On behalf of the Sacramento Metro Chamber and our coalition of licensed cannabis operators throughout the City of Sacramento, please see attached our comments on the proposed updates to Title 17 as it relates to cannabis land use.

The City says residents can participate in the Conditional Use Permit process. But who exactly gets notified?

This proposal creates a troubling message: children in kindergarten through high school deserve automatic protection, but preschool children do not.

Residential neighborhoods have been treated as sensitive uses for a reason. They are where families live, children play, seniors age in place, and neighbors build communities.

How does it make sense to protect a child at an elementary school but not a child at a licensed in-home daycare operating next door?

Will every parent with a child enrolled receive notice? Will every family on a waiting list receive notice? Will future families looking for childcare receive notice? The answer is no. Most parents will never know an application exists until it is approved.

If a marijuana dispensary seeks approval next to a daycare center through a Conditional Use Permit, how will parents be notified?

The City is proposing to remove daycare centers, in-home childcare providers, and preschools from the protected sensitive use list while continuing to protect elementary, middle, and high schools.

Who is supposed to monitor City Hall agendas? Who is supposed to read hundreds of pages of zoning documents? Who is supposed to hire lawyers and planning consultants? Most childcare providers simply do not have those resources.

Many licensed childcare providers operate from residential homes. By removing residential protections, the City is also removing protections for in-home childcare providers serving infants, toddlers, and young children.

Most people do not monitor City Hall agendas or read lengthy zoning documents. Many residents will never know a proposal exists until after it is approved.

A loophole that requires residents to constantly defend their neighborhoods is not a protection.

Why would the City weaken protections for facilities that serve our youngest residents?

State law requires cannabis lounges to operate in conjunction with cannabis dispensaries. Under this proposal, a dispensary and smoking lounge could potentially seek approval next to childcare facilities that serve infants, toddlers, and preschool-age children.
At the same time, cannabis businesses continue to experience armed robberies, burglaries, and violent criminal activity throughout California.

Why is the City proposing to remove protections for residential neighborhoods while maintaining protections for schools? Families deserve protection where they live, not just where they attend school.

Children live in homes. They ride bikes in neighborhoods. They walk on sidewalks. They play in front yards, parks, and apartment complexes. Protecting residential neighborhoods means protecting the people who live there every day.

Most neighborhoods do not have attorneys, planners, lobbyists, or organizations monitoring zoning applications. Working families, seniors, and residents should not be expected to fight complex land-use battles simply to maintain protections that already exist today.

eComment received from the City Clerk's Office.

respectfully oppose the proposed cannabis zoning amendments.

Supporters continue to point to studies claiming cannabis businesses do not create unique public safety concerns, yet Sacramento residents are watching armed robberies, burglaries, vehicle rammings, gunfire exchanges, and even homicide investigations tied to cannabis businesses occur in real time. These are not hypothetical concerns. They are documented incidents that have required significant law enforcement resources and have placed employees, customers, and surrounding communities at risk.

The issue before the Council is not whether licensed dispensaries check IDs. The issue is whether Sacramento should weaken protections that have existed for years around places where children, families, and vulnerable populations gather. Children do not stop being children when they leave an elementary, middle, or high school campus. Daycare centers, preschools, parks, churches, youth programs, after-school programs, rehabilitation facilities, and residential neighborhoods all serve the very same population the City claims it is trying to protect.

What is most concerning is the creation of a two-tier system of sensitive uses. Schools receive a hard-line protection. Everyone else is pushed into a Conditional Use Permit process that requires residents to discover a proposal, understand complex zoning documents, organize opposition, and attend public hearings. The Diamond House rehabilitation center example demonstrates exactly why this approach fails. Conditional Use Permits are not a substitute for clear protections.

Supporters ask where the evidence is that dispensaries sell directly to minors. That misses the point entirely. Sensitive-use policies have never been based solely on illegal sales. They exist because communities have long recognized that certain locations deserve additional protection from uses involving intoxicating products, smoking activities, public health concerns, and elevated security risks.

The City should also be honest about what these amendments accomplish. They are not simply housekeeping changes. They expand opportunities for cannabis businesses to locate closer to uses that Sacramento has historically recognized as deserving protection. If parks, churches, daycare centers, rehabilitation facilities, youth-serving organizations, and residential neighborhoods remain important community assets today, they should continue receiving meaningful protections tomorrow.

Protect all sensitive uses equally. Do not create loopholes. Do not force children, families, faith communities, daycare providers, recovery programs, and neighborhoods to fight project-by-project battles to preserve protections they already have.

Please reject the proposed amendments and maintain strong, clear buffers for all sensitive uses.

I support the proposed cannabis zoning amendments and appreciate the City's effort to create regulations based on facts, data, and real-world outcomes rather than assumptions.

According to the City's own Comprehensive Cannabis Study, regulated cannabis businesses have not been shown to negatively impact nearby property values, increase crime beyond levels generated by other businesses, or create negative economic effects on surrounding commercial and residential areas. The study also found that cannabis businesses generate significant tax revenue, employment opportunities, and economic activity for the City of Sacramento.

One issue I continue to hear raised is protecting children. We ALL support protecting children. However, I believe an important question should be asked: Where is the evidence that licensed dispensaries are selling cannabis to minors or advertising to minors?

Children cannot legally enter a dispensary sales floor without meeting strict requirements, and licensed dispensaries are required to verify identification before any purchase can occur. These businesses operate under some of the most heavily regulated retail rules in California.

If the concern is youth access to cannabis, we should focus on where underage individuals are actually obtaining cannabis rather than continuing to restrict licensed businesses that follow the law every day. The discussion should be driven by facts and enforcement data, not assumptions.

Along those same lines, I would encourage the City to re-evaluate whether all parks should continue to be classified as sensitive uses. A passive park with no playground, sports fields, youth programming, or regular youth activities does not present the same concerns as a park primarily designed for children and organized youth recreation. The City's regulations should distinguish between parks that are truly youth-oriented and those that are not. Doing so would better align zoning policy with the stated goal of protecting youth while avoiding unnecessary restrictions on legal businesses.

Another concern that is frequently raised is crime. Public safety matters to all of us, and every business owner wants safe neighborhoods for employees, customers, and residents.

However, when discussing land-use policy, we should be careful not to single out one industry without evidence. The City's own Comprehensive Cannabis Study found that regulated cannabis businesses have not created increases in crime beyond the levels generated by other businesses.

Throughout Sacramento, crime impacts many different types of businesses. Restaurants experience burglaries. Retail stores deal with organized retail theft. Jewelry stores are targets of smash-and-grab robberies. Businesses in Old Sacramento have recently reported increases in robberies, stabbings, and property crimes. Yet we do not respond by questioning whether these businesses should be allowed to open or by creating additional location restrictions on them.

Crime is a law enforcement issue, not a land-use issue.

The question before the Council should not be whether crime exists in Sacramento. The question should be whether there is evidence that licensed dispensaries create unique public safety problems that justify additional restrictions. The City's own data suggests they do not.

There is also an inconsistency in the public discussion surrounding cannabis. When the cannabis industry asks for tax relief or tax reform, we are often told that cannabis tax revenue is critical because it funds programs for children and youth through Measure L. Yet when it comes to allowing legal businesses reasonable opportunities to operate, the same argument is frequently used to justify additional restrictions.

If cannabis tax revenue is important because it supports youth programs, then the City should also recognize that those revenues are generated by licensed businesses that need reasonable opportunities to serve adult consumers. We cannot continue to rely on cannabis businesses for millions of dollars in tax revenue while simultaneously making it increasingly difficult for those businesses to exist.

The City's own study found that regulated cannabis businesses contribute significant economic benefits, support thousands of jobs, and generate millions of dollars annually for public services and youth programs. The facts show that regulation works.

Good public policy should be applied consistently. If a business follows the law, complies with regulations, verifies identification, pays taxes, creates jobs, and contributes positively to the community, it should be evaluated based on facts and performance—not perceptions or assumptions.

I encourage the Council to continue making decisions based on evidence, fairness, and the actual performance of Sacramento's regulated cannabis industry.

Thank you for your time and consideration.

Chris L.