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HomeMy WebLinkAboutMINUTES - 04122005 - C.64 C't TO: BOARD OF SUPERVISORS FROM: SUPERVISOR GAYLE B. UILKEMA Contra Costa DATE: April 12,2005 County SUBJECT: Contra Costa Agricultural Advisory Task Force Report SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATION: Refer Contra Costa County Agricultural Advisory Task Force Report of February 17,2005 to the Director of Community Development for a report and recommendation. BACKGROUND: CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER oe SIGNATURE: GAYLE B.UILKEMIAl MANE= ACTION OF BOARD ON AD14//12.2005 APPROVED AS RECOMMENDED OT R VOTE OF SUPERVISORS NT I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS (ABSE AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES:— AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN:, OF SUPERVISORS ON THE DATE SHOWN. ATTESTED ww, John Sweeten,Clerk of the Board of Supervisors and County Administrator BY DEPUTY Contact Person: CC: County Administrator Supervisor District 2 Dennis Barry,Director Community Development Attachment #2 Growers Guide To Roadside Stand Regulation in Contra Costa County (summary of current County requirements) CONTRA COSTA COUNTY A GRIC L A.D PTSOR Y TASK FORCE 14 E February 17, 2005 MAR 2 9 ^/ o_5 Contra Costa County Board of SupervisorsPERVISOR AM SUE B.UILKEMA G 651 Pine Street CONTRA COSTA COUNTY Martinez, CA 94553 Dear Chairwoman Gayle B. Uilkema,and Board Members: A little more than a year ago, we responded to your request to deal with promoting CCCo. Agriculture by recommending and by establishing Standards by which Wineries be established in CCCo. Since that time 6 wineries have applied for new licenses. Now we are responding to another one of your concerns by dealing with improving roadside stands and adding value to CCCo. Agricultural Products. As the Chair of the Contra Costa County Agricultural Advisory Task Force, I am writing on behalf of the Task Force to urge the Board of Supervisors to initiate actions necessary to improve the economic viability of farmers and ranchers in Contra Costa County. As mare.fully described in the attached report and recommendations, the Task Force has studied the matter of roadside stand regulations in Contra Costa County. Based on our study of this matter, we are recommending that regulations, as contained in both the County General Plan and County Zoning Ordinance Code,, be updated,to accornmodate the changing marketplace for agriculture in Contra Costa County. Most of the farmers and ranchers in Contra Costa County operate comparatively small-scale operations and must compete and survive in a rapidly changing agricultural economy. Across the United States small-scale farmers have been able to survive and thrive by capturing a greater share of each food dollar spent by consumers by marketing directly to the consumer and by establishing"value-added" agricultural enterprises on their property. Through"value- added" enterprises, a farmer adds value to their raw product by such means as cleaning, freezing, drying, processing, bottling, canning, etc. The essence of this value-added concept is to enable the farmer to convert an agricultural product they have grown into an item that then can be sold directly to the consumer. We are recommending that certain regulations be updated to enable Contra Costa farmers and ranchers to directly market their products to local consumers and visitors and to encourage the establishment of new agricultural enterprises based upon the"value-added" concept. We are respectfully requesting the Board of Supervisors to authorize the Community Development Department to initiate a General Plan Amendment Study, an associated zoning ordinance amendment, and permit review process that would focus on three areas of concern: 1. Expand Direct Marketing By Updating Roadside Stand Regulations Expand the ability of farmers and ranchers to directly market their products by updating the regulations that govern roadside sales in agricultural zoning districts. These changes would establish-within the County's agricultural zoning districts three new and separate roadside sales categories: Grower Markets, Grower Stands, and U-Pick Operations. The new Growers Markets category would allow through a conditional use permit in all agricultural zoning districts the sale of any raw agricultural product grown in Contra Costa County or any processed agricultural product grown in Contra Costa County in a permanent or temporary structure up to 3500 square feet of floor area. Additionally, up to 25% of the floor area would be allowed for the sale of non-valued added products, taxable items, and/or agricultural 'products not grown in Contra Costa County. Subject to compliance with health-and safety code requirements prepared foods and would be allowed for sale. The new Growers Stand category would permit the establishment of a roadside stand of not more than 1500 square, either permanent or temporary, in all agricultural zoning districts for the purpose selling any raw agricultural product grown in Contra Costa County and any value-added agricultural product made from Contra Costa County grown products but not intended for human consumption..It would also allow up to 5%of the floor area-to be used for the sale of taxable items, sale of prepackaged beverages dispensed from a refrigerator or vending machine, and sale of other items that promote the sale of agricultural products or educate the public about agriculture. U-pick operations would continue to be permitted in all agricultural zoning districts. This proposal only requests that an Administrative Review procedure be instituted for a u-pick operation based on complaints. This review would be aimed at assuring that u-pick customers can park safely off-street without causing safety problems in terms of entry and exit on to the roadway, and that the u-pick operation meets the appropriate property set back requirements. 2. Encourage Value-Added Agricultural Enterprise Acknowledge the concept of value-added agricultural enterprises in the General Plan and Zoning Code. This recommendation specifically involves amending the text for Agricultural Core designation in the Land Use Element to allow through a conditional use permit the operation of commercial kitchens and other small-scale processing facilities, such as those that involve canning, drying, freezing, or packaging agricultural products. 3. Improve The Permitting Process 2 Focus on improving the permitting process for agricultural uses by forrm*ng an interdepartmental team, comprised of the Community Development, Building Inspection, Environmental Heath Division—Health Services, and the Agriculture Commissioner, to review, identify obstacles, devise solutions and generally facilitate the permit process for agricultural uses and structures in Contra Costa County. Since agriculture revolves around growing seasons, it is vital that permits for agricultural uses and structures be processed in a timely, expeditious manner so that the farmer or rancher will not miss an opportunity to bring their product to market. The Task Force believes that improving the economic viability of agriculture in Contra Costa County depends in part on updating the County's roadside stand regulations and expanding the opportunities for agricultural enterprises based on the value-added concept. Thank you for your consideration of this matter. Sli rs,, om Powers Chair, Contra Costa County Agricultural Advisory Task Force Anacbment.,.1/111U) Contra Costa County Agricultural Advisory Task Force Report and Recommendations,,2/17/2005 CONTRA COSTA COUNTY AGRICULTURAL ADVISORY TASK FORCE IMPROVING THE ECONOMIC'VIABILITY OF FARMERS IN CONTRA COSTA COUNTY: UPDATING ROADSIDE STAND REGULATIONS AND ALLOWING VALUE-ADDED AGRICULTURAL OPERATIONS IN THE COUNTY'S AGRICULTURAL CORE REPORT AND RECOMMENDATIONS TO CONTRA COSTA COUNTY BOARD OF SUPERVISORS AS APPROVED ON FEBRUARY 17,2005 BACKGROUND Eastern Contra Costa County(CCC)is one of California's most productive fanning regions, producing agricultural products valued at more than$100 million dollars and contributing more than$300 million dollars to Contra Costa County's annual economy. Agriculture provides Contra Costa citizens with jobs, open space and a source of fresh, local food, as well as intangible historical,, cultural and col"�III mnity benefits. However, Contra Costa County farmers are struggling to survive economically due to the consolidation of California agriculture, globalization of food production, and increased costs. Between 1997 and 2000, the prices California farmers received for the food they grow dropped 7%,while their costs rose 19%. According to the 2002 USDA Agricultural Census, 94% of Contra Costa farmers met the federal definition of"small farmers"with gross produce sales of less than $250,000. The average net profit realized by Contra Costa farmers in 2002 was $41,868. Consequently, despite efforts to preserve prime agricultural land through zoning and conservation easements, the number of farms in Contra Costa County has dropped 25%in the past 5 years. Between 1997 and 2000 Contra Costa County lost 4,381 acres of farmland and ranked fourth among counties in California in the loss of agricultural land to urban use. Innovative small scale fanners throughout the United States are successfully capturing a greater share of each food dollar through packaging,processing, marketing, direct sales and other"value- added"ventures on their farms. Through"value-added" enterprises, farmers add value to their crops by cleaning, freezing, drying,processing, and preserving their crops. For instance, crops can be converted into jams,jellies, salsa,pies and baked goods, soaps, dried herb wreaths and other high-value items created from their raw agricultural products. A recent survey of California farmers indicates that selling directly to consumers provides farmers with four times the net profit than they would receive from marketing their produce conventionally. Labor intensive direct marketing and value-added production provide additional community benefits, creating jobs, stimulating the agricultural economy, rebuilding local agriculture infrastructure and keeping food dollars in the County. An overview of the value-added concept and examples of local value-added enterprises are included in Attachment 1. Contra Costa farmers have a successful history of dire'ct marketing through roadside stands and U- pick operations. The proximity to Bay Area markets and the rapidly expanding populations in East County offer tremendous economic opportunities for Contra Costa farmers. Expanding direct marketing and adding value to raw produce have long been recommended by the USDA,UC Cooperative Extension and other experts in small-scale fanning to help small farmers maintain economic viability. Many of these agricultural enterprises require limited retail and processing facilities on agricultural land. Current Contra Costa County zoning for the agricultural districts needs to be updated to accommodate the changing marketplace and allow a greater range of economic opportunities for Contra Costa farmers. Local suburban and nearby Bay Area populations are increasingly demanding local agricultural products, and creating new opportunities for local fanners to capture nearby urban markets with value-added agricultural enterprises would contribute to a vibrant agricultural economy in Contra Costa County. ISSUES During the summer of 2004 the Contra Costa County(CCC)Agricultural Advisory Task Force conducted a survey of local growers to determine the nature and extent of constraints that limit agricultural viability in the county. This was done in response to a variety of problems brought to the attention of the Task Force by local growers, Harvest Time(a CCC direct marketing grower's association), and the Agriculture Enterprise Committee of the Brentwood Agricultural Land Trust. The survey identified several regulatory constraints that limit agricultural viability and direct marketing opportunities. These include: • Limits on the size of Roadside Stands: The current county zoning code allows all agricultural properties to have a roadside stand by right but limits the size of the stand to a maximum of 200 - 400 sq. ft., depending on the zoning district. These roadside stand limits were widely recognized by survey respondents as too small to offer the volume and variety of produce needed to meet the needs of the modem consumer. With dual income families and long commutes, customer purchases have changed in recent years from larger volume, single commodity purchases for home canning to smaller, multiple commodity purchases for weekly consumption. These tiny stands cannot successfully compete with the variety and convenience offered by the many new supermarkets built within a 5-10 minute drive of the Agricultural Core. Other counties have amended their zoning to allow larger roadside stand facilities so that local farmers can satisfy the needs of their suburban neighbors. • Limits on products which can be sold at Roadside Stands: The current zoning code only allows for the sale of raw agricultural products that are grown on the same property as the roadside stand. This restriction limits the volume and variety of produce necessary to attract customers for regular visits. Growers cannot legally sell products for neighboring farmers who may not have the volume,resources, time or location to operate their own stand. Many growers farm more than one parcel and must operate a separate stand for each parcel. A proliferation of many, small, limited product stands are neither convenient for consumers nor feasible for farmers. Additionally,the code does not recognize the concept of value-added agricultural products (jams,jellies, fruit pies, wreaths, olive oil,honey, soaps, seasoned nuts, dried fruit, etc)that allow the farmer to preserve their product,*extend their season, increase product variety and ultimately to improve their economic viability. Finally,the code does not allow the sale of bottled water or other drinks necessary during high summer temperatures, especially at U-pick operations where customers may be in the hot sun for long periods. • No Conditional Use Permits are allowed in the Agricultural Core: New language was added in the 1991 General Plan update that prohibited all conditional uses in the Agricultural Core. Conditional uses are allowed by permit in all other agricultural zoning districts. The intent was to preserve prime agricultural land for fanning rather than for farm related activities. This blanket ban on conditional uses has unduly restricted even small scale agricultural enterprises that would have minimal impact on the land resource but would increase the economic viability of productive agriculture on these prime agricultural lands. For example, the current restrictions do not allow for small scale processing facilities in the Agricultural Core (such as commercial kitchens or freezing, drying,packaging, culturing facilities) that add value to raw agricultural products. Current restrictions do not allow for the sale of small quantities of products not grown on the roadside stand property that would advance the sale of agricultural products or educate the public about agriculture. Expanding these opportunities would help to preserve the productive use of agricultural lands by facilitating a more vibrant agricultural economy. 2 • Permit requirements for roadside stands are not clear or standardized. Several agencies have rules and regulations that govern the construction and operation of roadside stands. Depending on the stand size and level of activity, these may include the CCC Departments of Community Development, Building Inspection, Agriculture, and Environmental Health. Each of these departments has their own, sometimes complex code,that they are responsible for enforcing. An overview of each department's responsibilities and governing codes are included in Attachment 2. The survey revealed there is a perception that the requirements of one department may conflict with those of another, leaving the applicant unsure as to how to proceed. There is an additional perception that some requirements are subject to interpretation by agency staff and that the codes are unevenly applied for similar projects. Since there are fewer agricultural permit requests than urban/suburban requests staff may not be as familiar with agricultural operations and requirements. • Traffic Safety: The rapid urbanization of East County has led to excessive commuter traffic on narrow rural roads. This has made it difficult for farmers to move equipment to their different properties safely. It has also made it difficult for customers to safely tum into and out of roadside stands located on roads that have become quite busy(such as Walnut Blvd., Concord Ave., Sellers Ave., and Marsh Creek Rd.). It is no longer safe for customers to park along the now very busy rural roadways to visit roadside stands as they have done in the past. RECOMMENDATIONS The CCC Agricultural Advisory Task Force has reviewed each of the issues outlined above and proposes the following to address these concerns. We request that the Board of Supervisors direct the Community Development Department to initiate a General Plan Amendment Study, an associated zoning ordinance amendment, and a permit review process that would: I. Expand opportunities for direct marketing by updating regulations to provide workable, clear, land use and related regulatory processes that allow farmers and ranchers in Contra Costa County to directly market to local consumers and tourists. These new regulations are intended to promote the sale of CCC farm produce and related goods. They are not intended to encourage the proliferation of retail stores or convenience markets in agricultural districts. They would establish three separate categories for roadside sales that would be allowed in all agricultural zoning districts: Grower Stands, Grower Markets, and U-Pick Operations. A. Grower Stands: Grower stands are similar to currently defined roadside stand operations in that the stand must be an accessory to the grower's agricultural operation and is allowed by right. The current Code should be updated to include: i. Physical requirements: The sales area cannot exceed 1500 square feet in size. Structures* may be permanent or temporary depending on the grower's needs. Any building greater than 1 20.sq. ft. will require a building permit, as directed by current code. Electricity would be allowed. Stands should have adequate parking, safe exit and entry, and conform to property set back requirements. Inadequate provision for parking, ingress, egress or set back requirements will trigger an Administrative Review by the Community Development, Public Works or other appropriate Department. The Administrative Review would 3 require an appropriate fee and the submission of a corrective site plan for approval that includes the owner's name, address, stand parcel number, map showing buildings,parking, ingress, egress, and setbacks from rights-of-way. ii. Products sold: Any raw agricultural product gown in CCC can be sold at these stands. In addition,, any value-added agricultural product made from CCC grown products and not for human consumption(soap, wreaths, etc.)may be sold at these stands. This will help to increase product variety,,, extend the season, encourage the sale of local products, and assist farmers in marketing their products. Additionally, 5 %of the floor area may be used to sell taxable items that are not grown in Contra Costa County. This includes prepackaged beverages dispensed from a refrigerator or vending machine and other items which promote the sale of agriculture products or educate the public about agriculture. All food products sold at the Grower Stand will be subject to the regulations set forth in the CA Health and Safety Code(see Attachment 2). B. Grower Market: This new Grower Market category allows for a larger floor area and/or a larger diversity of product sales but must still be accessory to the grower's agricultural operation. Grower Markets would be subject to approval through a Conditional Use Permit. New regulations should include: i. Physical requirements: The floor area cannot exceed 3500 square feet in size, Structures may be permanent or temporary depending on the grower's needs. Any building greater than 120 sq. ft. will require a building permit, as directed by current code. Electricity would be allowed. Off street parking of one space for every 300 sq. ft. of sales area would be required. A site plan (including the owner's name, address,parcel number, map showing buildings, parking, ingress, egress, and setbacks from rights-of-way)must be submitted and approved as part of the Conditional Use Permit process to assure adequate parking, safe exit and entry, and conformity to property set back requirements. ii. Products sold: Any raw agricultural product grown in CCC can be sold at these markets. Any processed or value added product grown in CCC can be sold. In addition, a seasonal average of up to 25% of the floor area can be used for the sale of non-value added,, taxable items and/or farm products which are not grown in CCC. In addition to agricultural products grown outside CCC, Grower Markets may sell drinks,prepared foods, snacks, ice, craft items, antiques, canning supplies and other items related to agriculture that advance the sale of agricultural products or educate the public about agriculture. No petroleum products, magazines,tobacco or alcoholic beverages (except wine grown in CCC with the proper permit)may be sold at a Grower Market. All value-added and processed foods will be subject to the regulations set forth in the CA Health and Safety Code(see Attachment 2). C. U-pick operations: U-pick operations are allowed by the existing code but must provide customers with adequate parking, safe exit and entry, and conform to property set back requirements. Inadequate provision for parking, ingress, egress or set back requirements will trigger an Administrative Review by the Community Development Department. The Administrative Review would require an appropriate fee and the 4 submission of a corrective site plan for approval that includes the owner's name, address, parcel number,map showing buildings, parking, ingress, egress, and setbacks from rights-of-way. The storage and operational area of the U-pick portion of any operation that is combined with a Grower Stand or Grower Market will not be included in the floor area calculation of the Grower Stand or Grower Market. Ii. Encourage Agricultural Enterprises. A. Conditional Use permits: Amend the CCC General Plan to allow conditional use permits to be issued in the Agricultural Core as they are in other agricultural zoning districts. The permit process should limit agricultural operations to those that are incidental to the grower's primary agricultural operations and are appropriate in size and nature to preserve the prime farmland of the Agricultural Core. Appropriate uses to be allowed under permit in the Agricultural Core can include,but are not limited to: i. Grower Markets, as defined above. ii. Commercial kitchens and other small-scale processing facilities including but not limited to: the canning, drying, freezing, or packaging of agricultural produce primarily grown in Contra Costa County. These facilities would be subject to the regulations set forth in the California Health and Safety Code (see Attachment 2) B. Agricultural Permit Streamlining. The Task Force recommends that the Board of Supervisors direct the County Community Development Department to assemble a committee composed of representatives from the CCC Departments of Community Development, Agriculture,Environmental Health, and Building Inspection. The purpose of this committee would be to review, identify obstacles, devise solutions and facilitate the permitting process for Grower Stands, Grower Markets and other agricultural enterprises. This facilitation may include but not be limited to: • The development of a single form that could address the needs of all the permitting agencies/departments and replace the multiple forms currently required by each agency. • A user-friendly flow chart of the regulatory requirements for Grower Stands, Grower Markets and other agricultural enterprises. • A committee review of permits that are exceeding the expected processing time to discover and alleviate impediments to timely and efficient permit processing. Attachments 1. "Value-Added"Agriculture Concepts 2. Summary of current County requirements re: Roadside Stands 3. Flowchart comparing existing requirements with proposed changes GAAdvance Plsnning\adv-plan\Ag Task Forcc\RSS Gen Plan Amcad 7.doc Aftachment #1 Walue aidedw Agriculture Concepts dded te � �r ` � 4 J. Value. T�Mloll I C 5= A' r., � 8 ded °fk�aecis, s njp *Ut peacs Ptf . �►�r's � l ce A SL G� 4 r: 4 5 � r l�. s �1 .X d� f { YOM mit L©de ��tfi✓�elli Sells ft beth the, Caq�o u o� c� h ATS A GR A D CELLAR URL OLD F 1 w ► Wt A g7tr� 'i.F�y7��� t•` AM so Q%Q the wbom 4T, 11W f Ago F f ����f 4J• 'w '"T I . _ ..,�. ,.•:fir.; - y` f ,:. , � ^`��• '1�,�.... � .: ff? ° Pte' O t ' 4`: � ,, � M � ! �►' �, "fib � 40p { r OW 4'. � � �n ,• � fwwlbw 104* rw fl, Vol . x w�wrr�rw► ,�r�rirwMrl r ter. 3 s e - t �.pa�Ft/�,�y�bj.�i'VPt`M'' "{_� Ol"rp•f -_ nt �1 <i., remix 4 li As of 2/17/2005 GROWERS GUIDE TO ROADSIDE STAND REGULATIONS IN CONTRA COSTA COUNTY Basic Requirements: A number of different agencies can be responsible for compliance with regulations of a grower's roadside stand based its size and scale of operation. The following is a list of Contra Costa County departments that are responsible for compliance with certain state and local regulations related to roadside stands and it summarizes the basic regulatory requirements for each County department related to growers selling agricultural products of their own production: Building Inspection Department • A building permit ermit is required for a permanent building or structure exceeding 120 square feet (e.g. roadside stand over 120 square feet). A building permit is not required under the following circumstances: a one-story detached accessory building used as a equipment or storage shed provided the floor area does not exceed 120 square feet; fences not over 6 feet high; movable cases, counters, and partitions not over 5 feet 9 inches high; painting, papering and similar finish; and, window awnings supported by an exterior wall when projecting not more than 54 inches. • Three sets of plans (plot plan, floor plan and construction plans) are required to be submitted with a building permit. • Sanitary facility (toilet and wash basin) may be required for the workers. • American With Disabilities Act (ADA) handicapped accessibility is required for the workers and customers in parking, building access, and sanitary facility. • Engineering design may be required if the building structure does not conform to code defined conventional construction. • Title 24 energy design is required if the building is heated or air-conditioned. Regulatory Authority: The Building Code for Contra Costa County is the 2001 Edition of the California Uniform Building Code. Contra Costa County Ordinance Code Title 7, Building Regulations, assigns responsibility for enforcement of the Building Code to the Building inspection Department. Community Development Department No Land Use Permit (or Conditional Use Permit) is required for the following situations: • Roadside stand no larger than 200 sq/ft on property located in A-2 or A-3 zoning districts; or, Roadside stand defined within a Williamson Act contract as an allowable use for properties located in A-4 zoning district (Agricultural Preserve/Williamson Act contract land); or, • Roadside stand no larger than 400 sq/ft on property located in A-20, A-40 or A-80 zoning districts. Roadside stand is located at least 25 ft. from the property line, and; • Roadside stand is located on property at or near point where the agricultural product was produced, and on property controlled by the producer. Regulatory Authority: Contra Costa County Ordinance Code Title 26-2, County Planning Agency, Title 8, Zoning, and Title 9, Subdivisions, and the Contra Costa County General Plan. 1 As of 2/17/2005 GROWERS GUIDE TO ROADSIDE STAND REGULATIONS IN CONTRA COSTA COUNTY • Selling agricultural commodities that are not of a grower's own production requires meeting standard pack, size, container and labeling requirements. Contact the County Department of Agriculture to confirm. CONTRA COSTA COUNTY DEPARTMENT CONTACT INFORMATION Building Inspection Department: (925) 646-2300 Application and Permit Center Main County Administration Building 651 Pine Street, 2"d Floor North Wing Martinez, CA 94553 OR East County Office: Building Inspection Dept. (925) 427-8850 1191 Central Boulevard, Suite C Brentwood, CA 94513 Community Development Department (925) 335-1360 Application and Permit Center Main County Administration Building 651 Pine Street, 2nd Floor North Wing Martinez, CA 94553 Agriculture Department (925) 646-5250 g p 2366-A Stanwell Circle Concord, CA 94520 OR Kinghtsen Office: Agriculture Dept. 3020 2nd Street Knightsen, CA Environmental Health (925) 646-5225 2120 Diamond Boulevard Concord, CA 94520 These departments may also be contacted through the Contra Costa County Government Website: http://www.co.contra-costa.ca.us/ GAAdvance Planningladv-plan\Ag Task Force\Growers Guide To Roadside Stand Regulations.doc 3 Attachment 03 Flowchart comparing existing requirements with proposed changes room% 4; �:7 40- 0 Ol c) 0 4- %4?-4- 4- 4--T S.-%r0 %A 0 ..wo .tow 4- .0 ,0. id 0 470-- 0 0 t:_ lop -0 Co. +�' � �- of �► � yr ° � o CM tow S.- .v 0 U) 0 000 ran 0 cs 0 W cis --o- 0 4-0 41000 qw ,4* 40' %) S.-T 60 • rw 6) co Out "M%Vft f'- 0 4) %4- 4000 ,op- or 0 0 ..Ow 0 %n ..cdo-O cn 0 .000 to 4-- 0 0 S.- C�- Cf. 0 r4 S, 0 0 0 1:1 0 o i 0 0 moo a 0 0 4-- to '� p cs o � o � r� co cr 0 4- 0 0 0 Cf. 0 0 0 C%l 0 .0 of 0 N �,L,. 0 T O lu 400 3 Soo O 0 � t3- Soo4000 o Upoa N 3 0 Soot o S... O- L � d � v d 4001 400. to N d d �l �n mood y-too N � L O 'd d� per. 1� 00 N � ouloo 0 � d o loo � v V o mow N y- -a t. 0 Soo. •�- t) o F.1 d o ;0S o� 3 o v -00 �' X � p Q o � � �- Soo � a 4100, 0 3N o 0 0 � � o � C� a o CI'o 0 3;, t.- v N M � � a o o 0 N L 0 0 0 0 � ,.5 W G• � � tJ �r s- .. *00 0. 0 4 N� .0 �s dt 40 5: &.0 moop 60010 145 00000 doo -rs CP too CDlop ► ,,,► � o � � o 00000 *Now* JIG is t� .000- %kwo Soo cn 0 400-0 S 0 0 •� o cs - o 0 �cn ?' sow , car soom a •000 VPA 0 0 ° EXISTING ROADSIDE STAND • Size: 200-400 sq. ft. • Products: o Raw ago products only o Grown onsite o No drinks o No value-added items • Requirements o By right (no CU permit) o Bldg permit >120 sq. ft.