HomeMy WebLinkAbout10/16/2018 Item 20, Roth
From:Marie Roth <marie@slocollaborative.com>
Sent:Tuesday,
To:E-mail Council Website
Subject:Comments regarding Agenda dated 10-16-18 item # 20
Dear Honorable Mayor Harmon and SLO City Council Members,
I'd like to offer my 2 cents concerning application requirements for cannabis businesses here in
SLO City. This issue is very near and dear to my heart as I'd hoped many of our local producers
& providers would eventually realize the dream of legitimate business ownership, providing SLO
made products to this emerging market. It's a great opportunity for those who live, work and
play here. I do not want to see it handed to some outside entity that has no stake in San Luis
Obispo or the County. I've seen it happen all over the wine industry and it's disheartening.
I am the former director for San Luis Obispo County Cannabis Association. SLOCCBA is currently
being dissolved, simply due to banking issues. However, I am still keeping tabs on our local
cannabis industry development as myself, not hired or affiliated with any group.
Here are my humble remarks in response to the proposed applicant requirements:
Community Benefit: The applicant shall demonstrate to the satisfaction of the City of its intent
to local hiring and community support.
I think this really needs to be more defined. Intending is not doing. There are lots of
local folks who would love the opportunity to become a "bud tender", or to work in the
cannabis industry in some capacity but that might be considered as under qualified as
far as experience goes compared to another displaced stakeholder from Northern or
Southern CA with greater experience, and looking to relocate to the central
coast. Perhaps a ratio of local to outside employees would be considered? Or even
incentives for hiring locals?
• Education Plan: A plan describing the type of cannabis education and abuse prevention efforts
that will be provided by the business to the community.
In my eyes, this is essential. I would go a step further and suggest creating guidelines
for some collaboration between substance abuse and mental health treatment centers,
and even the County Public Health Dept. There's great potential to reach the
population most in need through the acceptance of the use of cannabis as a treatment
for anxiety, PTSD, and other social or environmental disorders. We've got to figure
this out as a community. No one's going to lose their federal funding for "listening" to
cannabis patients. And what better way to discover the actual needs of community
members?
Side note- I was so disappointed to learn that Transitions Mental Health actually let
one of their long time people go because of his use of cannabis. He was viewed as a
liability. This ought not be how our community treats it's own, especially those less
fortunate and in need of alternative medicine. Removing the prejudice will open up
communication and greater understanding of each other and ourselves.
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• Safety and Security Plan: A detailed safety and security plan outlining the measures that will
be taken to ensure the safety of persons and property on the business site. The safety and
security plan must be prepared by a qualified professional. It would be nice to encourage the
use of a local provider, of which we have right here in SLO County.
• Lighting Plan: A detailed lighting plan showing existing and proposed exterior and interior
lights that will provide adequate security lighting for the business site. Be considerate of light
pollution. Perhaps motion activated lights might be acceptable?
• Site Plan: A scaled site plan of the business site, including all buildings, structures, driveways,
parking lots, landscape areas and boundaries. The site plan must be professionally prepared by a
licensed civil engineer or architect.
• Floor Plan: A scaled floor plan for each level of each building that makes up the business site,
including the entrances, exits, walls and cultivation areas, if applicable. The floor plan must be
professionally prepared by a licensed civil engineer or architect. I wonder if this could all be
covered in the security plan. If the business can hire an experienced cannabis security
consultant would it be possible for that consultant to address not only the safety and
security, but the lighting, site and floor plan would all be taken into consideration and
perhaps save the business owner time and $$. In conjunction with a licensed civil
engineer or architect? Let's be reasonable when we can.
• Water Efficiency Plan: The applicant shall demonstrate to the satisfaction of the City that
sufficient water supply exists and that appropriate conservation measures for the use will be
implemented.
• Wastewater Plan: The applicant shall demonstrate to the satisfaction of the City that wastewater is minimized
through, but not limited to, water efficient processes, re-circulation, and recycling. What incentives does the
city offer for creative resource management? This should be for all businesses.
• Air Quality Plan: When deemed necessary by the City staff for purposes of compliance with
CEQA or state cannabis regulations, the applicant shall provide a calculation of the businesses
anticipated emissions of air pollutants and greenhouse gas. The applicant shall also provide
assurance that the business will comply with all Best Management Practices established by the
San Luis Obispo County Air Pollution Control District.
• Odor Control Plan: A detailed plan describing how the applicant will prevent all odors
generated from the cultivation, manufacturing and storage of cannabis from escaping from the
buildings on the business site, such that the odor cannot be detected by a reasonable person of
normal sensitivity outside the buildings. There should also be a detailed plan for
mitigation should there be a complaint. These businesses should not fear sudden
closure because someone mistook the smell a dead skunk near a cannabis business.
• Hazardous Materials Plan: To the extent that the applicant intends to store or use any
hazardous materials in its operations, the applicant shall provide a hazardous materials
management plan that complies with all federal, state and local requirements for management
of such substances. This is going to be a tricky one, but it could be handled brilliantly if
met with an open mind. Currently there is no real good solution for disposal of the
"hazardous" material if we're referring to plant material. I would propose
collaboration with creative companies (or Cal Poly) who would like to research how
best to recycle the materials that would be considered as waste. We need to think
through this part sustainably, not just wrapping it up in red plastic and considering it
hazardous waste, because it's not. It's all useful in some capacity.
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• Energy Efficiency Plan: Documentation that the applicant has identified the best way, including
carbon free power sources to provide reliable and efficient energy solutions for their business.
• Business Operations Plan:
o Business Plan: A plan describing how the cannabis cultivation business will operate in
accordance with City code, state law, and other applicable regulations. The business plan must
include plans for handling cash and transporting cannabis and cannabis products to and from the
cultivation site.
o Community Relations Plan: A plan describing who is designated as being responsible for
outreach and communication with the surrounding community, including the neighborhood and
businesses, and how the designee can be contacted.
o State Licenses: Copies of the state licenses relating to the commercial cannabis business
licenses, the applicant holds (when available). State licenses will not be issued to the
business until it has local authority (permission) to operate.
o Tax Compliance: A current copy of the applicant’s City business operations tax certificate,
state sales tax seller’s permit, and the applicant’s most recent year’s financial statement and tax
returns (for first time applicants, the business operations tax account will be set up in-house
after the application has been submitted).
o Insurance: The applicant’s certificate of commercial general liability insurance and
endorsements and certificates of all other insurance related to the operation of the cultivation
business.
o Budget: A copy of the applicant’s most recent annual budget for operations (if available) I'd
take out the (if available) and make this a requirement. My biggest concern for these
businesses is that they will come in, get started and having underestimated the cost of
doing business will be out of business in less than a year. That does not bode well for
the cannabis industry, therefore, setting a standard for best business practices, this
should be included in the business operations plan even if it's just a projection.
o Financial Capacity: Financial information such as bank balances, available loans and other
sources of funding for the enterprise. This is going to be a problem since it is illegal to
deposit money derived from the sale of an illegal substance into any federally insured
bank. Whether or not people are doing it, it could be used as evidence for money
laundering and should not be encouraged at this time. With luck and alot of hard work
happening on the federal level we could have some solutions coming our way after
mid-term elections provided we keep the same administration. My personal opinion is
that this admin wants to get this money into the economy. It's a monumental task to
make it happen, but I remain hopeful.
o Price List: A list of the most recent or expected prices for all products and services provided by
the applicant
Keep in mind I work with small family owned operations because I think that's more conducive
to the way we've traditionally supported Agra business here in SLO County. I'm aware of well
funded, larger, non native "corporate entities" looking to apply in SLO City. My first concern is
the experience I've had watching the dynamics within these "quilted" together businesses. It's
hard to really pinpoint where the money is coming from, there can be multiple LLC's associated,
often there's contention within the ranks and there can be quite a bit of turnover within
"management" or officers. I'm sure this happens with other companies, but given what we are
dealing with, it's made me somewhat apprehensive working with representatives from those
types of entities. Also if one is to consider the principles of "Anti Money Laundering", banks are
encouraged to do business transparently and with local people we know and trust. Obviously,
there's still much to unravel with the debut of legal cannabis into the legal marketplace.
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My other concern is, will those outside companies allow for a symbiotic relationship with our
local producers? How can we structure guidelines that cause the dispensaries to support
distribution from the local producers? I'm not saying there can't be a diversified state menu, but
we definitely want those larger entity resources to be available to help our local producers to be
competitive not only here in SLO but across the State as well.
That's the one thing we should really be cognoscente of, is our local cannabis economy being
nurtured by outside owned large dispensaries or will they be gobbled up and our local resources
exploited? Not unlike what we see happening in our wine industry in the North County of
SLO. For example, Company A is from Northern California and is looking to open several
dispensaries throughout CA. They also have partnered with growers and product suppliers in
Northern California. Company A opens in SLO City but only carries the products from the
providers they work with in Northern CA, leaving little to no shelf space for SLO grown or
produced products. How does that help us and our local producers? Conversely, what's to
protect our local industry from a grower using the resources here and selling product in another
jurisdiction? There needs to be some kind of cooperative, mutually beneficial relationship
between local growers, producers (manufacturers) and providers (dispensaries), in my opinion.
Thank you again for allowing me to comment, I regret not being able to added the proceedings
this evening, but keep up the great work!
Marie Roth,
(805) 712-5963
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