Regarding this entire “identify the problem sites” exercise, it is stupid and useless.  Listing problem sites today ignores the likelihood that there will be more applications for new problem sites in the future.  It is an entirely backwards way of doing planning and is not used for any other planning exercise that i know of.

The proper way to proceed is to identify sites, not where there are or may be problems, but THOSE THAT ARE SUITABLE based on a set of planning criteria.  That is the way ALL planning is done.  For example, in preparing the General Plan and Zoning Maps, planners identify those areas where specified uses are environmentally suitable and compatible with surrounding uses.  Thus we end up with identified commercial zones, industrial zones, multi-residential zones (apartments and condos) and residential zones.  Those areas not so identified do not allow any of these uses.

Similarly, the County should study it’s environmental and land use information and identify locations where cannabis grows ARE SUITABLE based on criteria such as:

  •                 Areas where public water and other necessary public services are available including power, sewer, storm water drainage, etc..
  •                 If not on public water, areas located in a groundwater basin where water use will not impact environmental resources.
  •                 Areas served by adequate and safe road access.
  •                 Areas remote from incompatible residential sites.
  •                 Areas remote from public and private schools.
  •                 Areas remote from public and private parks, children’s camps, trails and other recreation sites.
  •                 Areas easily secured and accessible to law enforcement.
  •                 Areas free of extreme or high danger of wildfire.
  •                 Areas free of landslides, flooding and other natural hazards.
  •                 Areas free of rare and endangered or sensitive plants.
  •                 Areas free of historic and/or archaeological resources.
  •                 Areas free of important wildlife habitat and corridors.
  •                 Areas free of other identified incompatibilities.

Once areas meeting these criteria are identified and mapped, planners would normally do an assessment of how much such suitable land can be projected as reasonably necessary to meet current and future (20 years for a General Plan) demand.

These proposed suitable areas are then presented to the public in hearings, and after collecting all public comment, the planners select those areas where permits for grows will be considered.  

Individual proposals are then evaluated to make sure that they do indeed meet all of the necessary criteria and go through the Conditional Use Permit and California Environmental Quality Act processes where the public has the opportunity to provide comment and participate in public hearings.

THIS IS THE WAY PLANNING IS ALWAYS DONE.  And, the County’s failure to undertake the appropriate planning process is why we all have the problems with these grows that keep popping in unsuitable areas.  The County would not and has never done planning for any other land use by asking for the public to identify UNSUITABLE or problem sites.  The ALWAYS do an analysis and pick areas that are most likely to be SUITABLE.   It’s like saying you can locate a junk yard anywhere unless enough neighbors show up after the fact and complain.  That’s why I don’t hesitate to call the current process stupid.  

These controversies could have all been avoided, if the County had undertaken the usual, normal planning process that is applied to all other land uses.  

The proposed Phase II compatibility planning process should follow the normal and appropriate planing process described above.

So asking us to identify “problem sites” is inappropriate and essentially a useless effort,  There will always be additional proposals for “problem grows” in incompatible sites in the future that no one can reasonably predict.

I don’t understand why in the world the Board assigned this effort to Economic Development instead of Planning.  Economic Development never had the experience and doesn’t have the expertise to manage the land use planning for cannabis grows.

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