ZF #2022-0087: Public hearing to consider revocation of a Cannabis Use Permit issued to Edward Walker as Trustee of the Edward G. Walker 2019 Revocable Trust, which allowed the issuance of a cannabis cultivation license to Diamond Back Genetics for up to one acre of canopy on a 38-acre agriculturally-zoned parcel at 20910 County Road 79B, approximately 3.3 miles northwest of the town of Capay (APN: 048-060-008), and determine that the revocation of Cannabis Use Permit #2022-0087 is exempt from the California Environmental Quality Act (CEQA). (Permittee: Edward Walker/ Property Owner: Edward G. Walker 2019 Revocable Trust) (Planner: Jeff Anderson)

That the Planning Commission: 

On December 14, 2023, the Planning Commission unanimously approved a Cannabis Use Permit, issued to Edward Walker as Trustee of the Edward G. Walker 2019 Revocable Trust (Permittee) which allowed issuance of a cannabis cultivation license to Diamond Back Genetics for up to one acre of canopy (Attachment K). The project site is located on a 38-acre Agricultural Intensive (A-N) zoned parcel at 20910 County Road 79B, approximately 3.3 miles northwest of the town of Capay, within the Capay Valley. Due to Cannabis Land Use Ordinance buffer restrictions requiring a minimum 1,000-foot separation from outdoor cannabis uses to off-site residences, the Permittee proposed to relocate all cultivation operations into greenhouses. The Permittee did not request to construct additional greenhouses and was therefore limited to approximately 9,000 square feet (sf) of mature cannabis canopy within the existing greenhouses.

The Permittee cultivated cannabis under County and State licenses until March 31, 2025, when the County cannabis license expired. The Permittee’s State license expired on August 15, 2025. Both County and State licenses must be active in order to legally cultivate cannabis. Therefore, March 31, 2025, was the last day the Permittee could legally cultivate cannabis at the property. In May 2025, Sugarleaf Church notified Yolo County staff of its intent to cultivate cannabis at the Permittee’s property without obtaining a County license for the April 1, 2025, to March 31, 2026, license period. Later in 2025, the Yolo County Cannabis Unit verified that cannabis cultivation activities were occurring on the property without licenses. On September 11, 2025, the Yolo County Cannabis Unit served an Inspection and Abatement Warrant and issued a Notice of Violation to the Permittee for illegal cultivation without a license. The cultivation of cannabis without a license is in direct violation of the Cannabis Land Use Ordinance (YCC Section 8-2.1406(C)), Cannabis Licensing Ordinance (YCC Section 12-04.05), and the Project’s conditions of approval (COA #31). A detailed timeline outlining the illegal cannabis activities occurring on the property is provided below.

Pursuant to Section 8-2.217(f)(3), an action to revoke a Use Permit may be initiated by the order of the Board of Supervisors or Planning Commission, on its own motion or on the request of the Planning Director or Zoning Administrator, or his/her authorized designee. This action to revoke Cannabis Use Permit #2022-0087 is initiated on the request of Jeff Anderson, Principal Planner, authorized designee of the Planning Director, upon determination that there are reasonable grounds for revocation as summarized below and included in the findings in Attachment B. 

A revocation hearing is a quasi-judicial hearing. The Board of Supervisors adopted guidelines for quasi-judicial hearings which apply to procedures related to this hearing (Attachment C). As set forth in the guidelines, the chair of the Planning Commission may modify or waive provisions of the guidelines as appropriate. The guidelines do not create any additional rights and any failure to follow the guidelines shall not affect the validity of the hearing or decision made. [YCC Sec. 8-2.217(f)(4)(a)]

As provided in Yolo County Code Section 8-2.217(f)(4)(d), the public hearing shall be conducted as follows:

SUMMARY
The timeline of activities, below, demonstrates that the Permittee caused or allowed an unlicensed cannabis operation at the property. The timeline is compiled from documentation provided by the Yolo County Cannabis Unit and from the Administrative Hearing Decision and Order, dated January 16, 2026, by Katie Bellotti Porter, Hearing Officer (Attachment D).

March 31, 2025: Yolo County Cannabis cultivation license (PR0063359) expired.

April, 3, 2025: Yolo County Cannabis Unit conducted a close-out inspection of the property and verified that no cannabis plants or product were on the property (Attachment E).

May 25, 2025: Reverend Heidi Grossman-Lepp notified the County via email that Sugarleaf Church would be engaging in cannabis cultivation at the property under the stewardship of Ed Walker (Attachment F). Rev. Grossman-Lepp asserted that Sugarleaf Church is entitled to full legal protection under the Religious Freedom Restoration Act (RFRA) and is exempt from the County Cannabis Licensing Ordinance. Rev. Grossman-Lepp further claimed that the church had federal legal standing and authority to cultivate, distribute, and administer sacraments for spiritual purposes, and advised against interference. Additional emails continued.

May 27, 2025: The County responded to Rev. Grossman-Lepp’s email, explaining that the RFRA does not apply to state or local governments and that large-scale unlicensed cannabis cultivation is unlawful under state and local laws (Attachment G).

June 3, 2025: Nate Smith, Cannabis Inspector, contacted Grant Genho, Chief Financial Operator Diamond Back Genetics, cultivation site manager, and Mr. Walker’s grandson. Mr. Genho confirmed that the property owner intended to cultivate commercial cannabis at the property without renewing its County Cannabis Cultivation license for the April 1, 2025, to March 31, 2026, license period.

June 6, 2025: Rev. Grossman-Lepp sent an email to the County asserting that Sugarleaf Church was under no obligation to comply with the Yolo County Code pursuant to the RFRA, the Religious Land Use and Institutionalized Persons Act (RLUIPA), and the First Amendment of the Constitution of the United States. The County requested information and documentation regarding Sugarleaf Church’s formation, operation, claimed religious status, and religious beliefs and practices. Rev. Grossman-Lepp refused to provide any such information and did not provide any of the information during the subsequent administrative hearing (see below). Despite multiple requests from the County, no information was provided as to the legal relationship between the Permittee and Rev. Grossman-Lepp/Sugarleaf Church, such as a lease agreement or other evidence establishing a legal right to the illegal cannabis grown on the property.

August 5, 2025: Nate Smith, using aerial imagery, observed cannabis cultivation on the property. Mr. Smith observed plants growing in three separate outdoor cultivation areas and one uncovered greenhouse (Attachment H).

September 9, 2025: The County obtained an inspection warrant to inspect the property for an illegal cannabis operation.

September 11, 2025: The County executed the inspection warrant, located a large-scale, unlicensed cannabis operation at the property, and issued a Notice of Violation (Attachment I). The Notice of Violation stated that conditions existed that violated Yolo County Code sections 12-04.05 and 12-04.08 and imposed administrative fines and fees. While serving the inspection warrant, the County observed and recorded 1,713 cannabis plants on the property and seized approximately 247 pounds of processed cannabis, which tested positive for THC levels exceeding one percent.

October 15, 2025: Aerial imagery obtained by the County confirmed that the cannabis at the property, as documented in the Notice of Violation, had not been abated (Attachment J).

October 29, 2025: The California Department of Cannabis Control inspected the property and removed all of the remaining cannabis. The eradicated cannabis plants and dried processed cannabis product were taken to the landfill for disposal.

December 3, 2025: Administrative hearing held with Katie B. Porter, Hearing Officer, to determine whether to uphold the Notice of Violation, Unlawful Cannabis Operation (Yolo County Code Title 12, Chapter 4, et seq.) issued by the County on September 11, 2025. Present at the Administrative Hearing were Cedric Hopkins, Senior Deputy County Counsel, Nate Smith, County Cannabis Inspector, Christina Gonzalez, County Cannabis Inspector, Cassandra Mendoza, Associate Cannabis Program Analyst, Ed Walker, property owner, Grant Genho, Mr. Walker’s grandson, and Reverend Heidi Grossman-Lepp, on behalf of Sugarleaf Church.

January 16, 2026: Katie B. Porter, Hearing Officer, issued an Order affirming the Notice of Violation dated September 11, 2025, for violations of Yolo County Code Sections 12-04.05 and 12-04.08 (Attachment D). The Order stated the total administrative penalties and costs imposed are $151,341, plus the costs of the administrative hearing upon receipt of an invoice from the County and any future costs and expenses related to, arising out of, or incurred by the County relating to enforcement or abatement action pertaining to this matter upon receipt of an invoice from the County. Additionally, all cannabis seized by the County in connection with the enforcement action, having been unlawfully cultivated without a valid license, shall be destroyed by the County in accordance with applicable law, as part of the completed abatement of the violations. The County destroyed the cannabis at the County landfill on January 21, 2026. The Order required payment of penalties and costs in the amount of $151,341 to be made to the County within twenty calendar days of the service of the Decision (February 5, 2026), unless timely appealed to the Superior Court in accordance with Government Code section 53069.4, subdivision (b) (Yolo County Code Section 12-04.20(J)).

February 2, 2026: Petition for Writ of Mandamus and a Motion to Stay filed against County of Yolo Department of Community Services/Environmental Health/Cannabis Task Force by Edward G. Walker, as Trustee of the Edward G. Walker 2019 Revocable Trust, and Reverend Heidi Grossman-Lepp, Sugarleaf Church. A hearing has been set for April 2, 2026, to set a briefing schedule. The filing of this Petition does not preclude the Planning Commission from hearing and deciding the matter addressed in this staff report. 

ANALYSIS
Under Yolo County Code Section 8-2.217(f)(1) and 8-2.1412(A), a use permit may be revoked if the Planning Commission makes an affirmative finding on one or more of the grounds set forth below. Staff has included only those grounds in Sections 8-2.217(f)(1) and 8-2.1412(A) that are applicable to the revocation of Cannabis Use Permit #2022-0087. A summary of the evidence to support each finding is included in Attachment B.    

Section 8-2.217(f)(1) Use Permits: 

Section 8-2.1412(A) Enforcement: 

As documented in the Notice of Violation issued by the Cannabis Unit on September 11, 2025, and as evidenced by determinations set forth in the Administrative Hearing Decision and Order, it is undisputed that neither Edward Walker, as Trustee of the Edward G. Walker 2019 Revocable Trust (Permittee and property owner), nor Sugarleaf Church possessed a cannabis license issued by the County to cultivate cannabis at the property. The defiance of the Permittee to willfully not obtain a license to cultivate cannabis is in clear violation of the Yolo County Code. Cannabis Land Use Ordinance Section 8-2.1406(C) states: “Each permitted cannabis use requires a County Cannabis License. The County Cannabis License is assigned to the licensee and is not transferrable, unless approved by the County.” Similarly, Cannabis Licensing Ordinance Section 12-04.05(A) states: “It shall be unlawful for any person to engage in any cannabis operation in the unincorporated areas of Yolo County without possessing a valid and current license for such business.” The purpose of the cannabis licensing program is to regulate commercial cannabis activities in a manner that preserves the public peace, health, safety, and general welfare of the citizens of Yolo County and the environment.

Despite being notified of these requirements and given the opportunity to comply, the Permittee refused to obtain the required license and nevertheless cultivated cannabis on the property. This conduct violates the conditions of the Use Permit, the County’s Cannabis Land Use Ordinance, and state law under the Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA), which requires commercial cannabis cultivators to obtain all required local authorizations prior to commencing cultivation. By cultivating cannabis without a license, the Permittee operated an unregulated cannabis cultivation site rather than the licensed, compliant operation reviewed and approved by the County. This bypassed the regulatory safeguards intended to protect public health and safety—such as environmental oversight, security standards, odor control, pesticide management, and operational inspections—and prevented the County from verifying compliance with required standards. The Permittee’s refusal to obtain the required license materially altered the nature and scope of the approved use, created conditions contrary to public welfare, and constitutes a clear violation of both County Code and state cannabis regulations. Additionally, the property owner is delinquent payments owed to the County, including cannabis taxes, property taxes, and application review fees.   

NEXT STEPS
Should the Planning Commission decide to revoke Cannabis Use Permit #2022-0087, staff will file the Notice of Exemption with the County Clerk-Recorder. Should no appeals be filed within the 15-day appeal period, the revocation will take effect on April 24, 2026. Pursuant to Cannabis Land Use Ordinance Section 8-2.1412(C), upon revocation of a Cannabis Use permit of a permitted cultivation site, the Permittee and/or property owner shall remove all materials, equipment, and improvements on the site that were used in connection with the cannabis use and that are not adaptable to non-cannabis permitted use of the site. If any of the materials, equipment, or infrastructure is to remain, the Permittee and/or property owner shall prepare a restoration plan and description of the non-cannabis continued use of such material or equipment on the site. The property owner shall be responsible for execution of the restoration plan, subject to monitoring and periodic inspection by the County. Failure to adequately execute the plan shall be subject to enforcement.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) REVIEW
The revocation of Cannabis Use Permit  #2022-0087 has been determined to be exempt from environmental review pursuant to CEQA Guidelines (Public Resources Code Section 21080(b)(9); Administrative Code, Title 14, Chapter 3, Section 15321, Class 21, Enforcement Actions by Regulatory Agencies), and there are no features that distinguish this project from others in the exempt class; therefore, there are no unusual circumstances. Section 15321 exempts actions by regulatory agencies to enforce or revoke a lease, permit, license, certificate, or other entitlement for use issued, adopted, or prescribed by the regulatory agency or enforcement of a law, general rule, standard, or objective, administered by the regulatory agency. Staff will file a Notice of Exemption (Attachment A) upon direction by the Planning Commission.

SUMMARY OF PUBLIC CORRESPONDENCE 
County staff sent the Permittee a Notice of Intention to Revoke Cannabis Use Permit #2022-0087 via email and USPS mail on March 23, 2026, notifying the Permittee that the County has initiated proceedings to revoke their Cannabis Use Permit, including the date and time of the April 9, 2026, Planning Commission hearing. A public hearing notice was mailed to the Permittee/property owner and property owners within 1,000 feet of the property, and to interested parties who previously requested notification on matters relating to ZF #2022-0087 on March 27, 2026, and published in the Davis Enterprise on March 29, 2026.

Any person who is dissatisfied with the decisions of this Planning Commission may appeal to the Board of Supervisors by filing a notice of appeal with the Clerk of the Board within fifteen (15) days from the date of the action. A Planning Commission Appeal Form and appeal fee immediately payable to “County of Yolo” must be submitted at the time of filing. The Board of Supervisors may sustain, modify or overrule this decision. The Planning Commission Appeal Form can be accessed at the following link: https://www.yolocounty.org/government/board-of-supervisors/clerk-of-the-board/planning-commission-appeal