Date: June 12, 2025
To: The Honorable Lake County Planning Commission
From: Peggie King, Environmental Professional, Kelseyville
Subject: Consideration of Summary of Cannabis Policy Recommendations
and Request for Planning Commission Recommendation(s)
I have worked in the environmental field for about 30 years. Partly as a Lake County
employee (12+years) and in the private sector for a few large corporations. Most of
my work has been in California, where I specialize in understanding and advising on
complex environmental regulations with an emphasis on water resources. I worked
in cannabis for a former grower and processor in Lake County for about 8 months
and am familiar with the business and environmental issues.
I would like the Planning Commission and subsequently the Board of Supervisors to
consider including the following bullet points in the subject discussion item, if
possible, to address a few environmental concerns related to water resources.
Below is a very brief list of concerns:
Be aware of the Sustainable Groundwater Management Act (SGMA) and
potential future consequences of overdraft in groundwater basins that are
not presently on the high priority list, yet could be in the future if the water
resources are not carefully considered and managed. SGMA requires local
agencies to address undesirable impacts of over pumping to bring
groundwater basins into balance. The Big Valley Groundwater Basin is
currently the only basin that is regulated by SGMA and maybe it is very costly
to the county and citizens.
The county policies/ordinance should address the current required
Hydrology Reports to be consistent and include a minimum amount of
information, perhaps a report template could be provided to the project
proponent. The Hydrology Reports need to be accurate, clear, concise and
fact based. Stating that a cannabis plant uses as much water as a tomato
plant is vague and does not quantify the use based on factual evidence, as it
should, in order to demonstrate sustainability. Groundwater well pump
times should be conducted for 24 consecutive hours to accurately reflect the
drawdown and recovery of the well. In some areas, well production is very
low (e.g., 10 gpm) and that may necessitate around the clock watering for a
commercial grow.
Groundwater wells close to creeks/streams could be considered under the
influence of surface water. Surface water includes all groundwater sources
that are deemed to be under the influence of surface water such as springs,
shallow wells, and wells close to rivers. This condition needs to be better
understood with regards to water rights and regulated waterways such as
Putah Creek and particularly with regards to groundwater recharge. In
California, groundwater wells that are influenced by surface water may
require a water right from the State Water Resources Control Board
depending on the specific circumstances and well location. This is a complex
issue that does not appear to be well understood within the Hydrology
Reports that I have read associated with proposed cannabis projects.
Before the Cannabis Task Force disbanded, CDD said that community concerns would be addressed. This has not happened. The public should be allowed to offer facts that are of importance. Of these mitigation measures, site inspections, background checks, odors, lighting, traffic, numbers of projects and size, biological resources, noise, cultural resources, fire, soil, sedimentation, hitch protection, lake health and more need to be addressed. Public input, then Board of Supervisor input, then Ag Committee input, and then it could come before to the Planning Commissioners should be the path bringing this ordinance forward.
Date: June 12, 2025
To: The Honorable Lake County Planning Commission
From: Peggie King, Environmental Professional, Kelseyville
Subject: Consideration of Summary of Cannabis Policy Recommendations
and Request for Planning Commission Recommendation(s)
I have worked in the environmental field for about 30 years. Partly as a Lake County
employee (12+years) and in the private sector for a few large corporations. Most of
my work has been in California, where I specialize in understanding and advising on
complex environmental regulations with an emphasis on water resources. I worked
in cannabis for a former grower and processor in Lake County for about 8 months
and am familiar with the business and environmental issues.
I would like the Planning Commission and subsequently the Board of Supervisors to
consider including the following bullet points in the subject discussion item, if
possible, to address a few environmental concerns related to water resources.
Below is a very brief list of concerns:
Be aware of the Sustainable Groundwater Management Act (SGMA) and
potential future consequences of overdraft in groundwater basins that are
not presently on the high priority list, yet could be in the future if the water
resources are not carefully considered and managed. SGMA requires local
agencies to address undesirable impacts of over pumping to bring
groundwater basins into balance. The Big Valley Groundwater Basin is
currently the only basin that is regulated by SGMA and maybe it is very costly
to the county and citizens.
The county policies/ordinance should address the current required
Hydrology Reports to be consistent and include a minimum amount of
information, perhaps a report template could be provided to the project
proponent. The Hydrology Reports need to be accurate, clear, concise and
fact based. Stating that a cannabis plant uses as much water as a tomato
plant is vague and does not quantify the use based on factual evidence, as it
should, in order to demonstrate sustainability. Groundwater well pump
times should be conducted for 24 consecutive hours to accurately reflect the
drawdown and recovery of the well. In some areas, well production is very
low (e.g., 10 gpm) and that may necessitate around the clock watering for a
commercial grow.
Groundwater wells close to creeks/streams could be considered under the
influence of surface water. Surface water includes all groundwater sources
that are deemed to be under the influence of surface water such as springs,
shallow wells, and wells close to rivers. This condition needs to be better
understood with regards to water rights and regulated waterways such as
Putah Creek and particularly with regards to groundwater recharge. In
California, groundwater wells that are influenced by surface water may
require a water right from the State Water Resources Control Board
depending on the specific circumstances and well location. This is a complex
issue that does not appear to be well understood within the Hydrology
Reports that I have read associated with proposed cannabis projects.
Before the Cannabis Task Force disbanded, CDD said that community concerns would be addressed. This has not happened. The public should be allowed to offer facts that are of importance. Of these mitigation measures, site inspections, background checks, odors, lighting, traffic, numbers of projects and size, biological resources, noise, cultural resources, fire, soil, sedimentation, hitch protection, lake health and more need to be addressed. Public input, then Board of Supervisor input, then Ag Committee input, and then it could come before to the Planning Commissioners should be the path bringing this ordinance forward.