Letter to Board of Supervisors on County's Misleading Cannabis Ordinance
December 7, 2025
From: Neighborhood Coalition <sonomaneighborhoodcoalition@gmail.com>
Sent: Sun 12/7/2025 8:48 AM
To: BOS <bos@sonoma-county.org>; cannabis@sonomacounty.gov; david.rabbitt@sonomacounty.gov; rebecca.hermosillo@sonomacounty.gov; chris.coursey@sonomacounty.gov; james.gore@sonomacounty.gov; lynda.hopkins@sonomacounty.gov
Subject: County's Misleading Cannabis Ordinance
December 7, 2025
Dear Supervisors:
The Neighborhood Coalition advocates for sustainable, environmentally sound, and neighborhood-compatible cannabis policies in Sonoma County.
This is a follow-up to our November 25, 2025 letter to you concerning the County’s misleading proposed cannabis ordinance. In most cases cannabis businesses wil be unable to obtain a license for those operations from the Department of Cannabis Control (DCC) without adjusting their business plan to comply with state law and undergoing an added expensive state review. Much of this would be unnecessary if the County attempted to comply with state law.
The attached five records from our Public Records Act requests, which Permit Sonoma carefully avoided placing in the record, emphasize this point:
1. Email from Wesley Stokes, California Department of Fish and Wildlife, to Crystal Acker and Marina Herrera (May 3, 2024). Mr. Stokes informs Permit Sonoma that “The county’s ministerial ordinance does not require every grow site to undergo environmental review. But the state’s discretionary process does, which means the two sets of regulations do not match.”
2. Email from Caitlin Hengeveld, DCC, to Crystal Acker, Marina Herrera, and McCall Miller (February 23, 2024) forwarding the project description memorandum and questionnaire that DCC provides to applicants when the DCC acts as lead agency for environmental review. This occurs because ministerial land use permits lack an adequate environmental review.
3. CEQA Practice Recommendations from DCC for Cannabis Licensing – Project Description Content (May 12, 2023) describing procedures to apply for a DCC license when a county issues a ministerial land use permit with inadequate environmental review.
4. DCC Project Description Questionnaire for license applicants for ministerial land use permits.
5. Email exchange between Jacqueline Campion, DCC, and Andrew Smith, Sonoma County (September 24, 2025) regarding the DCC’s puzzlement concerning redefining cannabis as “controlled agriculture.”
A recent phone conversation with Kevin Ponce, DCC Senior Environmental Scientist, and the Neighborhood Coalition reconfirmed that DCC would take over from Sonoma County as lead agency for CEQA site analysis for any ministerial land use cultivation permit approved by Sonoma County.
Why did Permit Sonoma make no effort to educate supervisors or the public that its proposed policies in the ordinance do not comport with State law? Does staff believe that ignorance is bliss for the supervisors?
When will the supervisors and the public see Power Points or a staff report explaining the problems with many of the policies the supervisors are on the verge of adopting in the revised Cannabis Ordinance?
Why is the County willing to adopt an ordinance containing policies that either violate or are difficult to achieve under state law?
The purpose of General Plan amendment is to authorize provisions in the ordinance that cannot be implemented under state law. It accomplishes nothing except sowing confusion as to what “controlled agriculture” means.
At a bare minimum, shouldn’t the County explain to the public what it is doing? This entire process breeds cynicism and a well-grounded belief that the County is incompetent, deliberately confusing the public, or worse.
Thank you.
Neighborhood Coalition
Nancy and Brantly Richardson, Communications Directors
SonomaNeighborhoodCoalition@gmail.com
Attachments