forward. At a bare minimum, a full scale EIR should be conducted.

Sincerely,

Cap and JJ Jones

Sample Letter 5: This is an actual letter that was sent to the Planning Commission with a few edits to make it pertinent to the BOS. Jim said he’s fine with people using whatever parts of it they would like if it’s helpful to them.

Re: ARCATA LAND COMPANY, LLC COMMERCIAL CANNABIS OUTDOOR LIGHT-DEPRIVATION AND MIXED-LIGHT CULTIVATION PROJECT. APPLICATION NUMBER; 12255

The red box in this photo defines 8.69 acres, the proposed size of the Arcata Land Company cannabis cultivation. This is the area that would be covered by plastic hoop houses if this were to be allowed in downtown Arcata.

Dear Board of Supervisors,

Overview and Summary:

The proposed Arcata Land Company, aka The Sun Valley Group, project will be the largest permitted cannabis cultivation in Humboldt County.  The environmental and social impact of locating this project on the western edge of the city of Arcata and within their “Sphere of Influence” cannot be overstated. There are over 900 people, three schools, two playgrounds, two childcare centers, and one proposed senior housing unit/care facility located downwind and within ½ mile of this project.  Cannabis is a crop that is better suited to warmer/dryer climes where the growing environment does not have to be manipulated in such an extreme manner as is needed in the Arcata Bottom. Sun Valley would be advised to move their cannabis operation inland where they currently farm 120 acres (or to their property in Oxnard) and where the social and environmental cost would be considerably less. Additionally, the cumulative impacts associated with this and other projects must be considered-they were basically not addressed in the Initial Study/ Mitigated Negative Declaration (IS/MND)

My Ask: 

I respectfully request that you do not approve this project and instead require the applicant to submit an EIR prior to any CUP being issued.  

Facts supporting the need for an EIR:

The IS/MND was poorly conducted and many false or misleading statements were made that were not supported by evidence. There were also omissions (such as no bat study). The major concerns of our neighborhood, and many people throughout the community, center around the environmental impacts of air quality and odor, water impacts, energy demands, biological/wildlife impacts, light pollution, noise, and cumulative impacts.  Each of these is discussed below. 

1. AIR QUALITY AND ODOR:  

The (IS/MND) asked the following questions on page 31:   “Would the project:

-Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?

-Expose sensitive receptors to substantial pollutant concentrations 

-Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?” 

For all the above, the county checked the box “less than significant impact”.  This is a direct contradiction to the findings in the Final Environmental Impact Report (FEIR) which stated under 5.1: MAJOR CONCLUSIONS OF THE ENVIRONMENTAL ANALYSIS. The FEIR identified the following significant impacts related to the project: “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.”   Humboldt County Cannabis Program Final EIR 60mb (PDF)

Sensitive receptors include residences, schools, playgrounds, childcare centers, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. The IS/MND falsely states “With the exception of scattered rural residential, there are no sensitive land uses within the vicinity.”  According to Parks for California there is a total population 922 people living within ½ mile of the cultivation site. (https://www.parksforcalifornia.org/communities/  ) Additionally, there are three schools, two childcare centers, two parks and the proposed Creekside Annexation which will house seniors along with a long-term care facility all of which are downwind from the cultivation site.

The EIR goes on to say: “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.” Humboldt County Cannabis Program Final EIR 60mb (PDF)

The wind at the project site often exceeds 10 miles per hour (NWS data) and many days is well above 20 mph.  The Volatile Organic Compounds (VOCs) venting and escaping from the hoop houses will be transported downwind toward the Westwood and Bloomfield neighborhoods.  These VOCs are especially dangerous to people that have respiratory illnesses (including at least three people I know of personally with severe asthma living within 800 feet). https://www.tandfonline.com/doi/full/10.1080/10962247.2019.1654038  

Note: There is a device (the Nasal Ranger) that can quantify the concentration of odors but the county does not have one.  Odor complaints investigations should be objectively quantified with this or a similar device.

I recognize that the FEIR was published in January of 2018 and that there might have been technological advances in filtration systems since then.  This is all the more reason to require the applicant to do an EIR for this project to prove that a more advanced filtration system (if available) might work to reduce odors.  

 2. WATER: 

The amount of water to be used in the scaled down version of this application is estimated at 36-acre feet (11,736,000 gallons) per year.  These numbers are suspect because calculations of water usage are dependent on the number of plants grown and the number of crop rotations, none of these data were disclosed in the IS/MND.  The cultivation period was not disclosed in the latest staff report. Is the cultivation period still April thru October?

3. ENERGY DEMANDS:

Downsizing this project from 22.9 acres to 8.69 acres does not necessarily decrease the energy demands. The 5.7 acres of mixed-light cultivation and the 30,000 sq. ft. nursery are the same size in both plans and hence the energy usage will be approximately the same. In the IS/MND, the estimated energy usage for the mixed-light cultivation was projected at 6,750 MWh/year. These estimates apparently do not account for the energy usage of ancillary equipment such as fans, dehumidifiers odor suppression equipment, etc. What are the energy demands for these? There is also reference to gas boilers for heating: “In addition to PG&E power, the Project proposes three natural gas boilers rated at 1 million British thermal units per hour.” This quote from the IS/MND does not clarify if this rating is for all three or a single boiler.  These boilers will be used to heat 8.7 acres of hoop houses.  All of these energy demands will create a huge carbon footprint.  In the staff report of 18 March 2021 (page 69), under Addendum No. 1 to the Operations Manual, it states that during the vegetive growth state of the plant the energy requirements will be less than 1.9 MW.  1.9 MW is the equivalent of the energy demands of 1,513 average homes in the pacific northwest. https://www.nwcouncil.org/reports/columbia-river-history/megawatt.

The bottom line is that this is the wrong location to be cultivating the largest cannabis site in Humboldt County because of the cool, damp, and windy environment in the Bottom close to the ocean.  This is a heat loving plant that is better suited to a warmer dryer clime. The Sun Valley Group aka Arcata Land Co. owns and operates properties in Oxnard CA, Baja California, and 120 acres in Willow Creek, all of which are better suited for growing cannabis instead of on the coast where an artificial environment has to be created and sustained. This is at a huge environmental cost added to the social cost to the nearby neighborhoods.

4. BIOLOGICAL ASSESSMENT AND IMPACTS:

This section of the IS/MND illustrates one of the many inadequacies of the IS/MND and thus supports the need for an EIR. As a Wildlife Research Biologist with over 4 decades of experience in the field conducting bird and mammal survey data for the federal government, I believe the study is inadequate for the following reasons:

  1. The sample size, only two partial days in the field collecting data, was far too small to be statistically significant. No night time survey for bats or owls was conducted as required by CEQA. (*Mitigation Measure 3.4-1ki: Preconstruction bat survey and exclusion. The following shall be included as performance standards in the proposed ordinance for the protection of the pallid bat and Townsend’s big-eared bat from new development related to cannabis activities. ψ Before commencing any new development related to cannabis activities, a qualified biologist shall conduct surveys for roosting bats. If evidence of bat use is observed, the species and number of bats using the roost shall be determined. Bat detectors may be used to supplement survey efforts. If no evidence of bat roosts is found, then no further study will be required.)
  2. No methodology was presented in the study.
  3. The dominant bird species, Canadian and Aleutian Geese, that utilize this project site during their migration period (January – April) were not accounted for in the study because the limited survey days occurred outside their migration period.  On a personal note, I have observed, from my living room widow, flocks of 500 -1000 geese foraging daily on the study site over the past three months.
  4. Despite a literature review to identify potential bird species within the study, there are at least the following 16 species missing from the IS/MND, among many others: Peregrine falcon, Marsh hawk, Red-shouldered hawk, White tailed kite, Allen’s Hummingbird, Rufous Hummingbird, Raven, Crow, Barn owl, Killdeer, Western meadowlark, Egrets, Great Blue Heron, White Crowned Sparrow, Canadian Geese, Aleutian Geese, and Song Sparrow. 
  5. The study states that no migratory corridors were detected.  In fact, the entire county coastline is a migration corridor. 
  6. If Red-legged frogs are found in the storm water drainage basins, what will the mitigation measures be? There are none in the IS/MND.
  7. To understand the impact on birds and mammals, an EIR should be required.

5. LIGHT POLLUTION:

The staff report for 22 April 2021, page 13 states “The project is consistent with the Conservation and Open Space Scenic Resources policies as the only applicable policy is related to restricting light and glare. The project involves mixed-light cultivation. The CMMLUO requires that mixed light cultivation comply with International Dark Sky Association standards for Lighting Zone 0 and Lighting Zone 1 and be designed to regulate light spillage onto neighboring properties resulting from backlight, uplight, or glare (BUG). The project is required to follow International Dark Sky Association Standards that exceed the requirements of Scenic Resources Standard SR-S4, Light and Glare, that lighting be fully shielded, and designed and installed to minimize off-site lighting and direct light within the property boundaries. Comments have been raised by the public regarding lighting impacts, however compliance with the ordinance will ensure that there are no adverse impacts to adjacent populations from nighttime lighting.”

On the other hand, the Staff Report 18 March 2021, page 10 states “Lighting will be designed to regulate light spillage onto neighboring properties resulting from backlight, uplight, or glare, and light will not escape at a level that is visible from neighboring properties between sunset and sunrise. The project would comply with all CMMLUO performance standards for lighting, and new structures, including lighting plans, would be subject to approval by the Humboldt County Building Department.”

Please note the difference in the wording of the two staff reports.  Which standard will be followed?  Again, this requires an EIR.

6. NOISE:

Per the FEIR, pages 2-11: The County has also updated the proposed ordinance’s performance standards for noise at cultivation sites that now prohibit noise from cultivation and related activities from increasing the ambient noise level at any property line by more than 3 dB. As identified on DEIR page 3.10-2, the human ear can begin to detect sound level increases at 3dB above existing noise levels.

The Staff report for 22 April 2021, page 14 statesComments have been raised regarding the potential of the project to create substantial noise which will adversely affect adjacent property owners and residents. The project will be consistent with the CNEL standards of the Humboldt County General Plan which will require the project to be demonstrated to not contribute more than 60 decibels as measured at the property lines. This will ensure that noise levels at any sensitive receptor are below the noise threshold established in the General Plan as suitable for sensitive receptors. If the findings of the investigation show that noise levels do not meet the CNEL standard, an appropriate noise study shall be conducted at the applicant/operators’ expense. If the findings of the noise study show that noise levels do not meet the CNEL standard, the applicant/operator shall have a minimum of 10 days to PLN-12255-CUP Arcata Land Company, LLC April 22, 2021 Page 14 develop a plan to bring noise levels into compliance.”

There seems to be a discrepancy between the staff report and the FEIR. The staff report describes < 60 decibels as being acceptable while the FEIR prohibits noise from cultivation and related activities from increasing the ambient noise level at any property line by more than 3 decibels.  Which standard will be applied to this project?

7. CUMULATIVE IMPACTS

 While this current permit may seem inconsequential to some, the impact on the bucolic nature of the Arcata bottom lands is significant when combined with current and future cannabis applications that have been applied for. According to the IS/MND there are four applications within a one-mile radius of this project. Two of these are adjoining parcels with one permit already approved for manufacturing, processing and distribution.  If approved, this permit may have the domino effect that will eventually cover the Arcata bottom in a sea of plastic hoop houses the likes of which is already occurring in Santa Barbara as evidenced by this photo.

Thank you for your consideration.

Respectfully,

Jim Cotton

Arcata, CA