Humboldt County Growers Alliance, in conjunction with California Growers Association and the Mendocino County Growers Alliance, submitted comments to the State Water Resources Control Board regarding the Statewide Draft Waiver of Waste Discharge and Principals and Guidelines. Collectively our organizations represent the interests of thousands of cannabis cultivators who are seeking to become legal and compliant businesses within the State of California.
Our primary concern is simple, we believe that if the Statewide Order is adopted as is, "Early Adopters" of the North Coast Regional Water Board Order would be disproportionately affected, over those who choose to wait or not enroll at all.
We offer three potential solutions to the State Water Board for consideration:
The State Water Board should allow for (provide an exemption or waiver) those cultivators, the Early Adopters, who have enrolled with the North Coast Regional Water Board Order prior to July 1, 2017.
If the Draft Order is adopted as is, cultivators who have enrolled under Order need to be given additional time to integrate landscape level compliance into their multi-year business plans.
Develop a clear process to allow for regional boards to make site specific and/or programmatic exceptions and variances where appropriate.
Given the scope of the challenge and the expeditious timeline, it is no surprise that the State Water Board developed a one-size-fits-all series of specific prescriptive standards for the entire state of California. However, without consideration for the time, money and emotions invested, this one-size-fits-all approach will have real and lasting negative impacts on the relationship between regulated and regulator. The end result will not be improved conditions to water resources. We implore the State Water Board: please do not punish early adopters.