2520 Venture Oaks Way, Suite 100, Sacramento, CA 95833 | (916)646-5999 | cfca.energy April 17, 2026
Chula Vista City Council
276 Fourth Avenue
Chula Vista, CA 91910
RE: Comments On Potential Tobacco Policy Amendments
H
onorable Mayor and Councilmembers,
The California Fuels & Convenience Alliance (CFCA) represents a majority of California’s 12,000+ retail fuel and convenience store operators, including in the city of Chula Vista. We appreciate the opportunity to share our perspective as the City moves forward with exploring potential policy changes. Below, you will find CFCA’s recommendations for any tobacco policy amendments that the Council may consider.
POLICYMAKING DECISIONS SHOULD BE DRIVEN BY TRIED-AND-TRUE METHODS We understand and support the City’s intention to regulate safe and compliant tobacco sales.
However, we would caution against doing so while utilizing arbitrary regulatory tactics such as geographic distance restrictions from community-frequented areas and other retailers. These zoning restrictions could impose undue strain on small “mom-and-pop” convenience store operators. The CDC and U.S. Surgeon General have provided guidance for proven and effective tobacco regulation measures, many of which are successfully implemented throughout California. Some of these guidelines include taxation of tobacco products, bans on smoking in public spaces, public education campaigns, and strong enforcement and hefty fines for non- compliant retailers. Despite scrupulous studies regarding public health, there has not been a demonstrated causal link between tobacco retailer proximity and underage tobacco use. Hence, we strongly urge the Council to prioritize tried-and-true methods of tobacco regulation backed by evidence and real-world implementation, as opposed to arbitrary tactics that only serve to harm small businesses.
CURRENT TOBACCO REGULATIONS ARE EFFECTIVE
According to the City’s data on tobacco enforcement and inspections, the rates of compliance amongst Chula Vista’s tobacco retailers sit at an impressive 99% in 2025. This indicates that the City’s current tobacco regulatory structure has been exceptionally effective when implemented in full. Some recent violations involving flavored tobacco products stemmed from ambiguity regarding the new Unflavored Tobacco List (UTL), rather than being driven by malice. It is Written Communications
Item No. 8.5 Lam
4-17-26
2520 Venture Oaks Way, Suite 100, Sacramento, CA 95833 | (916)646-5999 | cfca.energy expected that following the publication of the new UTL, flavored tobacco violations will decline to nearly 100 percent compliance as a result of the added clarity.
Introducing additional regulations could only prove to hinder and complicate business operations for the City’s already-compliant tobacco retailer base.
THE CITY’S PENALTIES ARE ALREADY AMONG THE STRICTEST IN THE REGION In addition to Chula Vista’s existing tobacco regulatory structure, tobacco retailers are also subject to the City’s stringent penalty structure. Out of the 18 cities within the San Diego region, Chula Vista ranks in the top three for penalty severity. A 90-day and 365-day suspension for a retailer’s second and third violation respectively, coupled with a five-year lookback period, are what have led to the City’s success with tobacco regulation. We respectfully suggest that any and all penalties be made proportionate to violation severity and frequency, particularly for compliant retailers who may make unintended errors.
TOBACCO LICENSE TRANSFERABILITY PRESERVES BUSINESS EQUITY We recognize and applaud the City’s intention pertaining to the management of tobacco retailer density in certain neighborhoods. That said, any new caps on Tobacco Retail Licenses (TRL) should consider the financial realities of running a small business in today’s business landscape.
In an industry where a majority of businesses are family-owned and operated, businesses themselves could represent an operator’s primary retirement asset. Unlike workers with a traditional retirement pension or 401(k), these business owners rely on their business valuation at the time of sale to fund their retirement. As is the reality for many small retail convenience store operators in other municipalities, owning a store where TRL caps or geographic restrictions have been implemented, severely depreciates the business’ value and impacts the owner’s retirement possibilities. We respectfully urge the City not to include any caps on the number of TRL’s citywide, and to omit any language that would prohibit tobacco license transferability.
We respectfully urge City Council to enforce the current tobacco policy, emphasize tried-and- true methods of tobacco regulation, and prioritize Chula Vista’s local businesses when exploring potential policy changes moving forward. Thank you for your time and consideration.
Sincerely,
B
ryan Lam, Policy & Engagement Analyst
California Fuels & Convenience Alliance
From: Rana
To: CityClerk
Subject: Protect Responsible Small Businesses – Tobacco Retail Policy Feedback Date: Tuesday, April 21, 2026 10:53:14 AM
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Dear Mayor and Members of the City Council,
I am writing as a business owner/manager in Chula Vista to respectfully ask that you carefully consider the impact of any new tobacco retail regulations on small, responsible businesses like ours.
We do not support youth tobacco use or the sale of illegal products. We are committed to compliance by consistently checking identification, training staff, and adhering to all applicable laws and regulations. Responsible retailers should not be penalized for violations they actively work to prevent.
As you consider new policies, we strongly encourage the inclusion of protections for existing businesses in good standing. Specifically, we ask that current retailers be allowed to transfer ownership and continue operating under a new owner, regardless of caps or distance buffer requirements. A clear grandfathering provision is essential to ensure that business owners can sell their businesses without losing their livelihood or investment.
We also have concerns about adopting the proposed “massage business” enforcement model. Its lack of clarity may create uncertainty and increase the risk of inconsistent or unfair enforcement. Instead, we recommend strengthening the current system by incorporating a structured fine-based approach that supports increased inspections and consistent accountability.
Written Communications
Item No. 8.5 Habib
4-21-26
Additionally, when ownership changes, the new owner should be evaluated independently. Violations associated with a previous owner should not carry over, as this creates an unfair burden and discourages responsible business transitions.
We respectfully urge the City Council to focus enforcement efforts on addressing actual violations, while protecting businesses that are in compliance and contributing positively to the community. Thoughtful, balanced policies will help maintain public health goals without unintentionally harming small, law-abiding retailers.
Thank you for your time and consideration.
Sincerely,
Saad Habib
Broadway Smoke Shop in Chula Vista
04/21/2026