September 25, 2023
To toleary, cvecchio, cheryl.safaty, marketing@sonomacounty.com, bryce.martin, Tennis, Scott, Crystal, john.danna, bos, PlanningAgency, Christina.Rivera, McCall.Miller, Cannabis, Jennifer.Klein, sita.kuteira@sonoma-county.org,
September 22, 2023
Todd O’Leary (toleary@sonomacounty.com)
Vice President of Marketing and Communications
400 Aviation Blvd #500
Santa Rosa, CA 95403
Re: Cannabis: Sonoma County Tourism’s Next Marketing Initiative
Dear Mr. O’Leary:
The Neighborhood Coalition advocates for sustainable, environmentally sound, and neighborhood-compatible cannabis policies in Sonoma County.
An article published both in the North Bay Business Journal and the Press Democrat entitled “Cannabis: Sonoma County Tourism’s next marketing initiative” states that Sonoma County Tourism has revised its strategic plan to promote cannabis events and related experiences.
We understand that Sonoma County Tourism is funded by a voter-approved Transit Occupancy Taxes as well as Tourism Business Improvement Area assessments on the lodging industry.
Your draft strategic plan offers few details, and identifies no specific events that you intend to promote on your website or elsewhere. Nor does it identify any specific story ideas that you might pitch to travel writers. The Neighborhood Coalition is concerned that Sonoma County Tourism and its consultant, Cultivar Strategies, may be unfamiliar with the legal prohibitions to canna-tourism. Perhaps you have naïvely succumbed to the entreaties of a cannabis industry that may have little concern for the legal jeopardy of Sonoma County Tourism.
The Sonoma County Cannabis Ordinance, section 26-88-250(c)(1), provides that commercial cannabis activities are prohibited without a use permit. In addition, section 26-88-250(c)(5) provides “Tasting, promotional activities, and events related to commercial cannabis activities are prohibited.” These prohibitions apply to unincorporated Sonoma County, and you can readily verify this information by contacting Scott Orr, assistant PRMD director (707-565-1754).
As to activities in the nine cities, you should contact the appropriate city attorney where an event is being proposed to determine whether or not the event is legal. Few, if any, city ordinances in Sonoma County allow cannabis events. Moreover, the state regulations issued by CalCannabis prohibit canna-tourism at cultivation sites. Cal. Code Regs. Tit. 4, § 15042 limits access to cultivation sites to “authorized individuals,” which does not include tourists, and a grower is not allowed to receive compensation for permitting an individual to enter a grow site.
The promotion by Sonoma County Tourism of events that violate the law would undermine public support for its work, threaten its funding, and could expose it to legal liability. Sonoma County Tourism does not promote illegal activities like sideshows or cock fighting and should not promote any other illegal events or activities. To do so would violate its obligations to the taxpayers and the public.
We urge Sonoma County Tourism to reconsider its strategic plan and promotion policies considering these issues.
Thank you.
Neighborhood Coalition
Nancy and Brantly Richardson, Communications Directors SonomaNeighborhoodCoalition@gmail.com
cc: Claudia Vecchio, CEO, Sonoma County Tourism (cvecchio@sonomacounty.com)
Cheryl Sarfaty (cheryl.sarfaty@busjrnl.com)