The Sierra Club Lake Group supports Appeal AB24-02 of the Major Use Permit, UP20-96 Highland Farms. We are concerned that the environmental impacts of this project have not been adequately assessed or mitigated for in the current plans for this project as approved by the Planning Commission. The recreational impacts for park users and the rare native plants in the area have also not been adequately assessed. The Highland Springs area is one of the natural areas that helps maintain the physical and mental health of the residents of and visitors to Lake County.

There are several areas of concern that have not been adequately addressed making it necessary to appeal the approval.

Wetlands: Wetlands were found by the applicants biologist during a second visit to the site. To date no protocol-level wetland delineation to US Army Corps of Engineers (ACOE) standards has been performed.

Foothill Yellow-legged Frog (FYLF): To-date no targeted surveys for FYLF were ever completed and thus it is not currently possible to determine whether impacts to FYLF will occur.

Special Status Plants: The PES report states that two special-status plants are found in the chaparral areas of the property, scrub oak (Quercus dumosa) and Konocti manzanita (Arctostaphylos manzanita ssp. elegans). Both of these chaparral plants are considered special-status species, thus CEQA and other State laws require quantification of impacts and mitigation for impacts to these species.

This project needs to have a new CEQA-level BA performed that includes the access roads. Without appropriate plant, animal, or wetland surveys we believe the project would be in violation of CWA, CEQA, and County of Lake Municipal Code because impacts to wetlands, plants, and animals are not sufficiently assessed or mitigated for.

The Highland Farm project needs to be put on hold until all of these assessments are completed and deemed to be in compliance with the Clean Water Act, California Environmental Quality Act, and County of Lake Municipal Code.

Air Quality: The movement of large quantities of serpentine to provide access to the property has the potential to put asbestos, a known carcinogen and teratogen, into the air and water endangering people and other life forms. The odor of the cannabis plant will pervade the area and be a nuisance to some local residents and visitors to the park.

Respectfully,
Deb Sally
Chair, Sierra Club Lake Group

We are writing in support of the Appeal (AB24-02) for Highland Farms, LP (UP20-96). The applicant failed to present all the facts. An EIR should have been completed. Many of the wetlands on the parcels were not identified. Also, if a continuance is requested, please continue with the hearing as planned. The appelant filed the papers with CDD on time over 2 weeks ago. Thank you. Respectfully, Richard and Donna Mackiewicz

RE: Appeal AB 24-02 Highland Farms. I am writing in support of this appeal as there appears to be significant information that was not provided by CDD staff to the Planning Commission nor the public for review at the original hearing on May 23, 2024. One specific area of concern is the Lake County GIS website which includes a map overlay for Commercial Cannabis Exclusion Zones. No maps of Highland Springs trail systems and boundaries were made available before or during the May 23rd Planning Commission hearing. Additionally, no reference was made or visuals aids provided as to the proximity of this project to an exclusion zone.

The GIS website contains a disclaimer before entry which clearly states: “IF ANY PORTION OF A PARCEL INTERSECTS AN EXCLUSION ZONE, THE ENTIRE PARCEL SHALL BE CONSIDERED TO BE WITHIN THAT EXCLUSION ZONE”. (Photo attached from Lake County GIS Page)

All 6 parcel numbers listed for this project appear to have a portion that intersects with the exclusion zone which encompasses the Highland Springs Recreational Area. (Photo attached from Lake County GIS Commercial Cannabis Cultivation Exclusion Zones page with parcel numbers listed).

This appeal brings to light the many deficiencies in the county's current permitting process, including but not limited to; pertinent information/documentation not being made available timely, CDD staff thoroughly vetting all aspects of a UP and addressing them sufficiently (ie: exclusion zones), lack of in-house professional review of submitted documentation or analysis for accuracy (ie: hydrology).

For these reasons, I support the Board of Supervisors approving Appeal AB 24-02 and overturning the Planning Commission's decision on May 23, 2024.

Thank you for your consideration.

My Wife and I live at 7000 Highland Springs Road, and I am writing in support of the Appeal (AB24-02) for Highland Farms, LP (UP20-96). We feel that the Planning Commission’s March 23rd, 2024 Approval of the Major Use Permit was done without the applicant completing essential elements of the application.
A Project of this magnitude requires the completion of a full California Environmental Quality Assessment(CEQA), which would reveal several deficiencies in the application. Instead of a full CEQA, the Community Development Department required only a “planning checklist,” and was only completed for the area of the grow(s) and support buildings. A full CEQA would address many additional issues, such as access, traffic, road conditions and endangered species during a wet period, rather than only during the drought periods the applicant’s agents conducted their examinations.
Highland Springs Road is an uncontrolled, no posted speed limit road. It is NOT regularly patrolled by either the Sheriff’s Office or California Highway Patrol. Highland Springs Road was not listed on the County’s Ten-Year Paving Rehabilitation Plan, and is in poor condition. There have been multiple accidents related to speed and/or intoxication on Highland Springs Road, especially on the sharp, narrow, blind curves South of Bell Hill Road. On most weekends, traffic is heavy with many cars, trucks with trailers and bicycles going to and from Highland Springs Reservoir. Several of the curves are not negotiable by larger, longer vehicles without using more than one lane of the road on those blind corners. The park itself is used by many people year-round for riding, hiking, fishing, equestrian, and family events, as well as special events authorized by the Watershed Protection District.
The Applicant’s agent also states there is no serpentine geology within the proposed area. Serpentine rock formations have significant deposits of asbestos. However, several species known to grow in serpentine soils have been noted. The area examined also did not evaluate the proposed 7,500 foot long access road, where several seams of serpentine can be observed, especially where the proposed access road meets Highland Springs Road.
The application also references several sites where culverts will be required, but does not make any mention of the proposed 7,500 foot long access road, or the intersection at Highland Springs Road. Any run-off will flow directly across Highland Springs Road.