6b 26-06159:20 AM - Consideration of proposed Major Use Permit PL-26-115 (UP 21-17), Seigler Springs North LLC/ Forest Ellie, and Mitigated Negative Declaration PL-26-115 (IS 21-18), for the approval of no more than 130,680 square feet (sf) of commercial cannabis cultivation and a Type 13 Distribution, self-transport license located at 11615 and 11625 Seigler Springs North Road, Kelseyville (APNs 115-007-03 and 115-007-06).
Increased truck traffic, dust, noise, and road impacts along both Seigler Springs North Road and Loch Lomond Road • Negative effects of water usage on Seigler Canyon Creek which runs through Mountain Of Attention Sanctuary • Negative effect on retreats and neighboring homes • Inadequacy of environmental review under CEQA • Failure to address fire prevention and suppression • Negative effect of tree removal at a time when tree mortality due to water stress, bark beetle, new Mediterranean oak bore beetle, and Sudden Oak Death syndrome.
Date: June 9, 2026
From: Magdalena Valderrama Hurwitz, Chair
Seigler Springs Firewise Community
To: Lake County Planning Commission
RE: Major Use Permit PL-26-115 (UP 21-17) / Seigler Springs North
Subject: Formal Objection to Mitigated Negative Declaration and Adequacy of Fire Protection and Noise Findings
Dear Commissioners,
I am writing on behalf of the Seigler Springs Firewise Community to formally object to the proposed approval of Major Use Permit PL-26-115. The two parcels under review (11615 and 11625 Seigler Springs North Road) sit squarely within our recognized Firewise boundary. While the Revised Initial Study attempts to address prior deficiencies, it remains fundamentally flawed. It fails to account for the cumulative noise load in our unique topography, provides an unstable project description regarding habitat and fire mitigation, and relies on unverified fire safety assurances that do not reflect the reality of our evacuation corridors.
1. Failure to Address Cumulative Acoustic Impacts and the "Amphitheater" Effect
The Revised Initial Study relies on standard noise thresholds (NOI-2) that are fundamentally divorced from the physical reality of our geography. These standards are designed for flat, open ground where sound dissipates predictably over distance. This is a scientific error when applied to the Seigler Springs basin, which functions as a natural acoustic amphitheater. The topography of our region causes low-frequency mechanical noise—specifically the industrial drone of high-velocity ventilation fans and motorized tarp-pulling systems required for the proposed light-deprivation hoophouses—to travel, reflect, and intensify as it focuses downward into our residential pockets.
Furthermore, this analysis fails to account for the cumulative industrial load already imposed by the massive Pasta Farms expansion. Under the California Environmental Quality Act (CEQA), the County is legally mandated to evaluate this permit within the context of the existing industrial baseline; ignoring the current noise floor to find this project's impacts "less than significant" is a fundamental procedural error. By failing to model how our specific basin geometry compounds this industrial drone, the analysis remains scientifically incomplete. It treats this permit in a vacuum, ignoring the reality that residents over a mile away are subjected to a constant, compounded mechanical hum that shatters the rural ambient baseline. Because the current finding ignores both the physics of our local topography and the mandatory cumulative context of the existing industrial baseline, it is legally and factually insufficient.
2. Procedural and Scientific Inadequacies
The Revised Initial Study fails to provide a "stable project description," a fundamental requirement of CEQA. We have identified critical inconsistencies that demonstrate a fragmented and unreliable environmental review:
a) Conflicting Fire Suppression Specifications: The Revised Initial Study fails to provide a stable project description, a fundamental CEQA mandate. The document contains critical internal inconsistencies regarding fire protection infrastructure, simultaneously listing "six 5,000-gallon water tanks" and a separate "5,000-gallon fire suppression tank." This creates an unresolved ambiguity: it is unclear whether the applicant commits to a total of six tanks (where one serves fire) or seven tanks (six for cultivation plus an additional fire tank). Furthermore, the site plan (Figure 1 on page 3) only labels the six cultivation tanks, creating an ambiguity that leaves the fire suppression infrastructure "hidden" or potentially conflated with the cultivation storage in the site plan and the text does not clarify if the fire suppression tank is a separate physical unit or if it is being double-counted as one of the six storage tanks. This operational uncertainty renders the Commission unable to make a valid finding of "adequacy," as the baseline infrastructure required for fire suppression is demonstrably ill-defined.
b) Contradictory Habitat Mitigation: The proposed mitigation strategy for the removal of 76 mature Black Oak trees relies on a speculative planting plan that lacks essential scientific validation. Specifically:
i. Lack of Baseline Metrics: The Revised Initial Study fails to provide a projected survival rate for the 327 saplings, nor does it define the timeline for these saplings to reach functional maturity. Relying on an unquantified planting plan without a guaranteed survival threshold renders the mitigation unenforceable and ecologically insufficient.
ii. Conflicting Regulatory Requirements: The project simultaneously demands the protection of saplings while explicitly prohibiting deer fencing under Mitigation Measure BIO-1 to protect "wildlife passage." The County provides no evidence that these saplings can survive without protection in a high-browsing environment, creating a fundamental conflict that guarantees a high failure rate for the proposed replacement canopy. This "plant-and-abandon" approach fails to mitigate the immediate loss of mature, fire-resilient habitat.
iii. Insufficient Evacuation Analysis and Omission of Local Operational Jurisdiction
The Revised Initial Study treats evacuation as a perfunctory, "box-ticking" exercise. Rather than engaging in a rigorous analysis of site-specific emergency response, the document relies on a broad, superficial application of CAL FIRE oversight, effectively blurring the lines of local accountability. By defaulting to this state-level designation, the County has avoided the critical work of confirming actual jurisdictional coverage and operational coordination with the South Lake Fire Protection District (SLFPD).
This failure to identify the specific agency responsible for day-to-day emergency response in this "Very High Fire Hazard Severity Zone" represents a fundamental gap in environmental review.
We demand proof of formal, project-specific coordination with the SLFPD, specifically requiring evidence that they have:
1) Reviewed and explicitly approved the projected traffic load for Seigler Springs North Road during an active emergency; and
2) Verified that this constrained corridor can handle the simultaneous egress of residents alongside industrial workforce and any distribution traffic during a fire event.
Without agency-vetted, site-specific analysis, the current plan remains an unverified operational assumption rather than a proven safety measure.
Action Requested
The Planning Commission cannot legally determine that impacts are "less than significant" while ignoring the compounding nature of these projects. We request that the Commission deny or continue this permit until:
1. A Cumulative Acoustic Study is conducted that includes the operational mechanical noise profile of the entire basin, accounting for the existing noise from Pasta Farms and the amplification characteristics of the Seigler Springs topography.
2. A Site-Specific Evacuation Flow Analysis is produced, accounting for workforce traffic egress during high-fire-risk weather events, and verified by the South Lake Fire Protection District (SLFPD).
3. The applicant provides verified, singular specifications for all fire suppression infrastructure, correcting the internal inconsistencies regarding water tank capacity and the ability to implement its use.
Increased truck traffic, dust, noise, and road impacts along both Seigler Springs North Road and Loch Lomond Road • Negative effects of water usage on Seigler Canyon Creek which runs through Mountain Of Attention Sanctuary • Negative effect on retreats and neighboring homes • Inadequacy of environmental review under CEQA • Failure to address fire prevention and suppression • Negative effect of tree removal at a time when tree mortality due to water stress, bark beetle, new Mediterranean oak bore beetle, and Sudden Oak Death syndrome.
Date: June 9, 2026
From: Magdalena Valderrama Hurwitz, Chair
Seigler Springs Firewise Community
To: Lake County Planning Commission
RE: Major Use Permit PL-26-115 (UP 21-17) / Seigler Springs North
Subject: Formal Objection to Mitigated Negative Declaration and Adequacy of Fire Protection and Noise Findings
Dear Commissioners,
I am writing on behalf of the Seigler Springs Firewise Community to formally object to the proposed approval of Major Use Permit PL-26-115. The two parcels under review (11615 and 11625 Seigler Springs North Road) sit squarely within our recognized Firewise boundary. While the Revised Initial Study attempts to address prior deficiencies, it remains fundamentally flawed. It fails to account for the cumulative noise load in our unique topography, provides an unstable project description regarding habitat and fire mitigation, and relies on unverified fire safety assurances that do not reflect the reality of our evacuation corridors.
1. Failure to Address Cumulative Acoustic Impacts and the "Amphitheater" Effect
The Revised Initial Study relies on standard noise thresholds (NOI-2) that are fundamentally divorced from the physical reality of our geography. These standards are designed for flat, open ground where sound dissipates predictably over distance. This is a scientific error when applied to the Seigler Springs basin, which functions as a natural acoustic amphitheater. The topography of our region causes low-frequency mechanical noise—specifically the industrial drone of high-velocity ventilation fans and motorized tarp-pulling systems required for the proposed light-deprivation hoophouses—to travel, reflect, and intensify as it focuses downward into our residential pockets.
Furthermore, this analysis fails to account for the cumulative industrial load already imposed by the massive Pasta Farms expansion. Under the California Environmental Quality Act (CEQA), the County is legally mandated to evaluate this permit within the context of the existing industrial baseline; ignoring the current noise floor to find this project's impacts "less than significant" is a fundamental procedural error. By failing to model how our specific basin geometry compounds this industrial drone, the analysis remains scientifically incomplete. It treats this permit in a vacuum, ignoring the reality that residents over a mile away are subjected to a constant, compounded mechanical hum that shatters the rural ambient baseline. Because the current finding ignores both the physics of our local topography and the mandatory cumulative context of the existing industrial baseline, it is legally and factually insufficient.
2. Procedural and Scientific Inadequacies
The Revised Initial Study fails to provide a "stable project description," a fundamental requirement of CEQA. We have identified critical inconsistencies that demonstrate a fragmented and unreliable environmental review:
a) Conflicting Fire Suppression Specifications: The Revised Initial Study fails to provide a stable project description, a fundamental CEQA mandate. The document contains critical internal inconsistencies regarding fire protection infrastructure, simultaneously listing "six 5,000-gallon water tanks" and a separate "5,000-gallon fire suppression tank." This creates an unresolved ambiguity: it is unclear whether the applicant commits to a total of six tanks (where one serves fire) or seven tanks (six for cultivation plus an additional fire tank). Furthermore, the site plan (Figure 1 on page 3) only labels the six cultivation tanks, creating an ambiguity that leaves the fire suppression infrastructure "hidden" or potentially conflated with the cultivation storage in the site plan and the text does not clarify if the fire suppression tank is a separate physical unit or if it is being double-counted as one of the six storage tanks. This operational uncertainty renders the Commission unable to make a valid finding of "adequacy," as the baseline infrastructure required for fire suppression is demonstrably ill-defined.
b) Contradictory Habitat Mitigation: The proposed mitigation strategy for the removal of 76 mature Black Oak trees relies on a speculative planting plan that lacks essential scientific validation. Specifically:
i. Lack of Baseline Metrics: The Revised Initial Study fails to provide a projected survival rate for the 327 saplings, nor does it define the timeline for these saplings to reach functional maturity. Relying on an unquantified planting plan without a guaranteed survival threshold renders the mitigation unenforceable and ecologically insufficient.
ii. Conflicting Regulatory Requirements: The project simultaneously demands the protection of saplings while explicitly prohibiting deer fencing under Mitigation Measure BIO-1 to protect "wildlife passage." The County provides no evidence that these saplings can survive without protection in a high-browsing environment, creating a fundamental conflict that guarantees a high failure rate for the proposed replacement canopy. This "plant-and-abandon" approach fails to mitigate the immediate loss of mature, fire-resilient habitat.
iii. Insufficient Evacuation Analysis and Omission of Local Operational Jurisdiction
The Revised Initial Study treats evacuation as a perfunctory, "box-ticking" exercise. Rather than engaging in a rigorous analysis of site-specific emergency response, the document relies on a broad, superficial application of CAL FIRE oversight, effectively blurring the lines of local accountability. By defaulting to this state-level designation, the County has avoided the critical work of confirming actual jurisdictional coverage and operational coordination with the South Lake Fire Protection District (SLFPD).
This failure to identify the specific agency responsible for day-to-day emergency response in this "Very High Fire Hazard Severity Zone" represents a fundamental gap in environmental review.
We demand proof of formal, project-specific coordination with the SLFPD, specifically requiring evidence that they have:
1) Reviewed and explicitly approved the projected traffic load for Seigler Springs North Road during an active emergency; and
2) Verified that this constrained corridor can handle the simultaneous egress of residents alongside industrial workforce and any distribution traffic during a fire event.
Without agency-vetted, site-specific analysis, the current plan remains an unverified operational assumption rather than a proven safety measure.
Action Requested
The Planning Commission cannot legally determine that impacts are "less than significant" while ignoring the compounding nature of these projects. We request that the Commission deny or continue this permit until:
1. A Cumulative Acoustic Study is conducted that includes the operational mechanical noise profile of the entire basin, accounting for the existing noise from Pasta Farms and the amplification characteristics of the Seigler Springs topography.
2. A Site-Specific Evacuation Flow Analysis is produced, accounting for workforce traffic egress during high-fire-risk weather events, and verified by the South Lake Fire Protection District (SLFPD).
3. The applicant provides verified, singular specifications for all fire suppression infrastructure, correcting the internal inconsistencies regarding water tank capacity and the ability to implement its use.
Respectfully submitted
I'm concerned about water usage in an area that is prone to fire and drought.