There are several issues with this draft ordinance. Those in the industry have had plenty of time to apply for permanent structures and go through the already established permitting process for permanent structures.

Additionally, this item was not properly noticed to the public hence the reason my comment is being submitted less than 3 hours before the hearing. Please strongly consider postponing this item to allow for sufficient notice to the public for review and comments.

I'm glad to see this being done, but the restrictions on containers need to be revised. Only allowing them to be used for 60 days is not enough time, there is no need for this. An operator should also not be forced to remove them after 60 days. Remove them to where? I'm not aware of any local container rental facilities, the farmer usually purchases them. Removing them adds traffic, contributes to greenhouse gases, and creates an unnecessary financial burden on the farmer. Better to give the applicant a certain amount of time to construct a building to place the containers in. Containers do create a bit of an eyesore (why are they all different gaudy colors?) but they are a very effective way of storing and curing cannabis.

In regards to containers being allowed for only 60 days out of the year for total of two years. The result of this part of the resolution needs to be examined. The intent seems to be to give cultivators an incentive and time to build permitted structures to replace the shipping containers and it may indeed achieve that, but with some unintended results as well. Let us take an example of a farm with 2 acres of agricultural development, which would allow for 4356 SF of shipping containers for storage or dry sheds. This would amount to 13 - 40 foot shipping containers or 27 - 20 foot shipping containers. The logistics and shipping would total of 4 times over the 2 years. This would add an unnecessary financial cost to already struggling cannabis operations and would have environmental costs related to carbon use, road wear, traffic and road safety concerns. A 2 year limit on the use of containers to achieve the goal of transitioning to permanent permitted structures.

The prohibition on the installation of any mechanical systems in exempt ag buildings or shipping containers will effectively eliminate their efficacy as "Storage or Dry Sheds" . Mainly because temperature and humidity control are the main drivers of both the storage and dry functions of these closed areas. Perhaps, the wording can be changed to be more specific to the types of mechanical systems allowed. Such as "Mechanical installations are limited to Air conditioning, dehumidification and air moving units that are stand alone and plug in. No permanently fixed HVAC systems used except for odor control systems upon prior approval of the Community Development Director. No propane or natural gas used."

testing