February 20, 2019

Santa Barbara County Board of Supervisors

c/o Planning and Development, Hearing Support

123 East Anapamu Street

Santa Barbara, CA 93101

RE: Hoop Structures Ordinance Amendment

County Board of Supervisors Hearing on March 12, 2019

Dear Supervisors:

We are collectively writing to you regarding the proposed Hoop Structure Ordinance Amendment. Hoop and shade structures are an important tool for the cultivation of specialty crops in Santa Barbara County, particularly berries and more recently, cannabis.

Hoop houses offer numerous benefits to the environment, the community, and to farmers by:

• Reducing water use;

• Extending the growing season for frost-sensitive crops;

• Protecting crops from inclement weather;

• Protecting crops from toxic overspray from neighboring farms;

• Reducing the presence of mold; and

• Decreasing the use of pesticides by providing a barrier to insects.

We are extremely concerned about the Planning Commission’s proposed changes to the Hoop Structure Ordinance Amendment, namely reincorporating the 4,000 square foot size limitation on all hoop and shade structures located within the Santa Ynez Valley Community Plan Design Control Overlay. A 4,000 square foot limit (1/10th of an acre) is essentially a prohibition, as no commercial farmer, cannabis cultivator or otherwise, would ever reap any benefit from such a small cultivated area.

There are approximately 290 agriculturally zoned parcels located within the Design Control Overlay in the Santa Ynez Valley, comprising approximately 8,311 acres. Effectively prohibiting the use of hoop and shade structures on over 8,000 acres of agriculturally zoned prime farmland in the Santa Ynez Valley is unprecedented, and if implemented, will result in undue hardship on numerous cultivators in the Valley.

The proposed permit path for landowners within the Design Overlay, a Development Plan and compliance with California Environmental Quality Act (CEQA), is not an option for cannabis farmers who have already spent hundreds of thousands of dollars applying for local County land use permits and complying with numerous state regulations. Obtaining a Development Plan is not appropriate for a temporary farm accessary, and will result in an additional yearlong delay. CEQA has already been completed via the County’s PEIR. Requiring additional compliance amounts to double jeopardy.

By placing visual benefits and impacts over and above the vitality and feasibility of agricultural businesses, the Commission is placing a heavy burden on the shoulders of those of us who have chosen to grow berries and cannabis, invest in Santa Barbara County (or ancillary cannabis businesses), comply with the numerous regulations, and pay our taxes. There is no question that this amendment would severely restrict the freedom of growers and the burgeoning cannabis industry, and, for some of us, limiting hoop houses to 4,000 square feet per lot or requiring a Final Development Plan before installing hoops, would destroy our business entirely.

Given the profound impacts this regulation will have on the County’s agricultural industry, we believe that the Commission should reject the onerous restrictions on hoops within the Design Overlay, and instead exempt from permitting all hoops and shade structures in the County that are under 20 feet in height and comply with the development standards (no lighting, no permanent footings, compliance with setbacks, etc.).

Thank you for your attention to this matter.

Sincerely,