The remote and rugged terrain that once attracted illicit cultivation attempting to avoid detection may now hinder the ability of farms in these areas to comply with environmental regulatory standards and ultimately become licensed. Multiple environmental permits may be required in order to obtain a CDFA cultivation license if growing outdoors or in greenhouses, and the fees and information requirements may represent significant hurdles to some farmers . Initial evidence indicates the first wave of regulated, industrial scale cannabis has largely begun not in the historical epicenter of Northern California, but in the hills and isolated valleys of the Central Coast. Although select counties in the Central Valley have allowed a token number of large cannabis farms , licenses for farms of equivalent size have been issued en masse in counties such as Santa Barbara and Monterey . In these areas, it is not yet clear if large-scale cannabis farms will more commonly repurpose existing infrastructure or stake out new territory further from existing agriculture and closer to natural spaces. Understanding the potential environmental impacts of industrialized cannabis requires knowing where and why extensification or intensification occurs, patterns of natural resource use, and how these dynamics relate to regulatory mandates. For example, regarding the issue of water, the legacy of illegal cannabis cultivation sites and their tendency to divert from streams and springs has led to these sources of water becoming tightly regulated within the legal cannabis industry. In particular, air racking extraction from these sources is prohibited during the growing season and farms that rely on them must either instead collect and store this water in the off season or use an alternative source.
For the majority of regulated cannabis farms, the choice has been to use well water and this is already the most common source for irrigation . Given the hurdle of developing sufficient storage, especially at increasingly larger farm sizes, the use of wells will likely increase in frequency . While the story of groundwater depletion in California is common knowledge , the use of wells by commercial cannabis farms is fundamentally different, given their tendency to occur outside of large aquifer basins . Such wells that are located instead adjacent to watercourses, in small alluvial aquifers, or fractured bedrock have potential to reduce crucial stream flow during the summer months , although this topic is currently understudied and generally beyond the purview of current California groundwater policy . This is a concern not only for large-scale farms in the new frontier of the Central Coast, but also for farms on the North Coast that must compete with these operations. The prospect of farms on the North Coast increasing in size to compete and shifting to groundwater extraction to comply has latent environmental implications, deserving further research. Characterized by geographically isolated, small farms, the informal cannabis cultivation sector represented a form of agriculture distinct from California’s consolidated, credit-supported industrial model. The historic legacy of the cannabis industry in Northern California has differentiated this region and led to worldwide recognition of its products. However, remoteness has now isolated traditional cultivation regions from an emerging legal supply chain and new markets, while obligating farms to navigate high regulatory costs associated with operating in environmentally sensitive locations.
How farmers in these remote watersheds respond holds importance for the future of the cannabis industry and its socio-environmental dynamics. Formation of grower cooperatives , appellation systems , caps on farm size and license consolidation , or a return to medical provisioning collectives may provide tools to overcome steep start-up and licensing costs for small farmers. Due to ongoing federal prohibition, farmers do not have access to traditional supports such as bank loans or crop insurance and instead must rely on private capital, limiting engagement in legal markets by many smaller farmers. Paradoxically, if barriers to capital are reduced, it may invite institutional investment and accelerate further industrial consolidation and up-scaling. More research is needed to understand the socio-ecological dynamics that underpin changes in cannabis cultivation in California and beyond. California’s statewide legalization opens some research pathways through regulatory databases, harmonization among institutions and jurisdictions, and new funding mechanisms. Yet, federal prohibition still creates a “quasi-legal challenge” for robust research , with consequences for effective policy-making and environmental health . Federal prohibition can inhibit institutional funding , discourage participation of informants in studies , lead to suspicion of researchers by potential study participants , create difficulty for Institutional Review Boards and researchers to estimate and mitigate risks for human subjects, and create asymmetries in data collection and knowledge types. High numbers of producers operating outside of regulatory systems impede the ability for comprehensive and representative studies and projects limited to only “compliant” producers cannot account for the total socio-ecological dynamics of cultivation.
With a lack of robust research, resulting policies cannot be driven by direct research on cannabis, may impair social equity in the transition of informal producers to formal markets , and complicate implementation of strategies to govern common environmental resources . Further, policies that incentivize industrial consolidation and eliminate small producers may have environmental consequences . Among cannabis producers, decisions about production can alter ecological and hydrological conditions, requiring attention not just to stream flows, pest management, indicator species, and wildlife movement patterns, but also to the social calculus of decision-making. Analyses of production decisions necessitate the development of qualitative research methods to understand how policy formations, social norms, knowledge access, and enforcement practices, among other variables, shape production practices across different kinds of ecologies and regions. In particular, many farmers are electing to avoid compliance . Factors influencing non-compliance may derive from prohibition or may only emerge post-legalization . Understanding the perspectives of non-compliant farmers is crucial to researching the social and ecological dynamics of cannabis production. Equally important is a qualitative, political economic understanding of how and why policies take particular forms in certain jurisdictions at certain times. Which interests and groups are most and least influential in forming polIcy? Who bears the consequences and rewards of the resulting regulatory regimes? Rapid transformations in cannabis policy are corresponding to the emergence of new scales, practices, and ecological consequences of cannabis cultivation. Lessons from other legal forms of agriculture suggest that increased market pressures may lead to industrialization, extensification and/or intensification, and increased reliance on credit fueled by debt. Siting patterns described here indicate that all three may already be trending upward in California since legalization of production for recreational use. As changes rapidly occur, research is urgently needed to understand the relations between regulatory change, farm size, location, environmental outcomes, and the geographical distributions of benefits and impacts. Such analyses will aid policy maker’s ability to govern and farmer’s capacities to participate in this newly regulated industry. If done with an eye toward equitable and just outcomes, drying weed it may also point the way toward a cannabis agriculture that incorporates and learns from the lessons and failures of industrialized agricultural production. Assessing the environmental impacts of the cannabis industry in Northern California has been notoriously difficult . The federally illegal status of cannabis has prevented researchers from obtaining funding and authorization to study cultivation practices . Fear of federal enforcement has also driven the industry into one of the most sparsely populated and rugged regions of the state , further limiting opportunities for research. An improved understanding of cannabis cultivators’ water use practices is a particularly pressing need.
Given the propensity of cannabis growers to establish farms in small, upper watersheds, where streams that support salmonids and other sensitive species are vulnerable to dewatering , significant concerns have been raised over the potential impacts of diverting surface water for cannabis cultivation. The environmental impacts of stream diversions are likely to be greatest during the dry summer months , which coincide with the peak of the growing season for cannabis. Further, because cannabis cultivation operations often exhibit spatial clustering , some areas with higher densities of cultivation sites may contain multiple, small diversions that collectively exert significant effects on streams . An important assumption underlying these concerns, however, is that cultivators rely primarily on surface water diversions for irrigation during the growing season. Assessments of water use impacts on the environment may be inaccurate if cultivators in fact use water from other sources. For instance, withdrawals from wells may affect surface flows immediately, after a lag or not at all, depending on the well’s location and its degree of hydrologic connectivity with surface water sources . Documenting the degree to which cannabis cultivators extract their water from above ground and below ground sources is therefore a high priority. In 2015, the North Coast Regional Water Quality Control Board , one of nine regional boards of the State Water Resources Control Board, developed a Cannabis Waste Discharge Regulatory Program to address cannabis cultivation’s impacts on water, including stream flow depletion and water quality degradation. A key feature of the cannabis program is an annual reporting system that requires enrollees to report the water source they use and the amount of water they use each month of the year. Enrollees are further required to document their compliance status with several standard conditions of operation established by the cannabis program. These include a Water Storage and Use Condition, which requires cultivators to develop off-stream storage facilities to minimize surface water diversions during low flow periods, among other water conservation measures. Reports that demonstrate noncompliance with the Water Storage and Use Standard Condition indicate that enrollees have not yet implemented operational changes necessary for achieving regulatory compliance. In this research, we analyzed data gathered from annual reports covering 2017 to gain a greater understanding of how water is extracted from the environment for cannabis cultivation. The data used in this study was collected from cannabis sites enrolled for regulatory coverage under the cannabis program. The program was adopted in August 2015, with the majority of enrollees entering the program in late 2016 and early 2017. The data presented in this article was collected from annual reports submitted in 2018 , which reflected site conditions during the 2017 cultivation year. The data therefore represents, for the majority of enrollees in the cannabis program, the first full season of cultivation regulated by the water quality control board. Because the data was self-reported, we screened reports for quality and restricted the dataset to reports prepared by professional consultants. Most such reports were prepared by approved third-party programs that partnered with the board to provide efficient administration of, and verification of conformity with, the cannabis program. Additional criteria for excluding reports included claims of applying water from storage without any corresponding input to storage, substantial water input from rain during dry summer months and failure to list a proper water source. Reports containing outliers of monthly water extraction amounts were also identified and excluded due to the likelihood of erroneous reporting or the difficulty of estimating water use at very large operations. Extreme outliers were defined as those values outside 1.5 times the bounds of the interquartile range . Farms were not required to use water meters, and those without meters often estimated usage based on how frequently they filled and emptied small, temporary storage tanks otherwise used for gravity feed systems or nutrient mixing. The final dataset included 901 reports. Parcels of land where cannabis was cultivated — including multiple contiguous parcels under single ownership — constituted a site, and this is the scale on which reporting was conducted. The spatial extent of the cannabis program included all of California’s North Coast region ; however, only a subset of the counties in this region allow cannabis cultivation and therefore reports were only received from the following counties: Humboldt , Trinity , Mendocino and Sonoma . Because Sonoma County contributed relatively little data, we combined Sonoma County’s enrollments with those from Mendocino County when making county-level comparisons. The data used for this analysis included the source and amount of water that cultivators added to storage each month as well as the source and amount of water applied to plants each month. We did not analyze absolute water extraction rates. Rather, we used the amount of water extracted each month — whether water was added to storage or applied to plants directly from the source — to analyze seasonal variation in each water source’s share of total water extraction. Water sources included: surface , spring , rain , well , delivery and municipal .