April 22, 2021
Humboldt County Planning Commission 3015 H Street
Eureka CA 95501
SENT VIA EMAIL TO: [email protected]
Re: Arcata Land Company, LLC Commercial Cannabis Project Application No. 12255
Dear Humboldt County Planning Commission:
The City of Arcata is writing this letter in response to the overwhelming public comment received from Arcata constituents. The Arcata City Council requests that Humboldt County give very thorough and transparent review of the cannabis project proposed by the Arcata Land Co. Many in the community believe this project has a strong likelihood of causing health, safety and nuisance (noise, odor etc) impacts to neighboring residents, schools and businesses. The City Council understands that the Planning Commission will need to make findings under the California Environmental Quality Act, as well as the County zoning and General Plan. The Council is requesting the Humboldt Planning Commission specifically deliberate and ensure your findings address the matters raised here.
The City appreciates that the project includes a minimum 600-foot setback from the city limits and Ennes Park expansion parcel western boundary. But for a project of this size and proximity to a residential center, the Planning Commission should consider whether larger setbacks are appropriate. This new eight-acre grow will be near homes, schools, and parks. The project lies on lands within county jurisdiction; however, impacts from the project will largely be borne by residents of Arcata living in the Westwood neighborhood. Concerns of noise, light, and odor pollution have been raised. Residents report that they chose to live in the neighborhood because of the rural ambiance and peace of the quiet farmlands of the Arcata bottom. Those who have studied the reports have raised concerns that these impacts will not be mitigated. The City Council requests careful consideration of these factors during your project review. Specifically, please consider whether the setbacks from adjacent residential and other uses will provide appropriate buffers for any incompatible or conflicting uses and if the size of the project will be a detriment to our agriculture lands and undermine the small, craft cannabis community Arcata and Humboldt County has been growing for decades.
Several residents have confirmed health conditions specifically susceptible to worsen from air contaminants and heavy odors. There are schools in close proximity to the project and a long-term healthcare facility proposed directly adjacent to the project.
The City recognizes that the project proposes odor control via charcoal filters and outlines a secondary option if additional odor control is necessary. It is unlikely that the project will be able to control odor 100%, based on experience from other greenhouse growing operations countywide. While odors are part of allowable uses under the heavy industrial zoning and past uses on the site have produced odors, the City requests that the size of the project be scaled to ensure, that odors will be controlled and that there are satisfactory enforcement conditions to implement if needed.
This project will lie in the middle of prime agricultural land and the beautiful Western Greenbelt of Arcata. Although the project is outside of the current coastal zone boundary it is very close to the coast, sits in a low-lying coastal region vulnerable to early effects of climate change and sea level rise. There remains many questions from the public about the source of water for the project, as well as runoff and the use of pesticides in the area. The City notes that the current analysis proposes water from an existing well. The review documents also note a potential secondary potable water source from the City of Arcata’s domestic water system. The City is unable to provide new service outside the City limits or expand service to the Sun Valley current site to provide this water source. Since the City will not be providing water to the project, we encourage your Commission to ensure that the project’s water needs can be satisfied with on-site wells without deleterious impacts to groundwater.
The size of the proposed project is not consistent with current land use in the bottom and will turn beautiful pastoral scenery into an industrial landscape. The approval of this project could also open the door and set a standard for future development of this area and demonstrate a pathway for more oversized, heavy impact operations, of which several appear to be on the verge of making application.
The project will convert several acres of current open space to covered greenhouses with controlled lighting. The prepared analysis states that the project is designed with dark sky compliant lighting and that all of the outdoor lighting will be low lumens and shielded. The hoop houses will have blackout plastic or other screening. Local experience with controlled lighting hoop houses demonstrate the difficulty of containing light. The project should be conditioned in such a way that the County retains regulatory authority to enforce against offsite glare.
The City encourages the Planning Commission to consider all measures possible to reduce greenhouse gas emissions from this project including requirements for solar offset; increased and weather secure employee bicycle parking, continuing the Class 1 Bicycle trail along Foster Ave, and pedestrian and bicycle easements along 27th Street.
The project will have ongoing impacts to Foster Avenue and City of Arcata roads that are analyzed in the traffic impact study. The City requests that if the project is approved that it be conditioned to fund a portion of the ongoing maintenance of Foster Ave and 27th Street.
The City recognizes this could be directly from the applicant or potentially through the Measure S tax generated by this project.
In closing, the City wants to emphasize that many City/County residents have raised valid and significant concerns regarding the depth and breadth of the environmental analysis and the ability of the project to mitigate neighborhood impacts. Additionally please consider the cumulative impacts of potential and future projects in the neighborhood. If you find that the cumulative impacts are not fully mitigated, an Environmental Impact Report (EIR) should be considered.
Public members have noted that the EIR adopted for the County’s cannabis regulation acknowledged that GHG and Air Quality impacts had a cumulatively considerable and significant impact that could not be fully mitigated. Please closely evaluate the process and the studies that indicate that all impacts have been identified, analyzed and addressed fully through mitigation.
Thank you for your careful review and attention to local concerns. Sincerely,
Sofia Pereira, Mayor
City of Arcata