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Subject: Slow down in MPF process because of CEQA reviews
UT 4.09.18 David Garrick
San Diego marijuana supply chain faces hurdles
(Online title - San Diego's climate action plan puts hitch in marijuana supply chain)
• Approval of pot farms and marijuana edible factories in San Diego is being delayed by environment hurdles.
• The city's climate action plan is forcing applicants to do greenhouse gas studies.
• A local supply chain would eliminate the need to truck marijuana in from elsewhere and help prevent a black
market.
San Diego may not have a local supply chain for its marijuana dispensaries as quickly as expected because of rigorous
city environmental approvals and other regulatory hurdles facing indoor pot farms and factories for edible
products. The 65 applicants seeking to open such businesses in San Diego are facing requirements for studies of their,
energy use, water consumption and greenhouse gas emissions in order to gauge their compliance with the city's
climate action plan.
The applicants are also unsure what kind of lengthy reviews they might face under state environmental law because
city officials haven't decided whether to require comprehensive environmental impact reports or more cursory
analysis. Meanwhile, citizen -led community planning groups where the businesses will cluster — Mira Mesa and Otay
Mesa — have taken the unusual step of delaying their recommendations until all environmental analysis is complete.
City officials want the 18 legal dispensaries they've approved to have a local supply chain as soon as possible to
eliminate the need to truck marijuana in from elsewhere and to prevent a local "black market" of marijuana
producers. The businesses are expected to boost the local economy, create jobs and improve the quality and safety of
local marijuana, while also generating revenue for the city from its new 5 percent cannabis tax.
The city has agreed to allow three dozen local businesses already allowed to engage in cultivation and manufacturing
without formal city approval to continue operating through November 2019 before shutting down. But it's not clear
how many are actually producing marijuana, or how much of the marijuana products sold at local dispensaries they
supply.
When San Diego agreed last November to allow pot farms and edible factories, industry leaders said they expected the
approval process to be shorter than the 14 -month average for the dispensaries approved over the last few years. That
was primarily because the local marijuana industry had become more familiar with city development regulations and
had developed relationships with the city officials overseeing the process.
In addition, during the dispensary approvals the city revised and made easier to understand a series of requirements
that marijuana businesses be certain distances away from schools, parks, housing and other sensitive uses. But that
optimism has been tempered by the more rigorous environmental review and the decision by planning groups to take
a different approach than they did with dispensaries. In addition, some of the proposed businesses could get rejected
outright, instead of just being delayed.
"The city is making some requests that are different than with dispensaries," Kimberly Simms, one of the region's
leading marijuana attorneys, said by phone last week. "I think approvals will take longer because they are asking for
more." The greenhouse gas emissions studies, which cost about $25,000 each, have played a key role in delaying
applications for marijuana production businesses, partly because such analysis is a relatively new process.
"You need to analyze whether this project uses more gas and power than what was there before," Jessica McElfresh,
another marijuana attorney, said by phone. "We've had to hire firms to do these reviews."
San Diego's climate action plan, which was adopted in 2015, commits the city to slashing its greenhouse gas emissions
15 percent below 2010 levels by 2020 and 50 percent below that benchmark by 2035.
State law. The greenhouse gas studies and other requirements under the climate action plan are also delaying a city
decision on how to handle approval of the marijuana producers under state environmental law, McElfresh said.
Dispensaries were deemed exempt under the law, the California Environmental Quality Act, but city officials won't
decide whether to grant the same exemptions to marijuana producers until they see the greenhouse gas studies.
If not, the pot farms and edible factories could have to analyze their impact on traffic, water and other parts of the
surrounding environment with either a mitigated negative declaration or a more intense environmental impact
report. McElfresh noted that many cities and counties around the state, including Chula Vista last month, built
CEQA exemptions into their decisions to allow marijuana production businesses.
A city spokesman declined to say what factors will determine what type of CEQA analysis is required for each project,
or to say when those determinations will take place. "The timing of the determination depends on the project scope,
and features and setting," wrote the spokesman, Scott Robinson. "Furthermore, sometimes additional information is
needed to be able to analyze the project for potentially significant impacts."
Local groups. The environmental requirements have prompted community planning groups in Mira Mesa and Otay
Mesa, where 30 of the 65 proposed businesses would be located, to change their approach to making recommendations
on the projects. "We decided as a group we didn't want to hear any of them until they've done their full
environmental with the city, which is usually the last thing done with the city," said Rob Hixson, chairman of the Otay
Mesa Planning Group, by phone last week.
That approach will require applicants to schedule hearings, make presentations and receive planning group
recommendations near the end of the process instead of near the beginning. "Usually we like to give input on what a
development will look like before somebody designs the whole thing, but because most of these facilities are going to be
in existing industrial buildings we thought this would be a better way to go about it," said Hixson, whose community is
considering 12 proposed marijuana production businesses.
In Mira Mesa, the planning group has asked the 18 applicants to make two presentations: one at the beginning of the
process and another once the environmental work is done. "By that time, we'll have all the comments back from the
city and whatever environmental document the city decides that they need," said Jeff Stevens, chairman of the Mira
Mesa Community Planning Group, by phone last week. Stevens said during the initial presentations over the winter
that some additional concerns came up.
One applicant is jeopardizing the building insurance for other tenants of the same property because insurers are
reluctant to do business with marijuana producers. Another would be located near the Miramar Caf6 on Miramar
Road, possibly damaging the restaurant's business if strong odors emanate from the production facility. The city's
ordinance requires that marijuana production businesses have "odor -absorbing ventilation and exhaust systems," but
it's unclear how the city will handle such businesses if there is odor anyway.
The planning groups play only an advisory role when they make recommendations on projects. But even when
projects get approved despite their objections, their comments can prompt the addition of new requirements such as
more parking spots or relocated entrances.
Stevens said he is unsure how many of the proposed marijuana production facilities his group will endorse. "We're
working to make sure the ones that go in do not have negative side effects," he said. "1 think what we're looking for is
that they don't cause problems for their neighbors, they don't emit odors and they satisfy environmental
requirements. If they're basically not a bother to anyone, then they'll probably go through."
McElfresh, one of the marijuana attorneys, said despite the additional requirements, she doesn't believe city officials
are singling out the controversial marijuana industry for extra scrutiny. She compared the climate action plan's role
in the process to when accessibility requirements under the Americans with Disabilities Act were a new thing cities
had to deal with during project approvals. "This is a use the city's never processed before and the climate action plan
is new," she said. "It doesn't mean we are being treated unfairly."
While the city is processing 65 applications for marijuana production businesses, the city law includes a cap of 40 total
in San Diego, so the first 40 that get final approval will be allowed to operate.