Cannibals are upon us!

March 22, 2019 by Fred Allebach

The following is a reprisal of a public comment made to the Sonoma Valley Citizens Advisory Commission (SVCAC) concerning a proposed cannabis growing project in the 8th Street East industrial warehouse area on MacArthur. The hearing on this item will be on 3/27/19 at the city council chambers in Sonoma, 6:30 PM.

I read through the SVCAC packet items for this proposed cannabis growing operation. The water source is municipal water. As you may know, Sonoma gets all its municipal water from the Sonoma Aqueduct; the water all comes from the Russian River, and serves the city and VOMWD water districts.

I think it is fundamentally inappropriate to be using Sonoma Valley municipal water for commercial ag-type growing operations of any sort. Municipal water should favor human uses. The concept of “beneficial use” needs to have a hierarchy, not simply an allowing of all of it.

Of note for this proposed project, the MacArthur and 8th East industrial area is on city water, but is not connected to the Sanitation District. All waste water is and will have to be processed through a septic system. Trusting that high levels of cannabis fertilizers etc. will actually be removed, with enforcement likely only from self-reporting, is asking for more groundwater contamination in the already compromised groundwater area, that of the southeast valley groundwater pumping depression.

If reverse osmosis and filtering is the proposed wastewater cleaning mechanism, this is known to take high amounts of energy, so not only will commercial cannabis on municipal water use water better suited for other purposes, it will contribute more energy demand and to more global warming, with concomitant greenhouse gas emissions costs.

Yes, there is money to be made on cannabis, but at what cost to the environment and to natural resource use? We don’t have an endless frontier, and we can’t keep ramping up uses when we know very well there are costs, and consequences of unsustainability.

In spite of seeing a letter from the city Public Works Director asking for some accounting of the quantity of water expected to be used, I see the applicant has assiduously managed to mask and avoid disclosing water use, and not address the issue of how much municipal water will be used, on a daily, monthly and annual basis. Are plans for future growth? Will there be a meter for just this operation? Municipal water is a finite resource for the valley urban service area.

Before any determination can be made as to the appropriateness of this project, there needs to be data on water use volumes and projected use volumes. With no packet data, the SVCAC cannot make a determination. Anecdotal statements by the applicant at the hearing will not suffice as objective, packet criteria. The applicant has not prepared an adequate accounting of water use.

A long-term grower Tim Blake (Emerald Cup/ Area 101), estimated cannabis water use at 15 gal. per day for a mature plant. Per capita water use for conscientious water consumers in the Bay Area ranges from 60 to 39 gallons per day. A mature cannabis plant, at lower Bay Area per capita rates, matches per one person’s per capita water use every three days. One cannabis plant, generally then, uses one third as much water as a person on a daily basis.

Municipal water for cannabis irrigation ends up displacing human per capita use for daily indoor human needs. How much of this displacement to allow in the valley urban service areas?

In an area on imported aqueduct water, and subject to periodic drought, is this the kind of permitted use we want to be encouraging? What if there is a drought? Will municipal cannabis operations have to cut back? In a drought, people cut back landscape irrigation, and people have moved to xeriscapes long term, and to low water use plants. In a drought, will permitted cannabis operations just use their allotments no matter what? The SVCAC could call for a proportional reduction of municipal commercial cannabis in a drought, proportional to what everyone else is asked to cut back to percentage-wise.

I suggest that the SVCAC work on making an overall recommendation to Permit Sonoma, the city and VOMWD, about what an appropriate ceiling on commercial cannabis water use will be in the valley, for municipal, surface and groundwater sources. It seems to me to be folly to have a burgeoning, high water use commercial endeavor like cannabis now knocking at our water use door. To approach this on a simple case by case basis, has a high likelihood of missing the big picture, and allowing a Trojan Horse of high water use to come into an area that needs to be defined, water use-wise, as an area with high conservation awareness and practice.

Just because cannabis is legal does not mean it is not subject to regulation. All rights-based uses are subject to oversight and regulation, to protect the common good. This is what government is for. Burgeoning cannabis uses in Sonoma Valley call for an up-front definition of limits, a cap on the percent of cannabis water use overall, from all water sources. Municipalities in the urban service areas of the valley are now trying to come up with affordable housing for the people who work here, how much of the water needs here will be taken up by cannibals?

Cannabis needs limits on water use in Sonoma Valley. This is an industry better suited to a climate and geography with more disposable water. Until the time that appropriate cannabis water use limits can be defined, all potential projects should be put on hold, and not recommended to go forward by the SVCAC.