Neighborhood Coalition: Final Comments on FEIR and Proposed Ordinance

October 23, 2025

Comments on FEIR and Proposed Ordinance

The Neighborhood Coalition advocates for sustainable, environmentally sound, and neighborhood-compatible cannabis policies in Sonoma County. We endorse the comments filed by Shute Mihaly & Weinberger on behalf of Save Our Sonoma Neighborhoods. The Planning Commission largely ignored our September 15, 2025 comments which are attached to the email with these comments. Rather than repeat ourselves, we summarize and refer to them below.

I. The County’s Implementation of Socio-economic Equity is Hypocritical and Indefensible.

A primary objective of the revised cannabis ordinance (DEIR, ES-2) is to “Consider the protection of public health and safety and racial and socio-economic equity when implementing the above objectives.” The County has implemented its notion of “socio-economic equity” by sending checks of about $40,000 to four male Caucasian executives of SPARC, including CEO Erich Pearson who subsequently donated $5,500 to Supervisor Gore’s Senate campaign. As noted on page 13 of the Summary Report, “wealthy, white stakeholders increasingly own the County licensed landscape.” The County’s approach to land use ensures that this continues, especially for dispensary operators and cultivators who are not required to live onsite and experience the full effects of the health problems they create. Sonoma County utterly fails to protect those most affected by its cavalier approach to health and safety.

Many agricultural worker families live on Ag- and RRD-zoned lands and will be highly impacted by the inadequate (as little as 100 feet) setbacks from residences. Those families will inhale very high levels of unhealthy cannabis emissions in their homes and be exposed to carcinogens. Even if the parents or children escape developing cancers years later, they will likely suffer every summer and autumn from periodic or chronic bouts of nausea, headaches, vomiting, asthma, coughing, eye irritation, sore throat, respiratory irritation, and sleep disruption. Many if not most ag workers in Sonoma County are Hispanic or other minorities who occupy the lower rungs of the socio-economic scale. Unlike cannabis business owners, ag workers lack the funds to “pay to play” to protect their interests and have not participated in this process by filing written comments or speaking at public hearings. The County’s implementation of “equity” is shameful. It is the rural equivalent of locating industrial facilities near the homes of lower socio-economic people who must bear the burden of the associated health problems while the owners of those businesses fare very well and live far from the pollution they generate.

II. The Board Should Not Certify the Final Environmental Impact Report.

Instead of disclosing the environmental impacts of the cannabis ordinance, the FEIR obfuscates them. The County has not made a good faith effort to analyze odor and health impacts, nor consider public input, much less modify the DEIR in response. The County must provide a reasoned analysis supported by facts. CEQA Guidelines § 15088(c). Comments must be “addressed in detail giving reasons why specific comments and suggestions were not accepted.” Id. The County’s approach, to put it mildly, does not achieve the goals of CEQA. See September 15 Comments, pp. 1-5.

III. Minimum Setbacks from Residences Must Increase

The County must mitigate or avoid the significant impacts of the projects whenever it is feasible to do so. Pub. Resources Code § 21002.1(b). We support lengthening the setbacks to 1,000 feet for RR and AR parcels (Summary Report, p. 5), but it is insufficient in many instances. The setbacks should be a minimum of 1,000 feet from all parcel lines, regardless of zoning, with greater setbacks depending on the size of the cultivation and factors such as topography, meteorology, and thermal inversions. DEIR 3.3-23. We support retaining a minimum parcel size of 10 acres (Summary Report, p. 4).

Cannabis emissions have numerous health impacts on humans, and the FEIR fails to disclose many of them, as summarized below.

A. Many publications confirm immediate harm to workers in cannabis grow facilities

• 70% reported respiratory irritation, and 38% have asthma.

• 2 deaths from asthma have been reported.

B. Volatile Organic Compounds (VOCs; terpenes) from cannabis emissions are responsible

• Beta-myrcene is the dominant terpene and a Proposition 65 carcinogen.

C. The VOCs that neighbors are exposed to from outdoor cultivation are identical to those from indoor cultivation.

• Neighbors are exposed 24/7 (168 hours/week vs 40 hours/week for indoor workers), thus neighbors have 4 times greater exposure than indoor workers.

D. The cannabis terpenes travel thousands of feet as confirmed by quantitative scientific measurements by experts as well as neighbor reports.

• The FEIR provided no measurements of terpenes or odor, and instead presented theoretical models for myrcene which were very far from reality, as they said levels were so low at the edge of a 1-acre grow that they could not be smelled.

• The FEIR presented two odor graphs from the same “expert” which reached dramatically different conclusions for Yolo County and for Sonoma County, both using the same theoretical model, thus rendering the conclusions for Sonoma County untenable. Their 2019 Yolo EIR showed 100 times higher levels, with high odor levels 2500 ft from a 1-acre grow, very much in alignment with the NC Consultant’s measurement of high levels of 2600 ft from a 4 acre grow.

E. Science supporting respiratory harms

• Myrcene is a known respiratory and eye irritant; also reacts with air to make formaldehyde (a proposition 65 carcinogen), formic acid and ground-level ozone- all potent irritants. Other terpenes also are irritants. The FEIR ignored all of this.

F. Other health harms from Myrcene: cancer and reproductive/developmental harm

• Myrcene is a potent carcinogen, listed on Proposition 65 in 2015, no safe lower level found.

• Neighbors inhale toxic levels, validated by outside medical experts (UCSF, Stanford), Sonoma County Public Health

o FEIR dismissed this, and focused on 1000-fold lower levels in food flavorings

• FEIR dismissed odor as a “subjective nuisance” saying it was an unavoidable impact. FEIR erred in calculation of “safe” myrcene levels by 100-fold, ignoring that:

o Myrcene accumulates in people, predicted 20 times greater levels or more

o Inhalation provides 3-5 times higher levels than oral

o Children weight much less than adults, toxic level reached in 3 months

o Development and reproductive toxicity are predicted at levels inhaled by neighbors

• Inhalation provides direct route to brain- yet no toxicity studies done on inhalation

For further discussion and explanation, see September 15 Comments pp. 5-11.

IV. Crop Swaps Must Comply with Cal Department of Fish and Wildlife Criteria

The California Department of Fish and Wildlife (CDFW) is a Trustee Agency under CEQA, and its comments are not mere suggestions that the County can ignore. Page 4 of CDFW’s July letter requests that SCC Section 26-18-115 (C)(4)(h) be updated to include 7 prohibitions for ministerial crop swaps because they would endanger our water supply and biotic resources. Sonoma County has implemented none of the prohibitions. For example, section 26-18-115 C 4(h)(3) expressly allows the use of temporary hoophouses and imported potting soils, contrary to CDFW’s criterion 2. Regarding criterion 5, water use during August, September, and October when riparian (wetland or stream) habitats are especially stressed, CDFW demands water use be net zero on a “monthly on finer resolution timescale.” Finer resolution in this context means weekly or daily, but the county employs a 6-month basis (May 1-October 31). SCC Section 26-18-115 (C)(4)(h)(9)(b). That does not protect the environment and as a practical matter kills (“takes”) the endangered creatures that live in riparian areas. In addition, cumulative impacts are ignored. See September 15 Comments pp. 11-13.

V. Limit all Cannabis Events and Retail to Commercial or Industrial Areas

Allowing farmstands, cannabis tasting, and sales at events at rural cultivation sites invites crime and irresponsible driving on our narrow rural roads. An October study in Ohio concluded that 42% of drivers killed in vehicle accidents had elevated levels of THC in their bodies. These averaged six times the levels that most states consider to be impairment. For further discussion see September 15 Comments, p. 14. By limiting cannabis events and retail to commercial or industrial areas, there would be no reason to define cannabis as “controlled agriculture,” a phrase not recognized by any other agency or entity in California.

VI. Alternative 2 (Indoor Cultivation in Industrial Areas) is the Environmentally Superior Alternative.

As we explain in September 15 Comments, pp. 14-16, Alternative 2 is the environmentally superior alternative once the false premise is that it invariably increases energy impacts is corrected. The FEIR ignores the obvious availability and use of solar power to substantially diminish any energy impacts. Adopting an ordinance where all cultivation must take place indoors with appropriate filtration system in industrial areas, with existing outdoor permits expiring, would solve all problems that the Neighborhood Collation has identified.

Sincerely,

Neighborhood Coalition

Nancy and Brantly Richardson, Communications Directors

SonomaNeighborhoodCoalition@gmail.com

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