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HomeMy WebLinkAbout2.0 Staff Report PC 09.14.16Land Use and Development Code Text Amendment Planning Commission - Staff Report Exhibits Applicant is the Garfield County Board of County Commissioners September 1 4,2016 (Fi le TXTP-07 -1 6-847 3) Exhibit Number Exhibit Description 1 Public Hearinq Notice lnformation 2 Proof of Publication 3 Garfield Countv Land Use and Development Code, as amended 4 Garfield Countv Comprehensive Plan of 2030 5 Application 6 Staff Report 7 Referral Comments f rom the Town of Parachute, dated August 16, 2016 8 Referral Comments from Colorado River Fire Rescue, dated September 6, 2016 I 1o TYPE OF REVIEW:Text Amendment to the Garfield County Land Use and Development Code Marijuana Grow Operations in Garfield County - Regulation of Marijuana Personal Use, Medical Use, and Caregivers in Garfield County rxTP-o7-1,6-8473 Board of County Commissioners September L4,201.6 - Planning Commission FILE NUMBER: APPLICANT: DATE: I. PROPOSAT DESCRIPTION BOARD OF COUNTY COMMISSIONERS DIRECTION On July t8, 20t6, the Community Development Department held a Public Meeting with the Board of County Commissioners (Board) concerning the proliferation of marijuana grow operations in Garfield County as a result of legal personal use, medical use and caregiver grows authorized by Amendment 64 of the Colorado Constitution. At this Meeting, the Board directed Staff to begin to process a Text Amendment to the Land Use and Development Code of 2073, as amended (LUDC) with the Board as the Applicant to codify Standards for Marijuana Personal Use, Medical Use, and Caregivers within Garfield County. These Standards are to address nuisance, health and safety issues related an individual's rights to grow marijuana for personal and medical use under the State Constitution. BACKGROUND Since the passage of Amendment 20 and Amendment 64, Garfield County has seen and experienced a proliferation of personal marijuana grow operations. Many of these grow-ops are inside residential homes but many are also large scale outdoor grow operations and greenhouses. Currently under the County's land use regulations, the County only has the ability to regulate the grow operations related to Operation Premise Cultivation Operations ("OPCOs"), as defined by the County's Land Use and Development Code. The County's current code (Section 7-903) regulates OPCOs, but not Caregiver facilities or personal grows. This Section states, it "will not be construed to apply to the private cultivation of Medical Marijuana by a registered patient or primary caregiver as defined in Article XVlll, Section 1.4, of the Colorado Constitution." Simply put, this means that medical marijuana growers, caregivers, and recreational growers are not currently regulated through Garfield County's local land use regulations. Since most greenhouse structures are considered exempt from the County's adopted Building Code, these types of growing facilities are not subject to the County's building code provisions and associated perm itting. The State Department of Public Health and Environment, and law enforcement agencies are tasked with enforcing state laws, rules, and regulations governing personal medical and recreational marijuana. However, since the legalization of marijuana the County has learned that these agencies have little to no ability to control the growing of personal marijuana because of the various nuances in the law. For instance, Article XVlll, Section 14 of the Colorado Constitution authorizes medical marijuana patients to possess no more than six plants and no more than two ounces of marijuana, however if medically llPage necessary, a patient may possess more than 6 plants. There are medical marijuana patients in Garfield County with extended plant count prescriptions of 99 plants. Unlike recreational marijuana, growing of medical marijuana is not limited to enclosed, locked space. Therefore and for example, two medical marijuana users each with medical cards for 99 plants, living in the same household, may legally grow 198 plants outdoors. Amendment 20 specifically provides that a person shall not grow marijuana plants in public, however there is no sanction or penalty written into the law for growing plants within view of the public, thus no way to enforce against persons who grow in public. lf a patient violates any of the provisions of the medical marijuana laws, such patient is subject to criminal charges, and CDPHE may revoke the patient's medical marijuana card for a period of one-year. Medical marijuana patients may designate a primary caregiver, and a caregiver may grow for up to 5 patients, unless they obtain a waiver from the state to grow for more. There are currently 17 people in Colorado who have a waiver to grow for more than 5 patients. Statutes require caregivers to register with CDPHE, provide their location, and keep copies of their patient's medical marijuana cards, however there are no criminal or other sanctions written into the law to punish those caregivers who fail to either register with CDPHE or provide their location. A caregiver may however be charged under the criminal statutes if they possess more plants than allowed under the law. For instance if a caregiver has the maximum of five patients, each authorized to have 6 medical plants, the caregiver may be charged with a crime if they possess more than 30 plants. A caregiver may live with other caregivers, thus it is possible for multiple caregivers to live in the same home and each grow up to 30 marijuana plants per person without a waiver from CDPHE. With respect to recreational marijuana, Article XVlll, Section 16, authorizes individuals to possess and grow six plants of marijuana for recreatlonal use, and to further assist another person 2L years or older in growing marijuana. The Colorado Attorney General's Office opined that the language "assisting another person" means a person can assist an unlimited number of individuals, not just one person. Therefore, an individual can grow up to six plants each for an unlimited number of other individuals so long as each additional individual is a resident of Colorado and is over the age of 2'J.. Under the current law, recreational marijuana must be grown in an enclosed locked space, not viewable by the public. Without zoning regulations, individuals can legally grow hundreds of plants in enclosed, locked space in Garfield County. No state agency has authority to enforce rules applicable to recreational marijuana growers and as a result, enforcement has fallen to local governments. ln the case of both medical and recreational marijuana, individuals exceeding legal plant counts are subject to criminal penalties; however, as evidenced in the above discussion, there are a variety of defenses available to both medical and recreational marijuana growers with large plant counts, and it is likely the person charged can present a defense to the crime. The County continues to receive frequent complaints regarding grow operations, ranging from those in residential areas that are growing within traditional single family homes to those growers with large open air grows and large greenhouses in the County's rural areas. Because these personal grow operations are legal, law enforcement can take no action. The Community Development Department has significant concerns with the size and scale, especially as they relate to potential issues regarding health, nuisance, and building safety. Among these concerns are the safety issues such as the growth of mold due to inadequate ventilation, accessibility to children and wildlife, impacts on land values, noxious odors, and those noted by the Building Division including structural issues, inadequate ventilation, excessive humidity in enclosed spaces which causes mold, and electrical issues associated with inadequate electrical wiring of larger enclosed personal grow operations. 2lPage PERSONAT USE MARTJUANA (AKA RECREATTONAL) According to Amendment 64, codified in the Colorado Constitution Article XVlll, Section 16, Personal Use and Regulation of Marijuana, an individual has a right to grow up to 6 plants (3 flowering, 3 in the vegetative state). Amendment 64 further allows an individual over the age of 21 to assist another Colorado residents over the age of 21 in growing up to six plants. The County's land use code is silent on the growing of recreational marijuana. Because the Colorado Attorney General's Office has interpreted the language "assisting another" to include more than just one additional person, and there have been no further amendments to this language orcontrarycase law, it is possibleforan individualto legallygrowan unlimited number of recreational marijuana plants as long as those plants are for the purpose of "assisting another" person. This has resulted, we believe, in recreational grow operations serving more than just two people, sometimes in a cooperative scenario, and therefore having the propensity to become quite large in scale. MEDICAL MARIJUANA CAREGIVER According to Amendment 20, codified in Article XVlll of the Colorado Constitution, Section 14, Medical Use of Marijuana for Persons Suffering from Debilitating Medical Conditions, a Primary Care-Giver ("Caregiver") is defined as "a person, other than the patient and the patient's physician, who is eighteen years of age or older and has significant responsibility for managing the well-being of a patient who has a debilitating medical condition." The Colorado Department of Public Health and Environment restricts Caregivers to 5 patients unless a Caregiver's Patient Limit Waiver is applied for and approved. Each patient may have 6 plants each (3 flowering, 3 in the vegetative state). Without a waiver, a Caregiver can have up to 30 plants. With a waiver of the patient cap the Caregiver can have additional patients -thus additional plants. ln addition, there are doctors who will "prescribe" additional plants for a particular patient stating "patient x must have 30 plants for her debilitating pain." ln some known cases, the Caregiver's grow has easily exceeded 100 plants. The County's land use code is silent on the growing of medical marijuana. We are now aware that patients frequently have medical cards authorizing them to have far in excess of 6 plants. Therefore, the County is seeing large scale medical marijuana open air grows in the County that claim to be caregiver facilities. II. STAFF ANALYSIS. LUDC CRITERIA FOR A TEXT AMENDMENT Section 4-114 outlines the procedures and criteria for consideration of a Land Use Code Text Amendment request to the LUDC. The criteria for approval of a Land Use Code Text Amendment are as follows: 1. The proposed text amendment is in compliance with any applicable intergovernmental agreementsl and There are no intergovernmental agreements impacted by the proposed text amendment. 3lPage 2. The proposed text amendment does not conflict with State law. Following review by the County Attorney's Office, it is Staff's opinion that the proposed text amendments do not conflict with State law. III. REFERRAT COMMENTS Public Notice has been accomplished as required by the LUDC. No public comments were received as a result of the public notice. Referral Comments received on the Application are attached as Exhibits and summarized below: - Town of Parachute - Stuart McArthur. Town Manager (Exhibit 7): States that the Town supports the proposed changes to the County regulations regarding limitations on the size and plant count of personal, medical and caregiver marijuana cultivation. - Colorado River Fire Rescue - Orrin D. Moon, Actine Division Chief/Fire Marshal (Exhibit 8): Expressed support for the amendments and requested that the County Code Enforcement Officer keep the Fire District informed of any known non-commercial grow operations. No comments were received from the following referral agencies: Garfield County Sheriff, Garfield County Environmental Health, Garfield County Emergency Management, Garfield County Public Health, the Colorado Division of Local Government, the Town of Carbondale, the City of Glenwood Springs, the Town of New Castle, the Town of Silt, the City of Rifle, the Carbondale and Rural Fire Protection District, the DeBeque Fire Department, the Glenwood Springs Rural Fire Protection District, and the Gypsum Fire Protection District. IV. OPTIONS FOR REGULATION ln response to size, scale, safety, nuisance (odor) and health-related issues, numerous jurisdictions across the State adopted regulations in their land use code to limit the growing of personal and medical marijuana. Many jurisdictions (ie. Jefferson County, City and County of Denver, Eagle County, Huerfano County amongst others) have adopted plant count caps, whereby they limit the number of marijuana plants that can be grown on a single property. Other jurisdictions (eg. Boulder County and Park County) have taken the approach of limiting the area in which one can grow which has the effect of ensuring grow operations are smaller in scale and thus do not generally have the elevated concerns for building safety and other health and nuisance related issues. ln 20L4, Staff brought an option of regulating grow operations through a plant count proposal. Should the Board want to consider new land use regulations, either plant counts or limitation on grow area may be an effective means for regulating this use. V. RECOMMENDATION The Community Development Department suggests the following approach for regulations that we think may be successful in addressing the size, scale and location issues related to grow operations. First, staff recommends several definitions be added to the LUDC that clearly define terms used within the language of the regulations. These terms are consistent with the terms used in the State Constitution. 4lPage Staff further recommends that the definition of "Agriculture" be amended so that marijuana is excluded as an agricultural product. The definitions should be amended as follows: Agriculture. The use of land for production, cultivation, growing and harvesting of crops and plants; raising and breeding livestock, commercial animal feed lot operations; harvesting, storage, grading, packaging, processing, and distribution of agricultural commodities; construction of internal roads, ponds, dams and ditches necessary to agricultural operations, excepting those regulated as Water lmpoundment; dairying, aquaculture, horticulture, floriculture, viticulture, nursery, and animal and poultry husbandry; and the necessary Accessory Uses and Structures needed for harvesting, packing, treating, or storing, excluding forestry. Agriculture does not include the growing of marijuana for Medical Use, Personal Use, Caregiver, or Optional Premises Cultivation Operation (OPCO) purposes. Enclosed Locked Space. Shall mean a permanent or semi-permanent structure covered and surrounded on all sides (eg. walls, roof and doors) so that no plants are visible to the public or adjacent property that is secured at all points of ingress or egress with a locking mechanism designed to limit access such as with a key or combination lock. Marijuana, Personal Use. Notwithstanding any other provision of law, the following acts are not unlawfuland shall not be an offense underColorado laworthe lawof any localitywithin Colorado or be a basis for seizure or forfeiture of assets under Colorado law for persons twenty- one years of age or older: a. Possessing, using, displaying, purchasing, or transporting marijuana accessories or one ounce or less of marijuana. b. Possessing, growing, processing, or transporting no more than six marijuana plants, with three or fewer being mature, flowering plants, and possession of the marijuana produced by the plants on the premises where the plants were grown, provided that the growing takes place in an enclosed, locked space, is not conducted openly or publicly, and is not made available for sale. c. Transfer of one ounce or less of marijuana without remuneration to a person who is twenty-one years of age or older. d. Consumption of marijuana, provided that nothing in this section shall permit consumption that is conducted openly and publicly or in a manner that endangers others. e. Assisting another person who is twenty-one years of age or older in any of the acts described in paragraphs (a)through (d)of this subsection. Marijuana, Medical Use. The acquisition, possession, production, use, or transportation of marijuana or paraphernalia related to the administration of such marijuana to address the symptoms or effects of a patient's debilitating medical condition, which may be authorized only after a diagnosis of the patient's debilitating medical condition by a physician or physicians, as provided by this section. 5lPage Marijuana, Caregiver. "Primary care-giver" means a person, other than the patient and the patient's physician, who is eighteen years of age or older and has significant responsibility for managing the well-being of a patient who has a debilitating medical condition. Colo. Const. Art. XVlll, Sec. 14 (f). To address size thresholds in the LUDC, staff recommends that the growing of marijuana for either personal or medical use be limited to size/square feet per an individual property/parcel and by adopting a maximum marijuana plant count for an individual property/parcel. SQUARE FOOTAGE OF GROW SPACE AND PLANT COUNT LIMITATION The following recommended text amendment is to address a change to the standards instituting a square foot growing space and ptant count limitation. Staff believes this size and plant count limitation acknowledges individual rights to grow medical or personal marijuana while protecting the citizens of Garfield County and neighboring property owners from safety risks caused by unrestricted growing of personal marijuana mentioned above, risks associated with unsafe building practices found in personal marijuana grow structures, and other major nuisance issues. A benefit of adopting regulations based on square footage is that the size limitation more directly address building safety concerns and accounts for the transient nature of the marijuana plants, meaning that if a landowner moves the plants, we still may be able to demonstrate that they were growing marijuana outside of the allotted square footage. Meanwhile, some jurisdictions are using a 36 plant count cap which is derived from the ability of caregivers to grow up to 30 plants without a State granted waiver plus the ability for a person to also grow 6 plants for personal use. ln 2074, a 12 plant count was proposed that was based upon the ability for a person to grow 6 recreational plants for oneself and 6 for another. Based on input from the Building Official as well as from other jurisdictions, if the Commission considers a grow area limitation, 300 square feet of grow area per property is a recommended area limitation. For reference, 300 square foot is approximately the size of a modest living room or about the size of a one- car garage. ln addition, a benefit of adopting regulations that includes the number of plants is that the plant count tracks very closely to the constitutional amendments for the number of plants allowed for medical and personal marijuana. To this end, Staff recommends a standard that limits personal, medical and caregiver grows to 300 square feet and not to exceed 36 plants. Standards. ln order to clarify the provisions and regulations that pertain to these specific types of grows, the following standards are recommended to be added to Section 7-120L; a section currently designed for accessory uses and structures. Note that Amendment 20 (Medical) does not require growing to occur in Enclosed Locked Space, but staff is recommending that become a more restrictive standard for growing medical or caregiver marijuana within the County. 6lPage 300 Square Feet and not to exceed 36 Plants per Lot20,000 Square Feet or more and with 2 or fewer Dwellins Units Less than 20,000 Square Feet and with 2 or fewer Dwelline Units L00 Square Feet and not to exceed 12 Plants per Lot 100 Square Feet and not to exceed 12 Plants per Dwelling UnitAny Lot with 3 or more Dwelling Units 7-t201C. Marijuana, Medical, Personal or Caregiver i. Any person growing marijuana for their own medical use, for their patients' medical use, or for personal use shall comply with the County land use code and the adopted Building Code. ilt. tv. il.Any person growing marijuana shall grow it in an Enclosed viewable by the public or adjacent property. All cultivation of marijuana shall only occur as an accessory Unit. Locked Space not use to a Dwelling All cultivation of marijuana shall only occur in the primary residence of the patient, caregiver or person over 21 years old, or in an accessory structure on the same property. v. Each Lot is restricted to the following marijuana growing space and plant count limitations regardless of the number of patients, primary caregivers, or persons over the age of 21 residing on one Lot: All cultivation of marijuana shall not cause odors, smoke, heat, glare or light that is detectable to a person of normal senses beyond the property line of the property upon which the use is being conducted, or in an adjacent dwelling unit or public area. All chemicals utilized in the growing of marijuana shall be used, stored, and disposed of in accordance with all applicable laws and regulations. ln addition, all spent soils shall be disposed of in accordance with all applicable laws and regu lations. vl. vil. TlPage Uses. ln order to provide additional clarity about the accessory growing use, it is recommended that the Use Table 3-403 is modified to reflect this type of accessory use. luilding or Struclure, Accegsory P P P P P P P a P P P P t -1201 :ence" lhdge or Wall P P P P P P P a P P P P t-1201 Ytdt{udlE, rHwil4 usts! tYteuruat u5g o laregiver (S$ Ft and Plant Count -irnitatlons) P P P P P P P a P P P P 7-r201(C) lf the Board decides to regulate the growing of personal marijuana as provided herein, staff also recommends the heading description for Section 7-1201be modified to state "The following shall apply to all Accessory Buildings, Structures or Uses." SlPage EXHIBIT*t8l Garfield Couln$ PUBLIC HEARING NOTICE INFORMATION Please check the appropriate boxes below based upon the notice that was conducted for your public hearing. lnaddition,pleaseinitialontheblanklinenexttothestatementsiftheyaccuratelyreflectthe described action. E"l/ *rapptication required written/mailed notice to adjacent property owners and mineral owners. Mailed notice was completed on the day of All owners of record within a 200 foot radius of the subject parcel were identified as shown in the Clerk and Recorder's office at least 15 calendar days prior to sending notice. All owners of mineral interest in the subject property were identified through records in theClerkandRecorderorAssessor,orthroughothermeans[list]- r Please attach proof of certified, return receipt requested mailed notice. ET My application required Published notice. Notice was published on the I I aay of ,4ctcpS f 2016. . Please attach proof of publication in the Rifle Citizen Telelram. E4tfirapptication required Posting of Notice. Notice was posted on the day of , 2016. Notice was posted so that at least one sign faced each adjacent road right of way generally used by the public. I testify that the above information is true and accurate. Name,-D- *.c/'fr*,z t, [--.- k Signatu re: 2076. Date: s/z z//C Ad Name: 123088544 Customer: Garfield County Building Your account number is: 1008693 PROOF OF PUBLICATION CITN T',t{f, Blf,"td ZEjNT'E.L.f,G STATE OF COLORADO, COUNTY OF GARFIELD I, Randy Essex, do solemnly swear that I am Publisher of The Rifle Citizen Telegram, that the same weekly newspaper printed, in whole or in part and published in the County of Garfield, State of Colorado, and has a general circulation therein; that said newspaper has been published continuously and uninterruptedly in said County of Garfield for a period of more than fifty- two consecutive weeks next prior to the first publication of the annexed legal notice or advertisement; that said newspaper has been admitted to the United States mails as a periodical under the provisions of the Act of March 3, 1879, or any amendments thereof, and that said newspaper is a weekly newspaper duly qualified for publishing legal notices and advertisements within the meaning of the laws of the State of Colorado. That the annexed legal notice or advertisement was published in the regular and entire issue of every number of said weekly newspaper for the period of I consecutive insertions; and that the first publication of said notice was in the issue of said newspaper dated 811812016 and that the last publication of said notice was dated 8/1812016 the issue of said newspaper. PUBLIC NOTICE Take Notice that the Board of County Commission- ers has requested to amend multiple articles of ihe Land Use and Development Code including, bul not limited, to Articles 3,7, and 1 5, in regard to the cultivation of marijuana for personal use, med cal use and by careqivers. All persons attected by the proposed text amend- ment are nvited lo appear and stale their views, protests or support. ll you cannol appear person- ally at such heaflng. then you are urqed to state yoir v,ews by letterl as the'Plarning Commissron w ll grve considerat,on lo all comments recerved, i^ decidi-g whether to recommend lo approve, modi- fy or deny lhe lexl amendments. The application may be reviewed at the oflice ol the Community Development Deparlmenl located al 'l 08 8th Street, 41h Floor, Garlield County Admrnistration Builoing, Glenwood Springs, Colorado between the hours of 8:30 a.m. and 5:00 p.m., Monday lhro-gh Friday. Alternatively, the application can be viewed atihtto://records.oadield-countv.comAVebLinUCust omSearch.asox?SearchName=BuildingDocument- Search (Search lor File No. TXTP-07-16-8473). A public heaflng with tl'e Plannrng Commrssron on lhis request has been scheduled lor the 14th day of Septemb€r at 6:00 p.m. rn the Counly Commrs- sroners Meetrng Room. Garfreld Counly Adminis- tralron Build,ng, 108 8th Slreel. Gle-wooo Springs, Colorado. Published in the Citizen Telegram August 1 8, 201 6. (12308854) In witness whereof, 08t2212016. I have here unto set my hand this ^ t /r.t ,X. "-'/'* '>t-t:11 / @ Publisher Subscribed and swom to before me, a notary public in and for the County of Garfield, State of Colorado this Pamela J. Schultz, Notary Public My Commission expires: November l,2019 EXHIBIT Z EXHIBIf *) 4._Ad Name: 1238061 1A Customer: Garfield County Building Your account number is: 1008693 PROOF OF PUBLICATION T'Hfl. R[F"Ld. g[T[Zf,IU T'E.LE.qRAIA STATE OF COLORADO, COUNTY OF GARFIELD I, Randy Essex, do solemnly swear that I am Publisher of The Rifle Citizen Telegram, that the same weekly newspaper printed, in whole or in part and published in the County of Garfield, State of Colorado, and has a general circulation therein; that said newspaper has been published continuously and uninterruptedly in said County of Garfield for a period of more than flfty- two consecutive weeks next prior to the first publication of the annexed legal notice or advertisement; that said newspaper has been admitted to the United States mails as a periodical under the provisions of the Act of March 3, 1879, or any amendments thereof, and that said newspaper is a weekly newspaper duly qualified for publishing legal notices and advertisements within the meaning of the laws of the State of Colorado. That the annexed legal notice or advertisement was published in the regular and entire issue of every number of said weekly newspaper for the period of ! consecutive insertions; and that the first publication of said notice was in the issue of said newspaper dated 912212016 and that the last publication of said notice was dated 912212016 the issue of said newspaper. ln witness whereof, 09t27t2016. I have here unto set my hand this R,4 €,,5y Randy Essex, Publisher Publisher Subscribed and swom to before me, a notary public in and for the County of Garfield, State of Colorado this 0912712016. Pamela J. Schultz, Notary Public My Commission expires: November 1,2019 PUBLIC NOTICE Take Notice that the Board ol Counly Commission- ers has requested lo amend multiple articles of the Land Use and Development Code including, but not limited, to Arlicles 3,7, and 1 5, in regard to the cultivation ol marijuana for personal use, medical use and by caregivers. All persons a,,ected by the proposed texl amend- ment are invited to appear and state their views, protests or suppo(. l, you cannot appear person- ally at such heanng then you are urged lo stale your views by lette,, as the Board ol Co-nly Com- mrssroners wrll grve consideralron lo all comments received, in decidrng w-et^er to approve. modify or dery the text amendments. The application may be reviewed at the office of the Commun ty Devel opmenl Depariment located at 1 08 8th Street, 4th Floor. Garf eld County Aomr.istratron Burld ng Glenwood Spnngs. Colorado belween lhe hours ol 8:30 a.m. and 5:00 p.m., Monday through Friday. Allernalively, the application can be viewed at http://records,oarf ield-countv.com/WebLinldc us- tomSearch.aspx?SearchName-BuildingDocu-mentsearch (Search for File No. TX- TP-07-1 6-8473). A public hearing with the Board of County Com- missioners on this requesl has been scheduled lor the 7th day of November at 1:00 p.m. in the Coun- ly Commissioners Meeting Room, Garfield Counly Admrnistratron Burlding. 108 8lh Street, Glenwooo Sprinqs, Colorado. Published in the Cltizen Telegram September 22, 201 6 (1 238061 1 ) EXHIBITIa8t From: Sent: To: Subject: David, David Pesnichak Stuart McArthu r < Stua rtMC @ parachutecolo rado.com > Tuesday, August 1.6,201"610:12 AM David Pesnichak FW: Personal, Medical, Caregiver Marijuana Regs - GarCo Text Amd - Referral The Town of Parachute supports the proposed changes by the County regarding the proposed regulation of the size and plant county of personal, medical and caregiver marijuana based on property and size. Stufr,t"t S. l'4cArthLw Town Manager Town of Parachute, Colorado 970-285-7630, X-106 From: Mark Chain Imailto:mchain@sopris.net] Sent: Tuesday, August L6,2076 9:08 AM To: Stua rt M cArth u r <Stua rtM C@ pa rach uteco lo rado.co m> Subject: RE: Personal, Medical, Caregiver Marijuana Regs - GarCo Text Amd - Referral Stuart: I have reviewed this and have no concern with how this proposed code change could affect . lt is being proposed by the BOCC to try to get some reasonable handle on the number of plants caregivers, medical marijuana growers and recreational growers can actually grow. The state does not enforce many of the limits presently in effect. Example, a "medical caregiver" can provide pot for up to five patients and gross six plants each, and can then get a waiver to care for more patients, etc. theoretically, it can get out of hand. Greenhouses are also exempt from the building code which provides other loopholes. The proposed regulations also provide for enforcement via odor control and other such items. lcan write something up in more detail if you would like. I'm also not sure of your procedures when you get a referral from the County on land use items. Does someone on your staff put comments together and then that letter comes from either Board or Planning Commission? We should talk to see if you want me to proceed further. From what I understand, this is a Semi-- hot button issue for some people in the town. Supporting reasonable regulations in the County may be seen as a good thing. Let me know or call and we can discuss. Thanks, Mark Mark Chain 811 Garfield Avenue THUTE EXHIBITI Colorado River Fire Reseue David Pesnichak Senior Planner 108 Sth Street, Suite 101 Glenwood Springs, CO Reference: TXTP-8473 David, September 6,2016 I have reviewed the proposed Code Text Amendment for the Personal Use, Medical Use, and Caregiver-Marijuana Regulations. CRFR is in full support of the proposed regulations from a public safety standpoint. With all of the non-commercial grow operations in our fire district we have concerns for public and firefighter safety. The grow operations will normally be in non-placarded buildings and homes that are designed for other uses. Our concerns are: 1. The normal electrical load on a building being expanded to a grow operation. Electrical is usually expanded without an electrical inspection and may not be to code which could lead to structure fires and possible loss of life. 2. Entanglement situations in grow rooms that we would need to enter for fire suppression or emergency medical response. Entanglement can come from extension cords and/or cables, chains, rope, and wire for hanging light fixtures along with other equipment that involves grow operations 3. Chemical/ pesticide storage and exposure issues to our personal that would be responding to the emergency. Due to the number of suspected non-commercial grow operations being located in our fire district, some of which could be in residential homes, we would ask the County Code Enforcement Officer keep us informed of the suspected non- commercial grow operations so we can inform our staff of the potential hazards that they may be encountering on an emergency response or call for service. Colorado River Fire Reseue With the passage of the new marijuana laws we have had to adapt to new response situations and encounter differenthazards. We expect and train for emergency response to commercial grow operations in our district due to the permit process, but like the County, we do not have the ability to permit the non-commercial grow operations. The ability to at least know where some of the non-commercial operations are located will help us plan accordingly. Thank you for allowing us to comment on the new proposed regulations. Please feel free to contact me with any questions or concerns. Orrin D. Moon Acting Division Chief/Fire Marshal