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Medical Marijuana and the Environment Fox 1 IF YOU SUPPORT THE LEGALIZATION OF MARIJUANA FOR MEDICINAL PURPOSES, DID YOU CONSIDER THE IMPACT IT WOULD HAVE ON OUR ENVIRONMENT? Matthew O. Fox University of Redlands Redlands, CA

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Page 1: MATT - Literature - APRIL - CAPSTONE

Medical Marijuana and the Environment Fox 1

IF YOU SUPPORT THE LEGALIZATION OF MARIJUANAFOR MEDICINAL PURPOSES, DID YOU CONSIDER

THE IMPACT IT WOULD HAVE ON OUR ENVIRONMENT?

Matthew O. FoxUniversity of Redlands

Redlands, CA

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Medical Marijuana and the Environment Fox 2

TABLE OF CONTENTS

ABSTRACT

I. INTRODUCTION

II. ROLE OF THE FEDERAL GOVERNMENT

III. IMPORTANCE OF CALIFORNIA

IV. QUANTIFYING DATA

V. PESTICIDES

VI. WATER

VII. LAND USUAGE

VIII. SURVEY RESULTS

IX. ACTION MUST BE TAKEN

X. CONCLUSION

ABSTRACT

Legalization of marijuana is gaining momentum both at the state and the federal levels of

government. Recently, Bernie Sanders, candidate for the Democratic Party’s Presidential

Nomination said he supported the de-criminalization of marijuana. The revenues to the states

that have legalized marijuana has been enormous and attractive to other states needing funding

for their infrastructures and education. While there is support for the legalization, the

environmental harms associated with legalization and also the illegal growing of marijuana have

not been adequately brought to the voter’s attention and the voters lack basic education on these

harms. This paper will outline the political issues, governmental issues, the fact that voters are

swayed by the environmental concerns. If a state or the federal government undertakes

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legalizing use and growth of marijuana, it must also comprehensively include in the legislation

limitation on the environmental harm that the legalization may cause.

I. INTRODUCTION

State legislatures and local governments have recently placed the issue of legalizing

possession of marijuana for medical purposes (and in some cases for personal use) on their

ballot. In fact, twenty states now allow marijuana use for medical purposes. However, none of

existing legislation nor the proposed legislation address the environmental concerns caused by

the growers including use of pesticides which kill local wildlife and vegetation nor the dangers to

humans ingesting the pesticides. Additionally, there is the environmental damage done to our

water supply and habitat where the growers strip the land.

While states are liberalizing their former stances and legalizing the use of marijuana, the

federal government has refused to reconsider its existing classification of marijuana as a

Schedule I drug subject to the same enforcement as heroin. Consequently, federal law

enforcement still subjects an individual caught possessing, growing and distributing marijuana to

criminal sanctions. Advocates on both sides of the legalization issues have addressed the general

public health issue, the appropriateness of criminal sanctions, and the fact that tax monies would

be raised while failing to address the environmental impact of marijuana legalization. While

recognizing that legalization will increase the use of marijuana and the corresponding demand

for an additional supply of marijuana, the arguments associated with legalization must address

the impact of current marijuana growth on our environment. The question remains: Can we

legalize marijuana, whether for personal use or restricted use for medical purposes only, without

also addressing in the same legislation curbs on the detrimental impact on the environment

associated with marijuana growth?

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II. ROLE OF THE FEDERAL GOVERNMENT

The federal government is the obstacle in meaningfully addressing the environmental issues

associated with the legalization of marijuana. With the enactment of the Controlled Substance

Act (CSA), the United States Congress determined marijuana to be a Schedule I controlled

substance. Marijuana consequently is classified along with the most serious and dangerous

substances known today. Today, the federal government still views marijuana as having a high

potential for substance abuse and refuses to recognize that it is part of an accepted medical

protocol.

The federal government and the medical community agree that the primary active

chemical in marijuana is delta-9-tetrahydrocannabinol (THC). The federal government argues

that THC will affect those parts of the brain that influence pleasure, memory, thinking,

concentrating, sensory and time perception, and coordinated movement2/ as well as increasing

the risk of schizophrenia, psychotic reactions, heart and respiratory function. The medical

community, while divided on the merit of suing marijuana as part of a treatment protocol still has

a significant number of physicians that believe that marijuana has a meaningful purpose in the

treatment of certain maladies. These medical advocates for the legalization of marijuana have

pointed to the favorable results patients have received when marijuana is part of their treatment

protocol in the treatment areas of glaucoma, Crohn disease, post-traumatic stress disorder,

epilepsy, Alzheimer disease, and chemotherapy-induced nausea and vomiting.1/ On the other

hand, the mainstream medical community only recently has added some recognition of the use of

marijuana and its medicinal value. The debate between the federal government and in part the

medical community will continue.

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1/ Wilkinson S, Deepak C. (2014). Problems with the Medicalization of Marijuana, Journal of American Medical Association, 311:23 Retrieved from http://jama.jamanetwork.com/article.aspx?articleid=1874073&.

III. IMPORTANCE OF CALIFORNIA

In 1996, California passed the Compassionate Use Act (Proposition 215) which

decriminalized marijuana for medical use in contradiction to the federal law. This Act was

challenged, held unconstitutional by the lower court, and the California Supreme Court in People

v. Kelly subsequently reversed the lower court finding the law constitutional. While California

legalized medical marijuana in 1996, it was not until October 9, 2015, that California Governor

Jerry Brown signed a trio of bills that have created a system of oversight for the growth,

manufacture, and sale of medical marijuana in California. It took almost 20 years to for

California to try to address environmental concerns. One of the three bills targets the

environmental damage to the state's water supply and death to wildlife in the state caused by

marijuana cultivation. The core of the legislation that remains recognizes marijuana and

classified marijuana as an "agricultural" product. As an agricultural product, growers must abide

by the State's regulations on insecticides and water use.2/ It is likely that this legislation will

also be challenged in the courts.

In 2012, voters in Colorado and Washington states passed laws legalizing marijuana for

use by adults 21 and older. Both states, like California, failed to address the environmental

issues associated with marijuana growing. It is understandable that Colorado and Washington

might not focus on the environmental consequences of growing marijuana because of the limited

impact marijuana growing would have on their respective states. However, the impact of the

grower in California is significantly greater than that in Colorado or Washington. This is

understandable when you appreciate the fact 60 to 70% of the marijuana grown for personal

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consumption in the United States is grown in California without any controls on its

environmental impact.3/

Failure to timely address the environmental concerns in California will most likely be “a

missed opportunity to reduce, regulate and mitigate environmental harm”.4/ Growing marijuana

currently has many detrimental consequences to the environment. “Its cultivation is associated

with land clearing, the diversion of surface water, agrochemical pollution, and the poaching of

wildlife in the United States.”5/ These negative consequences should be recognized and

addressed in the legislation that legalizes personal consumption of marijuana.

2/ Brosious, Emily. (2015). California passes first statewide medical marijuana industry regulations, Retrieved from http://extract.suntimes.com/news/10/153/4824/California-passes-statewide-medical-marijuana-industry-regulations.

Author takes the position that legalization of marijuana is good for the state as it will now allow marijuana grow sites to come under state legislation and control. However, it does not address how the state will be able to stop the illegal growing operations.

3/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

Article discusses the need for pesticide regulation. Relies on technical data from field studies. It emphasizes that the problem is not going away and that the harm currently exposed may be irreversible. It takes the environmental issue and moves it into the status of a “social issue” that must be addressed.

4/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel

M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full.

Timely article discussing negative “collateral effects” of marijuana cultivation on the environment. Focus is on California where the authors suggest that the danger of marijuana cultivation requires a policy response in framing marijuana policy. Cites a number of other articles that merit review. Research documented article. .

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5/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

See footnote 3

IV. QUANTIFING DATA

The problem with meaningfully identifying the environmental issues affected by

marijuana cultivation is that the issues are difficult, if not impossible to quantify. Outdoor

marijuana cultivation remains for the most part an underground activity sequestered away in

remote areas because growers are intent upon avoid federal detection. This problem is addressed

in an article by the California Department of Fish and Wildlife, “Marijuana has been cultivated

in the backwoods and backyards of northern California at least since the counterculture

movement of the 1960s with few documented environmental impacts”.6/ However, since the

location of most marijuana growing sites is undisclosed, data on their environmental impact

remains difficult to quantify. In fact, biologists and environmentalists avoid entering certain

areas where grow sites are located to collect data because many fields are occupied by armed

guards and these sites often are booby-trapped with explosives. Consequently, we must rely on

data that comes from the few sites uncovered by law enforcement. If the federal government

would legalize marijuana growing and possession, then data would now be obtainable and could

be quantified as grow sites would become subject to federal regulations and monitored for

compliance.

Marijuana growers often reside at their grow sites for months at a time with little concern

about the trash and waste that remain when they vacate the site. In California, marijuana is

primarily grown outdoors in remote areas. The growers are not concerned whether the land they

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use is private, public or Native American tribal. The important thing to the grower is that the site

is not easily visible to regulators and law enforcement. The grower’s lack of concern about

private property also is evidence in their lack of concern about poaching wildlife for food and

disregarding waste and garbage without concern for the appropriate disposal. It is not

uncommon for Black market growers also to generally live at their primitive sites for months

unconcerned about non-biodegradable trash and human waste. . “Environmental clean-up and

remediation efforts in the affected watersheds are limited, even after enforcement actions are

taken, because of lack of resources and staff in state or federal agencies.”7/ If the federal

government legalized marijuana use and growing, these grow sites could then be regulated and

existing laws and regulations enforced on the grower.

6/ Bauer S, Olson J, Cockrill A, van Hatten M, Miller L, Tauzer M, et al. (2015). Impacts of Surface Water Diversions for Marijuana Cultivation on Aquatic Habitat in Four Northwestern California Watersheds. PLoS ONE 10(3): e0120016: do:10.1371/journal.pone.0120016. Retrieved Google Scholar.

This research article by the California Department of Fish and Wildlife provides detailed data on the team’s efforts to determine the environmental impact of marijuana cultivation. It is thorough and concludes that marijuana cultivation has the potential to divert substantial portions of streamflow in the studied watersheds with “an estimated flow reduction of up to 23% of the annual seven day low flow in the least impacted of the study watersheds. Its research challenges the wisdom of Proposition 215, the Compassionate Use Act (1996), legalizing marijuana use in California. See cites of additional articles of interest.

7/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

See footnote 3.

V. PESTICIDES

We cannot disregard the impact that pesticides used at grow sites have on the

environment. “Marijuana growers apply insecticides directly to plants to protect them from

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insects. Chemical repellants and poisons are applied at the base of the marijuana plants and

around the perimeter of the grow site to ward off or kill rats, deer, and other animals that could

cause crop damage.”8/ It is this poison that is used by marijuana growing operations also that

also pollutes our water resources and potentially poison wildlife at the grow site (and

downstream).

Black market cultivators are known to use highly poisonous pesticides, some of which

are believed to be illegally brought into this country from Mexico. The linking of anticoagulant

rodenticide (AR) “to multiple deaths of a rare forest carnivore has been an alarming discovery.

Even more unsettling, we’ve learned that these deaths appear to be linked to illegal marijuana

cultivation on community and public lands – a finding that raises serious concerns for the health

of many species of wildlife including [Pacific] fishers, an Endangered Species Act candidate.”9/

“80% of deceased Pacific fishers (Pekania pennanti) . . . recovered in northern California

and the southern Sierra Nevada were exposed to anticoagulant rodenticides, pesticides used to

control wood rats (Neotoma spp.).”10/ Already endangered, the Pacific fisher may die out

because of its interaction with pesticides. Black market growers are not concerned with the

disposal of the pesticides and have been known to throw the pesticides directly into cisterns built

to hold water for irrigation contaminating the entire area.11/ In other cases, pesticides are

simply abandoned at grow sites. Law enforcement officers leave these pesticides on site as they

do not possess the requisite disposal skills to clean a grow site. Hence, these pesticides are left to

cause further damage to the environment. The use of pesticides is a continuing threat to the

native habitat of many animals. The most common used anticoagulant rodenticide used is what

is commonly known as d-Con.

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Pesticides is not an isolated problem. “. . . remediated sites, at least 50 of them had

SGARs (second-generation anticoagulant rodenticide). Beyond finding anticoagulant

rodenticides, the team and other remediation groups frequently find and remove restricted and

banned pesticides . . . as well as thousands of pounds of nitrogen-rich fertilizers. . . . marijuana

cultivators place pourable carbamate pesticides in opened tuna or sardine cans in order to kill

black bears, gray foxes, raccoons, and other carnivores that damage marijuana plants or raid food

caches at grow-site encampments.”12/

8/ Office of National Drug Control Policy, Answers to Frequently Asked Questions about Marijuana. Retrieved from https://www.whitehouse.gov/ondcp/frequently-asked-questions-and-facats-about-marijuana.

Pro federal government article on the issues that supported the government’s position.

9/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

See footnote 3.

10/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full.

See footnote 4.

11/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full.

See footnote 4.

12/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retreived Google Scholar.

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See footnote 3.

VI. WATER

Regretfully, state and local law enforcement are shorthanded and lack the resources to

properly police all marijuana growing operations for pesticides. However, the problem is not

limited to pesticides. It is estimated that 22 plus liters of water is needed per plant per day during

the months of June thru October.13/ Because marijuana requires so much water, even the

smallest farms can have disproportionately large effect on surrounding watersheds. In their 2015

report, the California Department of Fish and Wildlife stated: “The extent of potential

environmental impacts in these watersheds (4 California counties) is especially troubling given

the region is a recognized biodiversity hotspot.”14/ As a consequence, surface water diversion

potentially will significantly impact water flow in California which is already currently suffering

the consequences of an intense drought. Reduced stream flow “threaten the survival of rare and

endangered salmonids, amphibians, and other animals.”15/

The California Department of Fish and Wildlife study reported that during drought

conditions, water demand for marijuana cultivation exceeded 100% of the stream flow in three of

four study watersheds. Three of these watersheds went dry, the only stream that did not go dry

did not have any marijuana growing operations. It concluded that “diminished stream flow from

this water-intensive activity is likely to have lethal to sub-lethal effects on state and federally

listed salmon and steelhead trout and will cause further decline of sensitive amphibian

species.”16/ The environmental concerns brought to light by marijuana growing operations are

not limited to pesticides and water usage.

13/ Humboldt Growers Association, Review of Humboldt County Medical Marijuana Health and Safety Code, Humboldt County 2010 (11 December 2014). Retrieved from http://library.humbold.edu/humco/holdings/HGA2.pdf).

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14/ Bauer S, Olson J, Cockrill A, van Hatten M, Miller L, Tauzer M, et al. (2015). Impacts of Surface Water Diversions for Marijuana Cultivation on Aquatic Habitat in Four Northwestern California Watersheds. PLoS ONE 10(3): e0120016: do:10.1371/journal.pone.0120016. Retrieved Google Scholar.

See footnote 6.

15/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

See footnote 3.

and

Bauer S, Olson J, Cockrill A, van Hatten M, Miller L, Tauzer M, et al. (2015). Impacts of Surface Water Diversions for Marijuana Cultivation on Aquatic Habitat in Four Northwestern California Watersheds. PLoS ONE 10(3): e0120016: do:10.1371/journal.pone.0120016. Retrieved Google Scholar.

See footnote 6.

16/ California Department of Fish and Wildlife, News, Ecosystem Restoration, Environmental Science, Habitat Conservation, Marijuana, CDFW Scientist Publish Groundbreaking Work on Marijuana’s Effect on the Environment. Retrieved from https://cdfgnews.wordpress.com/2015/03/25/cdfw-scientists-publish-groudnbreaking-work-on-marijuanas-effect.

State government research that discusses all the issues detrimental to the environment that result from the illegal cultivation of marijuana.

VII. LAND USUAGE

The direct consequence of marijuana growing operations on the land itself is catastrophic.

“Land terracing, road construction, and forest clearing for both semi-legal and black-market

marijuana plantations remove native vegetation".17/ The consequence is erosion which sends

fine sediment into the streams endangering not only the local salmon and trout but also all native

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wildlife. The damage done cannot be easily corrected by remediation and in many cases is

irreversible.

17/ Milestone J, Hendricks K, Foster A, Richardson J, Denniston S, Demetry A, Ehmann M, et al. (2012). Continued cultivation of illegal marijuana in US western national parks. In: Weber S, editor. Rethinking Protected Areas in a Changing World: Proceedings of the 2011 George Wright Society Biennial Conference on Parks, Protected Areas, and Cultural Sites. George Wright Society; 2012. P. 209-216. Retrieved from Google Scholar.

Discusses the abuse by Mexican drug cartels at grow sites within the western national park system. Six sites were discovered with 26,028 plants worth $78,840,000.

VIII. SURVEY RESULTS

A survey was sent to individuals, students, faculty, and legislators with an assurance of

anonymity. First, there would be a division of responses seeking those who were (are) in favor

of the legalization of marijuana for either personal use or medicinal use. Those in favor of

legalization were then asked whether the environmental issues of pesticides and water issues

would cause them to change their position. While the sample was limited, the result of the

survey were evident.

Age Age AgeResponses

18 to 30

30 to 50 50+

Question 1: Would you vote for the legalization of marijuana without limitiation? 14 YES 6 3 2 NO 1 2

Question 2: Would you vote for the legalization of marijuana for medical purposes? 14 YES 6 4 4 NO

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Question 3: If you would vote for the legalization of marijuana then would you vote for it if you knew that pesticides were being used and could endanger a person's life? 14 YES 4 3 4 NO 2 1

Question 4: If you would vote for the legalization of marijuana then would you vote for it if you knew that our water supply was being contaminated? 14 YES NO 4 4 4

The obvious conclusion of the survey was that there is significant support for the

legalization of marijuana among those under the age of 50 and in all cases that the support for the

legalization of marijuana is reduced as environmental concerns are know.

IX. PROPOSED LEGISLATION

Along with any legislation legalizing the sale and use of marijuana should be companion

legislation that provides for the enforcement state wide and federally of all existing laws. The

laws involving enforcement must also include strict penalties but also remediation of any

environmental harm caused by the growers both indoors and outdoors. Registration of growers

needs to also be included along with bonds set that would protect the communities from the

dangers caused by marijuana growers in case they are not available for remediation.

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X. ACTION MUST BE TAKEN

While it has been estimated that wholesale marijuana sales in California total

approximately $16.7 billion18/ and is California’s largest cash crop, marijuana is not subject to

any effective statewide laws and/or regulations. The growers continue to remain anonymous and

thus are not concerned with regulatory compliance. This consequently separates the marijuana

growing industry apart from the traditional agricultural community which have historically tried

to Legalization of marijuana for medicinal purposes appears inevitable across the country as

more research is done by medical authorities as to the benefits in their treatment of specific

diseases. “In short, the semi-legal status of the medical market and the significant intermixing of

the medical and black markets complicate regulation of the industry. As a result, local

marijuana-specific laws and regulations, as well as other existing state and federal environmental

laws that apply (e.g., the state Fish and Game Code and Water Code and the federal Clean Water

Act and Endangered Species Act) are currently inconsistently and lightly enforced. The lack of a

robust legislative mandate to prevent and address the environment impacts associated with

marijuana cultivation adds to this challenge.”19/

Limiting legalization to user with medical purposes is not going to end the underground

and illegal industry when personal use is not addressed. Additionally, state-by-state legalization

is not going to limit underground growers from damaging the environmental. Federal legislation

without regulations to address the environmental effects of growth will also not be enough to

protect the environmental. Only fully legalizing marijuana use with federal legislation and

regulation of the growers will address the continuing environmental issues. Like prohibition of

alcohol, only legalization allowed a level of control.

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“The reduction of environmental harm associated with marijuana cultivation and the

enforcement of environmental laws are important social aims, regardless of the legal status of

marijuana. The current levels of ambiguity and secrecy surrounding the industry impede the

revelation of associated environmental impacts, as well as the creation and implementation of

solutions. Inherent trade-offs between marijuana cultivation and ecosystems needs exist, as they

do in virtually all types of agriculture, and those trade-offs should be quantified and debated

openly, as they are in other industries. There is a significant need to broaden the conversation to

encompass environmental concerns and to explore how current and future marijuana policy can

use both incentives and regulatory tools to prevent and mitigate the environmental damage

associated with marijuana cultivation.”20/ This is necessary to address the environmental

impact of marijuana growing.

While it could be argued that the total land area under marijuana cultivation may be

considered small when compared to more traditional California crops, its impact on California’s

ecosystem is extensive and not easily controlled as much of the marijuana is grown outdoors

using surface water and pesticides. Tony Silvaggio, an environmental sociologist at the

Humboldt Institute has opined that “The root cause of environmental damage on public lands is

the failed federal policy of marijuana prohibition. Prohibition inflates the price and makes it

profitable to grow weed anywhere.”21/

18/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full.

See footnote 4.

19/ Short AG. PhD dissertation. Berkeley, United States: University of California. (2010). Governing Change: An Institutional Geography of Rural Land Use, Environmental

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Management, and Change in the North Coastal Basin of California. Retrieved from Google Scholar. and

Article addresses the need for legislation that addresses the detrimental land use issues resulting from marijuana grow sites.

Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full .

See footnote 4.

20/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full .

See footnote 4.

21/ Levy, Sharon. (2014) Pot Poisons Public Lands, BioScience (April 2014) 64(4); 265-271. doi: 10.1093/biosci/biu020. Retrieved from http://bioscience.oxfordjournals.org/content/64/4/265.full.

Article focuses on the impact of marijuana cultivation on wildlife. It purportedly relies

on a number of authorities, none of which are cited. It is an emotional plea for the preservation of the fisher and the fact that law enforcement is not effective.

XI. CONCLUSION

The demand for marijuana for both personal use and medicinal use have clouded the

environmental issues associated with marijuana cultivation which deserve equal consideration to

issues -- social, public health issues, and taxing benefits . While medical marijuana growers in

California are supposed to (1) submit lake and streambed alteration notifications with the

California Department of Fish and Wildlife and (2) comply with applicable laws and regulations,

black market growers will not comply nor have they demonstrated any concern about the state’s

environmental issues. Voluntary action on issues of environmental concern is contrary to the

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grower's own objectives and therefore it is unrealistic to believe that there will be any voluntary

compliance even if laws were on the books.

REFERENCES

1/ Wilkinson S, Deepak C. (2014). Problems with the Medicalization of Marijuana, Journal of American Medical Association, 311:23 Retrieved from http://jama.jamanetwork.com/article.aspx?articleid=1874073&.

2/ Brosious, Emily. (2015). California passes first statewide medical marijuana industry regulations, Retrieved from http://extract.suntimes.com/news/10/153/4824/California-passes-statewide-medical-marijuana-industry-regulations.

3/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

4/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full.

5/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

6/ Bauer S, Olson J, Cockrill A, van Hatten M, Miller L, Tauzer M, et al. (2015). Impacts of Surface Water Diversions for Marijuana Cultivation on Aquatic Habitat in Four Northwestern California Watersheds. PLoS ONE 10(3): e0120016: do:10.1371/journal.pone.0120016. Retrieved Google Scholar.

7/ Gabriel N, Wengert G, Higley I, Krogen S, Sargent W, Clifford D. (2015). Silent forests? Rodenticides on Illegal Marijuana Crops Harm Wildlife, Wildlife Professional 2013; 7(1): 46-50. Retrieved Google Scholar.

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14/ Bauer S, Olson J, Cockrill A, van Hatten M, Miller L, Tauzer M, et al. (2015). Impacts of Surface Water Diversions for Marijuana Cultivation on Aquatic Habitat in Four Northwestern California Watersheds. PLoS ONE 10(3): e0120016: do:10.1371/journal.pone.0120016. Retrieved Google Scholar.

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17/ Milestone J, Hendricks K, Foster A, Richardson J, Denniston S, Demetry A, Ehmann M, et al. (2012). Continued cultivation of illegal marijuana in US western national parks. In: Weber S, editor. Rethinking Protected Areas in a Changing World: Proceedings of the 2011

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20/ Carah J, Howard J, Thomason S, Gianotti A, Bauer C, Carlson S, Dralle D, Gabriel M, et al. (2015). High Time for Conservation: Adding the Environment to the Debate on Marijuana Legalization. BioScience (August 1, 2015). 65(8): 822-809, doi:10,1093/biosci/biv083. Retrieved from http://bioscience.oxfordjournals.org/content/early/2016/06/17/biosci.biv083.full .

21/ Levy, Sharon. (2014) Pot Poisons Public Lands, BioScience (April 2014) 64(4); 265-271. doi: 10.1093/biosci/biu020. Retrieved from http://bioscience.oxfordjournals.org/content/64/4/265.full.