San Diego County Equestrian Foundation

SDCEF Ltr to Planning Commission re: Equine Ordinance

May 18, 2011

Chairman Leon Brooks

San Diego CountyPlanning Commission

5201 Ruffin Road, SuiteB

San Diego, CA 92123

Re: Options forUpdating Equine Regulations in the Zoning Ordinance, POD 10-010

Dear Chairman Brooksand Commissioners:

Thank you for your commitmentto establish new equine standards throughout San Diego County. We very muchappreciate having this opportunity to address these matters and look forward tothe completion of the process. Special thanks should be also given to staff fortheir time and dedication in bringing this process to fruition.

We support the Option Bapproach, a tiered ordinance which allows for all horse properties to bebrought into conformance with County law while enhancing owner’s abilities toparticipate in a wide variety of equestrian activities. The utility of thisapproach will be contingent on the structure of those tiers. We believe thesetiers should be based on the density of use at all facilities, meaning therelationship between the acreage of the horse ranch and number of horses onthat ranch. Using a density algorithm provides the means for simple permittingof low impact equestrian facilities while providing a mechanism to apply morestrict regulatory oversight for higher intensity use regardless of the size ofthe ranch.

At this juncture, weare not recommending specific ratios for a given hierarchy of permitting, butinstead we are proposing here a basis for a structure. We recommend that staffdevelop an ordinance that uses the average density for existing horse ranchesin the County as the basis for issuing an administrative permit. Less densitythan average would entail a ministerial permit, whereas greater density thanthe average would trigger a requirement for a Major Use permit. Once agreementon a permitting hierarchy approach is reached, it should be relativelystraightforward to craft the numerical standards.

That said,non-commercial uses are the most prominent equine activities throughout theCounty. For many horse owners, boarding horses can be a solution to the highcost of owning by reducing expenses.  As such, boarding by right should beallowed on all horse properties with a 1:1 ratio of owned to boarded horses.This boarding by right provision in a new ordinance would allow only boarding(no other commercial uses) and any owner/operator exploring additional uses(i.e., breeding, training, lessons, sales, etc.) would be required to get a usepermit. This structure preserves the horse community’s need for boarding byright while also protecting the larger community from the impacts of greaterscale operations/ uses.

Inconjunction with these revisions to the Zoning Ordinance, for the benefit ofboth horse owners and their neighbors, we are asking the County to develop astandardized set of Best Management Practices which every horse owner would berequired to implement. As long as an owner of a horse ranch meets thesepractices, they should be able to automatically be found by the County to beconforming and legal. This way, both neighbors and horse owners will beinformed as to their respective rights and responsibilities, thereby minimizingpotential code enforcement issues.

Additionally, werecommend the creation of a position for an ombudsman whose function is tofacilitate amicable resolution of potential code enforcement matters prior tocomplaints being filed.

Wehave many other, more detailed recommendations for your consideration as theprocess evolves. Thank you for taking these ideas into consideration as theCounty moves ahead with this important regulatory reform effort. Please do nothesitate to call me or our Executive Director, Jim Whalen, if you have anyquestions.

Very truly yours,


Michell A. Hunter


cc: San Diego CountyBoard of Supervisors

SDCEF Membership

Carl Stiehl, DPLU

Marcia Cook, DPW

Pam Elias, DPLU

SDCEF1042-B N El Camino Real, Ste. 414Encinitas, CA Copyright © 2010 SDCEF All Rights Reserved.