To: Zoning Administrator
From: Planning and Building Department
Agenda Section: Consent
SUBJECT:
title
Dirty Licks, LLC Coastal Development Permit, Zoning Clearance Certificate, and Coastal Development Permit Modification
Application Number: PLN-2025-19397
Assessor’s Parcel Numbers: 308-081-020-000
Loleta area
A Modification to an approved Coastal Development (PLN-2021-17381) to increase water usage for a commercial cannabis cultivation operation. The cultivation operation will use approximately 103,000 gallons of water per year. Per application materials the applicant anticipates capturing a maximum 176,560 gallons of water per year through rainwater catchment, dehumidifiers, and air conditioning units. 20,000 gallons of water storage have been installed on the property under the previously approved permit. The applicant is also seeking a Coastal Development Permit and Zoning Clearance Certificate for self-distribution and non-flammable manufacturing activities on site. Proposed manufacturing activities include trimming, rolling, and packaging cannabis, and will only involve cannabis produced onsite. There are no anticipated changes to traffic volumes, power needs, or staffing needs. All proposed new activities will occur within the footprint of an existing permitted non-residential structure.
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RECOMMENDATION(S):
Recommendation
That the Zoning Administrator:
1. Adopt the resolution (Resolution 26-__), (Attachment 1) which does the following:
a. Finds the Zoning Administrator has considered the has considered Environmental Impact Report prepared for the CCCLUO and the Addendum to the Environmental Impact Report that was prepared for the Dirty Licks, LLC Permit Modification, Coastal Development Permit, and Zoning Clearance Certificate; and
b. Finds the proposed project complies with the General Plan and Zoning Ordinance; and
c. Approves the Dirty Licks, LLC Permit Modification, Coastal Development Permit, and Zoning Clearance Certificate as recommended by staff, subject to the conditions of approval (Attachment 1A).
Body
DISCUSSION:
Project Location: The project is located in the Loleta area, on the East side of Table Bluff Road, approximately 50 feet from the intersection of Quinn Road and Table Bluff Road, on the property known as 3003 Table Bluff Road.
Present General Plan Land Use Designation: Agricultural Exclusive - Grazing (AEG(160)). Eel River Area Plan, 2017 General Plan. Density: 20 - 160 acres per dwelling unit, Slope Stability: Low Instability (1).
Present Zoning: Agriculture Exclusive (AE-160) / Archaeological Resource Area Outside Shelter Cove (A), Coastal Wetlands (W), Transitional Agricultural Lands (T)
Environmental Review: An Addendum to a previously adopted Final Environmental Impact Report has been prepared for consideration per §15164 of the State CEQA Guidelines.
State Appeal: Project is appealable to the California Coastal Commission.
Major Concerns: None
Monitoring Required:
Annual Compliance Monitoring
Executive Summary:
A Modification to an approved Coastal Development (PLN-2021-17381) to increase water usage for a commercial cannabis cultivation. The cultivation operation will use up to 103,000 gallons of water per year. Per application materials the applicant anticipates capturing a maximum of 176,560 gallons of water per year through rainwater catchment, dehumidifiers, and air conditioning units. 20,000 gallons of water storage have been installed on the property under the previously approved permit. The applicant is also seeking a Coastal Development Permit and Zoning Clearance Certificate for self-distribution and non-flammable manufacturing activities on site. Proposed manufacturing activities include trimming, rolling, and packaging cannabis, and will only include cannabis produced onsite. There are no anticipated changes to traffic volumes, power needs, or staffing needs. All proposed new activities will occur within the footprint of an existing permitted non-residential structure.
Water Resources:
The originally approved permit anticipated an annual water use of 18,250 gallons per year. The operations plan for the original project indicated that due to the scale of the project 100% water recycling would be cost prohibitive, and wastewater would be stored in a 500-gallon tank and hauled off-site for disposal. The project was approved in January of 2022, and inspection reports on file from 2022 to 2024 indicate water use was within permitted amounts. Water use records reviewed in April of 2025 indicate that the project had used approximately 21,500 gallons within the first three months of the calendar year, exceeding permitted amounts. The applicant indicated a new cultivation method was being utilized, and the cultivation operation will now use up to 103,000 gallons of water per year. Per application materials the applicant anticipates capturing a maximum 176,560 gallons of water per year through rainwater catchment, dehumidifiers, and air conditioning units. There are eight dehumidifiers in use that combined collect approximately 224 gallons of water per day, and eight air conditioning units that combined collect approximately 120 gallons of water per day. Cultivation cycles consist of vegetative growth and flowering stages over eleven weeks. Total water use per cycle is 21,700 gallons, and approximately 1,300 gallons of additional water is recaptured as runoff and cycled through the filtration system for reuse. Approximately 5 cultivation cycles can be completed annually with a total anticipated water use of approximately 103,000 gallons. Five weeks per cultivation cycle irrigation use will exceed recaptured water, by approximately 1,260 gallons, however the deficit can be recaptured within the first week of the new cycle, as irrigation while plants are in a vegetative state. The first two weeks of the cultivation cycle are the least water intensive time period (approximately 150 gallons of irrigation water is required per day). Approximately 21.7 gallons of irrigation water are required per square foot per cultivation cycle.
20,000 gallons of water storage have been installed on the property under the previously approved permit, and the applicant does not anticipate installing additional water storage. Per the applicant the increased scale of the project now allows for more efficient water recycling, and additional wastewater storage is not proposed.
Distribution and Manufacturing:
The applicant is proposing transport only self-distribution, which is allowable under the CCCLUO with issuance of a business license. The applicant is also proposing non-flammable manufacturing activities, including trimming, rolling, and packaging cannabis, in a 180 square foot room in the existing permitted non-residential structure. The applicant is proposing to manufacture using only cannabis that has been produced on-site. No additional traffic, increased staffing needs, power use, or ground disturbance is proposed.
Environmental Review:
Environmental review for this project was conducted and based on the results of that analysis, staff concludes that all aspects of the project have been considered in a previously adopted Environmental Impact Report adopted for the Coastal Commercial Cannabis Land Use Ordinance. An addendum to the Environmental Impact Report has been prepared for consideration by the Zoning Administrator (Attachment 2).
Relevant Conditions of Approval originally applied to the parent project remain in full force and effect. The Planning Department has conducted inspections and verified the conditions that were required to be completed before initiation of the project have been completed. Evidence of completion is on file. Remaining conditions applied to the original project that are to be satisfied for the life of the project are listed in section B of Attachment 1A.
Staff recommends that the Zoning Administrator make all the required findings based on the evidence in the record and approve the application subject to the recommended conditions.
OTHER AGENCY INVOLVEMENT:
The project was not referred to additional agencies for review or comment.
ALTERNATIVES TO STAFF RECOMMENDATIONS:
1. The Zoning Administrator could elect to add or delete conditions of approval. The Zoning Administrator could deny approval if unable to make all the required findings. Staff have concluded the required findings can be made based on the information available on file. Consequently, Staff does not recommend further consideration of these alternatives.
ATTACHMENTS:
1. Resolution
A. Conditions of Approval
B. Cultivation Operations Plan Addendum
C. Site Plan
2. CEQA Addendum
3. Applicant’s Evidence in Support of the Required Findings
A. 17381 Cultivation Operations Plan
B. Irrigation Schedule
C. Notice of Pre-operations Conditions Satisfied
Applicant:
Dirty Licks, LLC
1228 La Point Road
Eureka, CA 95503
Owner:
Arlan M Allen
DBA Agricultural Operation
656 Main St
Fortuna, CA 95540
Agent:
N/A
Please contact Michael Holtermann, Associate Planner, at mholtermann@co.humboldt.ca.us or 707-268-3737 if you have questions about this item.