Dear (Santa Barbara County Planning Commission) Chair and Commissioners:
Citizens Planning Association submits this letter in support of the La Barge appeal ABL Partners cannabis cultivation LUP. For reasons cited in great detail in the appeal letter, we concur that the findings for this project cannot be made.
Citizens Planning Association, representing residents from throughout Santa Barbara County, has supported sound land use policies on the Central Coast since 1960. CPA has submitted many comments on the inadequacy of the County’s Cannabis land use process dating back to the development of the ordinance. The use of a programmatic EIR to support Land Use Permits is wholly inadequate in most cases, and especially in a circumstance such as the one before you today.
In the present case, the project’s year-round use and potential diversion of surface water, as well as the impacts on adjacent cultivated agriculture, demand further and more site-specific environmental review.
CPA is concerned about the cumulative impacts of the multiple approved and pending large cannabis projects in this small area denoted by a blue circle in the cannabis GIS map taken from the County’s website on 4-22-22. These projects are adjacent to or near the Santa Ynez River, ranchettes, and cultivated agriculture. Hundreds of thousands of gallons of water storage in tanks is either already permitted or pending in the adjacent parcels—most with a simple land use permit. In addition, dozens of large projects east of HWY 101 along HWY 1, Sweeney Rd., and Santa Rosa Rd add further cumulative impacts- to land, water, air and agriculture.
CPA believes that County staff, Commissioners and BOS members must cease reliance on a five-year old countywide PEIR to substitute for site-specific environmental analysis. In the absence of such analysis, we see no rational way that decision makers can make the findings necessary for approval. As noted on Page 14 of the appellant’s letter, the County’s CEQA checklist limits its concerns with the State Water Resource Control Board’s waste discharge policy and does not consider the source of water, or its jurisdiction of administration and regulation.
Given those concerns, as well as other appeal issues such as conflicts with the potential disruption of surrounding agricultural operations, we urge the Planning Commission to uphold the appeal.
Marell Brooks, President
Citizens Planning Association