Humboldt County Planning & Building Department
Attn: Steve Lazar, Senior Planner
3015 H Street
Eureka, CA 95501-4484

via email to slazar@co.humboldt.ca.us

Re: Comments – Draft Environmental Impact Report for Amendments to Humboldt County Code Regulating Commercial Cannabis Activities

Dear Mr. Lazar,

The following comments are offered on behalf of the board, staff, and supporters of Friends of the Eel River. FOER advocates for the protection and restoration of our Wild and Scenic Eel River, with a focus on the fisheries that are the keystone of ecosystem health in our
watershed. FOER has been working for years to identify effective solutions to the environmental impacts resulting from the ongoing explosion in commercial marijuana cultivation, until now nominally for medicinal purposes, in the Eel River watershed.

Nobody has ever been in the pivotal position Humboldt County finds itself in today. Collectively, we have realized enormous private, and not inconsiderable public, wealth and revenues from an industry that was incredibly lucrative precisely because it was illegal. Because it was illegal, it couldn’t be regulated, or taxed, or effectively monitored. Now, it must be.

Humboldt County’s commercial cannabis industry is already too large. It has far too many impacts, because the County has been unable or unwilling to regulate land use to prevent significant impacts to public trust values like our fisheries, wildlife, and the waters and habitat they require to survive. In fact, of all California’s 58 counties, Humboldt has the biggest problems, the largest impacts, suggesting the County’s policy choices have been key drivers of the evolution of its cannabis industry.

The proposed Ordinance and DEIR do not break from the County’s history of abdicating responsibility for the consequences of its land use decisions. It’s a tragic failure of leadership that is likely to cost Humboldt County dearly. Worst, it squanders this moment of possibility, when we could begin to build the better history of effective governance and responsible land use our descendants will wish for.

Read Friends of the Eel River’s full comments here.