HomeMy WebLinkAbout5/6/2025 Item 7a, Tway and Gomez - Staff Agenda CorrespondenceCity of San Luis Obispo, Council Memorandum
City of San Luis Obispo
Council Agenda Correspondence
DATE: May 6, 2025
TO: Mayor and Council
FROM: Timothea (Timmi) Tway, Director of Community Development
Prepared By: Ivana Gomez, Cannabis Business Coordinator
VIA: Whitney McDonald, City Manager
SUBJECT: ITEM 7a - ANNUAL CANNABIS BUSINESS PROGRAM UPDATE AND
INTRODUCTION OF AN ORDINANCE TO AMEND SECTION 17.86.080
(“CANNABIS”) OF TITLE 17 (“ZONING REGULATIONS”) OF THE
MUNICIPAL CODE TO CLARIFY SPECIFIC LAND USE AND
OPERATIONAL REQUIREMENTS FOR COMMERCIAL CANNABIS
ACTIVITY [CITYWIDE] (CODE-0051-2025).
Staff received the following questions, regarding cannabis business relocation. The
questions are below with staff’s response shown in italics:
1) If a business loses a planned location and has no choice but to move to another
location within the same Overlay Zone area, do the proposed amendments require
it to restart the application process from scratch? If yes, what new language could
create a shorter application timeline?
Under current City regulations, if a cannabis business loses its location before or
after activating its Commercial Cannabis Operator Permit (activating means
opening the business), it must apply for a new operator permit under Chapter 9.10
of the SLO Municipal Code and would also require a new Use Permit for the newly
proposed location. This is because the Operator Permit process is competitive,
and applications are evaluated based on Merit Criteria such as land use
compatibility, site plans, financial capacity, property control, lighting, odor control,
and water efficiency plans, many of which are inherently linked to a particular
location. This means that the location of a proposed operator is considered when
applications are scored. Applicants generally cannot revise or relocate a selected
proposal, as doing so would undermine the fairness of the competitive process.
The proposed amendments do not change this requirement.
At this time, staff is not recommending language changes that would allow a permit
holder to move locations without completing a new competitive application
process. Modifying this process would require a comprehensive reevaluation of
the Merit Criteria and application procedures—an effort that could take over a year,
accounting for the typical public input process. Additionally, allowing relocation
prior to permit activation could incentivize applicants to propose one location to
secure a higher score, then change sites before opening.
ITEM 7a - ANNUAL CANNABIS BUSINESS PROGRAM UPDATE AND INTRODUCTION OF AN
ORDINANCE TO AMEND SECTION 17.86.080 (“CANNABIS”) OF TITLE 17 (“ZONING
REGULATIONS”) OF THE MUNICIPAL CODE TO CLARIFY SPECIFIC LAND USE AND
OPERATIONAL REQUIREMENTS FOR COMMERCIAL CANNABIS ACTIVITY [CITYWIDE] (CODE-
0051-2025). Page 2
As described above, the current municipal code also does not provide the ability
for permits that are activated (established businesses) to move without completing
a new competitive process that is required of all applicants. However, a
streamlined relocation process for an existing business could be considered.
Changes to streamline this process should be studied to ensure there are not
unintended consequences, and that fairness and equity in the process are
preserved.
A potential future amendment could mirror the three-year prohibition on majority
ownership transfers included in the City’s current regulations (SLOMC Section
9.10.120(C)), which could allow established businesses to relocate after
demonstrating three years of compliant operation. The modified regulation could
read:
Section 9.10.120 – Prohibition on Transfer of Commercial Cannabis
Operator Permits
A. Location Restriction: A commercial cannabis operator permit is valid
only for the location identified on the permit. The permit may not be
transferred to a different site, and no business may operate at a location
other than the one specified, except as specifically provided herein.
Relocation is not permitted until the operator permit has been activated in
accordance with Section 9.10.070(D).
Following activation, no relocation to a different site is allowed for a period
of three years from the date of activation. After this three-year period, the
operator may apply to relocate the business to another property within the
applicable zoning overlays without undergoing a new competitive
application process for a commercial cannabis operator permit. However,
such relocation would require approval of a new Use Permit in accordance
with Section 17.86.080.
This approach preserves the integrity of the competitive application process while
offering flexibility to long-standing, compliant operators. If the Council is inclined to
direct staff to proceed with an ordinance amendment along the lines outlined above
or otherwise, staff would recommend that the Council also direct staff to propose
criteria by which to evaluate such a relocation application, as well as a
recommendation as to the approval authority (e.g., Council, City Manager or
Community Development Director)
ITEM 7a - ANNUAL CANNABIS BUSINESS PROGRAM UPDATE AND INTRODUCTION OF AN
ORDINANCE TO AMEND SECTION 17.86.080 (“CANNABIS”) OF TITLE 17 (“ZONING
REGULATIONS”) OF THE MUNICIPAL CODE TO CLARIFY SPECIFIC LAND USE AND
OPERATIONAL REQUIREMENTS FOR COMMERCIAL CANNABIS ACTIVITY [CITYWIDE] (CODE-
0051-2025). Page 3
2) If an applicant loses their proposed location, how long is the process to complete
the competitive application process for an alternative location?
Under the current regulations, an applicant who has “lost” the location proposed in
their original application for a Commercial Cannabis Operator Permit may reapply
during the next annual application period or any subsequent application period
established by the City Manager. The process to open an application period, create
and publish application materials, and evaluate applications submitted to the City
can take roughly 6 months to a year, depending on the volume of applications
received, and whether there are legal challenges asserted among applicants. This
does not include time involved in the submittal and review of a Use Permit following
the issuance of a Commercial Cannabis Operator Permit. Additionally, significant
staff time is required for preparation of application materials, availability to answer
questions from interested parties, as well as for the Cannabis Application Review
Team (“CART” - staff from various City departments responsible for convening to
review and score commercial cannabis applications) to review and score
applications against the adopted Merit Criteria.