SMALL FARMER INCENTIVE PACKAGE
Prepared for Mendocino County Board of Supervisors
With the legislative passage of the MMRSA package for the regulation and safety of
medical cannabis in California, the Small Farmers Association (SFA) now turns their
attention to local government to assist in protecting small farmers of the Northcoast.
With a deadline written into the law of March 1, 2015, which may or may not be a hard
number, efficiency meets efficacy is where we must begin in unity to protect the lifestyle
and economy of the Northcoast.
The educational data and knowledge the SFA provides covering a five year period is the
richest knowledge available to the Northcoast. It is this knowledge that provides the
basis for our Small Farmer Incentive Package. The Small Farmers Association
unequivocally stands in their knowledge that protection and “carve-out” for the
Northcoast Small Farmer is imperative for protecting the rural economic base of our
unique region.
It is important to recognize that Medical Cannabis is now an Agricultural Commodity.
It is not agricultural production. The difference mainly lies at the reporting of pesticide
use level.
INTER/INTRA COUNTY DESIGN AND STRUCTURE
There are 7 different types of licensure with varying categories established by MMRSA:
Nursery
Cultivation
Testing
Distribution
Dispensing
Transportation
A local government must adopt regulations that address all of these licensure schemes
to avoid State MMRSA Administration and Enforcement in their local city/county.
While the MMRSA package accomplishes many goals for the state and local safety of the
general public along with taxation, what is does not directly address is the unique and
silent economic base that the Northcoast counties have gleaned the benefit of for more
than two decades. This silent economic benefit has not been quantified other than
through the data the Small Farmers Association has collected over the last five years.
Shifting an economic base from “Black-market” to local and state taxation and fees
leaves a vacant economy with no venue for financial recovery for the small businesses
that provide this economy and the small businesses and communities that benefit from
this economy. What is at stake is the financial viability of the rural counties in the
Northcoast and the patients, low income and fixed income, that depend on small farmers
for quality medicine, provided with unequalled care.
The SFA has provided already, and will continue to provide on an annual basis, the
average income and expense of the small farmers that is the foundation for our Small
Farmer Incentive Package (See attached 2015 White Paper). The small businesses of
the medical cannabis industry cannot afford value added components through hiring of
Distributors and Transporters, to their existing economic base, they simply can’t afford
it. What is left is a wide open door for the enormous corporate economic base to fill that
void. The result, the removal of majority of small farmers in our communities replaced
by corporate farming and facilities.
To mitigate this result, our Small Farmer Incentive Package is designed as an inter/intra
licensing structure. Local county intra licensure is designed with the successful and
grand breaking 9.31 Exemption Program in mind. The Small Farmer Incentive Package
adds a new class of licensure and participants. We are titling this new license as the
Small Farmer Incentive License.
The Small Farmer Incentive license, a separate and additional license issued only by
local City and County governing department(s), would be applied for and issued based
on certain critical criteria that must be met and verified through inspection: a local plan.
State issued inter county licensure is set up through MMRSA and the Medical Marijuana
Bureau, a plan governed by the State.
INTER/INTRA COUNTY TECHNICAL APPROACH
There are four phases the SFA defines to create our technical approach to the Small
Farmer Incentive Package.
1. Pre-Regulations
2. Regulations in Place
3. Initiative
4. Initiative Regulations
 Pre-Regulations: There is a 19 year time span from when the voters elected to
approve Proposition 215. There has been an unregulated industry that has
thrived without taxation, fees, and costly regulatory requirements. It is an
established industry that must be recognized and understood to allow incentives
for participation. MMRSA needs a buy in for this industry. Without a buy in,
this industry will continue its robust underground market as evidenced in
Colorado and Washington.
 Regulation in Place: This is the current phase. Local jurisdictions must address
regulation and taxation prior to March 1, 2016. MMRSA will not be issuing
licenses until January 1, 2018. This is where most of the work at both the local
and state levels must be undertaken and revised as appropriate. It is important
to understand whatever work is accomplished and implemented, could all be
eliminated by a successful voter initiative. How efficiency and efficacy unite is
through the local incentive package, while creating a holding pattern for MMRSA
implementation.
 Initiative: If an initiative is successful, that will be the indicators and direction
the MMRSA package will go. All regulatory implementation, or some, will need
to be altered to align with the new voter passed law. This Phase involves
identifying those components and determining, at a local level, where the new
road map will take the community.
 Initiative Regulations: The State will be the first to regulate a successful voter
initiative, which will take time. Local jurisdictions will need to follow close and
make sure their road map aligns with the State. MMRSA components that align
with the new voter approved law will need to be rapidly identified. The Medical
Marijuana Bureau will be the lead on this. Local jurisdictions will then need to
adopt rapidly.
Local Intra County:
The Small Farmer Incentive License, a new class of participants, will take into account
the needs of the Agricultural Commissioner and Department, Public Safety Department,
and the North Coast Regional Water Quality Board (NCRWQB). This license will
incorporate the existing laws regarding medical cannabis cultivation.
Specifically the Small Farmer Incentive License for Mendocino County is based on the
9.31 Exemption program, and would require the following:
1. A valid permit from the NCRWQB, if cultivation is over 2,000 square feet
2. Verification of residence for last two years (MMRSA)
3. Certified Inspection to verify compliance and Best Management Practices
4. A single plant identifier (with global code) that would include electronic GPS
tracking (MMRSA)
5. Sealed Packaging with plant identifier (MMRSA and County Sheriff requirement)
6. Fee
The Small Farmer Incentive License would allow a Mendocino County Small Farmer to
transport and distribute their agricultural commodity to market and to patients within
Mendocino County only, without the costs involved in hiring a transporter or distributor.
The result is more small farmers having the ability to continue their family income
stream without interruption or elimination. They will not be cost out of the industry.
This license creates new tourism tax dollars, as people will have to come to the County
to get Mendocino County Medicine, that otherwise has not been a requirement. It will
also provide the framework for branding and Appalachia, as required by MMRSA.
State Inter County:
A state license can be acquired after the local license starting January 1, 2018. The
state license will allow medicine to move out of the county via a Transporter and
Distributor. Anyone in or out of the county may acquire a state license. These licenses
will most likely require monetary endeavors that are unreachable by the small farmer.
SMALL FARMER INCENTIVE PACKAGE PARTICULARS
There are particular components that must be addressed based on MMRSA, that directly
apply to the Small Farmer Incentive License.
 Farms that were permitted during the 9.31 program or were in existence before
9.31 and have become an inspected member of SFA fall into 5 types of zoning:
1. Timber Land
2. Grazing/Grass Lands
3. Upland Residential
4. Remote Residential
5. Rural Residential
6. Agriculture
These zones must be approved zoning for the Small Farmer Incentive License to
allow them to continue production and the longstanding silent economic benefit
to the Northcoast, and specifically, Mendocino County. The County is not in the
business of uprooting families.
Zoning for Nursery and Manufacturing must mirror the cultivation zoning. The
transportation to and from the cultivation site within the county should not have
negative impact to the product or our pristine forested environment.
Zoning for Transportation and Distribution must be evaluated based on natural
environmental impact. Do rural county roads have the ability to withstand
traditional teamsters equipment? Can the product maintain it’s small farmer
high quality if traveling from Cultivation and Manufacturing sites to urban areas?
Because traditionally, the farmer has provided transportation and distribution of
product, how will this translate to off farm transportation and distribution? The
Small Farmers Association believes regional facilities may help to determine the
proper answers to these, and many more unrealized questions.
 Small Farmer Incentive License is restricted to only the following qualifications:
1. Must be grown outdoors (some refer to as sun grown) utilizing Best
Management Practices confirmed through inspection
2. The permit applicant must reside fulltime on the parcel as their main
residence
3. This permit requires compliance with all relevant provisions of the adopted
ordinance
4. Applicants must have legal interest in this one local permit only, and no other
local cannabis related permits may be acquired
SMALL FARMER INCENTIVE PACKAGE BENEFITS
1. The City/County will absolutely regulate its own cannabis via intra county
concerns.
2. Under this model the local small farmers can grow, process, transport and
distribute in the County of Mendocino avoiding additional fees/profits that
mandatorily exist under inter county licensing processes. The Small Farmer
incentive License is to the benefit of local commerce, patients, businesses,
farmers, and law enforcement.
3. This is most beneficial to the patients of Mendocino County because it avoids
mandatory value added costs under the inter county licensing scheme.
4. This package does not prevent larger farmers or small farms from entering the
inter county market.
POB 724 • Ukiah, California 95482
707-489-0996 • www.Smallfarmers.us
CALIFORNIA AND MENDOCINO COUNTY
MEDICAL MARIJUANA FARMER
STATISTICAL DATA: FARMER AND PLANT ECONOMICS
POVERTY IN CALIFORNIA AND MENDOCINO COUNTY
Six million Californians live in households with incomes below the federal poverty level
(FPL) which is defined as follows:
– Family of Four: $23,550
– Family of Two (i.e. single mothers): $15,510
– Single, Childless Adult: $11,490
Note: The most current data available from the Public Policy Institute of California
(PPIC).
The Census “Supplemental Poverty Measure,” which incorporates California’s high cost
of living and the effect of safety net programs such as food stamps, suggests that
California’s poverty rate is even higher—7.5% higher than the federal definition
according to facts released by the PPIC in August of 2013. By this definition, California
poverty level (CPL) is defined as follows:
– Family of Four: $25,316
– Family of Two (i.e. single mothers): $16,673
– Single, Childless Adult: $12,352
Poverty rates vary greatly across California’s 58 counties. According to the American
Community Survey of 2011, Mendocino County has 21.5% of its population living at or
below the $23,500 federal poverty level of a family of four. This does not take into
account those not surveyed. Those not surveyed most likely include families who
depend 100% on marijuana for their income.
SMALL FARMER ASSOCIATION PLANT COUNT INCOME
REPORT
These are sobering numbers not only for government officials, but also for Small
Farmers who are including medical marijuana in their farm plan. These numbers are
based off of the farm expectations done in 2014 in Mendocino County. This data is
collected during the harvest inspection from the attached blank expense page all SFA
farmers complete as part of their membership inspection. This does include disease and
weather spoilage. Data averages are as follows:
Average poundage per mature plant: 2
Average cost per pound: $1200
Average expenses per plant: 75% of cost per pound (costs are going up)
Average pay to farmer per plant: 25% of cost per pound (pay is coming down)
PLANT NUMBER
25 mature plants
35 mature plants
45 mature plants
55 mature plants
65 mature plants
75 mature plants
85 mature plants
INCOME TO FAMILY
$15,000
$21,000
$27,000
$33,000
$39,000
$45,000
$51,000
CPL
Below Family of 2
Below Family of 4
Just above Family of 4
Above Family of 4
Above Family of 4
Above Family of 4
Above Family of 4
CONCLUSION
A Small Farmers Association Farmer is required to grow vegetables, orchard or animals
alongside the medical marijuana, as multiple crop farming is more sustainable for a
farm ecosystem then “mono cropping”, although that term is usually in use for large
farm production such as the Central Valley.
The SFA farmer on average is a patch income medical marijuana farmer,
supplementing the family’s non-farming income. On average, our farmer’s
mortgages/rents are not at current rates because they’ve lived in their home for some
time, and lived in the County for an average of 30 years.
This is the first time such information has been gathered, calculated and presented. We
continue to do research and offer what statistics we have to date. If there are statistics
the County and State would like to include in our research, we are happy to
accommodate and provide what information we are able track.
Prepared by the Small Farmers Association
December, 2014