I recommend that this be passed back down to the planning commission for revision. Allowing containers for only 60 days will cause unnecessary impacts to the county. Additionally, requiring an exit in shipping containers within 20ft will make all 40ft containers require a rear door. This will be expensive and will make them unsellable at end of required disuse.

Strongly oppose. There are several issues with this draft that need more in depth considerstion. Possibly an initial study or CEQA review should be considered since the changes are quite significant. If a study or review of the overall changes is not feasible, then each project should at least require a revised IS or CEQA review.

*Setbacks - 50ft is insufficient.
*Ag exempt structures - Meant for storage only with no electrical or plumbing. This draft seeks to allow for elec/plumb in ag exempt structures.
*Temp ag structures - no limit on quantity per location. No enforcement guidelines for failure to remove after 60 days. CDD doesn't have staff.
*Generators - Can power not be sourced from the same power used for wells? Why is solar not discussed as a viable solution? CA is phasing out the use of generators by banning sales in other sectors including private and rv uses. Solar generators would seem to be much cleaner, quieter and a safer alternative. Why only tier 4 and not tier 5?

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 for a 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

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."