The Humboldt County cannabis community is facing yet another curveball: the Humboldt Cannabis Reform Initiative.

Originating in my hometown at birth, Kneeland, the initiative seeks a ballot measure that radically alters cannabis farming in our region. I believe the initiative to be somewhat heartfelt and sincere as it stems from real grievances shared by many, yet find some of its conclusions and demands ludicrous, especially given the current struggles within the local cannabis scene and the near-term economic collapse our county faces.

The purpose of the initiative “is to protect the county’s residents and natural environment from harm caused by large-scale cannabis cultivation.” It alleges that the cannabis farming landscape in Humboldt has changed, a marked move away from eco-conscious farmers to “larger, more industrialized grows with heated and ventilated grow houses, 24/7 lights, loud generators, and extensive water use.”

To be clear, our largest farms at just 8 acres are minuscule in relation to the 100-acre farms being launched across the state. California is unleashing another million square foot indoor facility this year, as well as many more large-scale outdoor and mixed-light scenes. Arguing that we have a single, industrial mega grow in Humboldt is disingenuous and out of step with reality.

The initiative further argues that Humboldt’s environmental review process with respect to cannabis cultivation fails to consider “cumulative” impacts and limits public input on proposed projects, especially smaller ones that get the nod from the planning department. It believes that cannabis cultivation has a negative collateral economic impact and inhibits tourism given a “fouling” of natural landscapes and a draining of local rivers.

With limited law enforcement, the initiative also argues that legal operators run afoul of regulations and harm the surroundings with their business practices.

Given this backdrop, the Humboldt Cannabis reform initiative offers several “solutions” to these perceived problems. I agree with some of them, but view the initiative on whole as a desperate ass grab that seeks to end cannabis cultivation in Humboldt once and for all. It’s easy for those with no dependence on cannabis farm revenues to desire such, but for the 75% of us that rely on cannabis directly or indirectly to sustain our lifestyles, this initiative is a slap in the face and will be defeated sorely if it ever makes the ballot in 2022.

As a lifelong Humboldt resident, an avid fisherman, a lover of the outdoors, and a fierce advocate for preserving the natural beauty of our area, I empathize to some extent with those behind this initiative. I have seen personally that there are some really shitty people with cannabis permits locally … folks that are money sick or from other states looking to cash in. In reality, though, most of the bad actors have already left Humboldt and the others operate in the black market, which the initiative clearly states it will not and cannot target.

While it’s true that approximately 35% of people nationally are opposed to cannabis and are bitter that national legalization looms, the ship has already sailed … cannabis will soon be legal nationally, and attempting to hamper the main industry keeping our county afloat is selfish and short-sighted.

Instead, I believe we should allow the local industry to grow, exponentially. Humboldt needs to ditch the 8-acre cap immediately and allow for large-scale mixed-light projects that attract buyers and put people to work with living wages. While I myself began my commercial farming career playing small ball on 10,000-16,000 sq feet sun-grown operations, it has become painfully obvious that smaller farms are struggling and at risk of failure. The market has erroneously moved away from sun-grown and this trend is real, and most likely lasting.

And trust me this saddens me deeply. We have an amazing regenerative farming community focusing on closed-loop, sustainable systems that benefit the earth and produce super tasty dank. I admire this focus immensely and have my own Hügelkultur beds in my vegetable garden at home. That said, I want to stay in business and have morphed into a mixed-light cultivator as this technique produces highly marketable flower with less impact on the environment than indoor.

The Humboldt Cannabis Reform initiative doesn’t get it. While greenhouse production is more energy-intensive, we already have laws on the books that govern these activities. Failure to acknowledge such is intellectually disingenuous and further proves that proponents of this initiative want to collapse, not support our local industry.

Let’s take a deeper dive into the specifics of this proposed legislation.

Water Storage and Forbearance

The initiative’s first point is about water storage and forbearance, which refers to when farms can utilize surface water sources such as springs for cultivation and tank filling. I am in agreement with this point. California has been suffering from drought for many years and we can all acknowledge that. Currently, farmers can draw from surface water sources from November 15 to the first of April. The initiative proposes we shorten this window to March 1. I agree with this proposed regulation, yet understand it will hurt some property owners.

Spring has been exceptionally dry for years now and this is a critical period for salmon and steelhead. Rivers like the Eel have a late run of blueback steelhead deep into April and they need flows. Additionally, salmon down migrate to estuaries in the spring and need ample flows to avoid predation and successfully reach the seas. 5,000-gallon water tanks are relatively cheap and anyone cultivating for years who can’t afford them should get out of the business. We don’t get to say we love the environment if we can’t comply with this simple rule – that’s precisely the insincerity that makes folks hate our industry.

While the initiative also seeks to limit the use of wells, a water witch and a $10,000 investment can often provide one’s property with all the water it needs without ever diverting one drop of surface flow. Again, those who have failed to make such critical investments at this point should not draw much sympathy.

Generator Limitations

The initiative also proposes that generators used for cultivation be phased out between 2024 and 2025, depending on when one’s license was obtained.

I have mixed feelings about this point. Many of our farms are off-grid and miles from major roadways. PGE power drops can be prohibitively expensive – we were quoted a quarter million a few years ago and were not far off AP Road. A power drop is out of reach for most farms, but I agree that generators can be problematic. Older models leak oil regularly, don’t receive Diesel Exhaust Fluid, and blow a contaminated plume into the atmosphere. Plus, they make noise. Even smaller models like 25K MQ’s disrupt the beautiful silence of mountain life, an aspect many like myself cherish deeply.

Some farms are required to build generator sheds and this should be a requirement for all. An enclosed space with an oil catchment and an exhaust system should be a requirement for all farms. Again, failure to comply with this regulation falls in stark contrast with an Earth First position, and again damages our credibility as stewards of the environment we profess to love and protect.

License Restrictions

The Humboldt Cannabis Reform Initiative also calls for license restrictions, license caps, and a restriction on license size, all of which are completely ridiculous and out of touch with market realities. A flawed licensing system has led to one parcel holding multiple license types, say a small outdoor, a small mixed-light, a medium outdoor, and a cottage license, for example – all for the cultivation of just one acre on the same parcel.

The initiative opposes the holding of multiple licenses, which is silly. Instead, the county and the state should revisit licensing requirements and allow for more streamlined property development and more sensible production capabilities. The limitation on licenses has been an abject failure with some corporate entities across the state stacking hundreds of small licenses and allowing for large-scale cultivation. This needs to change now.

Humboldt needs to get with the program. Rather than capping licenses or restricting further developments to just 5% above the current licenses in circulation as the Initiative proposes, we should open the floodgates and allow for real cannabis development in our area. Mixed-light, indoor, and outdoor cultivation should be allowed to flourish, not be hamstrung by short-sighted legislation that fails to understand current market dynamics. Protectionism never works. Market forces win and it’s time we leave the stone ages behind and join a modern economy characterized by competition, merit, and price discovery.

Many farms in Humboldt are going to fail, that’s a given. Allowing for development to replace this economic loss is a must!

If someone wants to launch a 100-acre scene in Humboldt I fully welcome such development. The many millions of investment dollars will help replace the enormous void small farm failure promises to create this season. As owners get over their ego trips, they can work for well-capitalized future developments and continue to earn an above-average living doing what they “love.” We can’t all own farms, just as we can’t all own auto dealerships or grocery stores and the sooner we come to realize that collectively, the sooner we can move forward together to create a productive and more sustainable local economy.

My home town of Fortuna has an enormous blighted property in the middle of town … a robust cannabis development on the abandoned mill site would create jobs, lessen dependence on social welfare, and help Humboldt stay on the map in terms of the ganja game. Failure to change and allow significant developments in the space will lead to much of the same … widespread farm failure, collapsing property values, and a cratering local economy. This reality sucks and hurts me too, but it is what it is.

Public Input

The Reform Initiative also alleges that many projects, including the smaller ones, fail to adequately solicit public input. I agree that neighbors should have some say in what they want in their neighborhoods, but also argue that zoning laws should be honored. If your property qualifies for a cannabis permit, one should be granted.

While I fully empathize that someone with a scenic view may be off-put by a row of greenhouses being constructed on the horizon, such is life. As long as a property honors night sky performance and generator regulations, that should be good enough. While many individuals oppose cannabis projects on moral grounds, it is easy to couch one’s opposition in sideshows – traffic, noise, criminality, etc.…

If a permit is granted in your neighborhood and it is run by bad actors who break the law – light leaking at night, abusing water rights, or other offenses, make a formal complaint to the Sheriff’s office and to Humboldt’s Code Enforcement Division. They are highly responsive to legitimate complaints backed by evidence such as photos or videos and will soon put an end to the nuisance.

As I have argued many times, the local cannabis industry and the economic success of Humboldt are in jeopardy. For retirees, trust fund babies, or others with significant assets, it is easy to shit on the local cannabis community and argue for “reform.” Rather than looking for creative ways to further hamstring a struggling industry, Humboldt should aggressively seek ways to bolster the industry, create a robust cannabis tourism economy, and remain relevant in the nation’s fastest-growing business. Demonizing legitimate operators, ignoring the repulsive conduct of many illicit market operators, and denying that larger farm size and scale offer the best path forward in this industry is old news and promises to decimate life here as we know it.

My very best always,



Jesse Duncan is a lifelong Humboldt County resident, a father of six, a retired financial advisor, and a full-time commercial cannabis grower. He is also the creator of NorCal Financial and Cannabis Consulting, a no-cost platform that helps small farmers improve their cultivation, business, and financial skills. Please check out his blog, his Instagram at jesse_duncann, and connect with him on Linkedin.