There have been several cannabis projects approved by the County of Lake in the Ogulin Canyon watershed. I was the real estate broker that sold almost every one of these, and water availability was of the utmost importance. I was present when wells were tested up and down Ogulin Canyon, and the wells on this property were some of the strongest. I have also been present when wells were tested on properties in Burns Valley and arranged for lab testing on them. The Ogulin Canyon wells are deeper, have much better GPM and much better water quality. The aquifers appear to be completely different from my experience. I find it hard to believe the mineral content in an aquifer can change so dramatically in just a couple of miles.
The subject property was a very successful hops farm. The wells used for this crop easily produced enough water for it. The best well on the property was not even used, it had been drilled and capped with no pump installed. Since hops are a close crop to cannabis (hops smell just like cannabis if you crush the flower) this seemed like a perfect location for a cannabis farm. Acres of land were already cleared, in crop cultivation, with deer fencing already installed. The project was Early Activated when the Use Permit was applied for, but the tenant at the time hired a project manager that totally ignored the restrictions under Early Activation and committed several serious violations. Early Activation was rightfully revoked by the County and the tenants lost their investment. These people should have never tried to participate in the cannabis industry. They knew nothing about it and definitely hired the wrong project manager. Since then the current owners of the property have been taking the blame for the sins of their former tenant.
I attended both the Planning Commission hearing when the Use Permit was approved and the Supervisors meeting when it was lost to the appeal. It was my impression that the BOS were still upset over the actions of the tenant and took it out on the owners. I felt the same way to a certain extent, an owner is responsible for a property and should control a tenant. Especially in the case of an Early Activated Use Permit. The shortcomings of the people involved don't change the fact that this particular property, given its location to other cannabis projects, the bountiful aquifer it sits on, and successful past agricultural use, is an excellent location for a cannabis project.
If this project was operating it would be generating tax revenue and providing local jobs. Instead, it sits fallow and neglected. Opponents of this are using water as their main concern, just as they did with the other 6 or more cannabis projects in the canyon. None of this has ever proven to be true, but if you want to pay a consultant enough money I guess they can generate a report to your liking. As I said before, I attended the previous meetings and feel that the last Use Permit was lost due to personal reasons rather than factual reasons. This is a good project and I hope the Planning Commission will approve it so this property can live up to its full potential.

Please consider several key issues that are central to your decision today for UP 23-10. Based on a review of the project record it does not appear that new, recent (within a couple of years) comprehensive biological or floristic field surveys have been conducted. I respectfully ask that you consider the following: None of the environmental documents for this project evaluate the presence or potential impacts of Mediterranean Oak Borer (MOB)—an invasive pest that is contributing to increasing oak mortality in Lake County. Implications of this omission include Oak woodland mitigation assumptions (such as replacement ratios) may not be reliable. Long-term survival of replacement plantings is uncertain. Loss of mature canopy is not adequately offset. Current baseline conditions affecting oak health are not reflected This omission represents a failure to incorporate current environmental stressors into the CEQA baseline. Relevant CEQA provisions include: CEQA Guidelines §15125 – Baseline must reflect existing environmental conditions CEQA Guidelines §15064 – A “fair argument” requires preparation of an EIR when substantial evidence exists CEQA Guidelines §15064(h) Cumulative impacts must be evaluated Reliance on outdated data, combined with the absence of recent multi-seasonal biological studies and the failure to incorporate emerging environmental threats such as Mediterranean Oak Borer, raises serious questions about the adequacy of the environmental review. Please consider that the draft Cannabis Ordinance, draft Local Area Plans, and the draft General Plan 2050 are all currently under review and may have direct relevance to decisions being made today. Additionally, the current analysis relies on earlier survey work and continues to depend on pre-construction surveys to determine the presence of special-status species. This approach indicates that the biological baseline may not fully reflect current site conditions. This is particularly important because the site consists of native habitats. The reports acknowledge the presence of suitable habitat Given that additional environmental review was previously determined to be warranted, ensuring that the biological baseline reflects current conditions -including invasive pasts to oaks, is especially important in this case. Without updated surveys, it is difficult to fully evaluate potential impacts prior to project approval. It might be helpful to review the 2022 Clearlake appeal comments by residents for this project, also. Thank you for your time and consideration.