HomeMy WebLinkAboutC-20-49 Komotos RedactedApplicant (Entity) Information
Application Type
Proposed Location
Commercial Cannabis Business
Permit Application
C-20-49
Submitted On: Dec 04, 2020
Applicant
Robyn Kale
Applicant (Entity) Name:
RKNC LLC
DBA:
Komoto's
Physical Address:
1536 Kern Street
City:
Fresno
State:
CA
Zip Code:
93706
Primary Contact Same as Above?
No
Primary Contact Name:
Robyn Kale
Primary Contact Title:
Chief Executive Officer
Primary Contact Address:
Primary Contact City:
Fresno
Primary Contact State:
CA
Primary Contact Zip Code:
93711
Primary Contact Phone:
Primary Contact Email:HAS ANY INDIVIDUAL IN THIS APPLICATION APPLIED FOR
ANY OTHER CANNABIS PERMIT IN THE CITY OF FRESNO?:
No
Select one or more of the following categories. For each
category, indicate whether you are applying for Adult-Use (“A”)
or/and Medicinal (“M”) or both
Both
Please make one selection for permit type. If making multiple
applications, please submit a new application for each permit
type and proposed location.
Permit Type
Retail (Storefront)
Business Formation Documentation:
Limited Liability Company
Property Owner Name:
Jennifer S. Blanton
Proposed Location Address:
1536 Kern St.
City:
Fresno
State:
CA
Zip Code:Property Owner Phone:
Supporting Information
Application Certification
Owner Information
93706 1-408-310-2233
Property Owner Email:
nora@monaco.us.com
Assessor's Parcel Number (APN):
46707201
Proposed Location Square Footage:
3500
List all fictitious business names the applicant is operating under including the address where each business is located:
Komoto's
Has the Applicant or any of its owners been the subject of any
administrative action, including but not limited to suspension,
denial, or revocation of a cannabis business license at any time
during the past three (3) years?
No
Is the Applicant or any of its owners currently involved in an
application process in any other jurisdiction?
No
I hereby certify, under penalty of perjury, on behalf of myself
and all owners, managers and supervisors identified in this
application that the statements and information furnished in this
application and the attached exhibits present the data and
information required for this initial evaluation to the best of my
ability, and that the facts, statements, and information
presented are true and correct to the best of my knowledge and
belief. I understand that a misrepresentation of fact is cause for
rejection of this application, denial of the permit, or revocation
of a permit issued.
In addition, I understand that the filing of this application grants
the City of Fresno permission to reproduce submitted materials
for distribution to staff, Commission, Board and City Council
Members, and other Agencies to process the application.
Nothing in this consent, however, shall entitle any person to
make use of the intellectual property in plans, exhibits, and
photographs for any purpose unrelated to the City's
consideration of this application.
Furthermore, by submitting this application, I understand and
agree that any business resulting from an approval shall be
maintained and operated in accordance with requirements of
the City of Fresno Municipal Code and State law. Under penalty
of perjury, I hereby declare that the information contained in
within and submitted with the application is true, complete, and
accurate. Iunderstand that a misrepresentation of the facts is
cause for rejection of this application, denial of a permit or
revocation of an issued permit. A denial or revocation on these
grounds shall not be appealable (FMC 9-3319(d)).
Name and Digital Signature
true
Title
Chief Executive Officer
Please note: the issuance of a permit will be determined based
on the application you submit and any major changes to your
business or proposal (i.e. ownership, location, etc.) after your
application is submitted may result in a denial.
All applications submitted are considered public documents for
Public Records Act request purposes.
For details about the information required as part of the
application process, see the Application Procedures &
Guidelines, City of Fresno Municipal Code Article 33 and any
additional requirements to complete the application process. All
documents can be found online via this link.
For questions please contact the City Manager’s Office at
559.621.5555.
Business Name: Komoto's
Application #: C-20-49
CANNABIS BUSINESS PERMIT APPLICATION REVIEW - RETAIL Points
Possible
All or
None Exceptional Good Acceptable
Applicant
Score
Evaluation Notes (Explain each time points are
deducted)
SECTION 1: BUSINESS PLAN 300 Points Possible for Section 1
Resume:
Resumes Provided for All Owners: Score 5 5 5
Resumes Provided in 2-page Format: Score 2 2 2
Education: (select highest academic level among ownership team, cannabis specific education
separately)
Cannabis specific education/training (accredited)2 2 0 not described
High School Degree Reported: Score 4 4 -
Bachelor's Degree Reported: Score 6 6 -
Master's Degree or Higher Reported: Score 8 8 8
Experience: (among ownership team, select one at highest level)
Regulated Cannabis Retail Ownership Experience CA 13 13 -
Regulated Cannabis Retail Experience CA (management level or below): Score 10 10 -
Other Retail Business Experience Reported, More than 5 years: or 8 8 8
Other Retail Business Experience Reported, Less than 5 Years: Score 5 5 -
1.1 Sub-Total:30 23
Construction Cost Estimate:
Construction Cost Estimate Provided: Score 8 8 6 4 8
very detailed w/ additional explanations and
breakdowns
Construction Contingency Factor Included: Score 6 6 6
All Labor, Trades, Materials, Supplies and Permits and other Cost Factors Identified: Score 6 6 4 2 6 Includes permits, materials, atty fees, etc.
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 3
Current market projections, seasoned
professionals & historic district requirements
Operation and Maintenance Cost Estimates:
Operation and Maintenance Cost Estimate Provided: Score 8 8 6 4 8
very detailed w/ additional explanations and
breakdowns
All Labor, Trades, Materials, Supplies, Utilities, and other Cost Factors Identified: Score 6 6 4 2 6
Annual Cost Escalators for Operating Costs Provided: Score 6 6 4 2 6 Costs escalated and explained
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 3
Current market projections, seasoned
professionals
1.2 Sub-Total:50 46
Proof of Capitalization Specific to one or more Owners: Score 5 5 5
1.1 Owner qualifications. Resumes are not to exceed two (2) pages per owner. (30 points possible)
1.2 A budget for construction, operation, and maintenance, compensation of employees, equipment costs, utility cost, and other operation costs.(50 points possible)
1.3 Proof of capitalization in the form of documentation of cash or other liquid assets on hand, Letters of Credit or other equivalent assets which can be verified by the City. (50 Points Possible)
Criteria Narrative:
Criteria Narrative:
i. Describe customer check-in procedures.
20 20 15 10 15
Doesn't describe type of ID's accepted or how they
or medical MJ recommendation is validated
II. Identify location and procedures for receiving deliveries during business hours.10 10 8 6 10
iii. Identify the name of the Point-of-sale system to be used and the number of Point-of-Sale locations.10 10 10 COVA, doesn't describe number of locations
iv. The estimated number of customers to be served per hour/day.20 20 15 10 20
v. Describe the proposed product line to be sold and estimate the percentage of sales of flower and
manufactured products.20 20 15 10 10
Did not estimate the percentage of sales for various
products.
vi. If proposed, describe delivery service procedures, number of vehicles and product security during
transportation. (if no delivery service application must state this clearly for full points)20 20 15 10 20
1.6 Sub-Total:100 85
Section 1 Total:300 217
SECTION 2: SOCIAL POLICY AND LOCAL ENTERPRISE 400 Points Possible for Section 2
Description of Commitment to pay a Living Wage provided: Score 10 10 8 6 10
Definition of Living Wage Provided: Score 5 5 4 3 5
Living Wage Defined as Greater than Minimum Wage: Score 5 5 5
2.1 Sub-Total:20 20
Wages and Salary
CCB Entry-Level Hourly Wage Greater than Minimum Wage 5 5 5 minimum
CCB Entry-Level Annual Salary Greater than Median Household Income ($50,432)5 5 0
Health Care Benefits
CCB Offers Medical Coverage to All Employees: Score 5 5 5
CCB Offers Dental Coverage to All Employees: Score 3 3 3
CCB Offers Vision Coverage to All Employees: Score 3 3 3
CCB Offers Health Reimbursement Account for Qualified Medical Expenses: Score 1 1 0
Employee Pays $0 for Employee Medical Premium: Score 3 3 0 Premiums not described
Employee Pays $0 for Employee Dental Premium: Score 2 2 0
Employee Pays $0 for Employee Vision Premium: Score 2 2 0
Employee Pays less than $500 per month for Family Health Care Coverage (Medical, Dental, Vision):
Score 2 2 0
Leave Benefits
Number of Paid Vacation/PTO Days Per Year: (10+ days = excep; 6-9 days = Good; 3-5 days Acceptable)5 5 4 3 3 offered but unspecified # of days
Number of Paid Holidays Per Year: (10 or more paid holidays = excep; 4-10 = Good; 1-3 Acceptable)5 5 4 3 0 unspecified
Number of days paid time off for Sick/Medical time: (7+ days= Exceptional, 4-6 days = Good, 3 days =
acceptable (8 hour day))5 5 4 3 3 offered but unspecified # of days
Retirement
2.1 Describe whether the Commercial Cannabis Business is committed to offering employees a Living Wage. (20 points possible)
Scoring Guidance: https://livingwage.mit.edu/counties/06019
2.2 Briefly describe benefits provided to employees such as health care, vacation, and medical leave, to the degree they are offered as part of employment. (50 points possible)
Criteria Narrative:
Criteria Narrative:
Offers employee retirement plan 2 2 2
Offers company match for employee retirement plan 2 2 2
2.2 Sub-Total:50 26
CCB Provides Tuition Reimbursement for Certificates: Score 3 3 3 Approved degree program- 1/2 tuition
CCB Provides Tuition Reimbursement for associate degrees: Score 3 3 3 Approved degree program- 1/2 tuition
CCB Provides Tuition Reimbursement for bachelor's degrees: Score 3 3 3 Approved degree program- 1/2 tuition
CCB Provides Tuition Reimbursement for master's degrees: Score 3 3 3 Approved degree program- 1/2 tuition
CCB Provides Tuition Reimbursement for Specialized Commercial Cannabis Business Operations
Training: Score 3 3 3 Approved degree program- 1/2 tuition
CCB Offers General Training for Health and Safety, Workplace Environment, Customer Service, etc. 5 5 4 3 4
referred to training and discussed tracking but did
not list topics.
2.3 Sub-Total:20 19
General Recruitment Plan Provided: Score 10 10 8 6 10
Social Policy Recruitment Plan Provided: Score 10 10 8 6 10
Recruitment Plan Includes Demographic Data for District, City or County: Score 10 10 8 6 0
Recruitment Plan Includes List of CBOs, Non-Profits and Public-Agency Hiring Partners: Score 10 10 8 6 10
Recruitment Plan Includes Hiring Targets (percentages) by Demographic Groups: Score 10 10 8 6 6
committed to FMC targets, did not describe
additional demographic targets
2.4 Sub-Total:50 36
Owners
Number of Owners:4
Number of Owners that live within the City of Fresno:2
Number of Owners that live in the County of Fresno:0
Number of Owners that Own a Business in the City of Fresno:1
51%+ ownership interest percent of the Owners live or own a business in the City: Score 80 80 80
51%+ ownership interest percent of the Owners live or own a business in the County: Score 40 40 -
Less than 50 percent equity of the Owners live or own a business in the City (If no owners are local,
score zero)20 20 -
Managers
Number of Managers (salaried, non-owners)15
Number of Managers that live in the City of Fresno:6
Number of Managers that Own a Business in the City of Fresno:1
100 percent of the Managers live or own a business in the City: Score 20 20 -
2.3 Describe compensation to and opportunities for continuing education and employee training.(20 points possible)
2.4 Describe the Commercial Cannabis Business plan to recruit individuals who meet the criteria listed in the Social Policy Section 9-3316 (b) (1) of the Fresno Municipal Code (FMC) and the percentage of local employees it hires. (50
points possible)
2.5 Describe the extent to which the Commercial Cannabis Business will be a locally managed enterprise whose owners and /or managers reside within or own a commercial business within the City of Fresno, for at least one year prior
to March 2, 2020.(80 points possible)
Data, non-scored. Write response in Evaluation Notes
column.
IF full points achieved for Ownership category, don't score managers.
Section is total of 80 points possible.
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Data, non-scored. Write response in Evaluation Notes
column.
75 to 99 percent of the Managers live or own a business in the City: Score 15 15 -
50 to 74 percent of the Managers live or own a business in the City: Score 10 10 10
Less than 50 percent of the Managers live or own a business in the City: Score 5 5 -
2.5 Sub-Total:80 80
Responsibilities Described for All Titles/Positions: Score 20 20 15 10 20
2.6 Sub-Total:20 20
Does CCB have more than five employees: 5 5 5
CCB has signed a peace agreement: Score 5 5 5
2.7 Sub-Total:10 10
Work Force Plan Provided: Score 10 10 8 6 10
Commitment to Local Hire Provided:10 10 8 6 10
Commitment to Offer Apprenticeships Provided:10 10 8 6 0 No discussion of apprenticeships
Commitment paying for continuing education provided 10 10 8 6 6
committed but no specifics of benefit (i.e.
maximum, qualification)
Description of commitment to paying a living wage provide. (Score same as sec. 2.1)10 10 8 6 10
2.8 Sub-Total:50 36
CCB is willing to serve as Social Equity Business Incubator: Score 100 100 80 60 100
Mentorship and Training: Score yes
Equipment Donation: Score yes
Shelf Space: Score 20%
Legal Assistance: Score
Finance Services Assistance: Score
Other Technical Assistance: Score
Scoring Guidance: full points for willingness to serve with detailed plan offering at least three aspects
mentioned above or of similar benefit. Less points for willingness to serve but vague or unclear
commitment. Zero points if there is no clear commitment to serve as Incubator.
2.9 Sub-Total:100 100
Data to inform score on first line of this section. Write
response in Evaluation Notes column.
2.8.3. Commitment to pay a living wage to its employees
2.6 Describe the number of employees, title/position and their respected responsibilities.(20 points possible)
2.7 Describe whether the CCB has five (5) or more employees and whether it has signed a labor peace agreement allowing employees to unionize without interference. (10 points possible)
2.8 Provide a workforce plan that includes at a minimum the following provisions: (50 points possible)
2.8.1. Commitment for 30% of employees to be local hires; the business must show that it has either hired or made a good faith effort to hire bona fide residents of Fresno who have not established residency after the submission of an
application for employment with the applicant/permittee.
2.8.2. Commitment to offer apprenticeships and/or compensation for continuing education in the field; and
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
2.9 Describe whether the business is willing to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf
space dedicated to Fresno equity business products, legal assistance, financial services assistance, or other technical assistance support.(100 points possible)
Section 2 Total:400 347
SECTION 3: NEIGHBORHOOD COMPATIBILITY PLAN 300 Points Possible for Section 3
CCB will document complaints (time of complaint, nature of complaint, resolution of complaint): Score 10 10 8 6 10
CCB will established a dedicated contact person to receive complaints: Score 10 10 10
CCB will establish a dedicated phone number to receive complaints: Score 5 5 5
CCB will establish a dedicated email address to receive complaints: Score 5 5 5
CCB will establish a response time standard for returning complaint calls and emails: Score 5 5 5
CCB will schedule or participate in periodic community meetings to engage with residents about the CCB
operation: Score 10 10 0 Info not provided
Other measure unique to business (i.e. website complaint form)5 5 5
Scoring Guidance: full points for detailed proactive plan addressing all aspects mentioned. Dock points
for leaving out aspect, vagueness, or reactive plans.
3.1 Sub-Total:50 40
CCB will maintain a listserv of community residents to update and information residents of business
operations.
10 10 0 Info not provided
CCB will schedule or attend periodic community meetings (at least annually) to engage with residents
about the CCB operation: Score 10 10 0 Info not provided
CCB will prepare a community outreach and engagement plan: Score 50 50 40 30 40 Needs more detail
CCB will issue periodic Newsletters to community providing information about CCB operations 10 10 0 Info not provided
CCB will hire residents from the community work at the CCB: Score 20 20 0 Info not provided
Scoring Guidance: full points for detailed proactive plan. Dock points for leaving out aspect, vagueness,
or reactive plans.
3.2 Sub-Total:100 40
CCB has identified sensitive receptors to nuisance odors in vicinity of business operations: Score 5 5 5 Stated in Section 3.4
CCB has prepared a nuisance odor control plan: Score 10 10 8 6 10
Nuisance odor control plan identifies locations where fugitive emissions may exit the premise boundary:
Score 5 5 5
Nuisance odor control plan describes specific odor control measures to reduce fugitive emissions exiting
the premise boundary: Score 5 5 5
CCB has established an odor reporting system: Score 5 5 5 Stated in Section 3.1
CCB will install a nuisance odor monitoring system: Score 10 10 10 Stated in Section 3.1
3.3 Describe odor mitigation practices.(40 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
3.1 Describe how the CCB will proactively address and respond to complaints related to noise, light, odor, litter, vehicles, and pedestrian traffic.(50 points possible)
3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having impacts on its neighbors and the surrounding community.(100 points possible)
3.3 Sub-Total:40 40
CCB has identified the potential sources of nuisance odors for the business operation: Score 10 10 8 6 10
Scoring Guidance: full points for detailed proactive plan. Dock points for vagueness or reactive plans.
3.4 Sub-Total:10 10
Nuisance odor control plan describes specific odor control equipment: Score 10 10 8 6 10
Nuisance odor control plan describes specific odor control measures/techniques: Score 10 10 8 6 10
Odor control measures are identified for different nuisance odor sources: Score 10 10 10
3.5 Sub-Total:30 30
Nuisance odor control plan describes the operation, monitoring, and maintenance requirements for
odor control measures: Score 10 10 10
Nuisance odor control plan describes the staff training required for system operations, maintenance,
repair, and troubleshooting.10 10 10
3.6 Sub-Total:20 20
CCB has identified the sources of waste generated by the business operation: Score
10 10 10
CCB has prepared a source-separation plan to segregate different sources of waste generated by
business operations: Score 10 10 10
The source-separation plan identifies policy, procedures, and locations where different sources of waste
are to be collected for disposal: Score 10 10 8 6 8 Needs more detail
The source-separation plan describes specific measures to control the collection and disposal cannabis
waste: Score 10 10 10
The name of licensed cannabis disposal company provided: Score 10 10 0 Info not provided
3.7 Sub-Total:50 38
Section 3 Total:300 218
SECTION 4: SAFETY PLAN 300 Points Possible for Section 4
Safety Plan Prepared by Consultant: Score 10 10 0 no consultant hired
Safey Plan Assessed by Consultant: Score (if prepared by, also give points for assessed by)10 10 0 "
Safety Plan Prepared for CCB Address (specific proposed location): Score 10 10 0 "
Safety Plan includes Site Plan of Premise: Score 10 10 10
3.4 Identify potential sources of odor. (10 points possible)
3.5 Describe odor control devices and techniques employed to ensure that odors from cannabis are not detectable beyond the permitted premises. (30 points possible)
3.6 Describe all proposed staff odor training and system maintenance.(20 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
4.1 The Safety Plan shall be prepared and/or assessed by a professional fire prevention and suppression consultant. (50 points possible)
Criteria Narrative:
3.7 Describe the waste management plan. (50 points possible)
Safety Plan includes Building Layout Plan: Score 10 10 10
4.1 Sub-Total:50 20
Written Accident/Incident Procedure Provided: Score 20 20 15 10 0 none
Procedures Address Multiple Accident/Incident Scenarios: Score 10 10 8 6 0 no proceedures
Total Number of Scenarios Described: Score 0
Active Shooter Incident Described: Score 10 10 0 not mentioned
Robbery Incident Described: Score 10 10 2 mentioned robbery no details
4.2 Sub-Total:50 2
Evacuation Plan Provided: Score 20 20 15 10 20
Adequate Number of Evacuation Routes Identified: Score 20 20 15 10 20
Evacuation Route Distance to Public Right of Way: Score 10 10 8 6 10
4.3 Sub-Total:50 50
Location of Fire Suppression System Elements Identified: Score 10 10 10
Type of Fire Suppression System Elements Identified: Score 20 20 15 10 20
Location of Fire Extinguishers Identified: Score 10 10 10
Adequate Number of Fire Extinguisher Locations Identified: Score 10 10 8 6 10
4.4 Sub-Total:50 50
Written Procedure for Fire Emergencies Provided: Score 20 20 15 10 0 none
Written Procedure for Medical Emergencies Provided: Score 20 20 15 10 0 none mentioned
Cardiac Arrest Medical Emergency Described: Score 20 20 15 10 0 not mentioned
Gunshot Wound Medical Emergency Described: Score 20 20 15 10 0 "
Other Medical Emergency Conditions Described: Score 20 20 15 10 0 "
4.5 Sub-Total:100 0
Section 4 Total:300 122
SECTION 5: SECURITY PLAN 300 Points Possible for Section 5
Security Plan Prepared by Consultant: Score 10 10 0 Prepared internally
Security Plan Assessed by Consultant(if prepared by, also give points for assessed by): Score 10 10 10
Security Plan Prepared for CCB Address (specific proposed location): Score 10 10 10
Security Plan includes Site Plan of Premise: Score 10 10 10
Data-write response in Evaluation Notes Column
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
4.4 Location of fire extinguishers and other fire suppression equipment. (50 points possible)
Criteria Narrative:
4.5 Describe procedures and training for all fire and medical emergencies.(100 points possible)
5.1 The Security Plan shall be prepared and/or assessed by a professional security consultant.(50 points possible)
4.3 Describe evacuation routes. (50 points possible)
4.2 Describe accident and incident reporting procedures. (50 points possible)
Criteria Narrative:
Security Plan includes Building Layout Plan: Score 10 10 10
5.1 Sub-Total:50 40
Premises (Security) Diagram Provided: Score 20 20 15 10 20
Diagram is drawn to correct scale: Score 5 5 5
Diagram provides required details for premise: Score 5 5 5
Diagram shows the location of all security cameras: Score 5 5 5
Descriptions of activities to be conducted in each area of the premise 5 5 5
Limited-Access Areas Clearly Marked: Score 5 5 5
Number and Location of All Security Cameras Identified: Score 5 5 5
5.2 Sub-Total:50 50
Intrusion Alarm and Monitoring System Identified: Score 15 15 15
Name and Contact Information for Monitoring Company Provided: Score 5 5 0 No mention
Total Points of Entry into Premise Identified: Score 5 5 5
All Points of Entry to be Alarmed Identified:5 5 5
Type of Alarm Identified (motion, infrared, glass break, etc.): Score 10 10 10
Backup Power Supply Identified: Score 10 10 10
5.3 Sub-Total:50 45
Written Cash-Handling Procedure Provided: Score 30 30 20 15 30
Dual-Custody is Practiced for all cash handling: Score 10 10 0 No mention of dual custody
Video Surveillance Used to Monitor All Cash Handling: Score 20 20 20
Armored Car Service Used for Bank Deposits: Score 10 10 10
All Cash Deposited weekly with Bank: Score 10 10 10
Onsite Vault Provided to Secure Cash Prior to Bank Deposit: Score 20 20 20
5.4 Sub-Total:100 90
5.2 Premises (Security) Diagram. In addition to diagrams submitted for other sections of the application, applicants are expected to submit a premises diagram (or site plan) which, focuses on the proposed security measures and how
they relate to the overall business. (Pursuant to CCR Title 16, Division 42, §5006. Premises Diagram).
5.2.1 The diagram shall be accurate, dimensioned and to scale (minimum scale ¼"). The scale may be smaller if the proposed location exceeds more than a 1/2-acre parcel but must not be printed on larger than an 11" x 17" sheet of
paper. (Blueprints and engineering site plans are not required at this point of the application process)
5.2.2 The diagram must be drawn to scale and clearly identify property boundaries, entrances, exits, interior partitions, walls, rooms, windows, and doorways. The activity in each room and the location of all cameras must be
identified in the diagram.
Criteria Narrative:
5.2.4 Limited-access areas, defined as areas in which cannabis goods are stored or held and only accessible to permittees, or its employees or contractors and areas used for video surveillance monitoring and storage devices
(Pursuant to CCR Title 16, Division 42, §5000 (m) Limited-Access Area and §5042 Limited-Access Area.
5.2.5 Number and location of all video surveillance cameras. (50 points possible)
5.4 Briefly describe cash handling procedures which covers day to day transactions with customers, vendors armor carrier vehicles and transporting it to the bank.(100 points possible)
5.3 Identify intrusion alarm and monitoring system including the name and contact information for the monitoring company (if the company has been selected).(50 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
5.2.3 Description of cannabis activity that will be conducted in each area of the premise. Commercial cannabis activities that must be identified on the diagram/site plan may include but are not limited to the following if applicable to
the business operations; storage areas, batch sampling areas, loading/unloading of shipment areas, packaging and labeling, customer sales areas, training areas, employee break room areas, extractions, infusions, processing, and
testing areas.
CCB will use onsite security guards: Score 10 10 10
All onsite guards will be licensed and bonded: Score 10 10 0 No mention of being bonded
All onsite security guards will be licensed to carry firearms: Score 10 10 0 No mention of firearms
Onsite security guards will be on duty before CCB opens for business: Score 10 10 10
Onsite security guards will be on duty after CCB closes for business: Score 10 10 10
5.5 Sub-Total:50 30
Section 5 Total:300 255
Section 1: Business Plan Total Points:300 217
Section 2: Social Policy & Local Enterprise Total Points:400 347
Section 3: Neighborhood Compatibility Total Points:300 218
Section 4: Safety Plan Total Points:300 122
Section 5: Security Plan Total Points:300 255
Total Points Achieved:1600 1159
72.44%
TOTAL SCORE
5.5 Discuss whether the CCB will utilize the services of on-site security guards. Include in the discussion: (50 points possible)
5.5.1 Number of guards.
5.5.2 Hours guards will be on-site.
Criteria Narrative:
5.5.3 Locations at which they will be positioned.
5.5.4 Guards' roles and responsibilities.
CONFIDENTIAL
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CONFIDENTIAL
1
California Secretary of State
Electronic Filing
LLC Registration – Articles of Organization
Entity Name:
Entity (File) Number:
File Date:
Entity Type: Domestic LLC
Jurisdiction: California
Detailed Filing Information
Entity Name:
Business Addresses:
DInitial Street Address of
Designated Office in California:
EInitial Mailing Address:
Agent for Service of Process:
Management Structure:
Purpose Statement:The purpose of the limited liability
company is to engage in any lawful act
or activity for which a limited liability
company may be organized under the
California Revised Uniform Limited
Liability Company Act.
Electronic Signature:
The organizer affirms the information contained herein is true and correct.
Organizer:
Use bizfile.sos.ca.gov for online filings, searches, business records, and resources.
RKNC LLC
202033510080
11/23/2020
RKNC LLC
Joshua Nunes
250 W. Spruce Ave., Suite 101
Clovis California 93611
United States
One Manager
Joshua Nunes
2
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CONFIDEN7IAL
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Section 1 | Business Plan
Table of Contents
1.1 Owner Qualifications 2
Robyn Kale, Chief Executive Officer 2
Dr. Kamell Eckroth-Bernard, MD, FACS, Chief Financial Officer 4
Nicholas Easley, Chief Operating Officer 6
Nichole Albright, Chief Compliance Officer 8
1.2 Budget & Operating Costs 10
1.3 Proof of Capitalization 14
1.4 Pro Forma 15
1.5 Hours of Operation/Opening & Closing Procedures 15
Opening Procedures 15
Closing Procedures 18
1.6 Daily Operations 21
Check-in Procedures 22
Receiving Cannabis Goods 24
Point-of-Sale System 26
Estimated Number of Daily Customers 29
Proposed Product Line 29
Delivery Services 32
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1.2 Budget & Operating Costs
We have worked with seasoned strategic partners specialized in all types of cannabis operations
to build out these financial models. All details and proper cash flow was organized into these
financial models with a focus on accuracy to current market projections in California.
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Based on the current status and location of the building we have meticulously reviewed the
Historic District requirements and costs associated with the betterment of the current proposed
facilities. Much of this additional cost is outlined in the Pre-Construction section along with the
additional 20% planned contingency budget to ensure we possess sufficient capital to restore this
historic and iconic building in the ChinaTown District.
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1.4 Pro Forma
1.5 Hours of Operation/Opening & Closing Procedures
In accordance with CCR §5403(a)and FMC Article 33 Section 9-3310(a)(1), the Applicant
will only sell and deliver cannabis goods between the hours of 6:00 a.m. Pacific Time to 10:00
p.m. Pacific Time. These hours may be altered due to the presence of COVID-19, in which case
the Applicant will fully comply with all permitted hours of operation in accordance with any
mandates by the City of Fresno, County of Fresno, and/or State of California. Our online website
and phone application will be up 24 hours and customers may pre-order products, but they may
not have it delivered or can pick it up during non-operational hours.
Opening Procedures
The following Standard Operating Procedure (“SOP”) for Opening Procedures reviews our entire
opening process beginning at 6:00 a.m. Each type of dispensary employee has a unique role in
opening the dispensary. SOPs for each role are further detailed and listed in this section. Note
that we have a full set of proven SOPs for all aspects of the operation, but we are highlighting
specific SOPs here based on the requirements of the application.
ROLE
Front Desk Staff/Receptionist
Retail Sales Associates
Opening Manager
TIMING
Every day before the store opens to customers/patients.
PURPOSE
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The opening process starts the moment a manager or shift lead unlocks the front door and ends
when the store opens for that days’ business. Opening is one of the times of greatest risk for
dispensaries, so it’s important to have thoughtful processes on entering the building and
preparing for the day, including counting cash, preparing products, cleaning, and auditing.
Failing to properly conduct opening tasks is a compliance and safety issue for your store and
employees. This SOP details every step in the opening process, including unlocking the door,
stocking products, preparing drawers/workstations, and welcoming the first customers of the day.
DISPENSARY MANAGER: OPENING PROCESS
This process outlines manager responsibilities at opening, with a focus on back of house.
RETAIL SALE ASSOCIATE - “BUDTENDER”: OPENING PROCESS
This process outlines retail sales associate responsibilities at opening, with a focus on the bud
room.
1.Turn on all computers and navigate to your COVA POS system.
2.Turn on all other systems, such as televisions, display panels, etc.
3.Ensure your badge is visible and placed on.
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4.Count your drawer to ensure the correct starting denomination. Inform the General
Manager if you need any change.
5.Position your drawer into your till.
6.Assign the drawer to yourself.
7.Log into the COVA POS system.
8.Bring products out to the bud room. Ask the General Manager which products should be
brought out first.
9.Ensure all products are stocked based on expected sales for that day. Aim to have enough
product stocked to get you through at least mid-day.
10.Refresh bud pods. If jars were cleaned the night before, fill, and label as appropriate. If
not cleaned, ensure the flower is fresh, fragrant, correctly labeled, and free from
dust/debris.
11.Ensure the check out area is clean, tidy, and well-stocked.
12.Ensure the storage room is clean and tidy. Spot clean any areas missed by closing staff.
13.Ten minutes before opening, you must be done with opening tasks and ready to start
helping customers. Ensure your badge is visible.
14.Throughout the day:
a.
b.Sanitize regularly as outlined by the company’s COVID protocols.
c.Sanitize the storage room and checkout area as time allows to make the closing
cleaning process smoother.
FRONTDESK RECEPTIONIST: OPENING PROCESS
This process outlines reception/front desk staff responsibilities at opening, with a focus on the
waiting room.
1.Visually inspect the front desk/waiting room area and note immediate tasks to complete
before customers start arriving.
2.Turn on the front desk computer. Log into the Identification Verification system utilized
to scan customer IDs.
3.Make sure all tech is charged and ready for use. If not, plug it in immediately.
4.Check trash cans, water stations, coffee stations, and refill as necessary. Check chairs,
furniture, and magazines/educational materials. Spot clean and straighten as necessary.
5.Sanitize, refold, and/or restock merchandise or other non-cannabis items for sale in your
waiting area.
6.10 minutes before opening, you must be done with opening tasks and seated at the front
desk. Ensure your badge is visible.
PROCESS FOR ENTERING THE BUILDING - ALL STAFF
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The General Manager will be inside the building prior to staff members. The General Manager
will unlock all doors and enter the building. Employees should park on their designated spots and
enter the building via the employee entrance.
EQUIPMENT
●Computer
●COVA and account and login information
●Cash drawers
●Cannabis vault
●Cleaning equipment
●Keys to all exterior doors
●METRC access and login information
Closing Procedures
The following Standard Operating Procedure (“SOP”) for Opening Procedures reviews our entire
closing process beginning at 10:00 p.m. Each type of dispensary employee has a unique role in
opening the dispensary. SOPs for each role are further detailed below.
ROLE
Front Desk Staff/Receptionist
Retail Sales Associates
Closing Manager
TIMING
Every day - during the last hour of business and after the store closes to customers/patients.
PURPOSE
The closing process starts around an hour before closing time and concludes after the last
employee leaves the store for the night. Closing is one of the times of greatest risk for
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dispensaries,so it is crucial to have thoughtful processes.Failing to properly conduct closing
tasks is a compliance and safety issue for your store and employees.This SOP details every step
in the closing process,including managing products,counting drawers,cleaning,and locking the
door/leaving the building.
RETAIL SALES ASSOCIATE: CLOSING PROCESS
This process outlines retail sales associate responsibilities at closing,with a focus on the bud
room.
1.If operations are not busy, begin closing drawers one at a time.
2.Retail Sales Associates on closed drawers will count their drawer,then begin closing
duties, focusing on back of house duties so as to not disturb customers.
3.Retail Sales Associates still serving customers are expected to provide service,but aim to
get all customers out by closing time.Pay close attention to any current mandated curfew
times due to COVID-19.
4.Count drawers and submit for review in the COVA POS system.
5.Manually count your drawer’s final cash totals down to zero.Enter each coin and dollar
denomination. Add relevant notes.
6.Select “Submit Drawer for Review” on the COVA POS System.
7.The closing manager will verify and close the drawer.
8.Divide up closing duties between other employees.
9.Lock up every product for the evening.
10.Empty and clean bud pods.Compliantly dispose of expired cannabis flower or safely
secure fresh cannabis flower while cleaning the containers according to the company's
cannabis waste disposal protocols. Clean the containers with alcohol and set out to dry.
11.Ensure the checkout area is sanitized, organized, and well-stocked.
12.Ensure the cannabis storage room is sanitized and organized.
13.Perform multiple walk-throughs of the store to make sure no messes remain,and that no
products are hidden behind shelves, counters, etc.
14.Log out of COVA and turn off all computers.Plug in any devices that need to be
charged.
15.Turn off any other technology (e.g., televisions, display panels, etc.).
16.Clock out.
RECEPTIONIST: CLOSING PROCESS
This process outlines reception/front desk staff responsibilities at closing,with a focus on the
waiting room.
1.Sanitize the waiting room area.
2.At closing time, the manager will come lock the front door.
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3.After all customers have been served, check COVA and make sure no customers are left
waiting in the queue.
4.Tidy and fold merchandise or other non-cannabis items for sale in your waiting area.
5.Tidy chairs, furniture, and magazines/educational materials. Sweep/vacuum floors, with
special focus on entryway rugs. Wipe down any customer-facing surfaces.
6.Close out of all computers, plug in anything that needs to be charged.
7.Clock out.
MANAGER: CLOSING PROCESS
This process outlines manager responsibilities at closing, with a focus on back of house.
1.Exchange tips. Count small bills or change and swap out for larger bills from a drawer.
2.Assign closing duties to each employee on the closing shift.
3.Bring in outdoor signage.
4.At closing time, lock the front door and turn off the Open sign.
5.Stay up front and let out any customers who are still shopping at the time of closing.
6.After the last customer leaves the store, perform a store security check, making sure no
customers remain anywhere in the store.
7.Reconcile all drawers. Retail Sales Associate informs the closing manager that their
drawer is ready for review.
8.Review the counts and notes submitted by the retail sales associate into COVA. Compare
the expected cash with the actual cash and look for over/unders for debit or cash.
9.If totals match, close the drawer. If totals do not match, recount and update totals and
reconcile the difference according to company protocols and procedures.
10.Count out your daily starting amount for each drawer for the morning shift. Put in secure
bags in the safe.
11.Put empty drawers back in the till, and leave the till open.
12.Verify that all drawers are closed in COVA.
13.Run your End of Day Sales PDF Report in COVA to help verify drawer totals and find
discrepancies. Upload your daily sales to METRC.
14.Count the safe and record totals. Keep the safe open for as short a time as possible.
15.As other employees complete their duties, go let them out using the “Leaving the
Building Process” below.
16.Send a closing note to the opening manager.
17.Clock out.
PROCESS FOR LEAVING THE BUILDING - ALL STAFF
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1.6 Daily Operations
Our goal is to responsibly dispense an unparalleled selection of adult-use and medical cannabis
products while observing the highest standards for product and service quality, promoting
community integration, delivering memorable service, and zealously complying with all
applicable laws and regulations at every level of operation. We will aim to create an immersive,
interactive, and impactful setting by exploring the science of cannabis in a highly aesthetic,
culturally conscious environment. Through the employment of knowledgeable and passionate
agents who are eager to serve our customers, the thoughtful selection of decor elements (such as
paintings by local artists), and the placement of state-of-the-art interactive displays with product,
inventory, and educational information in every corner, we will create a welcoming environment
that caters to our customers’ needs.
Our dispensary will be presented as a clean and vibrant facility that fully integrates modern best
practices. We work to reimagine how dispensaries can function beyond only serving adult-use
cannabis products by integrating the features of a responsible, service-oriented retail store with
the charming atmosphere of a social lounge that promotes kinship. Our contemporary design will
display products based on consumption goals as opposed to product types, and an Informed-Use
Consultant will establish tailored recommendations for each customer based on their specific
consumption goals. Additionally, each product’s exit packaging will feature a scannable barcode
that helps inform customers of its active ingredients, side effects, and cannabinoid profiles, all
developed by our Informed-Use Consultant based on current evidence-based data and research
approved by the Department of Public Health. None of the information provided to customers
will advertise statements or illustrations that make any health, medicinal, or therapeutic claims
about cannabis or cannabis-infused products, and instead will review the topics listed above.
We will use two customer relationship management (“CRM”) platforms, Seed and Baker (or
similar platforms). By having the voluntary option of creating unique profiles with these
platforms, our customers will be able to monitor their purchase history, understand their
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consumption goals,and access our best-in-class product inventory in real time in the waiting
room and online.Additionally,our curated selection of cannabis products will be sourced from
responsible and reputable California-licensed cultivators and processors.All day-to-day
equipment and supplies also will be sourced from local vendors when possible.We want to
expand access to cannabis to all types of individuals regardless of their socioeconomic status.To
maintain the affordability of our products,we will offer daily discounts as well as specialized
discounts for veterans,individuals residing in disproportionately impacted areas,and senior
citizens.Additionally,promotion codes will also be made available through our local vendors
and partners to encourage collaboration among neighborhood entities.
In regard to our staffing plan,we will give opportunities to individuals seeking to enter the
cannabis industry,with a particular focus on hiring individuals from disproportionately impacted
areas,and we will work to ensure that we retain exceptionally qualified employees.We will
recruit through local colleges so that new graduates may use their degrees to contribute to our
company’s development.Equally,we will have a program that allows for retired seniors in
California the tools and resources to fully integrate into the cannabis industry.
With an experienced Dispensary Manager leading both young and senior residents,we
effectively create a work culture that recognizes expertise while promoting inclusivity.The
employee compensation structure of our operations will be such that no employee will earn less
than a living wage.Each section demonstrates our ability to adapt,learn,and educate while
always working to put the safety and security of our customers,agents,and products first.With
our team’s many years of experience in business,retail operations,and highly regulated
industries,we fully anticipate that not only will each of our goals and milestones be achieved,
but actively improved and updated to fit the needs of the ever-changing cannabis industry.
Check-in Procedures
The public entrance will give customers access to the security check-in counter and the inviting,
comfortable waiting room.It will be designed in full compliance with the Americans with
Disabilities Act (“ADA”)as well as other applicable local,state,and federal laws to ensure that
persons with disabilities are provided with reasonable accommodation to access the dispensary.
Windows will be made of bullet-resistant glass,and a mantrap vestibule will be included for
enhanced security. Waiting rooms and point-of-sale rooms will be separated.
In addition to providing increased security,the separation between the waiting room and the
point-of-sale area will ensure that neither area feels crowded or unsafe and that each can receive
the appropriate level of attention and service from dispensary staff.Customers will not be
allowed to access the point of sale area unless there is at least one dispensary sales employee
present.The entrance to the point of sale area will remain locked at all times.Employee escorts
will grant customers access to this area with their RFID badges or security staff will buzz them
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in through an electronic/mechanical entry system.The Applicant will further post our license and
hours of operation in an area visible to customers.
Upon entering the dispensary,all customers and visitors (such as vendors,contractors,
consultants,transportation service providers,and others who are not customers or employees)
will check in at the security office and remain in the waiting room until an employee arrives to
escort them to their destination.For customers,this would be the retail point of sale area.
Escorted visitors will also be able to access certain other areas of the facility.Visitors will be
required to sign the visitor log and follow our established visitor policy procedures Customers
will not be allowed access to the point of sale area unless there is at least one retail employee
present per CCR §5402(d).Counters and display cases will be configured to protect cannabis
goods from direct access by customers,and to ensure that cannabis goods are not visible from
outside the premises per CCR §5405(b).
Facility visitors may include vendors,contractors,consultants,transportation service providers,
and other non-employees who may regularly or occasionally support facility operations.Regular
visitors,such as vendors and maintenance contractors,will follow applicable facility standard
operating procedures (SOPs)relevant to their role.All visitors who require access to designated
limited access areas will be escorted at all times by the licensee or an authorized employee.
Visitors may be issued a temporary visitor RFID badge to monitor their location and activity in
the facility.In order to obtain a badge,a visitor must provide a valid government-issued
identification which must contain their name, photograph, and date of birth.
Temporary badges will be surrendered to the facility at the end of the visit.A visitor log will be
maintained that will be available for inspection by state and local regulators and law enforcement
at all times.The visitor log records will be maintained for seven years in accordance with CCR
16 §5037(a).Notwithstanding the requirements of unregistered visitor access,employees of the
company,law enforcement,emergency medical personnel,in the event of an emergency,or
other federal,state of California,or local government officials may enter the dispensary facility
if necessary to perform their official duties.The visitor log will record the following information,
which will be available for inspection by the Bureau immediately upon request (CCR 16
§5042(d)):
●Full name of each visitor entering the regulated premises
●Company or agency
●Badge number, if applicable
●Purpose of visit
●Areas of the facility visited
●The assigned registered employee of the facility who is escorting the visitor, if applicable
●Time of arrival and departure, with visitor signature
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In order to access the point of sale areas, customers must provide a valid form of photo
identification that clearly indicates the age or birthdate of the individual (CCR §5402(c)).
Acceptable forms of identification include a valid motor vehicle operator's license, a current
government-issued identification card, a valid Armed Forces identification card, or a valid
passport issued by the United States or by a foreign government (CCR §5402(b)). In accordance
with CCR §5404(a), customers who wish to purchase adult-use cannabis goods must be at least
21 years of age.
Customers who wish to purchase medical cannabis goods must be at least 18 years of age and
provide a valid physician's recommendation. Primary caregivers who wish to purchase medical
cannabis on behalf of a qualifying patient must also be at least 18 years of age, as well as provide
proof of the patient’s age and physician’s recommendation. The proof of a physician’s
recommendation and the status of a person as a designated primary caregiver (if applicable) may
be provided as a county public health department-issued identification card provided under the
voluntary medical cannabis identification card program described by HSC §11362.71 through
11362.77. A copy of the physician’s recommendation, medical cannabis identification card, or
primary caregiver identification card as applicable will be retained in accordance with the
facility’s record keeping policies.
Receiving Cannabis Goods
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The Dispensary Manager will subsequently scan the new inventory’s barcodes into our online
METRC portal at the adjacent workstation. Products that have effectively been scanned, logged,
and inspected will be stored in our secure storage room. Once the products have been accurately
logged and stored, dispensing agents will be able to access the storage room with RFID badges.
During hours of operation, the products will be taken out of the storage room and placed in
enclosed glass cabinets in the point-of-sale area. These cabinets will equally be locked and
secured by dispensing agents and only released upon purchase. Additionally, to keep our
products safe and effective, the Quality Assurance inspections will accomplish the following:
●Ensuring that all cannabis goods are received from a licensed distributor per CCR 16
§5406(a)
●Verifying that the laboratory certificate of analysis (COA) associated with each batch or
lot of goods received from the distributor indicates a “pass” result for all analytical tests
specified by CCR 16 §5714(a): cannabinoids; foreign material; heavy metals; microbial
impurities; mycotoxins; moisture content and water activity; residual pesticides; residual
solvents and processing chemicals; terpenoids (if applicable); and homogeneity
(applicable to certain edible products)
●Inspecting all cannabis goods to verify they are properly packaged and labeled for final
retail sale in accordance with CCR 16 §5412(a): goods are packaged with a
tamper-evident seal affixed to the package opening; packages and labels must be
compliant with all applicable provisions of BPC §26120 including but not limited to:
resealable, tamper-evident, child-resistant packaging; date of manufacturing and
packaging; required government warning statements for adult-use products as applicable;
a list of pharmacologically active ingredients (e.g. tetrahydrocannabinol [THC], etc.) in
milligrams per serving; number of servings per package; product weight; for edible
products, a list of ingredients using generic food names and applicable allergen warnings;
and any other requirement set by the Bureau or the State Department of Public Health
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●Ensuring that manufactured cannabis goods meet State Department of Public Health
standards and other requirements set forth by BPC §26130,including standards for edible
cannabis products such as:edible products should not be designed to appeal to children;
the standardized concentration of cannabinoids shall not exceed 10 milligrams
tetrahydrocannabinol (THC)per serving;serving size should be clearly delineated;
product labels should provide customers with sufficient information to enable the
informed consumption of the cannabis product,including the potential effects directions
for how to consume;labels for edible products will be marked with the universal symbol
determined by the California Department of Public Health
●Confirming that cannabis goods are not misbranded as described by BPC §26121(a),
including goods with false or misleading labeling,goods that are not packaged or labeled
in accordance with BPC §26120,and goods that were not produced or packed by a
licensed commercial cannabis facility.The Bureau will be notified if any goods are
discovered that are misbranded,and the goods will be destroyed in accordance with the
facility cannabis waste disposal procedures.Cannabis products cannot be delivered or
sold if they are misbranded per BPC §26121(a)
●Coordinating exchanges of defective products procured from another licensee in
accordance with CCR 16 §5053(a)
●Enforcing first-in,first-out inventory control procedures to ensure fresh products within
their date of expiration are available for sale;cannabis goods that have exceeded their
expiration or sell-by date will not be sold (CCR 16 §5406(b))
●All cannabis goods intended for consumption are followed by the manufacturer’s
requirements to maintain safety and efficacy
Point-of-Sale System
The Applicant will utilize the COVA POS system in compliance with FMC Article 33 Section
9-3309(e),which will fully be able to track cannabis,inventory data,gross sales (by weight and
by sale),and other information which may be deemed necessary by the City.Cova's cannabis
retail POS is a full-featured tablet-based point-of-sale system that will enable our staff to deliver
an expedient,compliant,and personalized shopping experience from anywhere in the store.
Their award-winning,intuitive design guarantees ease-of-use and quick onboarding of staff in
just 30 minutes.Their essential dispensary POS features are designed specifically for cannabis
retail, making it exceptionally ideal for our purposes.
The COVA point of sale platform includes an inventory management tool that fully integrates
with METRC,including data validation features that ensure records exported into METRC are
complete,accurate,and free of errors to enable reliable and efficient inventory tracking and
reconciliation.The inventory management tool includes an extensive cannabis product catalog to
streamline the process of maintaining descriptions of cannabis goods available for retail and
delivery customers in keeping with the requirements of CCR §5423.The COVA platform is also
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compatible with hardware commonly used in retail sales including label,receipt,and barcode
printers, along with wireless barcode scanners.
The COVA POS platform protects sensitive patient,customer,and user information with end to
end data encryption through the latest Transport Layer Security (“TLS”)standards and login
credentialing.This will help the facility to safely collect and maintain medical cannabis sale
transaction data required per CCR §5425(b)including employee name and number,customer
first name and retailer-assigned customer number,list of goods purchased,and price and tax
data.The COVA ID scan feature will streamline the process of checking in medical cannabis
patients and caregivers who repeat business at our retail storefront.
The Quality Assurance department will be responsible for releasing cannabis goods received
from the distributor for sale to customers.The inventory tracking and management capabilities of
the ERP will ensure that inventory is released in accordance with a “first in,first out”principle
so that the oldest batches or lots are prioritized for transfer to point of sale or delivery.Cannabis
goods that are pending inspection and release will be designated at “quarantine”and will be
stored separately from other goods to avoid cross-contamination.Quarantine materials will also
include recalled or returned products that are subject to further testing or inspection.
All cannabis goods in the retail point of sale area will be stored or displayed in a manner that
prevents customers from having direct access.To further protect goods from the risk of theft or
diversion,the retail point of sale area and retail storage areas will be under continuous video
surveillance in accordance with the security plan described in Section 5:Security Plan.
Additional retail inventory not on display will be stored in a locked vault within a designated,
limited access area conveniently located near the point of sale area.The quantity of cannabis
goods on display in the retail point of sale area will be limited to the quantity anticipated to meet
the daily demand.
Cannabis goods available for customers to browse will be organized in locked display cases in
the retail point of sale area (CCR §5405(a)).Goods may also be displayed behind the retail
service counter,which does not provide access for customers.Cannabis goods labeled for
adult-use (“A”)will be sold.In keeping with CCR §5405(c),retail employees may remove
cannabis goods from their packaging and place it in special display containers to allow for
customer inspection;however,given the recent COVID-19 pandemic,customers may only
visually inspect cannabis flower and would not be permitted to touch or remove cannabis at the
facility.
The display containers will not be directly accessible to customers without assistance of a retail
employee,who will supervise the inspection and take possession of the container for secure
storage once the inspection is complete.Goods available for inspection will not be available for
sale (CCR §5405(d))and will be destroyed per CCR §5054 following all applicable inventory
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tracking procedures.Retail sales transactions will be completed using the COVA POS platform,
which is fully integrated with METRC for real time inventory tracking of all purchased items.
Every sale will be documented as a detailed and accurate record in accordance with CCR §5425,
which will enable us to provide all necessary gross receipts and revenue,sales,and tax data
required per CCR §5037.Since all products will be properly labeled and marked with a UIN and
RFID barcode,the point of sale system will be configured to automatically categorize each line
item on a sales invoice as an adult-use cannabis,medical cannabis,or non-cannabis product
purchase for accurate reporting and collection of applicable state and local tax.Adult-use
cannabis retail purchases,including in-store and delivery sales,are subject to the following daily
limits per single adult-use customer in accordance with CCR §5409(a):
●No more than 28.5 grams of non-concentrated cannabis (e.g. flower)
●No more than eight (8)grams of of concentrated cannabis,including concentrated
cannabis contained in cannabis products;concentrated cannabis is defined by BPC
§26001(h)as cannabis that has undergone a process to concentrate one or more active
cannabinoids,thereby increasing the product’s potency (resin is considered a concentrate
by this definition)
●A limit of six (6) immature cannabis plants
Medical cannabis retail purchases,including in-store and delivery sales,are subject to the
following daily limits per single patient or primary caregiver in accordance with CCR §5409(b):
●No more than eight (8)ounces of medicinal cannabis,which is defined by HSC
§11362.77(d) as the dried mature processed flowers of the female cannabis plant;
●A limit of 12 immature cannabis plants;
●A medical cannabis purchase may exceed these limits if specified by a valid physician’s
recommendation per CCR §5409(c)or in accordance with county or city medicinal
cannabis guidelines that exceed the state limits per HSC §11362.77(c); and
●Free medical cannabis goods provided under the provisions of CCR §5411(b)will count
toward the daily purchase limit,and will be fully inventoried and tracked in METRC as a
retail transaction per state-mandated cannabis tracking and monitoring protocols.
The inventory management capabilities of the point of sale system and METRC will be
leveraged to ensure the daily purchase limits for adult-use and medical cannabis are enforced.
All purchased adult-use and medical cannabis goods will be placed in an opaque exit package
per CCR §5413 before a customer may take possession and remove the goods from the licensed
and secured premises.No consumption will be allowed in or near the facility.Our retail sales
staff will ensure that purchase limits, age restrictions, and ID verification are compliant.
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Estimated Number of Daily Customers
The Applicant estimates to have between 10-40 customers an hour,depending on time of day,
with between 200-300 customers a day.This is based on the average customers per day in a
typical cannabis dispensary in California.With cannabis businesses being deemed essential
throughout the COVID-19 pandemic,business transactions have not slowed down for cannabis
retail operations;in fact,most data points to the opposite taking place,with sales continuing to
rise as more and more individuals combat the virus.Regardless of the number of customers we
receive per day,we will comply with all occupancy requirements to ensure and promote public
safety against this pandemic.
Proposed Product Line
The Applicant will apply for a Type 10 state licence with the Bureau of Cannabis Control in
order to provide both adult-use cannabis at its Fresno retail storefront.Pursuant to applicable
local and state regulations, the following goods will be available from our retail storefront:
●Adult-use cannabis goods, which will be clearly labeled with the “A” designation
●Live,immature cannabis plants and cannabis seeds,which will be obtained from a
state-licensed nursery and are subject to the requirements and restrictions of CCR §5408,
including a prohibition on the use of pesticides
○The Applicant will provide adult-use and medical customers who wish to
purchase cannabis plants with an informational pamphlet that provides education
on how to safely and legally grow cannabis at home in accordance with
Proposition 64 and other applicable state and local laws
●Non-cannabis goods per CCR §5407,for example brand apparel and accessories,organic
growing supplies for home cultivation of cannabis plants,and other goods,with the
exception of the following:
○Alcohol and alcohol products
○Tobacco and tobacco products (FMC Article 33 Section 9-3309(c))
○Live plants that are not cannabis (CCR §5408(b))
All of our products must be packaged,sealed in an odor-proof,child-resistant cannabis container
consistent with current standards,and labeled correctly for retail sales.The Applicant aims to
dispense a variety of products approved by the State of California to ensure that our customers’
preferences are accommodated.The Applicant will not produce or manufacture cannabis.At no
point shall the Applicant sell more than the permitted limit of cannabis products outlined in the
CCR within a single transaction. The following products will be offered to customers:
1.Tinctures:Cannabis tinctures are,in essence,alcohol-based extracts.Tinctures are
primarily used as an alternative to smoking as a consumption method.They can be
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administered sublingually or buccally or mixed with beverages and consumed as an
edible. Tinctures are known for their ease of dosing and consumption.
2.Cannabis Edibles:We will strictly prohibit the purchasing of any edibles that may be
attractive to minors, such as gummy bears and lollipops. Edibles less overtly appealing to
minors such as curated chocolate bars, brownies, and savory snacks will be available. As
stated before, we will ensure we only stock products that are fully compliant with
California and Fresno laws and regulations regarding edibles, specifically in that they
must be labelled with the following information:
a."Edible cannabis-infused products were produced in a kitchen that may also
process common food allergens."; and
b."The effects of cannabis products can vary from person to person, and it can take
as long as two hours to feel the effects of some cannabis-infused products.
Carefully review the portion size information and warnings contained on the
product packaging before consuming."
3.Cannabis Flower: Regardless of the popularity of oils and extracts, cannabis flower still
remains quite dominant in sales. Cannabis flower is more affordable than extracts for
many customers. Dry flower can be used in a vaporizer to minimize exposure to the
byproducts of combustion. Flower will be available in pre-packaged containers that
include 1 gram, 3.5 gram, 7 gram, 14 gram, and 28 gram sizes.
a.Cannabis Pre-Rolled Joints:Pre-rolled joints that are properly packaged will be
made available for sale. This will be available in one 1 gram packages, or one 0.5
gram, five 1 gram, or five 0.5 gram packages (Example included below)
4.Transdermal Patches:Another popular product in the medical and retail cannabis space
is the transdermal patch. This product is known for its incredibly easy application and
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soothing effects,especially its potential for reducing inflammation or chronic pain due to
arthritis or injury.
5.Cannabis Vaporizers:Highly popular,however,given the recent health concerns
revolving around vaporizers,we will ensure that no vaporizers have any trace of
Vitamin-E acetate—the compound most commonly associated with serious health
risks—in any of our vape products.
6.Topical Balms &Salves:Pre-packaged infused creams and lip balms will be made
available for sale at our dispensary.
7.Cannabis Oils:Given their versatility and potential for low-THC,cannabis oils have
been steadily increasing in sales along with the general industry.Manufacturers and
extractors have been increasing in number and overall production as well,given the fact
that oils per gram are more profitable than flower per gram.Coupled with the reality that
operators can control cannabinoid ratios consistently and precisely with extracts when
compared to dried flower,extracts and products containing extracts lend themselves
toward maintaining regulatory compliance.
a.Self-Regulating Dilute Oil Formulation:Pharmaceutical,dosage-ready extracts;
This formulation is self-administered via oral ingestion using volumetric dosing
oral syringes.Additionally,the oil formulation can rapidly absorb into the body
via the submucosal route of administration.This formulation is similar to a cough
syrup and is administered in larger volumes of controlled doses via oral ingestion
and the gastrointestinal route of administration.The oils are active pharmaceutical
ingredients (“APIs”)typically homogenized into a safflower-oil base.They can be
consumed directly, applied to food, or administered sublingually.
8.Discrete Sublingual Lozenge:Intended to dissolve,disintegrate in the mouth and deliver
API via sublingual and gastrointestinal passageways for systemic absorption.Supplied
lozenges must meet cGMP standards for production prior to being sold at our dispensary.
An advantage of a sublingual lozenge is discrete dosages in each unit.A lozenge will be
loaded with varying amounts of custom compositions of APIs (e.g.,5 mg CBD,5 mg
THC, 1 mg CBN) to target different effects.
9.Capsules:Intended for quick oral consumption with water.Like lozenges,capsules
deliver API via sublingual and gastrointestinal passageways for systemic absorption,
loaded with varying amounts of custom compositions of APIs (e.g.,5 mg CBD,5 mg
THC, 1 mg CBN) to target different effects.
10.Hash Oil:Various solvents are pressurized in a vessel and washed over plant material,
then the resulting solution is collected. Highly potent and concentrated product.
11.Rosin:A solventless concentrate extracted from dried buds,trim,or lower-grade hash or
kief through the application of heat and pressure.High-quality product and easily
manufactured.
12.Kief:Simplest of concentrates and composed of the trichomes broken away from the
dried plant material, typically through specialized filtering screens.
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13.Infused Gum:Chewable edibles made for easy consumption.Meant to be consumed
orally and chewed over a period of time.Contains varying amounts of custom
compositions of APIs (e.g., 5 mg CBD, 5 mg THC, 1 mg CBN)
14.Paraphernalia:Products to consume cannabis will be sold,such as papers,glass pipes,
cases,and cleaners.We will also sell a selection of well-vetted books on cannabis
cultivation, medicinal uses, history, politics, and culture.
15.Company Branded Promotional Items:In addition to cannabis products,we will also
see dispensary branded T-shirts,hats,and other apparel.These products will allow our
customers to help advertise our brand,while building a sense of consumer engagement.
All branded products will be compliant in that they will not:
a.Be false or misleading,
b.Promote overconsumption of cannabis or cannabis products,
c.Depict the actual consumption of cannabis or cannabis products,
d.Depict a person under 21 years of age consuming cannabis;
e.Make any health,medicinal or therapeutic claims about cannabis or
cannabis-infused products;
f.Include the image of a cannabis leaf or bud; or
g.Include any image likely to appeal to minors,including cartoons,toys,animals or
children,or any other likeness to images,characters or phrases that is designed in
any manner to be appealing to or encourage consumption to persons under 21
years of age.
Delivery Services
Throughout this section,we provide details of every aspect of our operations,ranging from tasks
associated with the delivery of cannabis goods to customers,types of vehicles we will use,
security features,and loading and unloading procedures.The Applicant will likely utilize the
either the Ford Transit Cargo Van modified with the XLH™Hybrid Electric upfit (more details
provided below)or Chevy Bolt EV to transport all cannabis products to consumers;the Ford
Transit Cargo Van vehicle has been chosen because of its fuel efficiency,cargo volume capacity,
storage security features,and ability to seamlessly add the electric upfit system mentioned
below,and the Chevy Bolt EV was chosen for its compact size,fully electric features,and
efficiency.In regards to our location,we are perfectly positioned for delivery,as we are
positioned near interstates and high population dense areas,permitting us to deliver nearly half
of the residents in Fresno within 15 miles.
All products will be tracked through our Enterprise Resource Planning (“ERP”)system,which
will be able to fully integrate with the State’s seed to sale tracking system,METRC.As part of
our plan to meet consumer demand,having proper inventory tracking,monitoring,and
recordkeeping procedures is paramount.Likewise,we further explore safety in this respective
section,which is divided into two sections:on-site safety and road safety.We describe how we
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will properly maintain our office/dispatch area,procure products from our dispensaries,and
commence delivery as efficiently and safely as possible.Proper storage of cannabis during
delivery is not only crucial for preventing illegal diversion of products and maintaining our
employees’safety,but is also for maintaining the integrity of our products we intend to deliver to
customers.
As stated before,we will likely utilize the Ford Transit Cargo Van with XLH™Hybrid Electric
upfit modification to transport cannabis and cannabis goods between licensed cannabis
businesses.The XLH™Hybrid Electric upfit modification improves this particular vehicle’s
miles per gallon (“mpg”)by 25%,and subsequently reduces its CO2 emissions by 20%.As a
hybrid vehicle due to the installation of the XLH™hybrid electric system,the vehicle would
utilize gasoline,ethanol (due to its already-installed flex-fuel system,described more below),
and electricity.
The XLH™hybrid electric system seamlessly installs onto the Ford powertrain,transforming it
into a hybrid electric vehicle with the same acceleration as the original vehicle,better braking,
and allows for the original Ford warranty to remain intact—demonstrating its compatibility and
integrative features.This hybrid electric technology is fully charge-sustaining,meaning it saves
fuel through regenerative braking,a process by which the electric motor helps slow the vehicle
during braking to charge the hybrid battery.As the driver accelerates,the hybrid battery releases
the stored energy to the electric motor,helping to propel the vehicle.The image below
demonstrates where the battery pack and inverter are installed.
XLH™ Hybrid Electric Upfit | Source: XLH™
The Ford Transit Cargo Van is a commercial vehicle designed specifically for medium to large
scale transportation and distribution operations and features approximately 275 cubic feet of
cargo space behind the driver and passenger seats.Maximum payload rating for the Ford Transit
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Cargo Van is approximately 2,960 lbs,with an additional 350 lbs added when installing the
electric upfit—accumulating to a total of only 3,310 lbs.The Applicant will likely utilize two to
three vehicles and possibly expand to four after a few months of operation,depending on
demand.The dimensions and specifications detailed below are close estimates and may slightly
be altered due to the installation of the electric upfit.
Ford Transit Hybrid Van Specifications
●Curb weight – Approximately 3,310 lbs (with electric upfit)
●Net payload – Approximately 2,700 lbs
●Engine – 2.0-liter (1,996 cc), 4-cylinder in-line, turbo diesel
●Max output – Approximately 130 PS (96 kW) at 3,500 rpm
●Max torque – Approximately 385 Nm at 1,500-2,000 rpm
●Hybrid system – Belt integrated starter/generator, 48V, 10Ah lithium-ion battery pack
●Transmission – 6-speed automatic, FWD
●Fuel consumption – Approximately 18.75 mpg (with electric upfit)
The Ford Transit Cargo Van is further equipped with a flex-fuel system that allows the use of
traditional gasoline and advanced fuel options such as Compressed Natural Gas and E85,an
ethanol-based fuel.These advanced fuels offer reduced greenhouse gas emissions over
traditional gasoline or diesel fuels.Advanced fuels,additionally,are manufactured using U.S.
based materials,and help limit our country’s dependency from offshore energy producers and
providers.With the flex-fuel system combined with the electric upfit system described above,we
can expect to significantly reduce CO2 emissions and inherently save fuel costs.Further
modifications will be implemented on the van to ensure optimal security.As seen in the images
further below,we will install steel-framed interior cages inside the cargo area (seen in picture
below)to further prevent unauthorized access to our cargo,in addition to the powered doors that
provide an additional layer of security.
Alternative Fuels and Greenhouse Gas Reduction:Our chosen delivery vehicle is equipped
with a flex-fuel system that allows for the usage of E85,traditional gasoline,or any mixture of
E85 and gasoline.E85 is a renewable,ethanol-based fuel consisting of 85%ethanol and 15%
gasoline.Per American Society for Testing and Materials (“ASTM”5798 requirements,E85
may contain anywhere between 51%and 83%ethanol by volume.E85 is readily available at gas
and truck stations throughout the state of California and produces lower emissions than
traditional gasoline.Ethanol,the main component of E85,is produced from the biomass of plants
such as corn and sugarcane.
Carbon emissions from the use of E85,therefore,are offset by the amount of carbon dioxide that
is captured by the feedstock crops required to produce ethanol.That is,the amount of carbon
emissions from E85 are offset by the crops grown to produce ethanol.No emissions are offset
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when traditional gasoline or petroleum products are being used,according to the U.S.
Department of Energy.Lifecycle analyses of E85 reveal that greenhouse gas emissions are
reduced by an average of 34 to 108-percent compared to traditional gasoline and diesel
production and usage.According to the U.S.Department of Energy,the total amount of
greenhouse gas emissions being reduced depends on the feedstock or source of the biomass
being used for the production of ethanol.
Ford Transit Cargo Van w/ Interior Steel Cages | Source: Ford®
Ford Transit Cargo Van w/ XLH™ Hybrid Electric Upfit | Source: XLH™
Alternative Vehicle (Chevy Bolt EV):Another vehicle we may use for delivery could be the
Chevy Bolt EV given its fuel efficiency and compact,discrete nature.Further specifications
regarding this vehicle are listed below.Although the Ford Transit Cargo is exceptionally ideal
for transport,we would like to expand on our vehicle diversity by including both large and small
vehicle types optimal for transport.This vehicle is fully electric and can drive for up to 259 miles
on a single charge.The Applicant will likely utilize this vehicle prior to the Ford Transit Cargo
Van for the first years of operation.With the COVID-19 pandemic expanding delivery
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operations more than ever, we may elect to utilize the larger Front Transit Cargo Van vehicle to
keep up with consumer demand.
Transportation Security:Transportation has the potential to be the most vulnerable phase in
the chain of custody. All vehicles utilized for distribution and transportation will be equipped
with a Global Positioning System (GPS) based tracking device, which shall be maintained at all
times and have the capacity to store historic data for no less than twelve (12) months, and permit
the Bureau to search all real-time and archived data upon request. For the safety of distribution
personnel and to protect the security of cannabis goods being transported, the following standard
operating procedures (“SOPs”) will be implemented prior to leaving the licensed premises:
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Loading Area Security:Loading areas at any location where the loading or unloading of
cannabis goods will occur will be established as secure, restricted access areas where access is
Delivery Vehicle Requirements:The Applicant will further deliver cannabis goods as permitted
by Fresno and California law. An up-to-date list of vehicles used for the transport of cash will be
maintained in a database. Vehicles used for delivery are subject to inspection by the Bureau at
any time per CCR 16 §5417(f). Vehicles used for these activities will meet the following
security requirements in keeping with CCR 16 §5417:
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Driver Requirements:The facility will maintain a database of all authorized drivers (CCR 16
§5415(f)), which will include a copy of each employee’s valid California driver’s license, and
verification that delivery employees are at least 21 years of age (CCR 16 §5415(b)). Transport
drivers will be strictly prohibited from using or consuming cannabis goods while conducting
delivery of cannabis in accordance with CCR 16 §5419.
Delivery Routes:Delivery will be established and documented in the transfer manifests, and
tracked in real time using the delivery vehicle’s GPS device (CCR 16 §5417(d)). GPS tracking
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logs will be recorded and backed up on the cloud database. Point-to-point locations along the
transport route may only include the licensed premises and the verified destination addresses
listed on the transfer manifests. Deviations from the planned routes are not permitted except for
necessary rest, fuel, or vehicle repair stops (CCR 16 §5311(j)), or because road conditions make
continued use of the route unsafe, impossible, or impracticable (CCR 16 §5421). Delivery
vehicles may not leave the State of California while possessing currency (CCR 16 §5416(b)).
The transport manifest will detail the amount and type of cannabis goods, and the addresses and
names of each customer that purchased a product intended for delivery. Delivery personnel will
obtain a receipt or other documentation verifying the successful and secure transfer of the
currency described by the transport manifest.
Incident Management:If a vehicle becomes inoperable during the course of delivery, either due
to an accident or a mechanical problem, the driver will secure the vehicle, ensuring the storage
compartment remains locked. The delivery employee will report the incident as soon as possible
but no later than two hours after the incident. Incident reports will be made to the Dispensary
Manager and Chief Compliance Officer and will note the location and condition of the vehicle,
the security of contents, and the safety of third-party personnel.
The third-party personnel will then monitor the situation until help arrives, updating the manager
of any changes, and ensuring that the storage compartment remains closed. Depending on the
severity of the incident, the transport will either be postponed, canceled, or delayed until another
armored vehicle can arrive to replace the disabled vehicle. A new transport crew of authorized
personnel may replace the team involved in the incident to complete the delivery. If so, the new
transport armored vehicle and the team will meet all of the same security requirements, and
currency will be immediately transferred to the new vehicle using the following procedures:
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Delivery Employee Requirements: Cannabis Delivery service will be provided by designated
employees of the licensed facility; contractors will not be retained for delivery (CCR 16
§5415(a)). The facility will maintain a database of all authorized delivery employees (CCR 16
§5415(g), which will include a copy of each employee’s valid California driver’s license, and
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verification that delivery employees are at least 21 years of age (CCR 16 §5415(b)).Delivery
employees will be prohibited from using or consuming cannabis goods while conducting
delivery activities in accordance with CCR 16 §5419.
Receipt of Cannabis Delivery:Upon delivery,the delivery personnel will personally verify the
identity of the delivery recipient,which will include a state-issued photo identification.For each
delivery,a receipt will be prepared that will then be signed by the customer,verifying successful
completion of the delivery.One copy will be provided to the customer,and a second copy will
be retained by the delivery employee (CCR 16 §5420(b)).The receipts will be used to document
and verify the account of gross receipts charged and received.The delivery receipt will contain
the following information per CCR 16 §5420(a):
●Retailer name and address;
●Name of each employee involved with delivery and preparing the order;
●First name and customer number of the delivery recipient;
●Date and time of delivery request;
●Delivery address;
●Invoice describing all cannabis goods requested for delivery,including amount by
weight,volume,or other accurate measure,and the cost of goods sold including taxes,
fees, and any other charges;
●Date and time the delivery was made; and
●Signature of the delivery recipient.
Cannabis Transport Manifests:At each stage of delivery or transport,from secure storage at the
facility to final handover at the receiving destination,all cannabis goods and related currency
will be tracked using RFID package tags and ERP inventory tracking protocols.This will enable
real-time tracking throughout the transport process.For each delivery run,certified transport
manifests will be developed using the ERP system to create an electronic record that will also be
printed at the time of delivery.
In the event of multiple deliveries being made in a single transport,each delivery will have its
own manifest.Transport manifests will be shared with the Bureau and applicable local
authorities (CCR 16 §5314(b)).The certified transport manifests will be generated by METRC,
the facility track and trace inventory management system.A printed copy of the transport
manifests will be generated immediately before delivery and will be retained throughout the
process by delivery personnel.The transport manifests will also exist in electronic form within
the facility ERP system.Delivery personnel will use database and GPS technology to record data
to each electronic manifest in real time as deliveries proceed.The transport manifests will
include the following information per CCR 16 §5049(b)(1)-(6):
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●Licensee name,premises address,and contact information;Licensee state and local
permit numbers;
●Vehicle information including make, model, and license number;
●Delivery personnel information,including names,badge numbers,and state-issued driver
license numbers;
●Name,address,and contact information for each delivery recipient,including driver
license or other identification number of customers;
●Itemized inventory that includes the name and type of cannabis goods,amount by weight
or count, and unique identification numbers (UINs);
○The total amount of all cannabis goods carried within in the vehicle will not
exceed $5,000 in retail value (CCR 16 §5418)
○Cannabis goods will be clearly identified and marked on packaging and the
transport manifest with an “A”for adult-use;Inventory will not include
non-cannabis goods,except for cannabis accessories as defined in the BPC
§26001(g)
●A date and time log to document each delivery or transaction,including vehicle departure
and arrival times from the premises,and time of delivery for each qualified patient,
primary caregiver, or customer listed on the manifest; and
●The route traveled for each destination listed on the manifest.
All of our processes described in this section will be continuously vetted throughout operations
to ensure we always maintain current best practice standards.Ultimately,we are selling products
that are intended for human consumption.Because of this,we are responsible for ensuring we
take every preemptive measure feasible in order to ensure the safety and security of these
products.Although we described our current plans for business transactions,security,delivery
operations,inventory control and recordkeeping,we fully understand that,in time,better
protocols,systems,and technologies will be established or created;we have a responsibility to
update our operations as regulatory and procedural evolution occurs.
We will not tolerate deviations outside our Business Plan or any other sections described in our
application.Quality Control personnel will work alongside our owners,managers,and
employees to ensure that all our standards are adhered to throughout operations.As promoting
product quality and safety is a chief concern that helps us advance and protect the interests of our
customers,the promotion of fair labor standards and a safe working environment is a primary
responsibility that will help us advance and protect the interests of our employees.The Applicant
pledges to always uphold the highest possible standards of throughout all facets of operations to
ensure that we meet the foregoing responsibilities.Throughout this Business Plan,we have
focused on requested materials for the application,however,we have a fully operational business
plan model that is already completed;in light of this,we would be able to quickly execute our
facility’s buildout as well as initiate staff hiring and training in order to open as soon as possible.
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Section 2 | Social Policy and Local Enterprise Plan
Table of Contents
2.1 Living Wages 2
2.2 Employee Benefits 4
2.3 Compensation for Continuing Education & Employee Training 5
2.4 Social Policy & Local Hiring 6
2.5 Local Management 9
2.6 Number of Employees, Titles, Positions, & Responsibilities 11
2.7 Labor Peace Agreement 20
2.8 Workforce Plan 23
2.9 Social Equity Business Incubator 24
Conclusion 25
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2.1 Living Wages
At RKNC LLC, our vision for a thriving business can only be met with the full engagement of
employees and agents, achieved through providing a safe, healthy, respectful, and economically
beneficial working environment. This Social Policy and Local Enterprise Plan summarizes our
intentions to provide our employees with the following:
●Head of Household jobs with salaries/wages that will enable employees to support
dependents with a moderate level of disposable income. The cost of living is only
getting higher. We at RKNC LLC want to ensure that we’re ahead of the curve when it
comes to employee wages and compensations;
●Employer-sponsored benefits,including health care and retirement benefits, will be
offered to employees;
●A strong sense of stability, via stable sources of income in permanent positions that will
increase in salary over time;
●Opportunities to climb up the career ladder will be made possible at RKNC LLC as we
expand; and
●An array of training and continuing education opportunities to develop technical
skills and educational levels.
In addition to the above, we will enthusiastically enter into labor peace agreements with
applicable labor unions if awarded a license, and will fully recognize our employees’ rights to
engage in labor organizing efforts, collectively bargain, and join trade unions—as this is crucial
to ensuring we are both accountable and responsible for promoting the well-being of all those
employed with RKNC LLC; more of this is explored in the Labor Peace Agreement section
further below.
If awarded a license and allowed to participate in this growing industry, RKNC LLC will
compensate employees well above the California minimum wage along with providing fair and
judicious opportunities for promotion.No employee at RKNC LLC shall earn less than a living
wage, regardless of their experience, background, or socioeconomic status, as RKNC LLC views
the cannabis industry as not only a resource for expanding community revenue but also for job
growth and creation.
RKNC LLC intends to have a majority of our workforce be composed of locals, including the
contractors we hire for construction. RKNC LLC will have a median annual wage of over
for our employees, which brings an average wage of per hour. Above all, we want
to ensure all earn a livable, fair wage of at least per hour. The following list is an example
of some of the positions we expect to have and their respective annual starting wages:
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The hourly wages will be increased each year by a percent determined by our owners (likely 1%
to an upwards of 5%). This wage increase may be provided quicker if employees demonstrate
exceptional performance throughout operations. Additionally, we will include a comprehensive
process to allow employees to apply for promotions within the company once they have gained
sufficient experience. A performance evaluation will be conducted every quarter for each
employee in hope of offering our staff with a predictable path to promotions and wage increases.
Ultimately, we as operators fully acknowledge that each employee—especially those at entry
levels—often seek opportunities for raises and promotions, and want to ensure that we provide
them with all the tools and resources to achieve these goals. For us, it is far more important to
reward employees who promote a stronger, more compliant cannabis industry as opposed to
retaining cost-effective wages and holding these employees in the same positions for as long as
possible.
As we elevate our employees to higher positions in time, we work to create more opportunities
for residents of Fresno seeking employment, which helps us meet our chief goal of promoting the
local economy. We further acknowledge that the definition of a “living wage” often changes
with the current economy at the time; this is why we too shall ensure that wages are adequately
adjusted appropriately for cost of living. In California, the living wage constitutes for an
individual with no children, and for individuals with at least two children. As stated
before, our median wage would be During the interview process, we may ask whether the
prospective employee has children at home and about their household situation in general.
Employees will not be obligated to answer any questions pertaining to this, as it may be personal,
however, given our commitment to ensuring each and every one of our workers is happy and
financially stable, we feel it is important to understand the circumstances of their household to
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best determine their living wage. Should an individual have two children, we will work to ensure
our living wage for this individual is at least to fit California’s living wage standard.
2.2 Employee Benefits
In addition to our competitive compensation plan, we will provide a comprehensive benefits
package following licensure, with ample medical insurance coverage for employees and
dependents that includes: emergency hospital care and hospitalization care with reasonable
co-pays and patient deductible amounts; prescription medication coverage with limited
exclusions and reasonable patient co-pay amounts; and access to preventative medical care by a
licensed physician or surgeon with the payment of a reasonable co-pay and patient deductible
amount. Furthermore, our employees will be awarded 1% commission that is shared among
them.
RKNC LLC recognizes that we will indeed hire individuals from low income areas that might
not own policy-acceptable clothing. As opposed to imposing further economic burden on such
agents, RKNC LLC will provide these employees with professional uniform stipends or work
clothes. This uniform will include a T-shirt, sweater, jacket, pants, belt, personal protective
equipment (“PPE”), and non-slip shoes. Ultimately, this decision was made because RKNC LLC
wants to encourage individuals from disproportionately impacted zones to apply to our company
as much as possible, as it is our goal to promote the local economy within these areas as well.
Additionally, RKNC LLC will offer employees a variety of supplemental insurance options that
include dental, vision, life, retirement, and long-term disability insurance after a license is
awarded. Retirement benefits will include defined contribution plans (i.e., 401k). Full-time
employees are provided sick leave, vacation, and personal time off. For employees that have
exhausted their compensated days off for the year, RKNC LLC will further provide at least ten
uncompensated days off per year for sick leave for the illness of the employee or his or her
immediate family.
Lastly, RKNC LLC pledges to cover the vaccination costs against COVID-19 for each and every
single one of our employees and their direct dependants, should they elect to do so. This is of
utmost importance, as we carry out our commitment to ensure that each of our employees, their
families, our customers, and our great community of Fresno are healthy and stay safe in light of
this global pandemic. Healthy, happy employees ultimately promote a safer, friendlier
environment for each other, as well as for our patrons. This, in turn, extends beyond our
business, out into the community at large.
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2.3 Compensation for Continuing Education & Employee Training
In regards to continuing education and employee training,RKNC LLC will actively encourage
its employees to seek higher education and training certification of relevant coursework
determined by our owners and reputable industry experts.As the cannabis industry progresses,a
notable number of universities and other institutions are beginning to allow for cannabis
programs.RKNC LLC will pay up to half of our employees’tuition costs involved in pursuing
degrees and/or certifications approved by us and related to our operation.
These employees will have to have worked at our facility for at least six months and must remain
employed for a period of time to access their educational benefits outlined above,of which the
particular details will be determined individually through personalized contracts.We want to
offer our employees a clear,comprehensive direction in regards to promotions and other such
opportunities,and higher education will be established as one such means for growth and
advancement in our organization.
Our Enterprise Resource Planning (“ERP”)system will document training attendance and
completion,as well as monitor staff metrics to allow for continuous improvement of the process.
This system will help management monitor and control individual employee development,assess
compliance with protocols,and identify any areas needing improvement,so appropriate training
modules can be implemented and further assessment can be performed.In the modern
competitive environment,employees need to replenish their knowledge and acquire new skills to
perform their jobs at maximum efficiency.This will benefit both them and the company.We
want them to feel confident about improving efficiency and productivity,as well as finding new
ways towards personal development and success.The policy applies to all permanent,full-time,
or part-time employees of the company.Employees with temporary/short-term contracts might
attend training at their manager’s discretion.
Employees,managers,and Human Resources (“HR”)will collaborate to build a continuous
professional development (“CPD”)culture.It is an employee’s responsibility to seek new
learning opportunities,it is a manager’s responsibility to coach their teams and identify
employee development needs,and it is HR’s responsibility to facilitate any staff development
activities and processes.In general,we approve and encourage the following training and
continuing education opportunities:formal training sessions (individual or corporate),employee
coaching and mentoring,participating in conferences,on-the-job training,job shadowing,and
job rotation.We will utilize the SellSafe Cannabis Training program to keep track of our all staff
member’s educational progression throughout operations.This will effectively ensure that
continuing education courses are provided year-round.Our employees will additionally have
scholarship programs offered to help encourage and realize educational advancement.
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2.4 Social Policy & Local Hiring
RKNC LLC is absolutely committed to local hiring practices, as this is a primary vehicle for
reinvigorating Fresno’s Chinatown--the area of our operation. Above all, we want our employees
to meet the criteria underlined in FMC Article 33 Section 9-3316 (b)(1), in that a minimum of
one-third (1/3) of the total annual work hours performed at the business who meets one of the
following:
●Annual family income below 80% AMI;
●Convicted for a cannabis related crime that could have been prosecuted as a misdemeanor
or citation under current State law;
●Lived in a low to moderate income census tract in the city for a minimum of three (3)
years;
●Veteran;
●Former foster home youth who was in foster care as a minor;
●Unemployed; or
●Receiving public assistance.
To further ensure we recruit additional employees that meet the criteria in FMC Article 33
Section 9-3316 (b)(1), we will work with local job recruitment services, such as the Fresno
Economic Opportunities Commission—a non-profit organization we pledged in our Community
Benefits and Investments Plan to donate a portion of our revenue to—in order to help facilitate
our hiring goals. We will communicate that we are looking for individuals that fit the criteria
outlined above to ensure well over one-third of our employees qualify for the Social Policy
section of the Fresno Municipal Code. If selected to receive a commercial cannabis business
permit, a condition of approval shall be to provide the City with ongoing proof of compliance of
this requirement.
In regards to local hiring, we are aiming to have at least 80% of our employees be Fresno locals,
and particularly locals in our proposed area of operation, Fresno’s Chinatown. In fact, we have
already signed a number of mutual Letters of Intent with Fresno locals already and plan to hire
them immediately following licensure. A list of these individuals is included below along with
additional information pertaining to their background, residence, and position.
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2.6 Number of Employees, Titles, Positions, & Responsibilities
The above organizational chart indicates our current staffing, and some titles have been left
blank for future hires. We will diligently work to hire as many local individuals as possible to
ensure we actively work towards our goal of promoting living wage jobs in Chinatown.
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AD - Administration Director
The Administration Director will be responsible for managing all administrative functions that
take place within the facility.These functions pertain to record keeping,accounting,human
resources,inventory control,and general facilities management.Other duties may include
onboarding new employees,defining workflow processes,and working with department
directors and managers to optimize use of all resources.
Ideal qualifications for the Administration Director position include:
●5+ years experience as an administration director or administration facilitator.
●Bachelor's degree or higher from an accredited university,preferably in Business,
Business Administration, or equivalent degree
●Keen organizational and communication skills
●Relevant experience in cannabis preferable
MD - Marketing Director
The Marketing Director will be responsible for developing,implementing,and executing
strategic marketing plans for the entire organization in order to attract potential customers and
retain existing ones.Day-to-day tasks include managing and coordinating marketing and creative
staff,leading market research efforts to uncover the viability of current and existing
products/services, and liaising with media organizations and other agencies.
Ideal qualifications for the Marketing Director position include:
●5+ years experience in marketing or sales management
●Bachelor’s degree or higher from an accredited university,preferably in Business or
Marketing/Advertising
●Recent experience building client relationships
●Recent experience being coached and coaching
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●Ability to manage all features of a marketing program
●Must be self-motivated and capable of developing sustainable marketing plans
SD - Sales Director
The Sales Director will be responsible for all sales related matters including pricing,
merchandising,special sales promotions,and all other extraction sales functions.Other
responsibilities of the Sales Director will include managing Sales Assistants as needed,offering
guidance and mentorship,providing sales reports and performance metrics to other extraction
facility staff,interfacing with the controller,administrator,and COO to ensure all sales practices
are in line with compliance regulations and company Standard Operating Procedures.
Ideal qualifications for the Sales Director position include:
●5+ years experience in marketing or sales management
●Bachelor’s degree or higher from an accredited university,preferably in Business or
Marketing/Advertising
●One year of prior management experience or demonstrated willingness and ability to
learn management basics
●Strong intrapersonal skills
●Exceptional written and verbal communication skills
●Familiarity with sales data analysis and reporting
SED - Security Director
The Security Director is responsible for the safety of all employees,products,and the facility as
a whole.The Security Director is involved in evaluating current procedures and practices and
assessing for safety concerns,identifying and resolving security issues,supervising security
operations and security personnel,developing and executing new security plans,ordering
equipment for security as needed,training security personnel as needed,and acting as a key
liaison between the company and public law enforcement or similar agencies.
Ideal qualifications for the Security Director position include:
●5+years experience in security management and performing supervisory responsibilities
or highly responsible work relating to tasks assigned to this position
●Bachelor's degree in Business Administration,Criminal Justice,or security or a closely
related field
●Demonstrated knowledge of Professional Protection Best Practices
●Any professionally recognized certifications in the security related field
●Strong time management, record keeping, analytical and problem-solving skill
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SA - Systems Administrator
The System Administrator will be responsible for effective provisioning,
installation/configuration,operation,and maintenance of systems hardware and software and
related infrastructure.
●This individual will participate in technical research and development to enable
continuing innovation within the infrastructure.
●This individual will ensure that system hardware,operating systems,software systems,
and related procedures adhere to organizational values,enabling staff,volunteers,and
Partners.
●This individual will assist project teams with technical issues in the Initiation and
Planning phases of our standard project management methodology.
●These activities include the definition of needs,benefits,and technical strategy;research
&development within the project life-cycle;technical analysis and design;and support of
operations staff in executing,testing and rolling-out the solutions.Participation on
projects is focused on smoothing the transition of projects from development staff to
production staff by performing operations activities within the project life-cycle.
●This individual is accountable for the following systems:Linux and Windows systems
that support ERP infrastructure;Linux,Windows and Application systems that support
Asset Management;Responsibilities on these systems include SA engineering and
provisioning,operations and support,maintenance and research and development to
ensure continual innovation.
Ideal qualifications for the Systems Administrator position will include:
●Bachelor of Science degree,preferably in Computer Science,Engineering (computer,
electrical, financial), Mathematics, Statistics, or any other data science related field.
●Must have a minimum of 3 years’ experience in system administration.
●Must have extensive experience configuring and managing McAfee HBSS for Antivirus,
Firewall, and Data Management
●Must have extensive hands-on experience deploying and managing domain services.
●Must have extensive experience deploying operating systems (WDS).
●Must have extensive experience patching systems and software (WSUS, System Center).
●Must have at least 1 of the following Industry Certifications: MCSA or MCSE.
●Must pass background check,reference check and must provide proof of eligibility to
work in the United States.
DSPM - Dispensary Manager
The Dispensary Manager is responsible for all day-to-day activities that are conducted inside the
retail dispensary. Further responsibilities of the Dispensary Manager will include:
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●Completes store operational requirements by scheduling and assigning employees;
following up on work results.
●Maintains store staff by recruiting, selecting, orienting, and training employees.
●Maintains store staff job results by coaching,counseling,and disciplining employees;
planning, monitoring, and appraising job results.
●Achieves financial objectives by preparing an annual budget;scheduling expenditures;
analyzing variances; initiating corrective actions.
●Identifies current and future customer requirements by establishing rapport with potential
and actual customers and other persons in a position to understand service requirements.
●Ensures availability of merchandise and services by approving contracts;maintaining
inventories.
●Formulates pricing policies by reviewing merchandising activities;determining
additional needed sales promotion; authorizing clearance sales; studying trends.
●Markets merchandise by studying advertising,sales promotion,and display plans;
analyzing operating and financial statements for profitability ratios.
●Secures merchandise by implementing security systems and measures.
●Protects employees and customers by providing a safe and clean store environment.
●Maintains the stability and reputation of the store by complying with legal requirements.
●Determines marketing strategy changes by reviewing operating and financial statements
and departmental sales records.
●Maintains professional and technical knowledge by attending educational workshops;
reviewing professional publications;establishing personal networks;and participating in
professional societies.
●Maintains operations by initiating,coordinating,and enforcing program,operational,and
personnel policies and procedures.
●Contributes to team effort by accomplishing related results as needed.
Ideal qualifications and skills for the Dispensary Manager position will include:
●Bachelor's degree or higher from an accredited university,preferably in Business,
Business Administration, or equivalent degree, or similar work experience
●Knowledge of METRC and California/Fresno law pertaining to cannabis operations
●Record keeping experience
●+3 years of experience as a manager or assistant manager in a cannabis retail
environment
●Knowledge in:
○Customer Service
○Tracking Budget Expenses
○Pricing, Vendor Relationships
○Marketing
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○Staffing
○Strategic Planning
○Management
○Client Relationships
DLM - Delivery Manager
Similar to a Dispensary Manager,the Delivery Manager would be involved in organizing and
facilitating all delivery operations associated with the Commercial Cannabis Business.The
Delivery Manager would be responsible for performing the following tasks:
●Completes delivery operational requirements by scheduling and assigning employees;
following up on work results.
●Maintains delivery staff by recruiting, selecting, orienting, and training employees.
●Maintains store staff job results by coaching,counseling,and disciplining delivery
employees; planning, monitoring, and appraising job results.
●Achieves financial objectives by preparing an annual budget;scheduling expenditures;
analyzing variances; initiating corrective actions.
●Identifies current and future customer requirements by establishing rapport with potential
and actual customers and other persons in a position to understand service requirements.
●Ensures availability of merchandise and services by approving contracts;maintaining
inventories.
●Formulates pricing policies by reviewing merchandising activities;determining
additional needed sales promotion; authorizing clearance sales; studying trends.
●Markets merchandise by studying advertising,sales promotion,and display plans;
analyzing operating and financial statements for profitability ratios.
●Secures merchandise by implementing security systems and measures.
●Protects employees and customers by providing a safe and clean store environment.
●Maintains the stability and reputation of delivery operations by complying with legal
requirements.
●Determines marketing strategy changes by reviewing operating and financial statements
and departmental sales records.
●Maintains professional and technical knowledge by attending educational workshops;
reviewing professional publications;establishing personal networks;and participating in
professional societies.
●Maintains operations by initiating,coordinating,and enforcing program,operational,and
personnel policies and procedures.
●Contributes to team effort by accomplishing related results as needed.
Ideal qualifications for the Delivery Manager position include:
●3+ years experience as a Delivery Manager or similar position
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●Bachelor’s degree in from an accredited university, preferably in Finance, Economics,
Statistics, or a related field, or or similar work experience
●Excellent communication skills and attention to detail
●Effective time management and ability to multitask
●Experience in measurements and analyses, enter data, and familiarity with quality control
requirements
ITM - Information Technology Manager
Responsibilities of the Information Technology Manager will include delegating duties and tasks
within the IT department,reviewing completed tasks to ascertain compliance with standards,
monitoring all team members and provide necessary advice and guidance,performing periodic
risk assessments and initiate risk control strategies,organizing regular seminars and trainings to
teach team members new computer techniques and methods,keeping up with trends in the
constantly evolving information technology industry,performing regular IT audit to discover
areas of weaknesses and fortify them,and working alongside other departments to achieve
company goals and visions.
Ideal qualifications for the Information Technology Manager position include:
●+3 years experience in IT help desk or IT services position
●Must have experience managing 10+ users in a structured IT network
●Must be comfortable addressing along with diagnosing network issues and
troubleshooting user problems
CRM - Community Relations Manager
The Community Relations Manager will identify and engage local stakeholders to support the
company,build partnerships as needed,and resolve community issues in the process.In addition,
the Community Relations Manager will be involved with outreach to local officials and with
preparation for meetings with key stakeholders.Further,a Community Relations Manager will
identify,organize,activate,and attend local events and community meetings,all while ensuring
the company remains engaged with the community’s concerns.
Ideal qualifications for the Community Relations Manager position include:
●+3 years in community engagement or management
●Bachelor’s degree in government or community relations fields
●Self-starter, ability to own and drive priorities
●Flexible, creative thinker, able to think outside the box and pursue new solutions
●Excellent communication and negotiation skills
●Strong cultural competence
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HRM - Human Resources Manager
Human Resources managers plan,direct,and coordinate the administrative functions of an
organization.They oversee the recruiting,interviewing,and hiring of new staff;consult with top
executives on strategic planning;and serve as a link between an organization’s management and
its employees.In addition,the Human Resources Manager will also oversee mishandling of
conduct in the work field.
Ideal qualifications for the Human Resources Manager position include:
●+2 working in human resources or administration
●Bachelor’s degree in human resources fields or administration are preferred,in addition
to an HR Certification Institute (HRCI)
●Excellent organizational ability
●Comfortable making key decisions regarding conduct mishandling
CS - Custodial Staff
The Custodial Staff is involved with maintaining facility sanitation standards and ensuring
facility safety.Job functions include sweeping,scrubbing,and waxing floors;vacuuming and
cleaning rugs and carpets;cleaning restrooms;emptying and cleaning waste receptacles,washing
and dust windows,walls,and blinds,and performing minor maintenance and repairs on
equipment or buildings such as replacing light bulbs, fixing doors, or minor painting.
Ideal qualifications for the Custodial Staff position include:
●Background in cannabis preferred
●High School Diploma or higher from an accredited school or university
●Standing,walking,lifting,twisting,and bending on a frequent basis for at least 8-hour
shifts
●Ability to lift to 50 pounds regularly and carry it up to 90 feet (or deposit into dumpster
or trash compactor)
SS - Security Staff
Security Staff members work with the Security Director and Security Director Assistant to
implement and executive security plans and oversee the safety of daily operations,in addition to
helping manage all matters related to security of all property,personnel,and other company
assets that may be processed by the facility.Other responsibilities include ensuring the safe
operation of the facility, preventing theft, vandalism, and other crimes.
Ideal qualifications for the Security Staff position include:
●Background in cannabis preferred
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●High School Diploma or higher from an accredited school or university
●At least 3 years experience in law enforcement, security, or loss prevention.
●Training in de-escalation and non-violent problem resolution will be highly desired.
●Must be comfortable sitting or standing for long periods of time
CSR - Customer Service Representative/Retail Sales Associate
Customer Service Representatives/Retail Sales Associates will directly interact with retail
customers on a day-to-day basis and must compliantly dispense cannabis products according to
company protocols and Fresno law.Customer Service Representatives/Retail Sales Associates
are essentially the face of the company and must act respectful towards customers,must have
knowledge pertaining to all cannabis products and paraphernalia sold at a dispensary,and must
perform all tasks associated with a retail cannabis business, including:
1.Utilizing a point-of-sale system
2.Storing cannabis products properly to prevent product adulteration
3.Tracking,destroying,and documenting old,expired,or contaminated cannabis products
according to company protocols
4.Weighing and measuring cannabis products
Ideal qualifications for the Customer Service Representative/Retail Sales Associate position
include:
●Background in cannabis preferred
●High School Diploma or higher from an accredited school or university
●Standing,walking,lifting,twisting,and bending on a frequent basis for at least 8-hour
shifts
●Capacity to follow orders directly from Dispensary Manager and perform tasks
compliantly according to local law and company protocols
ICM - Inventory Control Manager
An Inventory Control Manager is responsible for inventory management throughout the facility,
daily inventory reconciliation with sales reports, management of stored and quarantined
products, performing weekly audits, creating and implementing inventory control procedures and
developing related staff training, tracking all inventory including marijuana related accessories,
discovering and reporting trends in inventory, and complying with and updating standard
operating producers related to inventory tracking and management when industry guidance.
Ideal qualifications for the Inventory Control Manager position include:
●+3 years in inventory management
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●Associate’s or Bachelor’s degree in Business Management, Project Management, or a
related field
●Self-starter, ability to own and drive priorities
●Excellent organizational ability
CO - Controller
The Controller maintains a documented system of accounting policies and procedures, manages
outsourced functions, oversees the operations of the accounting department (e.g., design of an
organizational structure adequate for achieving the department's goals and objectives), in
addition to accounting operations of subsidiary corporations (e.g., control systems,
transaction-processing operations, and policies and procedures). In addition, The Controller
ensures that accounts payable are paid in a timely manner, ensuring that all reasonable discounts
are taken on accounts payable.
Ideal qualifications for the Controller position include:
●3+ years experience as a Controller or similar position
●Bachelor’s degree in from an accredited university, preferably in Finance, Economics,
Statistics, Mathematics, or a related field
●Excellent communication skills and attention to detail
●Effective time management and ability to multitask
●Experience in measurements and analyses, enter data, and familiarity with quality control
requirements
2.7 Labor Peace Agreement
The Applicant absolutely commits to signing a Labor Peace Agreement to ensure each and every
single one of our workers are unionized.As such,we pledge to hold a Labor Peace Agreement
with each of our employees in accordance with FMC Article 33 Section 9-3316(b)(2).The
Union shall be a bona fide labor organization that is the recognized or certified exclusive
bargaining representative of the employees of an employer.We will ensure that the union of our
choosing fulfills the following requirements:
1.It actually represents employees in California as to wages, hours and working conditions;
2.Its officers have been elected by secret ballot or otherwise in a manner consistent with
federal law; and
3.It is free of domination or interference by any employer and has received no improper
assistance or support from any employer.
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Job burnouts and stress associated with careers is at an all time high,especially given the recent
COVID-19 pandemic.We want staff to know that they can openly communicate with us
regarding their benefits,compensations,and work standards.Every quarter,the Applicant will
hold an internal meeting with all staff members individually to essentially check up on our staff
and determine whether they are currently happy working for our company.
We strongly believe in and will actively encourage open communication with our staff,as we
feel it would be impossible to live by our standards of service without having employees who are
genuinely proud of their place of work.We have included below an example of a Labor Peace
Agreement we would gladly commit to,however,once we identify and communicate with a
local Union,the terms of these agreements may change in order to ensure we remain an
absolutely fair and equitable business.
Labor Peace Agreement
RKNC,LLC,also known as Komoto’s,(“the Company”)and TBD (“the Union”)hereby agree
to the following terms (the "Agreement"):
1.Neutrality and Non-Disparagement.The Company agrees to take a neutral approach to
the unionization of workers,meaning that the Company,which also includes any
managers,agents,and representatives acting on its behalf,will neither help nor hinder the
Union's organizing effort,including making any statement or taking any action that
directly or indirectly indicates or implies any opposition to workers selecting the Union
as their collective bargaining representative,or directly or indirectly supporting or
assisting in any way the opposition efforts of any person or group who may oppose the
Union.This includes the Company refraining from making negative comments or
otherwise demean by word or action the Union,Union representatives,or unionization.
The Union agrees to refrain from exercising its rights to picket,handbill and engage in
other activities against,or otherwise disrupting or disparaging,the Company or its
facilities or operations;however,if the Company recognizes another union as the
bargaining representatives of any workers,the Union's obligation will automatically
cease to apply to those workers' facilities or operations.
2.Bargaining Unit.The Union will notify the Company of the facilities and/or operations
for which the Union seeks to invoke this Agreement's unionization process and,in this
notice,the Union will designate the bargaining unit.The Union is not limited in the
number of times it can provide such notice and invoke this Agreement's unionization
process for any of the Company's employees.
3.Access.Upon reasonable prior notice by the Union,the Company grants the Union and
its representative access onto the Company's premises to speak with bargaining unit
employees during non-working time,including meal periods and rest breaks.The
Company will cooperate with the Union in making arrangements to permit these
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conversations to be held in areas where the employees will be able to speak to the Union
representatives without monitoring by the Company's representatives.
4.Meeting.At the Union's request,the Company will conduct a meeting on a mutually
agreeable date(s)and time(s)with all of the bargaining unit employees.At the meeting,
the Company will tell the employees that it is neutral,does not object to their talking to
and supporting the Union,and will negotiate a collective bargaining agreement (CBA)
with the Union if a majority of the bargaining unit employees designate the Union as
their collective bargaining representative.Union representatives will attend the meeting,
and after the Company has introduced them and left the meeting,Union representatives
will talk with the employees about the Union without any disparagement of the
Company.
5.Contact Information.If the Union is unable to meet with employees at the Company's
location,at the Union's request and subject to any prior consent of the bargaining unit
employees required by law,the Company shall furnish to the Union the names,job
classifications,home addresses,cell phone numbers,home phone numbers and email
addresses,if known,of the bargaining unit employees (collectively,"contact
information").The Union shall be solely responsible for compliance with any applicable
federal,state or local laws concerning the protection of personally identifiable
information.The Company further agrees thereafter to provide updated worker contact
information, as reasonably requested by the Union.
6.Recognition.If and when a majority of bargaining unit employees designate the Union as
their collective bargaining representative,the Company will recognize the Union as the
exclusive representative of the bargaining unit,provided that the Union may assign
jurisdiction and representation rights to any of its affiliates.At either party's request,a
neutral third party may confirm majority authorization.The Company and the Union will
comply with all requirements necessary to obtain certification of the Union as the
exclusive bargaining representative of these employees.
7.Bargaining.Within 30 days from the date of recognition,the parties will begin good faith
bargaining for a CBA covering the bargaining unit.If the Union and the Company are
unable acting in good faith to agree to a CBA within 180 days of commencement of
negotiations,the parties agree that either the Company or the Union may require that all
open provisions and issues be submitted to final and binding interest arbitration per the
section titled herein "Arbitration."The parties anticipate that the term of the initial
contract would be 12 to 18 months.The arbitrator shall be guided by (but not bound by or
limited to)the:(I)the Company's size,type of business,and financial ability;and (2)the
employees'ability to sustain themselves,their families and dependents on wages,hours
and benefits they earn from the Company,and the living wage for their family size and
region as indicated in the MIT Living Wage Calculator (http://livingwage.mit.edu/).
8.Arbitration.The parties agree that final and binding arbitration will be the exclusive
remedy for any alleged violations of this Agreement and any dispute or claim arising
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from or relating to the interpretation or application of any provision of this Agreement.
Unless the parties promptly agree on an arbitrator,the parties will proceed to expedited
arbitration using the American Arbitration Association's rules and procedures.The
arbitrator is authorized to compel the attendance of witnesses and the production of
documents at the arbitration hearing,and to award appropriate monetary,injunctive and
declaratory relief.The parties agree not to challenge the arbitrator's decision in court and
consent to the entry of the arbitrator's award as the order of judgment of a United States
District Court.
9.Severability.If any provision of this Agreement is held illegal,void or invalid under any
applicable law,the parties will meet and confer to amend the provision to make it legal,
valid and binding,and the remaining provisions of this Agreement will remain binding
and enforceable according to their terms and the parties' intent.
10.Term of Agreement.The term of this agreement is one (1)year from the date of this
Agreement.The term will renew for additional 1-year terms unless and until either party
gives the other written notice no sooner than 60 days and no later than 30 days prior to
the expiration of the then-current term.
11.Confidentiality.The Company and the Union agree that the existence of and all terms and
conditions of this Agreement are confidential and proprietary between the parties and
shall not be disclosed to anyone else,except as may be necessary to effectuate this
Agreement,as required by law or court order,or as mutually agreed upon in writing prior
to disclosure.
We will further have a Collective Bargaining Agreement with each of employees in
compliance with FMC Article 33 Section 9-3316(b)(4).All employees at our facility will be
entitled to bargain collectively with respect to wages,work hours,and working conditions,and
have the right to decline or accept membership in a collective bargaining unit.All employees
will have the right to express,promote,pursue and/or defend common interests,which will be
discussed during regularly scheduled meetings between employee representatives and
employees.All collective bargaining agreements will be negotiated among and approved by the
Human Resource Manager,executive team,and our employees.These agreements will be
maintained in the company’s internal database,and a copy will be provided and made accessible
to each applicable employee.Further,the collective bargaining agreements will be made
available on request by any appropriate regulatory or other agency.
2.8 Workforce Plan
As it stands,more than 30%of the employees we have selected and secured through Letters of
Intent (“LOIs”)are Fresno locals.A list of these individuals is included in both 2.4 Social Policy
&Local Hiring and 2.5 Local Management.In total,we have secured 14 LOIs with employees
from diverse ethnic and professional backgrounds,most of whom are from California and a few
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others from Oregon. Out of these fifteen (15) employees, seven (7) of them are Fresno locals,
which contributes to roughly 46% of them being Fresno natives, exceeding the commitment
requirement of 30%. As time progresses, we want to bring this number closer to 80% and to
consist of particularly those who are local to Fresno’s Chinatown, our proposed area of
operation.
As further detailed in Section 2.3 Compensation for Continuing Education & Employee
Training, we are fully committed to not only train our employees under best practice guidelines,
but will both encourage and compensate our employees seeking a higher education or
certification relevant to their role, position, and/or cannabis in general. Having knowledgeable
employees is one of our absolute key goals, there we see every opportunity for our employees
seeking education or certification as an opportunity for investment. Lastly and as further
detailed in Section 2.1 Living Wages, we absolutely commit and pledge to giving each and
every single one of our employees a living wage, which we recognize can change and only
become higher as time passes. RKNC LLC will have a median annual wage of over for
our employees, which brings an average wage of $ per hour. Above all, we want to ensure all
earn a livable, fair wage of at least per hour as the minimum wage.
2.9 Social Equity Business Incubator
Our team consists of incredible industry professionals and leaders who have a strong history of
mentorship programs. In our Community Benefits and Investments Plan, we discussed how part
Owner and Chief Financial Officer, Dr. Kamell Eckroth-Bernard, had mentored several
individuals from various universities on surgery, which total over 90 students he personally
mentored, trained, and prepared for vascular surgery. Mentorships have been a part of our team’s
core goals and values, and will continue with Fresno’s Social Equity Business Incubator
Program.
To help facilitate this, one of our owners, Nic Easley, will aid and oversee mentorships and
training opportunities in cannabis businesses. Nic Easley has been a leading figure in the
cannabis industry since the early days of Colorado’s first cannabis program. Nic Easley is the
founder and CEO of 3C Consulting, LLC™—the leading global strategic cannabis consulting
firm and the CEO & Managing Director for Multiverse Capital™—a cannabis & hemp venture
firm. He is a globally recognized cannabis industry expert and a sought-after writer, panelist, and
keynote speaker for many top conferences and publications.
His impressive track record of building significant cannabis businesses and guiding others
towards their victories has established him as a trusted and proven resource for entrepreneurs and
investors across the cannabis industry. His scientific background and extensive 15 years of
experience in agriculture and biology offer the industry new possibilities of productivity,
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profitability,and professionalism.Nic’s background in the cannabis industry will help facilitate
any training and mentorships for businesses in the Social Equity Business Incubator,and his vast
network and connections can even help individuals who qualify for Social Equity seek licensure,
legal assistance, financial services assistance, or other technical assistance support.
In regards to our other owners who equally have strong philanthropic backgrounds,they agree to
committing equipment donations.We can further help facilitate this through one of Nic Easley’s
partners and connections,Natural Order Supplies,who are based out of Colorado and have been
helping businesses with cultivation equipment and supplies to enhance their cannabis cultivation
operations.Lastly,a percentage of shelf space will be dedicated to Fresno equity business
products.We commit to purchasing at least 20%of our products from reputable Social Equity
businesses in Fresno.At any opportunity or need for purchasing goods or services our
Procurement Manager will strive to ensure that we keep our purchases and vendors as local as
possible to help as many other small Fresno businesses benefit from this new program.
The owners of RKNC LLC will work with other new businesses in the Chinatown area and other
areas of the city to help leverage our numerous years of new business development experience to
educate new business owners achieve their dreams.We will work with the Fresno Chamber of
Commerce to best select which new and potential business owner in our area would be the best
fit and would benefit most from our experience.Our strong commitment to local small
businesses is already apparent in our service providers and selected staff.When choosing our
staff we look for diverse individuals and provide them the training and experience for them to
grow both personally and professionally,In turn,our Social Equity Business Incubator will be
something we do both in-house as well as throughout the Greater Fresno Community.
Conclusion
Through our various employee compensation programs and commitment to their education,
well-being,and safety,we have no doubt our employees will have all the tools,means,and
resources to thrive at RKNC LLC.Local hiring still remains a key priority for us,which is why
we took the time to find individuals in Fresno to take up key management positions.As Fresno
locals ourselves,the well-being of our community through viable,head-of-household careers that
incentivize our employees to continuously improve their knowledge and service,is absolutely
crucial to our business model.Ultimately,our goal is to lead by example and to always ensure
we place the well-being of our employees above all.Without happy employees,we simply
cannot have happy customers.Our goal is to turn each and other one of our staff into cannabis
industry leaders,and will further award them for their activism towards just causes.We are
absolutely excited to bring these career opportunities to the local community and will ensure they
are always proud of working with us.
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Section 3 | Neighborhood Compatibility Plan
Table of Contents
3.1 Addressing Complaints 2
Public Notices for All Complaints 2
Noise, Light, Litter, Vehicles, & Pedestrian Traffic Complaints 3
Odor Complaint Process 5
Contingency Measures for Continuous Public Nuisances 6
3.2 Neighborhood Impact 6
Volunteerism 7
Being A Good Neighbor 7
Law Enforcement 8
Emergency Contact 12
Signage Plan 12
3.3 Odor Mitigation Practices 14
3.4 Identifying Potential Sources of Odor 15
3.5 Odor Control Devices & Techniques 15
3.6 Odor Training & System Maintenance 20
3.7 Waste Management 20
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3.1 Addressing Complaints
Our company is founded upon the mission of realizing and maintaining positive community
relations.Our goal is to showcase how cannabis businesses can help reinforce the local
community by providing career opportunities for locals,ensuring safe practices and optimal
security,and promoting local businesses and non-profit organizations.Given the recent
COVID-19 pandemic and with cannabis businesses being deemed essential,this license
opportunity will give us ample means of providing secure career opportunities for those
impacted by COVID-19.
Essentially,we cannot achieve our goal without proper feedback from our customers and
neighbors.Throughout this section,we detail each process of handling complaints related to
noise,light,odor,litter,vehicles,and pedestrian traffic.In addition to describing our contingency
measures involving each of these aspects,we further review how we will ultimately work to
prevent these issues from arising to begin with,as prevention is far more important for us to
maintain community relations as opposed to focusing solely on reactive strategies.
Public Notices for All Complaints
On our website,phone application,and inside the waiting room of our dispensary,we will post
information pertaining to public complaints.Our website will have a page dedicated to local
community complaints,with a Complaint Form integrated on the website that asks the
following questions:
1.Name and contact information of the complainant;
2.Type of issue,which will be categorized as either noise,light,litter,odor,traffic,
vehicles, or other to keep the complaint process focused and to the point;
3.Description of the issue or concern the complainant may have; and
4.Feedback on how we can best address the complaint.
The Dispensary Manager will be notified if a complaint is documented on our website;and
immediately contact the complainant to get any additional information regarding the complaint.
All complaints will be addressed within 24 hours and our follow-up action will be communicated
with the complainant within 48 hours.In addition,our Chief Executive Officer’s contact
information,including her name,phone number,and email address,will be posted in the
dispensary’s waiting room as well as our phone application and website,to ensure a prompt
response to all complaints revolving around our commercial cannabis activities.
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Noise, Light, Litter, Vehicles, & Pedestrian Traffic Complaints
Our odor complaint process is described further below.In this section,we will describe how we
will work to both identify and resolve issues pertaining to noise,lights,litter,vehicles,and
pedestrian traffic.
●Noise Complaints
○Prevention:As described in our training modules and SOPs,each employee will
be trained to be respectful of the community and ensure that no excessive noise is
frequented out of the facility.Additionally,on-site security personnel will employ
deescalation strategies when appropriate;for example,when a particular
customer or group of customers may be producing excessive noise or engaging in
behaviors that are a general disturbance of.Any customer that causes issues
revolving around creating excessive noise will be warned by security personnel
and/or escorted off the premises,if necessary.In extreme circumstances,security
personnel may call local law enforcement should the problem persist.
○Reaction to Noise Complaint:Should a customer reach out with a noise
complaint,the Dispensary Manager will notify the complainant as soon as
possible that he or she has received the complaint,will draft a formal response to
the complainant,and give a list of action items in addition to a timeline as to
when the problem will be rectified.Staff will receive additional training to ensure
the issue does not persist.
●Lights Complaints
○Prevention:Only the necessary amount of light will surround the exterior of the
building,essentially enough to ensure everything is adequately lit yet not
overwhelming so.We do not anticipate we will receive too many complaints
pertaining to lights pertaining to our exterior lighting.
○Reaction to Lights Complaint:Should a customer reach out with a complaint
regardings lights,the Dispensary Manager will notify the complainant as soon as
possible that he or she has received the complaint,will draft a formal response to
the complainant,and give a list of action items in addition to a timeline as to
when the problem will be rectified.Staff will receive additional training to ensure
the issue does not persist.
●Litter Complaints
○Prevention:All staff will be trained to dispose of any items in appropriate
receptacles.Littering will not be tolerated in or around our building,including on
the street outside of our facility.The facility’s Sanitation Specialist will ensure the
parking lot and building interior are always clean and sanitized.We will further
place a trash bin inside the waiting room area,point of sale area,backroom area,
and the parking lot and front door areas to mitigate and prevent customer littering
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as much as possible.Staff will be required to report any littering incidents,be it
from a fellow employee or customer.
○Reaction to Litter Complaint:Should a customer reach out with a complaint
regardings litter,the Dispensary Manager will notify the complainant as soon as
possible that he or she has received the complaint,will draft a formal response to
the complainant,and give a list of action items in addition to a timeline as to
when the problem will be rectified.Staff will receive additional training to ensure
the issue does not persist.Additionally,any employee found to be littering will be
initially warned and if the problem persists,they may be suspended or terminated
depending on the severity of the issue.Customers who litter will equally be
warned for the first time,and potentially banned from entering the premises
should the problem continue.
●Vehicles & Pedestrian Traffic Complaints
○Prevention:In regards to vehicles,our site will have ample parking availability
with additional ADA and electric/hybrid spots reserved.A major factor that can
contribute to congested vehicle traffic would be poor ingress and egress access
points for customers and limited parking spaces,which is why ensuring sufficient
parking spaces would help prevent this issue from arising.Additionally,we will
further have bike racks installed to encourage cycling as opposed to driving to the
dispensary for nearby locals.In regards to pedestrian traffic,the COVID-19
restrictions often limit occupancy capacity,which can result in lines outside of the
dispensary.To prevent pedestrian congestion,we will provide customers with a
pre-built line that is separated from the center of the street and aligned alongside
our building.Security personnel will ensure there is no excessive loitering around
the building,and will further maintain order within the line to make sure
customers do not cause a nuisance.Signs will also be posted outside of the
dispensary notifying customers to wait alongside the line and not outside of it.
○Reaction to Vehicle &Pedestrian Traffic Complaints:Should a customer
reach out with a complaint vehicle and pedestrian traffic,the Dispensary Manager
will notify the complainant as soon as possible that he or she has received the
complaint,will draft a formal response to the complainant,and give a list of
action items in addition to a timeline as to when the problem will be rectified.
Staff will receive additional training to ensure the issue does not persist.
Additional signs may be posted outside of the building providing further
instructions for customers.Pre-order and express pickups will also be set up for
customers to ensure optimal customer flow and to prevent excessive waiting times
and line congestion on the street.We will also align our goals pertaining to
cycling with the Bicycle and Pedestrian Advisory Committee (“BPAC”).
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Odor Complaint Process
Upon receiving a complaint regarding odor,the complaint will be logged into our system,and
dispensary management and staff members will provide details on the event.An investigation
will be conducted to identify the source of the odor.
●If the source of the odor is due to a malfunction of an odor control or air quality
management system,a maintenance team will be immediately deployed to address the
issue.Following repair,the site manager,maintenance specialist,and facility team will
further test the system to verify if the problem has been resolved prior to resuming
operations
●If the source of the odor is found to be due to a client violating the non-smoking policy,
the client will be reminded of smoking restriction within the lot vicinity and will be asked
to leave by security personnel or by the site manager;first or repeated offenses can/will
result in a prohibition from future product purchases and site visits
●If the source of the odor is due to an employee violating the non-smoking policy within
the lot vicinity, they will be subjected to disciplinary action that can lead to termination
We will also work with the California Bureau of Cannabis Control (“the Bureau”)if a formal
complaint regarding odor has been filed through its website and will update the Bureau regularly
regarding the status of the resolution,as appropriate.After addressing the problem,we will
initiate a staff meeting to discuss the resolved issue and how to prevent future episodes of the
incident from reoccurring.The topics explored in this discussion will be included in all future
training programs for new hires in addition to scheduled staff meetings.
Overall,our policy will focus on preventative than reactive strategies to inhibit all odor-related
incidents from occurring.All staff members will be thoroughly trained on how to respond to
public complaints regarding odor in addition to effectively resolving the issue within policy and
regulation guidelines.Complaints records will be retained for a minimum of seven years per
CCR §5037(A), and will include the following information:
●Detailed information about complainant's odor nuisance experience;
●Date the complaint was received and the name,address,or telephone number of the
complainant, if available;
●Identification of personnel involved with documenting,reviewing,and investigating
complaints,in addition to management personnel involved with making decisions about a
follow-up action;
●Findings of the investigation and follow-up action taken when an investigation is
performed; and
●Response to the complainant, if applicable.
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Contingency Measures for Continuous Public Nuisances
In addition to our preventative measures for inhibiting odor nuisance issues,a contingency plan
will be deployed following an unresolved dispute regarding odor.The contingency plan is
individualized for each unique circumstance, according to the following plan:
●If the odor is unable to be effectively abated with the use of the HVAC system,we will
replace all filters with activated carbon filters (e.g.,polarized media filters with activated
carbon insert pads),which utilize electromagnetic polarization to fully optimize odor
filtration.This measure will ensure that air quality is thoroughly maintained throughout
facility operations and will be continued to be replaced, as needed
●If the odor is unable to be effectively abated due to repeated violations of the
non-smoking policy by clients,a security team will identify the offenders prior to entry
and will prohibit entry into the facility.In addition,violations from staff members will
result in immediate termination and a staff meeting will take place to review policy
●If the odor is unable to be effectively abated due to repeated malfunctions of the HVAC
system,a new unit will entirely replace the old system to ensure management of air
quality—which will be followed by multiple retests to ensure quality and
functionalibility.This plan will be coordinated between team leaders and site managers to
ensure the new system is promptly installed prior to resuming operations
3.2 Neighborhood Impact
In the previous section,we explored how we will address complaints to avoid becoming a public
nuisance in addition to prevention strategies,however,in order to fully solidify our commitment
in being good neighbors and fully integrating with our community,we strongly believe that this
goal can only be solidified by creating positive community impacts.Throughout this section,we
explore how we will impact the neighborhood in a positive manner,be it from volunteerism,
improving internal policies,and engaging in positive law enforcement interactions.We believe
every single area of our operations should contribute in some way to the general betterment of
the communities around us.That is why we will factor into our annual and quarterly business
reviews time reserved explicitly for discussing matters related to community engagement.
During these reviews,we will address various aspects of our reputation management program,
such as:
●Annual budget review for charitable giving;
●Current quarterly goals for community engagement;
●Staffing and resourcing community initiatives;
●Year-in-Review and goal setting;
●Identifying and exploring new opportunities; and
●Quarterly community impact evaluations.
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Volunteerism
The Applicant will ask each employee to commit eight (8)hours of volunteer time per quarter,of
which half will be paid by the Applicant.Employees will be encouraged to volunteer with
community non-profits,and meaningful participation within the community will be heavily
considered in hiring,promotion,and compensation decisions.The Applicant will sponsor
volunteer activities for our staff and will offer time-off for employees to volunteer with civic
organizations.We will compensate our employees the same as if they worked a normal day;this
will ensure that we give at least 20 hours per month of community support,which will be utilized
for park cleanups,service projects,non-profit organization aid,and any other requirements to
promote the well-being of our neighborhood.
Being A Good Neighbor
The Applicant will conduct business with consideration for neighboring businesses and residents,
especially in light of the fact that we are in Fresno’s historic Chinatown.We will regularly solicit
our neighbor’s input on our business rather than wait for complaints.We understand some
community members have concerns that The Applicant will attract criminal activity,illegal drug
dealing,and youth access.The Applicant will provide a community education program that will
empower residents with information and insight regarding a safe,responsible cannabis business
and the company’s commitment to make our neighborhood safer.Our educational programs will
be open to all.
The Applicant intends to engage elected officials,local businesses,neighborhood associations,
school boards,local Chambers of Commerce (of which we will join),community leaders,
organizers,and civic groups by offering collaborative dialogue,addressing concerns from
environmental impacts to anti-diversion tactics;and sharing the results of our efforts to mitigate
negative impacts to the neighborhood.We offer transparency and wish to maintain open
channels of communication with our community partners.In addition,The Applicant will be
incorporating the following actions:
●Providing the name,telephone number,and email address of a community relations
contact for problem solving to local officials and law enforcement;
●Providing the above-mentioned information to all businesses and residences located
within one hundred (100) feet of The Applicant’s location;
●During the first year of operation,having the owner,manager,and community relations
representative attend quarterly meetings with the local officials to discuss costs,benefits,
and other community issues; and
●After the first year of operation,having the owner,manager,and community relations
representative meeting with the local officials upon request.
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Law Enforcement
Cannabis businesses play a critical role in assisting law enforcement with minimizing illegal
activities while respecting the rights of adult consumers.We are fully committed to operating
strictly within California and local laws,including partnering with local law enforcement to
minimize the risk of illegal diversion of cannabis,impaired driving,and youth access.Our Law
Enforcement plan of action includes:
●Community Outreach:The Applicant will engage local law enforcement with regular
meetings to discuss issues of mutual concern,provide site tours,and address questions
and concerns regarding The Applicant’s business.We will maintain an open-door policy
with law enforcement officials,addressing anti-diversion tactics and encouraging
transparency throughout our entire operational chain of custody.
●Officer Training Sessions:We will partner with the local law enforcement to provide
education and training for law enforcement personnel regarding cannabis and its legal use
to maximize collaboration and the exchange of ideas while conserving the limited time
police officers have available.
●Support Local Law Enforcement:The Applicant will donate financial resources to
support law enforcement initiatives in a variety of ways.This will solidify and
demonstrate our sincere commitment to the local community and promote public safety.
●Impaired Driving Research and Education:The Applicant will collaborate with
institutions conducting studies on how cannabis affects consumers while operating a
motor vehicle,such as by measuring response time,eye-hand coordination,and cognitive
function.This research will help establish baselines for acceptable THC levels in the
bloodstream for drivers and will be shared and used in partnership with local and state
law enforcement.
Our property located on 1536-1542 Kern Street,Fresno,CA 93706,is fully compliant with the
regulations outlined in FMC Article 33 Section 9-3307.We are located in the DTN (Downtown
Neighborhood)zone,which is one of the zones identified in FMC Article 33 Section 9-3307(a)
as appropriate for commercial cannabis businesses,per FMC Article 33 Section 9-3307(d)(3).
We further conducted a thorough review of our surrounding area and determined the property
remains compliant with FMC Article 33 Section 9-3307(c),in that it is further than
eight-hundred (800) feet from:
1.A cannabis retail business, per Section 9-3307(c)(1);
2.A school providing instruction for any grades preschool through 12 (whether public,
private,or charter,including pre-school,transitional kindergarten,and K-12),per Section
9-3307(c)(2);
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3.A day care center licensed by the state Department of Social Services that is in existence
at the time a complete commercial cannabis business permit application is submitted,per
Section 9-3307(c)(3); and
4.A youth center that is in existence at the time a complete commercial cannabis business
permit application is submitted, per Section 9-3307(c)(4).
The building is fully enclosed and was formerly a department store,per FMC Article 33 Section
9-3307(d)(1),and structured in a way to make it impossible to visibly see cannabis from outside
of the building and public right-of-way.Given that we are located in the DTN zoning area,our
proposed location set in Fresno’s historic Chinatown,we fit under the City’s General Plans for
infrastructural development and improvements.As stated in our community engagement plan,
we are fully committed to helping revitalize our historic Chinatown through various means,both
in regards to donations,the commitment of a portion of our net revenue,and volunteerism.In
accordance with FMC Article 33 Section 9-3307(d)(2),we are absolutely committed to aligning
our operational goals right alongside the City’s General Plan.
The facility will be entirely enclosed,and only pre-sealed,pre-packaged products will enter our
facility,greatly reducing the risk of any odors that may cause public complaints.Furthermore,
we described in our Neighborhood Compatibility Plan the specifications of our state-of-the-art
HVAC system,which will further aid in odor abatement to keep with FMC Article 33 Section
9-3307(d)(4).The size of our proposed location is approximately 3,500 square feet,making it
more than adequate in spacing to comply with FMC Article 33 Section 9-3307(d)(5),as we
have plans to further secure the parking lot around the area in addition to the loading area for
delivery and shipments.In adherence with the Fresno HSR Station Master Plan,we also have
secured the adjacent building as part of our lease as well,in order to eventually expand in
accordance with input from the City and neighborhood,which would coincide with the City's
vision for the "Station District"which is slated to provide entertainment and "Fresno’s Front
Door"once the High Speed Rail is complete.As can be seen in the image below,our location is
positioned very close to the 99 Freeway,making it exceptionally ideal for our delivery services,
as it will connect us to most parts of the City,which further helps us remain compliant with
FMC Article 33 Section 9-3307(d)(6).By being essentially in the heart of Chinatown,we
further ensure that we can expand accessibility to those who need cannabis.
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Prior to committing to our proposed location,we further reviewed our “Walk Score”to
determine how accessible our business would be for locals,which would inherently improve our
neighborhood compatibility by causing less traffic and pedestrian congestion.An image of our
walk score is included below.Overall,our location received a walk score of 87/100,making it
very walkable for pedestrians and locals.The average walk time to reach our proposed
dispensary from the various residential areas is only 11 minutes by foot.Equally,the average
commute via vehicles is only 1 minute,2 minutes by bike,and only 8 minutes when taking
public transportation.There are a number of transit locations within our location,which helps
with accessibility and promotes public transportation.Accessibility for customers and especially
patients who seek cannabis as medicine are important for us,and a prime factor in why we chose
our particular location,as Fresno’s Chinatown has seen a gradual decline in basic infrastructure.
Offering locals easy accessibility to our dispensary is the least we could do to help them receive
the products they want or need.
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The facility is fully equipped with proper and adequate electricity,sewerage,disposal,water,fire
protection,and storm drainage,pursuant to FMC Article 33 Section 9-3307(d)(7),primarily due
to the fact that its previous intended use was as a department store,making it exceptionally ideal
for retail sales.We have further worked and developed a Neighborhood Compatibility Plan in
keeping with FMC Article 33 Section 9-3307(d)(8)to ensure that we stand as a positive
influence within our community.
Our facility falls under a historic region;therefore we cannot and will not make significant
modifications to the exterior of the building.We have chosen to retain the name of the original
department store’s name (seen in the picture below),Komoto’s,as our DBA.Our logo will be
designed to have a similar look and feel to the logo for Central Fish Co.,seen also below,to fully
integrate with the features of Chinatown and our local area.These steps will ensure compliance
with FMC Article 33 Section 9-3307(e)(1).
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We have ensured full compliance with all local zoning ordinances as stated before, per FMC
Article 33 Section 9-3307(e)(2), in addition to all the guidelines outlined in the City’s General
Plan. Lastly, we will ensure that our signage will be limited to that needed for identification only
and will not contain any logos or information that identifies, advertises, or lists the services or
the products we offer, per FMC Article 33 Section 9-3307(e)(3).
Emergency Contact
To help facilitate stronger neighborhood compatibility, RKNC LLC will comply with FMC
Article 33 Section 9-3309(g)by providing the City Manager or her designee with the name,
telephone number (both landline and mobile, if available) of an on-site employee or owner to
whom emergency notice can be provided at any hour of the day. We will provide our Chief
Executive Officer’s (who is also our majority owner) contact information, included below. Our
CEO may be contacted by the City Manager at any time.
Name: Robyn Kale
Personal Phone Number:
Email:
Signage Plan
Upon issuance of license, RKNC LLC shall prominently display the license on the licensed
premises where it can be viewed by state and local agencies and within plain sight of the public
per CCR §5039 and FMC Article 33 Section 9-3309(h)(1). Any advertising or marketing
RKNC LLC places in broadcast, cable, radio, print, and digital communications shall only be
displayed where at least 71.6% of the audience is reasonably expected to be 21 years of age or
older, as determined by reliable, up-to-date audience composition data. Upon request, RKNC
LLC shall provide to the Bureau audience composition data. This information shall be provided
to the Bureau within the time specified by the Bureau. If the Bureau determines that audience
composition data for advertising or marketing provided by RKNC LLC does not comply, or
RKNC LLC fails to provide audience composition data to the Bureau within the time specified
by the Bureau, RKNC LLC shall remove the advertising or marketing placement in question per
CCR §5040. Prior to any advertising or marketing from RKNC LLC involving direct,
individualized communication or dialogue through any form of communication, including
in-person, telephone, physical mail, or electronic, RKNC LLC shall use age affirmation to verify
that the recipient is 21 years of age or older. RKNC LLC shall use a method of age affirmation
before having a potential customer added to a mailing list, subscribe, or otherwise consent to
receiving direct, individualized communication or dialogue per CCR §5041.
In accordance with FMC Article 33 Section 9-3309(h)(2), no signs placed on the premises of
our business will obstruct any entrance or exit to the building or any window. Each entrance will
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be visibly posted with a clear and legible notice,in English,Spanish,Japanese,and Cantonese,
indicating that smoking,ingesting,or otherwise consuming cannabis or cannabis products on the
premises or in the areas adjacent to the business is prohibited,per FMC Article 33 Section
9-3309(h)(3).Business identification signage will be limited to that needed for identification
only and will not contain any logos or information that identifies,advertises,or lists the services
or the products offered,pursuant to FMC Article 33 Section 9-3309(h)(4);furthermore,
advertising will not be visible from the exterior of the establishment and will not be placed on
the exterior of the establishment.RKNC will also not advertise by having a person holding a sign
and advertising the business to passersby.
RKNC LLC shall not advertise or market in a manner that is false or untrue in any material
particular,or that,irrespective of falsity,directly,or by ambiguity,omission,or inference,or by
the addition of irrelevant,scientific,or technical matter,tends to create a misleading impression.
RKNC LLC shall not publish or disseminate advertising or marketing containing any statement
concerning a brand or product that is inconsistent with any statement on the labeling thereof.
RKNC LLC shall not publish or disseminate advertising or marketing containing any statement,
design,device,or representation which tends to create the impression that the cannabis
originated in a particular place or region unless the label of the advertised product bears an
appellation of origin, and such appellation of origin appears in the advertisement.
No banners,flags,billboards,or other prohibited signs will be used at any time,and signage will
not be directly illuminated,internally or externally,per FMC Article 33 Section 9-3309(h)(5),
and neither will we advertise on a bus shelter,placard,aircraft,or engage in similar forms of
advertising,per FMC Article 33 Section 9-3309(h)(6).RKNC LLC shall not advertise or
market cannabis or cannabis products in a manner intended to encourage persons under 21 years
of age to consume cannabis or cannabis products,nor publish or disseminate advertising or
marketing that is attractive to minors,nor advertise or market cannabis or cannabis products on
an advertising sign within 1,000 feet of a day care center,school providing instruction in
kindergarten, or any grades 1 through 12, playground, or youth center, per BPC §26152.
For the community,a 24-hour hotline number will be posted at the perimeter of the premises to
encourage citizens in the neighborhood to report any observations of potential safety concerns,
theft,or other crimes in the vicinity of RKNC LLC’s retail storefront.We will also provide the
name,telephone number,and email address of a community relations contact,who will be our
Chief Executive Officer,per FMC Article 33 Section 9-3309(m).We will also provide our
contact information to all businesses and residences located within one hundred (100)feet of our
facility.Even if the activity reported does not directly involve RKNC LLC’s retail storefront,the
security alarms,surveillance systems,and observations of on-site security offers may provide
law enforcement officials with valuable information to maintain the peace and security of the
neighborhood where RKNC LLC conducts its business activities.
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3.3 Odor Mitigation Practices
The Applicant will be responsible for the development,implementation,and maintenance of our
Odor Management Plan,which will be regularly updated to meet any new requirements
established by the City of Fresno and the State of California.The measures listed above are
up-to-date,and the HVAC is an industry-specialized system used as a gold standard for all
cannabis operations,including for cultivation and manufacturing.The Applicant prohibits the
consumption of cannabis (including smoking)within the vicinity of our property boundaries.
Internal and external signage will include the following statements:
“Komoto’s Dispensary prohibits any smoking activity of cannabis by all persons within the
following areas:
1.The common area of any duplex,triplex,or other multi-family residential complex not
open to the public; and
2.Any public park where tobacco smoking may otherwise be allowed.No person shall
smoke cannabis,without controlling odors emanated from that smoking,which are
disturbing to people residing or present on adjacent or nearby property or areas open to
the public.”
Consumption and smoking policies for employees are reviewed regularly,and failure to adhere
to the policy may result in employment termination.Staff will inform customers of Komoto’s
Dispensary’s consumption prohibition.Any customer failing to adhere to the policy may lead to
removal from the property and/or future restrictions (ban) from the premises.”
In addition to ensuring that the HVAC system provides appropriate environmental controls,we
will implement certain company policies to promote clean air quality in the facility,which
include the following measures:
●Signage inside and around the property will alert customers that cigarette smoking,and
smoking,ingesting,or consuming cannabis on the premises or in adjacent areas,is
prohibited;Volatile Organic Compounds (VOCs)are chemical compounds that can
off-gas from certain products and can adversely affect the environment and human
health;
●Whenever possible,low VOC-emitting building supplies,furnishings,wall coverings,
and office equipment will be used in the facility.Non-toxic,low VOC-emitting cleaning
supplies (preferably organic) will be used to clean the facility;
●Non-toxic (preferably organic biocides)will be used for pest control,if necessary,as a
component of Integrated Pest Management;
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●Radon,carbon monoxide,and smoke detectors will be installed in the facility.The
detectors will be tested regularly according to the manufacturers’recommendations and,
if applicable, their batteries will be changed on a regular basis; and
●If possible,the company will purchase low-emission vehicles that will park away from
air intakes to prevent vehicle exhaust from entering the building.
We will further maintain and provide to the Bureau all records that relate to odor management.
Upon installing a new HVAC system,dates will be kept as to when a service provider was
contacted as well as the duration of the installation.Additionally,the HVAC system will undergo
regular check ups throughout operations and will be maintained accordingly.Should any part of
the HVAC system malfunction,we will immediately contact a service person to fix the issue as
soon as possible.Should this service person deem the operation site potentially hazardous due to
this malfunction,all cannabis operations will cease until the HVAC system is fully operational
and verified to be operational by the professional.All employees,especially the site manager,
will be responsible for ensuring all ventilation systems and filters are functioning properly.The
site manager will be responsible for contacting and contracting a third-party service provider
specialized in HVAC and other filtration systems.All actions,timelines,and key notes regarding
this process will be kept on record and will be provided to the Bureau upon request.
3.4 Identifying Potential Sources of Odor
Cannabis facilities have the potential to produce nuisance odors in the surrounding community.
The odor is primarily due to an essential component of cannabis called terpenoids,which are
responsible for its pungent fragrance due to the presence of isoprene (i.e.,commonly prevalent in
other herbs such as sage,mint,and aromatic barks).The presence of cannabis products can result
in the release of this fragrance within its immediate vicinity,which can be significantly mitigated
through the use of contained spaces and a proper ventilation system.The only other source of
potential odor issues within the vicinity of a dispensary results from smoking activity in violation
of our internal policies regarding consuming cannabis on the premise.Everything will be
pre-packaged and completely sealed regardless,therefore significantly mitigating odor sources.
Cannabis waste will be disposed of in a secured, closed, and locked bin to further prevent odors.
3.5 Odor Control Devices & Techniques
As operators,we cannot risk the safety of our workers or surrounding community,therefore
having ample means of treating exchanged air is crucial.Ventilation is the primary control for
facility temperature and humidity.The facility will use closed-loop air systems for our
dispensary operation.Our intake air will have filters on them,which greatly reduces the risk of
bugs and diseases getting into the room as opposed to using an open-loop system.
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The extraction fans also exhaust the heat and humidity load accumulated at the top of the facility.
Filters and screens will be installed throughout the facility’s natural and mechanical ventilation
system to protect the quality of cannabis by controlling dust,biological organisms,and other
contaminants.Air intakes will be fitted with a dual filtration system.The first filter is a
high-efficiency particulate absorber (“HEPA”)that will remove fine particulates such as dust and
pollen.The second filter is an activated charcoal filter that will chemically deactivate or remove
harmful environmental pollutants and biological contaminants.
As an additional measure to protect dispensary areas from biological contamination,ducts will
be fitted with ultra-violet (“UV”)lights to destroy any bacteria,viruses,spores,or pollen that
may have passed through the dual filters;this is especially useful following the COVID-19
pandemic.Exhaust fans and vents will be fitted with carbon filters to mitigate cannabis odors
from air leaving the facility.Carbon filters are highly effective and easy to maintain once they
are installed.As such,an efficient Variable Refrigerant Flow (“VRF”)or a similar HVAC
system will be installed and maintained to provide a safe,comfortable,efficient,and hygienic
environment for employees.VRF systems are refrigerant-based heat pump systems that allow the
use of one outdoor condensing unit with multiple fan coil unit (“FCU”)zones within a facility.
According to a study conducted by Liu et al.,VFR HVAC systems have great potential for
energy saving,and the adjustability of a VRF air conditioning system is better than that of a
centralized air conditioning system used in most facilities.
Electrical Consumption Comparisons | Source: Liu et al.
The table above compares VRF HVAC systems compared to centralized air conditioning.
Building 1 utilized the VRF,whereas Building 2 utilized centralized air conditioning.When
comparing the kWh/m2 in the summertime,the VRF unit utilized 3.67 kWh/m2 for air
conditioning,whereas centralized air conditioning used more than double at 8.51 kWh/m2.The
researchers utilized further data to conclude the efficiency of the VRF system,highlighting its
incredible energy-saving properties.
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VRF HVAC System Overview
Each of the VRF’s FCU have variable cooling capacity to meet load,which ultimately promotes
a higher degree of indoor unit zoning and distributed cooling without ductwork typical of
traditional HVAC systems.Furthermore,the variable speed compressors in VRF systems allow
for varying cooling loads,which further allows us to have a variation in power consumption and
resource efficiency.In essence,what this means is that we can redirect heat to cooling zones and
vice versa,allowing us to save additional costs associated with power use.The only downside of
a VRF system is its potential risk of leakage from exposed refrigerant piping;therefore we will
properly inspect the system as frequently as needed to prevent leakage.
The VRF HVAC system will be balanced in accordance with the latest edition of standards
published by the Associated Air Balance Council or the National Environmental Balancing
Bureau.The operation and maintenance manual for the HVAC system will be used to establish
proper operation and maintenance protocols.Inspection and maintenance of the VRF HVAC
system will occur as often as recommended by the operation and maintenance manual,at least
annually, and will be documented in writing and retained for at least five years.
Regularly scheduled maintenance will be performed as recommended (e.g.,using biocide in
cooling water and drip pans,changing air filters,etc.).To provide a source of clean air,outdoor
air intakes will be located at least 25 feet from exhaust outlets,cooling towers,and sources of
vehicular exhaust or other noxious fumes.All air intakes will be equipped with HEPA filters to
remove dust,pollen,and small particulates,and activated charcoal filters to remove or neutralize
pollutants and microbial contaminants.Filters will be changed regularly based on the
manufacturer’s recommendations.Cannabis facilities have the potential to produce nuisance
odors in the surrounding community.The ventilation system and exhaust will be designed to
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prevent cannabis odors from escaping the building or being detected by the surrounding
neighborhood. This will include the most effective odor control technology available, including:
●Carbon filters with odor control will be used to mitigate odors,as the use of ozone
generators and hydroxyl generators will be prohibited in our facility due to their potential
health effects;
●An exhaust air filtration system with odor control that prevents internal odors and pollen
from being emitted externally, per FMC Article 33 Section 9-3309(j)(1);
●An air system that creates negative air pressure between the building interior and exterior,
so that the odors generated by cannabis are not detectable outside of the building,per
FMC Article 33 Section 9-3309(j)(2).
CamCarb CG HEPA Filter Side-View Diagram of Carbon Filters for
Odor
The HEPA filter shown above is likely the product we will use.The 24-inch-long plastic cylinder
and the appropriate grade of activated carbon represent critical components of the effective odor
control solution.The unit is engineered to provide the very highest levels of performance in
Indoor Air Quality (“IAQ”),comfort,and light-duty process applications while achieving
moderate pressure loss values.CamCarb cylinders utilize a high weight of adsorbent per unit
airflow.CG (engineering grade plastic)cylinders are made in four different sizes to handle
different airflow ranges,and CM (stainless steel)cylinders are made in the same sizes as the two
largest CG cylinders.
CG cylinders use the same base plate to mount the filters.Each filter has three bayonet fittings
on the end cap,which connect into the base plate with a simple push and turn action.To ensure a
very high integrity seal between the cylinder and the baseplate,each cylinder is fitted with a
performance gasket.The baseplates are modular and can be assembled together to handle any
airflow.The cylinders can be orientated for vertical or horizontal airflow.CamCarb CG
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cylinders can be filled with a very wide range of activated carbon or alumina (CamPure™)
medias to provide broad spectrum or targeted adsorption of contaminants,including but not
limited to odors,irritants,toxic and corrosive gases.To enhance sustainability,options are
available for refilling CamCarb CG cylinders,depending on the application details.Specific
opportunities should be discussed with your local Camfil representative.Additional features
include:
●Leak-free installation ensures maximum possible efficiency
●360-degree geometry and even air distribution ensures maximum possible lifetime
●Lowest possible Life Cycle Cost (LCC)
●May be filled with a wide range of molecular filtration medias
●Rapid bayonet fitting system and integral dual TPE gaskets
●Totally corrosion resistant
●Reduced weight compared to the metal version
●Modular and flexible assembly
The CARBTROL Odor Control System is also in consideration to ensure complete odor
abatement and control.This system absorbs odor-causing components typical in cannabis and
essentially traps them into pores of carbon,where they are collected and eventually discarded
and replaced.Activated carbon is an excellent means of controlling VOCs and odor.The
Skid-Mounted Deep Bed FRP Filter/Fan System unit,for instance,can hold a carbon weight of
4,200 lbs.For VOC removal,the unit has an air flow rate of 5,000 CFM,making it exceptionally
ideal for promoting optimal air circulation and filtration.
The HVAC system is also important for providing the ventilation,humidity,and temperature
control necessary to maintain the quality of cannabis goods stored or displayed for sale at the
facility.The ventilation system designs will include automated and manual controls as well as a
failure detection system with alarms to ensure that potential facility ventilation and air quality
problems are promptly addressed.The facility’s HVAC system will be installed and maintained
to provide a safe,comfortable,and hygienic environment for employees and customers.In
addition,installation of the HVAC system will comply with the California Building Standards
Code (CCR §5.508.1.1 and §5.508.1.2) and will not contain Halons or Chlorofluorocarbons.
Per CCR §5.410.4.2,procedures for testing and adjusting HVAC systems and controls will be
established in accordance with the manufacturer’s specifications and applicable standards.The
HVAC system will be balanced in accordance with the latest edition of standards published by
the Associated Air Balance Council,the National Environmental Balancing Bureau,or the
Testing,Adjusting and Balancing Bureau (CCR §407.3/CCR §5.410.4.3.1).Minimum
ventilation rates found in the California Energy Code (CCR §120.1)apply to new construction
only.
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However,they will be used as a guideline to determine the ventilation rate for this facility,unless
the local code is more stringent.In general,the minimum ventilation rate for retail stores is 0.2
cfm/sq ft of conditioned floor area.The HVAC system will be operated continuously during
working hours and will provide two to three outside air exchanges prior to the building being
occupied in the morning.During non-working hours,the HVAC system will continue to provide
appropriate environmental controls,including regulating proper temperature and humidity levels
to maintain the quality of the cannabis goods and to provide effective odor control.
The operation and maintenance manual for the HVAC system,consistent with OSHA
requirements in CCR §5142,will be used to establish proper operation and maintenance
protocols.Inspection and maintenance of the HVAC system will occur as often as recommended
by the operation and maintenance manual,at least annually,and will be documented in writing
and retained for at least five years.Regularly scheduled maintenance will be performed as
recommended (e.g., using biocide in cooling water and drip pans, changing air filters).
Lastly,to provide a source of clean air,outdoor air intakes will be located at least 25 feet from
exhaust outlets,cooling towers,and sources of vehicular exhaust or other noxious fumes (CCR
§407.2).All air intakes will be equipped with high-efficiency particulate absorber (HEPA)filters
to remove dust,pollen,and small particulates,and activated charcoal filters to remove or
neutralize pollutants and microbial contaminants.Filters will be changed regularly based on the
manufacturer’s recommendations.
3.6 Odor Training & System Maintenance
All staff will be trained thoroughly on how to detect if there are any issues surrounding the odor
control system.A third-party HVAC specialist will be retained to ensure that in the event of a
device or part malfunction,they will be able to thoroughly and promptly inspect and identify the
source of the issue.Should our HVAC system malfunction,an automated warning system will
notify the Dispensary Manager of the issue,and the Dispensary Manager will report and
document the issue,as well as compile a report that specifies what the issue is,actions taken to
fix the issue,and who was responsible for handling the issue,including accurate date and times
when certain actions were taken and by which individual.Each employee will receive training on
maintaining and handling our odor control devices and in our odor control internal policies.We
will emphasize the importance of neighborhood compatibility in regards to this and ensure they
are well familiar with all our odor abatement equipment.We further commit to ensuring that the
third-party HVAC specialist can also help in facilitating training for our employees and
particularly our Custodial Staff.
3.7 Waste Management
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Identifying Cannabis Waste:The Quality Assurance department will be responsible for
periodically inspecting all cannabis goods to ensure that quality control criteria are met,as
described in our Business Operations Plan.The Quality Assurance department will quarantine all
cannabis goods that do not meet quality control criteria,returned cannabis goods,cannabis goods
that are subject to a voluntary or mandatory recall action,and other cannabis goods that may be
contaminated,adulterated,deteriorated,or otherwise not suitable for consumption or retail sale.
RKNC LLC aims to minimize incidents involving product deterioration by implementing
preventative rather than reactive measures alone.To maintain the consistency of our
quality-driven products,routine inspection will be incorporated within daily operations.Further,
information modules regarding assessing product quality will be made readily available and
easily accessible for all RKNC LLC employees.
Destruction of Cannabis Waste:Before disposing of any cannabis waste,RKNC LLC will
provide the Bureau of Cannabis Control (the Bureau)with a notice in METRC at least 24 hours
prior to conducting destruction and disposal activities.To destroy cannabis waste,cannabis
products will be removed from its packaging,weighed,and destroyed in a manner that renders
the cannabis waste unusable and unrecognizable,per CCR 16 §5054.In accordance with CCR
16 §5054(d),all cannabis goods intended as waste will be removed and separated from the
packaging and mixed with either general landfill waste or compostable material at a 1:1 ratio by
volume.The cannabis waste and non-cannabis materials are typically mixed together using a
grinder or shredder so that the cannabis waste becomes unusable and unrecognizable.All
cannabis waste will be held in a secured,locked,limited-access area and stored in non-absorbent,
water-tight, durable, and vector-resistant containers.
Handling Cannabis Waste:In keeping with CCR 16 §5054(b),cannabis waste shall be stored,
managed,and disposed of in accordance with all applicable waste management laws.Cannabis
waste,such as expired or adulterated products,will be collected into a separate,secure (i.e.,
locked),and properly labeled disposal container located in a limited access area,per CCR 16
§5054(c)(1).Any product intended for cannabis waste will be tracked through our system and
separated from cannabis goods not intended for waste,per CCR 16 §5054(c)(2).The disposal
container will be kept securely closed and located in a well-ventilated area to minimize the
development of odors,which will subsequently allow for easier handling of odor abatement
efforts and systems.
All cannabis waste will be tracked in METRC in keeping with inventory control procedures and
with CCR 16 §5054(f).No member of the RKNC LLC Team will be involved in the sale of
cannabis waste defined under CCR §5000(d).In keeping with RKNC LLC’s Security Plan,
employees will be monitored by the video surveillance system while handling cannabis waste to
ensure compliance with company policy and legal regulations.Evidence of an employee-driven
sale of cannabis waste or otherwise deteriorated product will lead to immediate termination and
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possible criminal prosecution.Cannabis waste shall remain in the premises until it is properly
handled,prepared,and secured in a restricted area to be collected by the City’s permitted waste
hauling service, per CCR 16 §5054(c)(2).
Waste Tracking:All cannabis waste will be tracked in METRC in keeping with inventory
control procedures,including the weight of the cannabis waste,the weight of the general or
compostable waste,and the weight of the and resulting mixed waste,per PMC 8.11.070(H–I).
The data entered into METRC will also include the names of the employees performing the
destruction or disposal and the reason for destruction or disposal per CCR 16 §5049(b)(7).Per
CCR 16 §5037(a)(7),a record of all information entered into the METRC system will be
retained for at least 7 years.Surveillance footage for the limited access area where the cannabis
waste is stored and collected for disposal will provide further verification of proper waste
disposal practices.Once cannabis waste has been destroyed by mixing it with other waste,it will
be handled in accordance with the provisions of CCR 16 §5054 for proper disposal.The mixed
cannabis waste will remain in a secure container located in a limited access area until scheduled
pickup.As mentioned before,RKNC LLC will utilize a local waste hauler to bring the cannabis
waste to the appropriate manned,fully permitted waste facility.The following procedures will be
implemented to document and verify the proper disposal of cannabis waste:
●Notify the Bureau of the name,address,and primary contact information for the local
agency or permitted waste hauler that picks up the cannabis waste;
●Obtain documentation of the date and time of waste collection from the local agency or
permitted waste hauler;
●Obtain a copy of the certified weight ticket or other documentation confirming receipt of
the cannabis waste at the designated waste facility; and
●Provide the Bureau with the name,address,and primary contact information for the
designated waste facility (CCR §5049(b)(7)(C)).
Recycling Policy:RKNC LLC is committed to establishing a recycling program and purchasing
products that contain recycled materials,whenever possible.Paper,letterhead,envelopes,
business cards,and marketing materials will all have a content of at least 50%post-consumer
waste (“PCW”).Toilet tissue will contain a minimum of 20%PCW,and paper towels will
contain a minimum of 40%PCW.Shopping bags provided to customers will either be reusable,
certified compostable,or paper bags made with a minimum of 40%PCW content.All consumer
packaging will be minimalistic and use high-quality,bio-plastic material (hemp-based),as
packaging can be a significant waste and environmental issue given it is often discharged.Paper,
plastic containers,and aluminum cans will be recycled.Old office equipment will be taken to an
electronics recycling company.Food waste and other non-cannabis waste will be composted to
avoid overburdening landfills.Finally,all-natural,preferably organic,cleaning supplies will be
used to sanitize the building.
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Section 4 | Safety Plan
Table of Contents
4.1 Professional Safety Consultant 2
4.2 Accident & Incident Reporting Procedures 2
Dispensary Incident Management 2
Delivery Incident Management 10
4.3 Evacuation Routes 11
4.4 Location of Fire Extinguishers & Fire Suppression Equipment 13
4.5 Procedures & Training for All Fire & Medical Emergencies 13
Ergonomic Work Environment 15
Handling Illnesses in a Work Environment 16
Facility Personal Hygiene Training 16
HVAC System 17
General Sanitation Policies 17
Preventing Contamination 18
Occupational Safety and Health Administration (OSHA) Compliance 19
Biological Hazards 20
Policies for Handling Mold 21
Policies for Handling Allergens 21
Chemical Hazards 21
Policies for Reducing Chemical Hazards 22
Physical Hazards 22
Policies for Handling Physical Hazards 23
Safety Training 24
OSHA Requirements 24
Safety Training 25
Facility Personal Hygiene Training 25
Fire Prevention Training 26
Emergency Response Training 26
Substance Abuse Policy Training 27
Sensitivity Training 27
Sexual Harassment Training 28
Training Against Workplace Violence 28
COVID-19 Pandemic Response 29
Documentation/Continuing Education 31
Conclusion 31
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4.1 Professional Safety Consultant
The Applicant fully pledges to have our entire safety plan reviewed by a licensed third-party
Professional Safety Consultant.The security and safety and our customers,patients,and
employees is vital above all, in addition to the prevention of the illegal diversion of our products.
4.2 Accident & Incident Reporting Procedures
Dispensary Incident Management
Any health-related event associated with the use of a product that is undesirable,unexpected,or
unusual is an adverse event that may indicate a problem with the product itself.The Quality
Assurance department may initiate a voluntary recall if the result of a complaint investigation
indicates a possible adverse event,or if laboratory testing and other quality assurance checks
indicate a contaminated or adulterated product.The basis of the Dispensing Organization’s
Recall Plan is the following four core factors:
1.An established plan and mechanism reasonably calculated to contact
purchasers/consumers who have,or are likely to have,obtained the subject Product from
the Dispensing Organization;
2.An established plan and mechanism to identify and contact the source of the subject
Product (i.e., the cultivator or manufacturer that produced the subject Product);
3.An established plan and mechanism for communicating with the applicable public
agencies within 24 hours of the discovery of defective or potentially defective Product
(including,but not limited to the Bureau of Cannabis Control and the Department of
Health); and
4.An established plan and mechanism for destruction of any recalled Products consistent
with the requirements of the Act.
Recalls may also be initiated as mandatory actions by regulatory agencies in order to protect
public health and safety.SOPs for recall practices will further be compliant with the Code of
Federal Regulations,Title 21,Chapter 1,Subchapter A Part 7,regarding product recall as
authored by the Food and Drug Administration (the "FDA").The Applicant’s policies to address
recalls will be initiated as follows:
1.Mechanism to Contact Purchasers:Every affected or likely affected customer of the
facility will be notified of the recall.The METRC system will be leveraged to aggregate a
list of customers associated with a recalled batch.Procedures will be in place to contact
each customer,including automatic digital (i.e.,email)communication,as well as
protocols for written (mail-in)and telephone communication.The Quality Assurance
Director will also facilitate arrangements for return shipping and processing refunds or
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exchanges. Communication records will be retained in our ERP system.
Following identification of the problematic or defective product,The Applicant will
promptly determine the batch and lot number of the product(s)at hand through the use of
our inventory management system.The Applicant’s electronic manifest of goods
received through the database queries in our perpetual inventory control system will be
cross-referenced with the unique identification number (“UIN”)associated with the
product on our records.Following this,all purchasing receipts associated with that UIN
will be identified through the inventory control system,along with sales data as to who
the product was sold to,at which date,and how many were sold to begin with.This will
allow The Applicant to compile a list of all customers who purchased the product
intended for recall.
A written notification will be sent out to each customer through the addresses listed on
their government-issued IDs (which are required to enter the dispensary)via United
States Postal Service Certified Mail.The reason we will utilize Certified Mail is to track
and confirm that the notification was received by the customer.Simultaneously,
dispensing agents will also call each customer and communicate with them about the
recall,in addition to what steps they need to take to ensure they are safe and their product
is properly returned for destruction.Dispensing agents will inform customers of the
nature of the recall,identify the specific product at hand,and will inform the customer of
the date and time the purchase was made.If possible,The Applicant will also send out
emails of the written notification if the customer’s email had been previously provided.
2.Mechanism to Identify and Contact Product Producers:Utilizing the unique
identification number that matches the product with the producer’s batch and lot number,
the producer of our cannabis goods will be contacted and informed of this recall incident.
As with our method for contacting customers about recalled products,the product’s UIN
will be linked to the batch and lot number and cross-referenced with The Applicant’s
electronic manifest of goods received through the inventory control system.
Following identification of the product’s UIN and batch number,its original
manufacturer/producer will be contacted within 24 hours to notify them of the product(s)
at hand.The Applicant will generate a list of all California manufacturers and producers.
This list will be referenced and documented throughout the recall process,and
verification that these entities have indeed been contacted and informed of the recalled
product will likewise be documented.Information pertaining to the batch and lot number
of the product,the product type,and the reason for the recall will all be provided to all
applicable producers associated with the product(s).
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3.Policies for Communicating with Various Departments:Within 24 hours or less of
determining that a recall action will take place,the Quality Assurance Director will
contact the Bureau of Cannabis Control and the Department of Health,and other
applicable regulatory agencies to share information regarding the recall.Information such
as the type of product,its batch number,UIN,and other relevant information pertaining
to the defective product will be provided,and The Applicant will continue to
communicate with applicable state departments until the issue is entirely resolved.Any
correspondence with the various departments listed above shall be in both writing
through email form,as well as through a direct call.The foregoing written notification
will include, at minimum, the following information:
a.The UIN of the cannabis product(s)that are under recall as well as its/their
associated batch and lot numbers;
b.The product type and license type associated with the product(s) under recall;
c.A detailed description and explanation of the reason for a recall,including any
supporting documents such as laboratory test results,customer complaints,and
photograph evidence of adulteration or any other issue, if applicable;
d.Information pertaining to our plan of action for a recall,including how we will
contact manufacturers,producers,cultivators,customers,and vendors/suppliers,
in addition to how we intend to conduct product returns,quarantine,and
destruction, respectively; and
e.A list of all purchasing receipts and invoices for the recalled product(s)generated
by our inventory control and point-of-sale systems.
An overview of each of the foregoing information will likewise be provided to the
departments through a phone call,with references being made to the written notification
for further details regarding the matter.The Dispensary Manager will work closely with
the company’s Chief Compliance Officer to implement our contact protocols and
procedures to ensure absolute regulatory compliance and,above all,to ensure the safety
of our customers and staff members. Essentially, The Applicant will:
1.Contact the Bureau of Cannabis Control by phone at (833)768-5880 or email at
bcc@dca.ca.gov.When an inspector is assigned,this person’s contact information
will be added to the Dispensing Organization’s “Authority Contact Plan.”
2.Contact the Department of Health at (916) 328-3605.
Any written emails sent to each department will equally include the following
information (in addition to the information discussed above)in a pre-established template
to facilitate a timely response:
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●Source licensee names/contact information for all identified recalled products;
●The names of the recalled products,batch tracking numbers,and returned and
existing quantities in possession of the Dispensing Organization;
●A confirmation statement that all recalled products in possession and returned
products have been removed from any areas accessible by purchasers/consumers
or Dispensing Organization agents (e.g.,point-of-sale floor,back storage)and
placed in proper quarantine until further instruction and eventual destruction; and
●A confirmation statement that possible or confirmed consumers and the source
licensees have been identified and contacted through our contact plans.
4.Policies for the Destruction of Recalled Products:The facility is responsible for
destroying recalled cannabis that is returned to the facility in accordance with CCR
§5054.After recalled and returned cannabis is received,quarantined,and tracked in the
METRC system,it will be destroyed according to established cannabis waste disposal
protocols that are described in detail below.All destruction activity will strictly be
conducted under a minimum of two (2)cameras set at different angles under the direct
supervision of the Dispensary Manager.All products intended for destruction will be
documented and recorded into METRC and adjusted in our POS system.Documentation
pertaining to the destruction of the recalled product(s)will be held by The Applicant for a
minimum of five years.The following information will also be documented for any
recalled products intended for destruction:
a.The UIN,batch,and lot numbers of the cannabis products intended for
destruction;
b.The recorded number of units by fluid ounces or weight of the product(s)intended
for destruction;
c.The time and date of the destruction of the recalled product(s);
d.The names and job titles of the dispensing agents responsible for conducting the
destruction of the recalled product;
e.The names of the Dispensary Manager and other designated manager who will
both oversee the destruction of the recalled product;
f.A copy of the surveillance footage of the destruction of the recalled product(s);
g.The method in which the recalled product(s)is/are being destroyed and
information about how it/they will be disposed of; and
h.Verification that the recalled product(s)intended for destruction and disposition
have been thoroughly documented and recorded in the perpetual inventory
system.
Quarantine Procedures:The Applicant will implement policies and procedures to isolate all
products entering the facility in order to conduct inspections and perform quality assessments
prior to allowing products to be placed for sale.Products that do not meet acceptance criteria will
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be placed into quarantine until they are disposed of,following the procedure outlined below.
Once a product has been identified as necessitating recall,it will be quarantined until proper
destruction and disposal can occur.As all products The Applicant purchases will be
pre-packaged,there will be no onsite splitting,weighing,or measuring of cannabis flower to
reduce possible loss or contamination;dispensing agents will be informed that only packages
intended for smoking in the designated,secured lounge area may be opened for onsite
consumption (as permitted by the local municipality).
This step is important for not only compliance but also to add a layer of insulation to reduce the
frequency of preventable product adulteration.The vault will include a clearly designated,
segregated,and secured area for the storage of quarantined products,and the quarantined product
area will be capable of maintaining appropriate temperatures and other relevant conditions (e.g.,
humidity)to ensure packaging is not adversely affected.Quarantine,or in other words,the
storage or identification of a product to prevent distribution or transfer of the product,would be
kept in a physically separate area clearly identified for such use.The quarantine area will be
clearly separate from the rest of the inventory and will be kept locked.Access to quarantined
products will be restricted to the Dispensary Manager and other pre-qualified designated agents,
who will also be responsible for updating the track-and-trace system to account for all
quarantined products. Additionally, the following procedures will take place during quarantine:
●Outdated,damaged,deteriorated,misbranded,or adulterated cannabis will be kept in a
separate sterile environment until destruction;
●Containers storing cannabis that have been tampered with,damaged,or unduly opened
shall be labeled with the date opened and quarantined from other cannabis products in the
vault until they are disposed of; and
●Cannabis that was tampered with,expired,or damaged will not be stored at the premises
for more than 7 calendar days.
Secure Storage of Quarantined Products:Secured storage areas for quarantined cannabis will
be constructed of steel-reinforced concrete masonry blocks on all walls and ceilings.All
quarantine and waste cannabis will be kept in a steel safe or vault with an Underwriters
Laboratory (“UL”)Group 1 rating.Vaults and safes will have doors secured by an outside
combination lock and pin code and will only be accessible by identified key staff.Vault doors
will be attached to steel-reinforced concrete or similar masonry that is at least eight inches thick.
Safes will be bolted or cemented to the floor or wall,so they cannot be readily removed.Vaults
and safes will be secured with a commercial grade combination pin code reader for authorized
personnel to enter.The combination will be changed at irregular intervals,not to exceed every 90
days.A log of all safe/vault entries and code changes will be maintained with the security
records.An daily electronic log of agents who have access to the vault room as well as the access
code will be retained.
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The Applicant will strictly limit the number of individuals with access to quarantined cannabis
storage areas to the minimum number necessary,typically to a Dispensary Manager as well as
one other individual.All storage equipment,vaults,locks,alarms,and RFID equipment will
always be maintained in good working order by way of daily inspection.Dispensing agents must
have their RFID access badges and any keys for display on their person at all times to prohibit
them from being left in locks and preventing unauthorized access.Dispensing agents are strictly
prohibited from giving away combination numbers,passwords,or electronic or biometric
security systems to persons other than specifically authorized dispensing organization agents.
Quarantined cannabis placed in storage will be organized so that labels and other packaging
information can be clearly observed.All quarantined cannabis will be stored in enclosed cabinets
that are made exclusively accessible to authorized dispensing agents and subsequently locked in
restricted access storage areas in a steel vault after operational hours.Quarantine storage areas
will be maintained in a clean and orderly condition,be free of infestation by pests or vermin,and
have adequate lighting,ventilation,temperature,sanitation,humidity,space,equipment,and
security conditions to ensure the safety and quality of stored cannabis.
Identifying &Segregating Cannabis Intended for Quarantine:In association with our
quarantine procedures,The Applicant will encounter three primary categories of waste in its
operation:(1)cannabis product waste,(2)recalled product,and (3)general non-cannabis waste
(e.g., food waste, recycling, and general waste).
1.Cannabis waste will not be mixed nor stored alongside other non-cannabis waste
identified above.Instead,a color-coded,labeled,and secured waste bin will be utilized to
hold all cannabis intended for destruction and disposition.
2.Recalled products that are located onsite or are returned by purchasers will be kept in
separate,color-coded,secure,and labeled bins in order to prevent cross-contamination.
This recalled product will be in “quarantine”pending disposition.Color-coded bins will
be labeled with recalled product names and respective batch numbers,and a conspicuous
warning label on all four sides and top reading “Recalled Product –Waiting for
Destruction.”
3.General non-cannabis waste will be kept in separate,color-coded,and labeled waste bins
in order to prevent cross-contamination.
Step-by-Step Quarantine Procedures
The following is a step-by-step explanation of our The Applicant intends to implement the
quarantine procedures discussed above.
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1.The Dispensary Manager identifies the product intended for quarantine and tracks both in
the ERP and METRC system the reason for the product quarantine (e.g.,facilitated recall,
expired product, product return).
2.If the reason for the quarantine is a mandated or voluntary recall,the Dispensary
Manager will conduct Recall Procedures according to the Recall Plan discussed in this
Exhibit.If the reason for the quarantine is due to a product return or product expiration,
the Dispensary Manager will log this reason into the ERP and METRC system and
initiate quarantine.METRC’s batch tracking will track all batch numbers for all products
and to track product destruction.
3.All identified products intended for quarantine will be secured in separate,color-coded,
secured,and properly labeled bins to mitigate the risk of cross contamination.The labels
on the bins will clearly read either “Recalled Product -Waiting for Destruction,”
“Returned Product -Waiting for Destruction,”or “Expired Product -Awaiting for
Destruction.”
4.All quarantined products will be stored in a secured vault,as described previously,once
placed inside the bins and will be segregated from all other products.
5.Anytime a product storage container within the quarantine area is opened,the bin will be
labeled with the date and time it was opened.
6.All products will be kept in an appropriate climate-controlled setting,where temperature
and humidity levels can be monitored accordingly.If a quarantined product is (or
becomes)subject to a recall,such product will not be stored at the premises for more than
seven (7) calendar days, unless requested by the Bureau.
Customer Complaints,Returns,&Recalls:The facility Quality Assurance department will
establish written procedures to handle cannabis product complaints,including returns.These
procedures will specify a qualified person who will review product complaints to determine if
the complaint involves a possible failure of a product to meet any of its specifications or other
requirements.The qualified person will also investigate any complaint to determine if a product
defect may result in a risk of illness or injury.
Quality assurance management personnel will review reports,approve investigation findings,
and sign-off on decisions regarding any follow-up action required to resolve a complaint.The
review,investigation,and follow-up action must extend to all related batches and relevant
records.Related batches may include,but are not limited to:batches of the same product;
batches processed on the same equipment or during the same time period;and batches produced
using the same batches or lots of components or packaging components.Voluntary recalls may
be initiated by the Quality Assurance department based on the result of complaints and returns
investigations,laboratory testing,and other quality assurance checks,or any other information
that indicates a contaminated or adulterated product.Recalls may also be initiated as mandatory
actions by regulatory agencies. All recall actions will be initiated as follows:
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1.Regulatory Agency Notification.Within 24 hours of determining that a recall action
will take place,the Quality Assurance Director will contact applicable regulatory
agencies to share information regarding the recall.
2.Customer Notification.Every direct customer (i.e.,dispensary,processor,third-party
distributor)of the facility will be notified of the recall.The ERP system will be leveraged
to aggregate a list of customers associated with a recalled batch.Procedures will be in
place to contact each customer,including automatic digital (i.e.,email)communication,
as well as protocols for written and telephone communication.Communication records
will be retained in the ERP system.
3.Communication of Return Policy.All customers in possession of recalled products will
be notified of facility return procedures.The Quality Assurance Director will also
facilitate arrangements for return shipping and processing refunds or exchanges.
Returned products will be tracked in the ERP system via METRC per facility inventory
management procedures.Returned cannabis goods will not be made available for resale
per CCR 16 §5410(c).Complaints and returns records will be retained in the ERP system
for a minimum of seven years per CCR 16 §5037(a).
4.Media Outreach.Only urgent conditions would necessitate contacting the media as a
means to notify the public.The ERP system contains a website and press release platform
that will be utilized to publicly make available and archive official announcements
related to public health and safety.This will be the official channel by which customers
will be referred to view the facility recall history.
5.Destruction of Returned or Recalled Product.The facility is responsible for destroying
all recalled cannabis returned to the facility.After recalled and returned cannabis is
received,quarantined,and tracked in the ERP system via METRC,it will be properly
destroyed per facility cannabis waste disposal protocols that comply with CCR 16
§5410(e).
All recalled products will be quarantined within 72 hours and will ensure that all quarantined
products are rendered unrecognizable and unusable using our waste management procedures.
This quarantine will also ensure that all recalled or adulterated cannabis goods as stored
separately from other cannabis goods.Documentation of complaints and returns is important for
regulatory compliance,tracking data that could uncover patterns that result in changes to
operational conditions and SOPs,and ultimately for protecting the health and safety of
consumers,patients,and the public.All complaints,returns,and related issues will be
documented by the ERP system and stored in a master file of trouble tickets,complaints,and
adverse issues.Complaints and returns records will be retained for a minimum of seven years per
CCR §5037(a).Written complaints records will include the following information:product
identifying information,including batch,lot,or control number;date of complaint;contact
information of complainant;nature of the complaint including how the product was used;
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identification of personnel involved with documenting and investigating the complaint;
investigation findings; and follow-up action.
Delivery Incident Management
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4.4 Location of Fire Extinguishers & Fire Suppression Equipment
4.5 Procedures & Training for All Fire & Medical Emergencies
As stated above in our overview section, maintaining the health and safety of our agents and
customers involves not only establishing effective responses to critical situations (e.g., natural
disasters, medical emergencies, etc.) but also ensuring they maintain their health during
day-to-day activities. Lack of ergonomic working areas can lead to numerous long-term issues,
including but not limited to weight gain, type two diabetes, musculoskeletal disorders, and even
neurological dysfunctions. Ultimately, we want our agents to be comfortable, to be excited about
their working conditions, and to always prioritize their health above all other concerns. This is
why we will include an Ergonomics Program to educate our workers on how to go about
day-to-day operations while mitigating the risk of developing long-term health issues. To further
prevent risks associated with being distracted during work hours, dispensing agents will be
required to store away their phones in designated employee lockers. Wet-floor signs will be
placed in all applicable areas, and dispensing agents will be required to caution visitors or
customers about potentially hazardous areas in limited access areas. Each dispensing agent will
be trained on basic first aid response—and well as familiarized with the location of first aid
kits—to help any fellow agent, customer, or visitor in the event of an accident.
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Equally,we want to ensure absolute compliance with Occupational Safety &Health
Administration (“OSHA”)guidelines on promoting proper working conditions.As such,we will
take part in California OSHA’s On-Site Safety and Health Consultation Program to ensure that
all our policies,practices,and internal procedures not only meet,but exceed Federal OSHA
health and safety regulations.Throughout this Health &Safety Plan,we also describe internal
protocols related to natural disasters and fires as well as medical emergencies (including
protocols on how to use automated external defibrillators [“AEDs”], medical kits, etc.).
To further promote safety,we equally explore sanitation protocols and our “Non-Hazardous
Substance”policy,which includes only utilizing non-hazardous cleaning supplies and other
materials.Per OSHA standards,documentation is also a crucial part of maintaining health and
safety.We will record all instances involving accidents,illnesses,or emergencies.Following
these incidents,the company’s Chief Operating Officer (or an individual designated by the Chief
Operating Officer)will conduct a thorough review and investigate the situation,as to make any
required adjustments to our safety protocols.Additionally,we will hold monthly safety meetings
to familiarize employees with our safety and security standards,as to ensure they are upheld
throughout operations.We will establish policies to maintain a safe and healthy workplace
environment at its dispensary facility. Key policies include:
●Establish,implement,and maintain an Injury and Illness Prevention Program and update
it periodically to keep employees safe;
●Develop an Ergonomics Program to prevent repetitive motion injuries;
●Inspect workplace(s) to identify and correct unsafe and hazardous conditions;
●Make sure employees have and use safe tools and equipment and maintain them properly;
●Provide personal protective equipment (“PPE”) at no cost to employees; and
●Keep records of work-related injuries and illnesses.
Policies will be developed,continuously updated,and consistently implemented to ensure a safe
and hygienic workplace. General facility health and safety policies include:
●Employees will be provided with adequate hygiene stations, toilets, and break rooms;
●Food and drink will not be allowed except in break rooms and other designated areas;
●Smoking will not be allowed within the facility, including outdoor areas;
●Employees will use appropriate PPE,such as gloves and safety glasses,for specific tasks
such as cleaning,waste disposal,equipment maintenance,or other tasks that may expose
employees to potential hazards;
●Facility cleanliness and sanitation will be maintained through regular sweeping and
mopping,waste removal,removal of misplaced materials,inspecting storage areas for
signs of mold and contamination, and other tasks;
●Equipment used to clean and sanitize will be kept in good working condition and will be
kept in an area that prevents contamination;
●Non-cannabis waste will be collected in authorized sanitary receptacles and will be
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regularly collected and disposed of to prevent contamination and odors;
●Safety Data Sheets (“SDS”)will be maintained for potentially hazardous materials,
including cannabis goods if applicable; and
●Potentially hazardous materials,for example,cleaning products or motor oil for vehicle
maintenance, will be properly labeled and stored.
Ergonomic Work Environment
Promoting an ergonomic work environment can help mitigate a number of long-term health
issues that can result from working for a prolonged period in an office environment.Our retail
employees will be performing tasks that can lead to these issues,such as standing or sitting for
extended periods of time,working with computers,tablets,and other devices that may cause eye
strain or repetitive motion injuries,lifting containers that may be heavy,bending to reach for or
position items on the floor,and/or handling chemicals,such as cleaning agents.Although our
agents will have health insurance that covers medically-accepted practices,including but not
limited to chiropractic visits,and will be financially protected by worker’s compensation,it is
equally important that we invest in preventative rather than solely reactive strategies to maintain
the health of our agents.
To this end,we will utilize a number of ergonomic products and incorporate workplace policies
to promote injury and accident prevention.For day-to-day activities involving the use of a
computer,we will purchase ergonomic products such as a roller ball mouse and ergonomic split
keyboards to prevent carpal tunnel syndrome,as well as screen protectors for monitors to combat
visual fatigue and eyestrain.All tablets utilized for our POS system will also include a screen
protector,as retail operators will undoubtedly be utilizing the system throughout most of the day.
In addition,all office chairs will be ergonomic and fully adjustable to suit the user;these chairs
help individuals adopt proper posture while seated.For any agents who have difficulty operating
a computer due to injury or impairment,we will additionally purchase Dragon Professional
Individual 15 or a similar program, software that allows computers to be controlled vocally.
Example of Health Tip Signs | Source: OSHA
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At any given time,agents may also request additional ergonomic products that can help them go
about day-to-day activities.Agents will further undergo safety training in regard to basic
day-to-day activities;these training modules will cover various health topics that discuss the
importance of having ergonomic work settings.Signs will be posted that demonstrate how to
properly lift items and how to sit and stand with correct posture,in addition to information
regarding carpal tunnel syndrome and other complications following poor ergonomic practices
(e.g.,herniated discs,lethargy).In sum,we want to give our agents all the means of maintaining
their long-term wellness,as we equally want to promote this outcome for our customers seeking
our products for therapeutic purposes.
Handling Illnesses in a Work Environment
In order to safeguard customers and agents against infectious agents,employees who are sick
will be required to recover at home as opposed to working.This policy will be outlined during
safety training and briefings,and the agent-in-charge will ensure that all sick employees will
have all the resources for recovery.Due to the fact that retail operators engage with customers on
a day-to-day basis and handle consumable goods,we will take every step in ensuring that our
employees understand the importance of maintaining a hygienic and clean environment.
Employees will be allocated a certain number of sick days per local labor laws,which can be
extended upon request of an employee following an emergency.
Facility Personal Hygiene Training
We will train each employee on proper personal hygiene in a dispensary environment,especially
with respect to habitual handwashing to avoid accidental microbial contamination.Good habits
include,but are not limited to,washing after using the lavatory,storage,and break room areas
and when leaving and entering the facility.All signs posted in this regard will be written in each
of our employees’primary languages to ensure comprehensive adherence to regulations.We will
comply with all federal and local health,safety,and sanitation regulations and will welcome the
Department of Health,at any time,to confirm that no health or safety concerns are present which
may contaminate cannabis;therefore,the following measures will be put into place effective on
the first day of operation.
All members of staff will be trained to avoid wearing outer garments that could attract particulate
matter and contaminate the storage areas,and they will be trained to maintain high levels of
personal hygiene.Employees will be required to remove and place all loose or hanging jewelry
and other unsecured objects in the staff lockers before the commencement of each shift.
Fingernails must be trimmed and nail beds and cuticles must be clean.Staff wearing hand
jewelry,fingernail polish,or artificial nails will cover their hands with sterile,impermeable,and
unused latex-free gloves.Furthermore,employees must wear Personal Protective Equipment
(PPE)when disposing of cannabis waste and must strictly adhere to the company protocols.
Similar methods will be employed with staff members who need to wear coats,aprons,gowns,
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hair nets,caps,beard covers,and other hair restraints at the manager’s discretion.Employees
will be informed as to where to wash their hands and how to do so properly.Employees failing
these established standards will be dismissed for the day without pay and given a formal
warning. Subsequent violations will result in immediate termination.
HVAC System
Safety extends beyond physical and digital security of the facility and operations.The facility
HVAC systems are equally important for employee and client health.Our systems will be
installed and maintained by local,qualified,permitted contractors and vendors to provide a safe,
comfortable,and hygienic environment for employees and customers.The HVAC system is also
important for providing the ventilation and temperature control necessary to maintain the quality
of cannabis goods stored at the facility.Ventilation systems will be installed in keeping with
engineering standards for proper installation as well as intake and exhaust volumes appropriate
for each room or area.The ventilation system designs will include automated and manual
controls as well a failure detection system with alarms to ensure that potential facility ventilation
and air quality problems are promptly addressed.To maintain indoor air quality,all air intakes
will be equipped with high-efficiency particulate absorber (“HEPA”)filters to remove dust,
pollen,and small particulates,and with activated charcoal filters to remove or neutralize
pollutants and microbial contaminants.Cannabis facilities have the potential to produce nuisance
odors in the surrounding community,such as smoke from the lounge.Although all our products
will be in pre-sealed bags,we want to mitigate any risk of odor leaving the facility.The
ventilation system and exhaust will be designed to prevent cannabis smoke or odor from
escaping the building or being detected by the surrounding neighborhood.This will include the
most effective ventilation technology available including:
●An exhaust air filtration system with odor control,such as carbon filters or vapor barriers
as appropriate to mitigate odors; and
●An air system that creates negative air pressure between the building interior and exterior,
so that the odors generated by cannabis are not detectable outside of the building.
General Sanitation Policies
Following good sanitation practices is a critical component of safe and efficient retail operations.
The following general sanitation policies will be implemented at the facility:
●Areas at the retail facility will be separated by function (i.e.,storage,loading/receiving
etc.)to facilitate effective implementation of the most appropriate cleaning and sanitation
practices for each area and process;
●Regular cleaning and sanitation will occur,including sweeping and mopping,waste
removal, removal of misplaced materials, and inspection for signs of contamination;
●Equipment used to clean and sanitize will be kept in good working condition and will be
kept in an area that prevents contamination;
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●Non-cannabis waste will be collected in authorized sanitary receptacles and will be
regularly disposed of to prevent contamination and odors;
●Products used to clean and sanitize process areas and equipment will be properly labeled
and stored;
●All dispensing agents will be trained to keep the areas critical for operations in a sanitary
condition that mitigates or eliminates the risk of contamination of equipment,surfaces,
materials, products, components, and any other items necessary for retail operations; and
●All dispensing agents are required to report to their supervisors any personal health
condition that might compromise the cleanliness,quality,or integrity of products or
packaging that said dispensary agent might handle.
Preventing Contamination
The following sanitation policies will be implemented to prevent the risk of contamination in a
storage area:
●The storage area will be maintained in a clean and sanitary condition and will be
maintained in repair sufficient to prevent equipment,packaging components,packaged
cannabis and cannabis products, or contact surfaces from becoming contaminated;
●Cleaning compounds and sanitizing agents will be adequate for their intended use and
safe;
●The storage area will be inspected and sanitized after every transfer to a storage room.
Sanitation and decontamination will include:
○Cleaning of floors,walls,equipment,and other surfaces to remove dirt,debris,
standing water, waste, and other matter;
○Sanitation of cleaned surfaces with appropriate sterilizing agents;
○Storage of dry,cleaned,and sterilized equipment in a manner that prevents
contamination; and
○Proper destruction,disposal,and/or composting of any waste according to
established protocols and in keeping with applicable laws and regulations.
●Sampling to verify the effectiveness of sanitation protocols at eliminating microbial
contamination; and
●Damaged or contaminated equipment will be removed for proper disposal.
Employee Safety Training SOPS: The purpose of these training procedures are to outline the
training requirements for on-site personnel.
1.All new employees shall receive initial training prior to commencing their job function
and meeting with current or potential customers and patients.
2.Training may be in the form of Classroom Attendance, MS PowerPoint, Computer-Based
Training (CBT), or other methods deemed appropriate by the Dispensary Manager or
Vice President of Operations.
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3.Quick Reference Cards will be developed and made available for staff during training
and patient counseling.
4.At a minimum, training will be provided on the items listed below once every 12 months:
a.Federal and State medical cannabis laws and regulations and other laws and
regulations pertinent to the dispensary agent’s responsibilities;
b.Standard operating procedures;
c.Detection and prevention of diversion of cannabis;
d.Security procedures;
e.Safety procedures, including responding to;
i.A medical emergency;
ii.A fire;
iii.A chemical spill; and
iv.A threatening event such as armed robbery, an invasion, burglary, or any
other criminal incident
f.The pharmacology of cannabis and its active components;
g.The potential therapeutic and adverse effects of medical cannabis;
h.Dosage forms of medical cannabis and their pharmacodynamic impact;
i.Potential drug interactions and consumer safety issues with medical cannabis use;
and
j.Recognition of symptoms of substance use disorders and acute intoxication.
5.The Chief Compliance Officer will continuously update the training materials as
required.
6.All employees are encouraged to actively participate in training development and
improvement.
7.All employees shall sign a copy of the Employee Training Acknowledgment Record,
which will be provided on-site.
Occupational Safety and Health Administration (OSHA) Compliance
Our SOPs are primarily established by the framework provided by OSHA,which has been
proven to be effective through various studies.OSHA has developed a framework for
maintaining safe practice standards within any given operation.These standards help promote
not only safety but also accountability on all ends of an operation.Each and every core element
is established to coordinate OSHA safety protocols for the betterment of the employees,the
products,and consumers.There are primarily seven elements that contribute to the health/safety
of retail workers, which include the following:
●Management Leadershipinvolves executives promoting accountability within an
organization and setting examples for Directors and Retail Store Managers.Executives
must have a zero-tolerance policy for any actions that might endanger the employees or
products.Action Item(s):We will establish a written policy signed by top management
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describing the organization’s commitment to safety and health and pledging to establish
and maintain a safety and health program.
●Worker Participation is equally crucial in ensuring that the organization is accountable
and responsible for the safety of the facility.Workers play an important part in helping
We establish comprehensive policies and standards for the betterment of the organization.
Action Item(s):We will establish a process for workers to report injuries,illnesses,close
calls/near misses,and other safety and health concerns;respond to reports promptly.
Reporting processes may have an anonymous component to reduce any fear of reprisal.
●Hazard Identification and Assessment requires ongoing risk evaluations on behalf of not
only the executives,directors,or managers,but also the employees.Each and every team
member is responsible for continuously assessing and reporting potential hazard risks.
Action Item(s):We will collect,organize,and review information to determine what
types of hazards are present and which workers may be exposed or potentially exposed.
●Hazard Control and Prevention directly following hazard identification and assessment,
in which all management leaders and employees work to create preventative rather than
solely reactive strategies to minimize hazardous incidents.Action Item(s):We will
review sources such as manufacturers’literature,OSHA standards and guidance,industry
consensus standards,National Institute for Occupational Safety and Health publications,
and engineering reports to identify potential control measures.
●Education and Training involve developing comprehensive teaching and onboarding
programs that will effectively aid in maintaining best practice standards.Action Item(s):
We will emphasize that the program can only work when everyone participates and feels
comfortable discussing concerns,making suggestions,and reporting injuries,incidents,
and hazards.
●Program Evaluation and Improvement ensures that all training modules are continuously
up-to-date to best practice standards.Action Item(s):We will develop and track measures
or indicators of progress toward established safety and health goals.Track lagging
indicators,such as the number and severity of injuries and illnesses;results of worker
exposure monitoring; and the amount paid to workers’ compensation claims.
Biological Hazards
Most biological hazards in a retail operation can be mitigated by having good housekeeping,
such as ensuring the facility is properly sanitized.We must also have proper ventilation systems
(e.g.,an HVAC system)to ensure that all allergens,dust,and other particles are effectively
filtered out of the facility.Finally,having proper environmental controls can reduce the
likelihood of mold development by ensuring humidity is always controlled.High humidity can
result in the development of mold,which can be harmful to workers in the facility.Spores can be
airborne and directly impact the respiratory health of facility workers and visitors.Facility
workers exposed to mold might experience wheezing,coughing,increased asthma symptoms,
shortness of breath, and respiratory infections.
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Policies for Handling Mold
We will implement the following policies to prevent and mitigate the presence of mold at the
facility:
1.Implement water intrusion and mold mitigation practices in areas within the facility that
might be prone to floods or have conditions that include standing water;
2.Moisture control is the key to mold control on surfaces and within building structures;
3.Implement engineering controls and work practices to control or eliminate exposure to
mold (for example, vacuuming rather than sweeping and ventilation);
4.Conduct a PPE assessment to determine the need for respiratory protection,skin and eye
protection, or protective clothing;
5.In the absence of mold sampling data,consider respiratory protection for any dusty
operations and for employees reporting even mild respiratory symptoms;
6.Ensure employees are trained in the proper use of PPE; and
7.If an employee develops moderate to severe respiratory symptoms,they should be
medically evaluated and removed from the agent that caused the reaction.
Policies for Handling Allergens
We will implement the following policies to address handling of allergens at facility:
1.The most effective exposure control is to eliminate the exposure but this approach may
not work in all situations;
2.Engineering controls such as local ventilation can assist in controlling airborne exposures
to dust or chemical mists or vapors;
3.Exposure controls at staff level include work scheduling, job rotation, and staff training;
4.Determine if direct contact with products can be controlled first by the above-mentioned
elimination, engineering, or administrative controls;
5.Conduct a PPE assessment to determine the need for respiratory protection,skin and eye
protection or protective clothing; and
6.If an employee develops a rash they should be medically evaluated and removed from the
agent that caused the reaction.
Chemical Hazards
Chemical hazards are more likely in a manufacturing/extraction facility compared to a retail
facility,however,it is still crucial to maintain best practice standards to avoid these incidents
altogether.Having proper control systems—such as alarms or sensors—is an important step in
minimizing chemical hazards due to malfunctioning of the systems.Retail workers might
experience respiratory distress due to increased amounts of CO2 or CO in the air,which might
occur if ventilation systems are malfunctioning.Additionally,pesticides and sanitation supplies
can cause adverse reactions if handled improperly (i.e., without PPE).
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Policies for Reducing Chemical Hazards
We will implement the following policies to reduce chemical hazards at facility:
1.Install CO2 monitoring devices in areas where concentrations of CO2 might be elevated;
2.Consider using tools (including power washers)powered by electricity or compressed air,
if available;Implement engineering controls to reduce environmental concentrations to
the permissible exposure levels;
3.Install an effective ventilation system that will remove CO from work areas;Do not use
generators or gasoline powered engines indoors;Ensure space heaters or stoves are in
good working order to reduce CO buildup and are not used in enclosed spaces;
4.Install CO monitors with audible alarm;establish a preventative maintenance program for
all natural gas, propane, and gasoline powered equipment;
5.Educate workers about the sources and conditions that may result in CO poisoning as
well as the symptoms and control of CO exposure;ensure HVAC systems are
appropriately sized and working effectively;provide appropriate ventilation where
chemicals are used indoors;
6.Respiratory protection should be used as appropriate;
7.Establish a process for air quality complaints and how they will be addressed;
8.Provide protections to workers and handlers from potential pesticide exposure;
9. Provide training on the safe use of pesticides;
10.Provide training on how to avoid exposures to pesticides;
11.Ensure workers are able to identify pesticides exposure symptoms and how to respond
and manage exposures to pesticides if they occur;
12.Choose safer cleaning chemicals that meet the cleaning/disinfecting needs;
13.Ensure SDS are provided and cleaning chemicals are labeled to identify their contents
and hazards per hazard communication standards;Warn employees not to mix cleaning
products that contain bleach and ammonia;Ensure workers know which chemicals must
be diluted and how to correctly dilute the cleaners they are using;
14.Provide training on the use, storage, and emergency spill procedures for chemicals;
15.Operate ventilation systems as needed during cleaning tasks to allow sufficient airflow
and prevent buildup to hazardous vapors; review PPE needed such as gloves and goggles;
16.Provide areas where employees can wash up after using cleaning chemicals; and
17.Provide eyewash stations where corrosive chemicals may be handled.
Physical Hazards
Any work environment can pose physical hazards;these hazards can range from workplace
violence to natural disasters.Physical hazards can result in highly variable outcomes,from mild
injuries to mortality.Because of this,it is crucial to maintain preventative rather than reactive
strategies alone in addressing these potential concerns.
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Policies for Handling Physical Hazards
We will implement the following policies to handle physical hazards at facility:
1.Ensure the ready availability of medical personnel for advice and consultation on matters
of occupational health;
2.Ensure employees have been provided with clear instructions on how to report their
injuries and how and where to seek emergency medical attention;
3.Have a person or persons within the facility who are adequately trained to render first aid
as needed;employees should be aware of universal precautions should an event occur
where they may be exposed to blood or bodily fluids in the workplace;
4.Provide workplace first aid kits that meet ANSI/ISEA Z308.1-2015 standards;
5.Supply an AED at the workplace and provide initial and refresher training to employees
on how to properly use the AED;
6.Define clear goals and objectives for the ergonomic process,discuss them with their
workers,assign responsibilities to designated staff members,and communicate clearly
with the workforce;
7.Involve workers to encourage a participatory ergonomic approach,where workers are
directly involved in worksite assessments, solution development, and implementation;
8.Rotate employees to other jobs that use different muscle-tendon groups as practicable.
9.Hire adequate numbers of employees to compensate for staff absences;
10.Encourage by example and schedule stretch,rest,and movement breaks throughout the
workday;
11.Train line staff,supervisors and managers in proper ergonomic postures and techniques
to ensure employees are aware of potential ergonomic problems;
12.Provide workstations that encourage proper ergonomic postures;
13.Establish a zero-tolerance policy toward workplace violence.This policy should cover all
workers,customers,clients,visitors,contractors,and anyone else who may come into
contact with company personnel;
14.Ensure no worker who reports or experiences workplace violence faces reprisals;
15.Encourage workers to promptly report incidents and suggest ways to reduce or eliminate
risks, as well as a means of securely reporting such events anonymously;
16.Ensure passageways,storerooms,and service rooms are kept clean and orderly in a
sanitary condition;
17.Maintain clean, dry floors as much as possible;
18.Encourage employees to wear slip-resistant footwear;
19.Emergency exit signs must be lit and clearly visible;
20.Ensure emergency alarms are in place and are tested on a routine basis; and
21.Inspect and maintain fire suppression systems such as portable extinguishers and
sprinklers per fire code regulations.
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Safety training will begin within 30 calendar days of the start of employment and will include
training in all the SOPs;it will be conducted online and completion will be recorded and
individualized for each dispensing agent.All employees will be retrained and refreshed on all
applicable SOPs within 12 months of the previous training day.We will keep a record of the
training, which includes the following information:
1.An annual confirmation by the cannabis facility operator that the employee has received
and understood all the information and training provided in the training program;
2.A list of all employees at the premises, including at minimum; name and job duties;
3.Documentation of training topics and dates of training completion for all employees;
4.Training topics and dates of refresher training completion for all employees;
5.The signature of the employee and the cannabis facility operator verifying receipt and
understanding of each training or refresher training completed by the employee; and
6.Any official documentation attesting to the successful completion of required training by
the employee.
We will assign a person in charge to monitor these training programs;this individual will have
the education,training,experience,or a combination thereof necessary to ensure the sale of clean
and safe cannabis and cannabis products by all employees.This designated person in charge will
sign and date a document on an annual basis attesting that the supervisor has received and
understood all the information and training provided in the training program.This documentation
will be maintained as part of the record requirements.
Safety Training
The third day our training program involves training employees on maintaining the safety and
security of our customers,patients,products,as well as themselves during operations.The
Applicant will strictly adhere to the guidance outlined in the California Occupational Safety &
Health Act (“OSHA”)by the Department of Labor,and will utilize it as a primary means of
ensuring the safety for our employees.Additionally,our safety and security plan will be
reviewed by the State Police as well as Fire Department to ensure full compliance,as well as our
Chief Security Officer,who has years of experience training armed guards and served as a police
officer for a number of years.
OSHA Requirements
Our Safety SOPs are primarily established by the framework provided by OSHA,which has
been proven to be effective through various studies.OSHA has developed a framework for
maintaining safe practice standards within any given operation.These standards help promote
not only safety but also accountability on all ends of an operation.Each and every core element
is established to coordinate OSHA safety protocols for the betterment of the customers,
employees, and our products.
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Safety Training
Employees will receive training in general facility health and safety policies and SOPs,including
training on the following policies:
●Employees are provided with adequate hygiene stations, toilets, and break rooms.
●Food and drinks are not allowed except in break rooms and other designated areas.
●Smoking is not allowed within the facility,including outdoor areas,and all forms of
cannabis consumption will be prohibited by employees while on the premises.
●Employees must use appropriate PPE,such as gloves and safety glasses,for specific tasks
such as cleaning,waste disposal,equipment maintenance,or other tasks that may expose
employees to job hazards.
●Facility cleanliness and sanitation must be maintained through regular sweeping and
mopping,waste removal,removal of misplaced materials,inspecting storage areas for
signs of mold and contamination, and other tasks.
●Equipment used to clean and sanitize must be kept in good working condition and must
be kept in an area that prevents contamination.
●Waste must be collected in authorized sanitary receptacles and will be regularly collected
and disposed of to prevent contamination and odors.
●Safety Data Sheets (“SDS”)must be maintained for potentially hazardous materials,
including cannabis goods if applicable.
●Potentially hazardous materials,such as cleaning products or motor oil for vehicle
maintenance, must be properly labeled and stored.
●Employees must review the following during safety training briefings:
○Complaint and Product Recall Plan.
○Medical Emergency Procedures.
○Fire Prevention and Safety Procedures.
○Safety Alarm Systems.
Facility Personal Hygiene Training
The Applicant will train each employee on proper personal hygiene in a dispensary environment,
especially with respect to habitual handwashing to avoid accidental microbial contamination.
Good habits include,but are not limited to,washing after using the lavatory,storage areas,or
leaving and re-entering the facility.All signs will incorporate all primary languages of employed
staff indefinitely,to ensure complete adherence to regulations.As part of a comprehensive,
systematic approach to sanitation,personal hygiene and sanitation of employees,vendors,and
other authorized persons in the facility will be of utmost importance.The Applicant will comply
with all federal and local health,safety,and sanitation regulations and will welcome the Bureau,
at any time,to confirm that no health or safety concerns are present which may contaminate the
cannabis;therefore,the following rules will be put into place effective on the first day of
operation.
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All members of staff will be trained to avoid wearing outer garments that could attract particulate
matter and contaminate the production areas and maintain high levels of personal hygiene.
Employees will be instructed to remove and place all loose hanging jewelry and other unsecured
objects in the staff lockers before the commencement of each shift.Fingernails must be trimmed
and nail beds and cuticles must be clean.Staff wearing hand jewelry,fingernail polish,or
artificial nails will cover their hands with sterile,impermeable,and unused latex-free gloves.
Similar methods will be employed with staff members who need to wear coats,aprons,gowns,
hair nets,caps,beard covers,and other hair restraints at the manager’s discretion.Employees
will be instructed as to the places within the facility where hands can be washed,and proper
methods of hand-washing and a prompt to wash before returning to work will be prominently
displayed inside the lavatory areas.Employees failing these established standards will be
dismissed for the day without pay and given a formal warning.Subsequent violations will result
in immediate termination.
Fire Prevention Training
All employees will receive training on the facility Fire Prevention Plan,which is designed to
provide employees with information and guidelines that will assist them in recognizing,
reporting,and controlling fire hazards.The Fire Prevention Training Plan will help the facility to
eliminate the causes of fire,prevent loss of life and property by fire,and comply with state and
local standards on fire prevention.The Fire Prevention Training Plan serves to reduce the risk of
fires in the following ways:
●Identifies materials that are potential fire hazards and their proper handling and storage
procedures;distinguishes potential ignition sources and the proper control procedures of
those materials;describes fire protection equipment and/or systems used to control fire
hazards;
●Identifies persons responsible for maintaining the equipment and systems installed to
prevent or control the ignition of fires;
●Identifies persons responsible for the control and accumulation of flammable or
combustible material;describes good housekeeping procedures necessary to ensure the
control of accumulated flammable and combustible waste material and residues to avoid
a fire emergency; and
●Provides training to employees with regard to fire hazards to which they may be exposed.
Emergency Response Training
An Emergency Response Training Plan will be developed that describes procedures for
responding to emergencies including fires,medical emergencies,natural disasters,chemical
spills,and robbery.Training on the Emergency Response Plan will ensure all employees have
the ability to recognize,report,and respond to emergencies,and know where to find emergency
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exits,evacuation routes,and muster points.Emergency Response Training procedures will also
be provided to emergency responders such as the police and fire departments.The information
contained in the Emergency Response Training will include:
●The location of emergency and fire exits,which will also be clearly labeled and posted
throughout the facility;
●Evacuation routes;
●Designated safe rooms and muster points where employees can be accounted for and wait
for first responders in case of an emergency;
●Emergency vehicle access, including the location of designated fire lanes;
●Use of the KNOX-BOX Rapid Entry System safe box,which provides first responders
with a means to retrieve building keys or other means of access to prevent the need for
forced entry when the building is locked during an emergency; and
●The location of hazardous materials at the facility,including flammable materials and
potential ignition sources.
Substance Abuse Policy Training
The Applicant dispensary employees will be fully trained and educated on recognizing the signs
and symptoms of substance abuse.This includes abuse of alcohol,drugs (including opioids),and
cannabis.The Applicant will not dispense cannabis to any customer who is suspected of abusing
cannabis or other substances.The Applicant will also not furnish cannabis to any consumer that
The Applicant reasonably suspects of diverting or illegally distributing cannabis.The Applicant
will provide its consumers who are suspected of abusing cannabis or other substances with
information and educational materials to empower those individuals to seek help and treatment.
In the case of suspected diversion or illegal distribution,The Applicant will contact applicable
law enforcement authorities to share any information that The Applicant has obtained to support
law enforcement with any appropriate investigations or follow-up actions.In addition,The
Applicant’s employee assistance program will provide counseling or other resources to support
employees who may be struggling with substance abuse.
Sensitivity Training
Each and every employee will undergo sensitivity training in order to help them provide a better
workplace environment and customer service.This training module will include educational
material pertaining to sensitivity about sexual orientation,gender roles and identification,race,
class,equality,ethnicity,and age.Equally,this module will also explore topics around
interacting with people with disabilities and how to properly accommodate these individuals.
Overall,this module will help our employees understand that actions and words can be,even if
unattended,hurtful or offensive under certain circumstances.The Applicant will hire a
third-party company or individual specialized in sensitivity training to help bolster our training
module.
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Sexual Harassment Training
Dispensary agents will also be required to complete annual sexual harassment prevention
training,consisting of at least one hour with a California-approved Continuing Education (CE)
provider.Harassment can come in many forms and includes but is not limited to jokes,
comments,touching,bullying,exclusion from work-based activities,retaliation,quid pro quo
arrangements,and among other activities based on membership in a given protected class of
individuals.At no time shall any such harassment be tolerated by The Applicant.The offending
party will face discipline up to and including termination of employment.In order to ensure that
all our employees are fully aware of our no-tolerance harassment policy,new hires will undergo
sensitivity training pertaining to sexual and other types of harassment for at least one hour.Any
employee who believes that they have been subject to harassment will be informed to promptly
contact a manager in their chain of command or the Human Resources Director.Employees may
also file a written complaint with the office of the Director of Human Resources.
Retaliation,including intimidation,threat,coercion,or discrimination against an employee
because they have objected to discrimination,engaged or may engage in filing a complaint,
assisted in a review,investigation,or hearing or have otherwise sought to obtain their legal rights
under any law regarding individuals is prohibited.Any employee or applicant who believes that
he or she has been subject to retaliation should contact the Director of Human Resources.This
policy shall be communicated to all employees and managers annually via email,and a notice
shall be posted in employee areas of the facility.Training shall be provided annually on the
identification and prevention of harassment to all of The Applicant’s employees.The Applicant
monitors its environment for the presence of any form of harassment,intimidation,or coercion
and, where warranted, will take corrective action.
Training Against Workplace Violence
To handle workplace violence,operators must have both preventative and reactive strategies to
ensure the safety of our employees.As part of our preventative measures,employees will be
informed during both initial training and throughout annual meetings on how to deal with
workplace conflicts.Employees will be notified on the proper channels of filing complaints and
either the employee’s immediate supervisor or Human Resources will promptly deal with the
issue,as to prevent an escalation that may potentially lead to workplace violence.As with sexual
harassment,The Applicant will have a zero tolerance policy regarding workplace violence.As
part of our second preventative strategy,all employees will be trained on the potential hazards
that may occur during an altercation in a dispensary facility (e.g.,table edges,trimming
equipment,sharps,etc.).As part of our reactive strategy,the facility will at all times have
security staff available to intervene should workplace violence occur.Security staff will be
trained on how to safely and promptly intervene to help prevent injuries,equipment damage,or
product contamination.All products and equipment present in the area of the altercation will be
temporarily quarantined,inspected,and tested to ensure the safety of our patients and customers.
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Medical supplies,including automated external defibrillator (“AED”)and first aid kits,will be
present at the facility at all times.Security staff will additionally be trained in first aid and will
be both certified in CPR and in utilizing AEDs.Should an injury occur,security staff will be
trained on how to help any injured parties and how to promptly notify local EMS.An
investigation will be conducted as soon as possible and surveillance footage will be analyzed.
COVID-19 Pandemic Response
The recent Coronavirus,also known as COVID-19,has taken quite the toll on the world’s
infrastructure and economy.The U.S.recently surpassed millions of confirmed cases of
COVID-19,exceeding the prevalence rates of even China,Spain,and Italy,where the highest
death rates were recorded.This pandemic cannot simply be solved through a singular approach.
In order to promote the safety of our employees and end consumers and ensure there are no
production delays,operators must have a multifaceted approach to dealing with COVID-19,as it
impacts all levels of operation.COVID-19 is not only costing people their lives but also their
jobs.The U.S.recently broke the record for unemployment cases and reported five times higher
incidents than the previous record.This is why COVID-19 must be addressed at all levels,and
not only in regards to ensuring worker safety.In light of this,we describe in this section our plan
for dealing with COVID-19 in order to ensure the safety and well-being of both our employees
and our end consumers.The following list describes our plan of action for each foreseeable
impact of COVID-19:
●Unemployment
○Situation:As it stands,many States are prohibiting employers from permanently
firing or laying off their employees and instead mandate they furlough employees
for a certain period of time.The U.S.is also granting these individuals
unemployment pay for 3-4 months.
○Our Response:Should any of our employees be infected with COVID-19 or be
mandated by the government to not return to work for a period of time,they will
not be permanently fired or laid off.Instead,we will remain compliant with all
orders mandated by our government and furlough employees for a time.Once
they recover from COVID-19 or if the government allows them to return to work,
employees will be welcomed back and reoriented with our operations.
●Employee Safety
○Situation:Cannabis operations have been deemed essential by States and thus
will likely continue to operate throughout this pandemic.The current
understanding by medical experts is that the virus is transmitted through human
droplets, such as exposed vapors in the air following a cough or sneeze.
○Our Response:All workers must wear personal protective equipment (“PPE”)
when present at the facility,which will include a National Science Foundation
(“NSF”)face mask,nitrile gloves,and non-vented safety goggles for those
handling cannabis products.COVID-19 is typically contracted when humans
breathe in vapors,therefore we believe proper PPE will adequately protect them
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from being infected.Furthermore,all employees must be at least six feet away
from another as often and as feasibly as possible.
●Customer Safety
○Situation:California has been subjected to the highest COVID-19 incident rates
across the U.S.Several curfews and government mandates have been enforced
since the pandemic,which impacts occupancy capacities for dispensaries and
further requires additional safety measures to prevent contamination.
○Our Response:Up to three customers may be present inside the point-of-sale
area at a time.Everyone must maintain a six-foot distance from one another.All
surfaces will be wiped with sanitizing agents following each customer interaction.
Each customer is required to wear a face mask covering both their nose and
mouth.No customer will be permitted into the facility without a proper facial
mask.Customers may not touch any products until a purchase has been made.
Security personnel will enforce occupancy capacities and ensure the line at the
dispensary maintains complete order.Customers will have their identification
scanned via a no-touch method,meaning the Frontdesk Receptionist will scan
their IDs as opposed to taking the ID at hand to scan it themselves.
●Preventative Aid & Care
○Situation:As of December 2020,there is no approved vaccine for COVID-19.
However,it is likely that by the time we are operational,there will be an
established vaccine that can help people combat COVID-19.
○Our Response:Although we do not know whether the government will provide
COVID-19 vaccination through Federal or State funding (either complete or
partial aid),the Applicant will aid in covering the remaining costs of obtaining
vaccination for COVID-19 for all our employees.
●Supply Procurement
○Situation:A number of local vendors and suppliers have gone out of business
due to COVID-19,resulting in a supplies and equipment delay for many retailers,
producers, and other production specialists.
○Our Response:The Applicant will procure as many supplies and equipment as
locally as possible to ensure we retain control over procurement and have the
capacity to maintain communications with our suppliers.All containers that hold
supplies or equipment will be sanitized prior to being opened inside the facility.
Although the above actions are a response to specifically COVID-19,OPERATOR fully
understands that this might not be the only global health crisis we may face in the future.As
such,we will be proactive in our responses to any future health pandemics that may arise,
regardless if the health crisis may only have a minor impact on the national or global
infrastructure.We will have plans developed in place for such issues now,as opposed to waiting
until the situation gets worse and calls for a national emergency.By having these measures
incorporated,we work to promote the well-being of not only our employees,but also our
community and end consumers.
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Documentation/Continuing Education
The ERP system will document training attendance and completion,as well as monitor staff
metrics to allow for continuous improvement of the process.This system will help management
monitor and control individual employee development,assess compliance with protocols,and
identify any areas needing improvement,so appropriate training modules can be implemented
and further assessment can be performed.In the modern competitive environment,employees
need to replenish their knowledge and acquire new skills to perform their jobs at maximum
efficiency.This will benefit both them and the company.We want them to feel confident about
improving efficiency and productivity,as well as finding new ways towards personal
development and success.The policy applies to all permanent,full-time,or part-time employees
of the company.
Employees with temporary/short-term contracts might attend training at their manager’s
discretion.Employees,managers,and Human Resources (“HR”)will collaborate to build a
continuous professional development (“CPD”)culture.It is an employee’s responsibility to seek
new learning opportunities,it is a manager’s responsibility to coach their teams and identify
employee development needs,and it is HR’s responsibility to facilitate any staff development
activities and processes.In general,we approve and encourage the following training and
continuing education opportunities:formal training sessions (individual or corporate),employee
coaching and mentoring,participating in conferences,on-the-job training,job shadowing,and
job rotation.We will utilize the SellSafe Cannabis Training program to keep track of our all staff
member’s educational progression throughout operations.This will effectively ensure that
continuing education courses are provided year-round.Our employees will additionally have
scholarship programs offered to help each step of them progress their education.
Conclusion
It is our absolute goal to ensure that both new and seasoned dispensing agents not only follow all
the applicable regulations and guidelines described in this plan,but to continuously help us
exceed our regulatory requirements by way of feedback.The Applicant will actively listen to its
employees to identify any faults or weaknesses within our training programs and will be able to
provide suggestions at any time.Additionally,The Applicant will ensure that any mistakes done
by employees will be promptly addressed in a positive manner,as to ensure the employee is
aware of the mistake and receives all resources to continue to maintain compliant operations.
Inherently,our Chief Compliance Officer will actively monitor for any changes in regulatory
compliance in the near or far future,and will subsequently develop a system that allows our
operations to quickly and efficiently make necessary changes in a streamlined fashion.This step
is crucial for us to anticipate any new regulatory changes that will occur in the near or far future.
The Applicant strongly believes that our training modules and procedures will only improve as
we dive deeper into the future that the adult-use cannabis industry holds.
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Section 5 | Security Plan
Table of Contents
5.1 Professional Security Consultant 2
5.2 Security Diagram 3
Facility Access Controls 5
Limited and Restricted Access Areas 6
Public Entry Area Security 8
Waiting Room Security 8
Storage Room Security 10
Loading Area Security 12
Cannabis Waste Disposal Area Security 14
Number, Position, & Types of Video Surveillance Cameras 15
5.3 Alarm & Monitoring Systems 18
Security Alarm Systems SOPS 19
Digital Security Protocols 20
5.4 Cash Handling Procedures 21
Inventory Control Procedures & Security 22
Point of Sale Transaction Security 27
Counting & Reconciliation Procedures 27
Financial Records 27
Cash Transportation 28
Cash Transporter Vehicle Requirements 28
Third-Party Driver Requirements for Cash Transport 29
Cash Transport Routes 29
Incident Management for Cash Transports 30
5.5 Security Guards 31
Law Enforcement Interactions 33
Maintaining Chain of Custody 35
Conclusion 36
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5.1 Professional Security Consultant
All security systems will be installed, maintained, and monitored by a security company licensed
by the State of California Bureau of Security and Investigative Services, in accordance with the
FMC Article 33 Section 9-3310 (b)(1)(iii). The security and safety and our customers, patients,
and employees is vital above all, in addition to the prevention of the illegal diversion of our
products.
Throughout this plan, we detail our protocols and procedures pertaining to preventing the theft
and diversion of cannabis or other products; optimal safety measures to protect our visitors,
employees, and customers; safe storage and transporting or cannabis and currency; and
descriptions of how these procedures are compliant with California law. Although the
legalization of medical and adult-use cannabis has decreased the number of illicit operators to
some degree, the prevalence of illicit market cannabis remains high.
The illegal diversion of cannabis is one contributing factor to the presence of this market today.
This is why preventing illegal diversion is of great importance to us. Poorly regulated products
can lead to a multitude of safety issues, as they are not as meticulously vetted for contaminants
including pesticides and heavy metals, which can greatly impact the consumer’s health—which
is something we want to mitigate as much as possible in the City of Fresno.
As retail operators, it is our chief responsibility to prevent the diversion of products at any cost.
We want all licensed California operators to thrive in order to promote a stronger economy, an
increase in living wage jobs, and quality products for the benefit of all consumers. This is why
we will spare no expense when it comes to preventing products from being diverted to the illicit
market. It is our mission to ensure that no security breaches occur at its permitted facility and
that the presence of its state-of-the-art security systems will not only protect our assets, but also
improve the peace, safety, and security of customers, staff, and the surrounding neighborhood.
We will take all reasonable measures to prevent the loss, theft, or diversion of cannabis, and
ensure that there are suitable security arrangements at our dispensing facility. To this end, our
Security Plan will consist of a comprehensive suite of procedural measures that will be integrated
with best-in-class physical and technological security infrastructure. To effectively ensure
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optimal security throughout the facility, it is paramount to address it from multiple platforms as
opposed to a singular one. Such approaches includes ensuring:
Optimal security is ultimately to promote safety. Diverted cannabis typically has additives that
are dangerous for consumption and is seldom stored properly, leading to adulterated products
subsequently being sold for consumption. However, there are other factors aside from diverted
cannabis that can lead to major safety concerns surrounding a retail operation. These can include
anything from poor working conditions leading to long-term health issues for dispensing agents
to natural disasters and armed robberies.
No matter the degree of the circumstance, we will promote the highest level of safety standards
for customers, visitors, vendors, and dispensary agents. Any changes to the security plan
requested by the Bureau of Cannabis Control (“the Bureau”) will be implemented as soon as
possible. We strongly believe in listening to the concerns and needs of the community, therefore
all necessary adjustments to security protocols should they be requested by the community.
5.2 Security Diagram
[Included directly below].
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Section 6 | Location
Table of Contents
6.1 Description of Property 1
6.2 Location Photographs 5
6.3 Premise Diagram 8
Floor Plan 8
Site Plan 9
6.1 Description of Property
Our property located on 1536-1542 Kern Street,Fresno,CA 93706 is fully compliant with the
regulations outlined in FMC Article 33 Section 9-3307.We are located in the DTN (Downtown
Neighborhood)zone,which is one of the zones identified in FMC Article 33 Section 9-3307(a)
as appropriate for commercial cannabis businesses,per FMC Article 33 Section 9-3307(d)(3).
We further conducted a thorough review of our surrounding area and determined the property
remains compliant with FMC Article 33 Section 9-3307(c),in that it is further than
eight-hundred (800) feet from:
1.A cannabis retail business, per Section 9-3307(c)(1);
2.A school providing instruction for any grades preschool through 12 (whether public,
private,or charter,including pre-school,transitional kindergarten,and K-12),per Section
9-3307(c)(2);
3.A day care center licensed by the state Department of Social Services that is in existence
at the time a complete commercial cannabis business permit application is submitted,per
Section 9-3307(c)(3); and
4.A youth center that is in existence at the time a complete commercial cannabis business
permit application is submitted, per Section 9-3307(c)(4).
Additional Property Details
●Legal Description: 1536 KERN FR
●APN/Parcel ID: 467-072-01
●Submarket: Downtown Fresno Ret
●Subdiv. Plat Book: 1
●Subdiv. Plat Page: 2
●Additional Information: Building is located in a Historic Preservation District
The building is fully enclosed and was formerly a department store,per FMC Article 33 Section
9-3307(d)(1),and structured in a way to make it impossible to visibly see cannabis from outside
of the building and public right-of-way.Given that we are located in the DTN zoning area,our
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proposed location set in Fresno’s Historic Preservation District in Chinatown,we fit under the
City’s General Plans for infrastructural development and improvements.As stated in our
community engagement plan,we are fully committed to helping revitalize our historic
Chinatown through various means,both in regards to donations,commitment of a portion of our
net revenue,and volunteerism.In accordance with FMC Article 33 Section 9-3307(d)(2),we
are absolutely committed to aligning our operational goals right alongside the City’s General
Plan.
The facility will be entirely enclosed,and only pre-sealed,pre-packaged products will enter our
facility,greatly reducing the risk of any odors that may cause public complaints.Furthermore,
we described in our Neighborhood Compatibility Plan the specifications of our state-of-the-art
HVAC system,which will further aid in odor abatement to keep with FMC Article 33 Section
9-3307(d)(4).The size of our proposed location is approximately 3,500 square feet,making it
more than adequate in spacing to comply with FMC Article 33 Section 9-3307(d)(5),as we
have plans to further secure the parking lot around the area in addition to the loading area for
delivery and shipments.As can be seen in the image below,our location is positioned very
closely to the 99 Freeway,making it exceptionally ideal for our delivery services,as it will
connect us to most parts of the City,which further helps us remain compliant with FMC Article
33 Section 9-3307(d)(6).By being essentially in the heart of Chinatown,we further ensure that
we can expand accessibility to those who need cannabis.
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Prior to committing to our proposed location,we further reviewed our “Walk Score”to
determine how accessible our business would be for locals,which would inherently improve our
neighborhood compatibility by causing fewer traffic and pedestrian congestion.An image of our
walk score is included below.Overall,our location received a walk score of 87/100,making it
very walkable for pedestrians and locals.The average walk time to reach our proposed
dispensary from the various residential areas is only 11 minutes by foot.
Equally,the average commute via vehicles is only 1 minute,2 minutes by bike,and only 8
minutes when taking public transportation.There are a number of transit locations within our
location which helps with accessibility and promotes public transportation.Accessibility for
customers and especially patients who seek cannabis as medicine are important for us,and a
prime factor in why we chose our particular location,as Fresno’s Chinatown has seen a gradual
decline in basic infrastructure.Offering locals easily accessibility to our dispensary is the least
we could do to help them receive the products they want or need.
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The facility is fully equipped with proper and adequate electricity,sewerage,disposal,water,fire
protection,and storm drainage,pursuant to FMC Article 33 Section 9-3307(d)(7),primarily due
to the fact that its previous intended use was as a department store,making it exceptionally ideal
for retail sales.We have further worked and developed a Neighborhood Compatibility Plan in
keeping with FMC Article 33 Section 9-3307(d)(8)to ensure that we stand as a positive
influence for our community.Our facility falls under a historic region,therefore we cannot and
will not make significant modifications to the exterior of the building.We have chosen to retain
the name of the original department store’s name (seen in picture below),Komoto’s,as our
DBA.Our logo will be designed to have a similar look and feel of the logo for Central Fish Co.,
seen also below,to fully integrate with the features of Chinatown and our local area.These steps
will ensure compliance with FMC Article 33 Section 9-3307(e)(1).
We have ensured full compliance with all local zoning ordinances as stated before,per FMC
Article 33 Section 9-3307(e)(2),in addition to all the guidelines outlined in the City’s General
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Plan.Lastly,we will ensure that our signage will be limited to that needed for identification only,
and will not contain any logos or information that identifies,advertises,or lists the services or
the products we offer,per FMC Article 33 Section 9-3307(e)(3)and FMC Article 33 Section
9-3309(d),as our logo will not indicate that we are a cannabis business and neither will the
vehicles designated for delivery.
6.2 Location Photographs
Location from across the street
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Interior Entrance
Exterior Entrance
Additional exterior image across street
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Top Left: Additional Street View | Top Right: Back Alley
Bottom Left: Front Door Close-up | Bottom Right: Additional Interior
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6.3 Premise Diagram
Floor Plan
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Site Plan
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Section 7 | Community Benefits and Investments Plan
Table of Contents
7.1 Social Responsibility Plan 2
Expungement Clinics & Outreach Services 15
Environmentally Sustainable Business Model 18
Utilizing Vacant Buildings, Brownfields Lands, or Blighted Areas 26
7.2 Public Health Outreach & Educational Program 28
Plan of Action 34
7.3 Fresno Community Reinvestment Fund 34
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7.1 Social Responsibility Plan
The Applicant is fully committed to ensuring the well-being and prosperity of our community.
We have chosen Fresno’s Chinatown as an area to operate our business.Our Chief Executive
Officer,being of half-Chinese descent,is committed to promoting many of the City’s efforts to
restore Fresno’s Chinatown.Fresno’s original settlers were located along a new railroad line as
far back as the 1860s,of which many of these settlers were of Chinese descent and were
excellent brick makers.
Despite the incredible contributions these new Chinese-Americans made to ensure the building
of this new settlement,racially segregated residential enclaves were common in California in the
19th century.Chinatown was established in the Fresno area around 1872.Whereas the westward
direction of these new railroad tracks became thriving and vibrant areas,Chinese-Americans and
other immigrants exclusively lived within Chinatown.These individuals further worked to
ensure that Chinatown became a vibrant community as well,as many of the Chinese-Americans
became entrepreneurs with a variety of places of businesses ranging from restaurants to local
shops and even hotels and theaters.
Today,Fresno’s Chinatown is far from vibrant,especially in light of the recent COVID-19
pandemic.COVID-19 is not the first global pandemic that Fresno’s Chinatown has endured over
the years.The Spanish Influenza pandemic also impacted Chinatown precisely 100 years ago,
and many of the same problems related to poor infrastructure and lack of support have become
prevalent during COVID-19.
Local businesses are suddenly failing.Full Circle Brewing on F Street,a popular spot for local
events and concerts,has shifted to home delivery across California.Our owners are currently
investors for Full Circle Brewery situated in an Opportunity Zone as well,and are ardent
supporters for Chinatown’s restoration.Restaurants,such as Cuca’s on F Street,a classic
breakfast and lunch spot for downtown workers and those seeking authentic Mexican dishes
since 1976,and Esperanza’s,have also temporarily shut down.Rosie’s Flower Shop and
Panaderia Vista Hermosa,have scaled back their hours.Cris Meat Market is planning to close for
a month because of the escalating beef shortage.Chef Paul’s,whose soul food has been lauded
by Tyra Banks and comedian Joe Rogan,according to ownership,has lost 40%of its business
since Fresno’s shelter-in-place order went into effect on March 19.
Many of these businesses in Chinatown are owned by people of color.Federal support for this
area has been nonexistent.Only one business out of the hundreds of others in Chinatown,some
of which are over one hundred years old,received a SBA Disaster Recovery Loan or the
Treasury’s Payroll Protection Program intended for small businesses impacted by COVID-19,
despite the business owners going through an interview process for them.The one business that
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did receive some kind of aid, Ofelia’s Barbershop, was selected through a lottery process to
receive a ‘loan-to-grant’ from Fresno’s small business relief fund. Most business owners
simply stopped trying to apply. For our Chief Executive Officer, who feels a personal obligation
to help her fellow Asian-Americans, the treatment of Chinatown is unacceptable and something
has to change.
Unemployment continues to skyrocket in the U.S. and Chinatown is greatly impacted by the rise
of closing businesses. Because of this, we are entirely focused on exclusively hiring as locally as
possible to ensure those impacted by unemployment have not only jobs, but living-wage careers
they can thrive in. Equally, we want to prioritize purchasing supplies from local businesses when
available, such as printing supplies and equipment, office supplies, furniture, local artwork for
our waiting rooms, and many more.
Throughout this plan, we discuss each and every possible way we will help the locals of our
community in Chinatown become vibrant, and ultimately, how we can work together to battle
this ongoing pandemic. As a majority of our owners are Fresno locals, they have already been
donating to various charitable and non-profit organizations in Fresno for years. We include a list
of the businesses that our owners have already donated to as well as new ones they intend to
invest in.The City of Fresno is also looking to revitalize and build tunnels near our proposed
place of business. As such, the Applicant pledges a portion of our net revenue to help aid in the
development of these tunnels.
Poverello House (Poverty & Hunger)
Description:Believing in the dignity of every person, the talented and resourceful individuals at
Poverello House work to enrich the lives and spirits of all who pass their way by stewarding the
resources made available to them through Providential and community support. They have a
wide array of services such as providing healthcare, meals, shelter, and social services to Fresno
locals. In 1982, The Sisters of the Holy Cross and Saint Agnes Medical Center saw the need and
joined together to create the Holy Cross Clinic at Poverello House. The clinic provides free
medical and dental services to the poor and homeless of our community.
Clients may pick up a medical ticket from Poverello House at 11 a.m. Monday – Friday and 6
a.m. for a dental ticket. The clinic staff includes a part-time Nurse Practitioner and Volunteer
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Physicians. The rest of the medical team is made up of dedicated Saint Agnes staff and
volunteers who donate their time to fill this crucial need in the community. Last year, there were
nearly 5,500 medical exams and 1,000 dental visits at the clinic. Poverello House further serves
three hot meals, 365 days a year to anyone in need. Poverello House serves anywhere from 1,200
to 1,600 meals a day. Clothing, laundry, and shower services are also provided, as well as
referrals for mental health, housing and substance abuse treatment. Our Chief Executive Officer,
Robyn Kale, and Chief Financial Officer, Dr. Kamell Eckroth-Bernard, both of whom are Fresno
locals, have been actively donating to this organization since 2015. In total, over has been
donated from our two owners to the Poverello House thus far. As cannabis business owners, our
company will continue to support this organization by donating a portion of Komoto’s net
revenue to ensure this incredible organization continues its mission to help our local community.
The First Tee (Helping Local Children)
Description:First Tee of Fresno offers youth development programs, which focus on developing
life skills using the game of golf as its vehicle. Specifically designed for youth-serving
organizations, like the YMCA and the Boys & Girls Club, First Tee Community Program gives
kids the chance to learn about golf and develop character through fun golf games. They offer a
curriculum designed specifically for children, as well as the equipment and the training for youth
leaders. First Tee of Fresno’s Community Program is dedicated to introducing kids to golf and
First Tee’s Nine Core Values: respect, courtesy, responsibility, honesty, sportsmanship,
confidence, judgment, perseverance, and integrity. Our owners have been actively donating to
this foundation for several years. It’s a testament to their holistic approach to charity that
appreciates the essential services, but enough to thrive and to ensure that their children share in
this prosperity.
Critter Creek (Wildlife Preservation & Conservation)
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Description:Animals for Education-Critter Creek Wildlife Station has a three-fold mission and
presence in the Central Valley community.The first mission is rehabilitating injured and
orphaned wildlife in Tulare,Kings,Fresno,and parts of Madera and Kern counties.They
respond to calls from the public as well as agencies such as California Department of Fish and
Game,Animal Control (Fresno County),Tulare County Animal Control,Valley Oak SPCA,
Kings County Animal Control,California Highway Patrol,Fresno County,and Tulare County
Sheriffs. They have individuals answering the phone over 90% of the time-seven days a week.
Once they receive a call,they dispatch one of their volunteers living in that area.These runners
or first responders pick up the animal and either transport it to the vet or to the facility for care.
At least 30%of their time on the phone is spent educating and advising the public on wildlife
and other environmental questions they have.The second mission for this organization is doing
educational presentations.Several times a year,they have Open Houses for this very purpose.
Visitors are able to view the wildlife in their native habitat.These Open Houses are particularly
popular for children because they can take their time,run around taking pictures,and learn
information about their favorite animal.
The last mission of the facility is to provide a sanctuary for permanently imprinted native and
non-native wildlife.When illegal pets are confiscated,they are asked by law enforcement to give
the animal a safe place to live out its life,at the same time protecting the public from harm.
Whenever they can,they use these animals to educate the public about wildlife law and the sad
consequences when the law is disobeyed.Our Chief Executive Officer has been actively
donating to this organization for years and will continue to do so as a licensed cannabis entity.
Fresno Urban Run
Description:Open race participation to benefit the Burn Foundation in Fresno;medical staff,
police officers,and veterans are often involved in this event.This organization is an excellent
chance for the community to come together along with those who have and currently do serve
either in the military,medical field,fire department,or police force.To enhance a sense of local
community,we will encourage our employees to participate by creating a work-environment
activity out of this event,and cover the entry fee for all employees choosing to enter the race.
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Our two local owners have participated in the Fresno Urban Race for the past 3 years, and in
2019, rallied the Community Regional Medical Centers’ (“CRMC”) surgical team to participate
in the race as well. Thus far, our owners have donated to the burn unit at CRMC through
this organization.
UCSF Fresno Surgery Intentional Recruitment Coalition
Description:The UCSF Fresno Intentional Recruitment Task Force was established as a
collection of many different individuals, representing a multitude of cultural backgrounds, to
greatly increase underrepresented minority recruitment and matriculation to the UCSF Fresno
Surgical Program. Their mission is to perpetually diversify the UCSF Surgical Program to reflect
the underserved and underrepresented patient population that we learn from and care for on a
daily basis in the Central Valley with the ultimate goals of integrating our physicians with the
community, increasing cultural awareness and improving medical education.
In 2017, our Chief Financial Officer, Dr. Kamell Eckroth-Bernard, became a member of the
Clinical Competency Committee for the Department of Surgery at UCSF Fresno. In the wake of
George Floyd's untimely murder, Dr. Eckroth-Bernard was asked to put together and head the
Coalition and built it from the ground up. Since 2020, Dr. Eckroth-Bernard has acted as the
UCSF Fresno Intentional Recruitment Task Force’s Director. Our Chief Financial Officer
strongly believes in aiding those of minority descent to become all they can be as they expand
their field in surgery. Since he began his mission, Dr. Eckroth-Bernard has mentored numerous
individuals of various backgrounds to ensure and promote their well-being in the medical field.
Mentoring the residents and medical students is part of his daily clinical activities. He provides
mentoring through experiences in the clinic, operating room, didactic sessions, and on the wards.
Dr. Eckroth-Bernard focuses primarily on vascular surgery, but also is equally excited to share
career advice with students and foster opportunities for them to experience and explore any
special interest that they may have. He has helped several students network with other physicians
and helped them get involved in opportunities that they may have not been aware of. A list of all
these individuals is included below.
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Chinatown Fresno Foundation
Description:The Chinatown property and business owners have formed the Chinatown Fresno
Foundation with the purpose to “foster civic pride and enhance the quality of life by generating
additional sources of funds to support the improvement of the social, physical, and cultural
environment of Historic Chinatown Fresno within the meaning of 501(c)(3).”In conjunction
with the Chinatown Fresno Partnership, the operating goals are to:
●Develop a strong unified voice: Unite property and business owners to reverse neglect
from the City of Fresno, local organizations and foundations that have been going on for
years;
●Create a vibrant and inclusive live-work-play environment: Improve the business
environment, expand housing opportunities and create events and activities;
●Provide business development and marketing services: Create programs that improve
business opportunities, draw customers, and position the district as a restaurant and
retail destination;
●Friends of Chinatown: Collaborate with community organizations, City of Fresno
departments and interested people to expand services and create a safe environment in
the district; and
●Manage TCC and other major projects: TCC monies projected to come to Chinatown
include a housing project and a Complete Streets project, both of which will have a
neighborhood input component. Other major projects include TCC PBID funding and
efforts to protect the historic built environment.
The Chinatown business district has drawn help and support through the TCC and road closure
processes. Some of these organizations include:
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●Fresno Housing Authority: This organization helped this non-profit get started with TCC
Complete Streets submission and has committed to start-up funding for CFF.
●EDC of Fresno County: EDC is currently assisting with marketing efforts to combat road
closures, is providing technical assistance in fund application and has committed to
start-up funding for CFF.
●Downtown Fresno Partnership and Downtown Fresno Foundation:Have helped in
several areas and pledged an ongoing commitment to work together with this non-profit
organization.
●City of Fresno: Strongly supports through the TCC process to create Complete Streets
project.
●Central Valley Community Foundation: Provides support through the TCC project
development process.
As stated in our introductory paragraph,investing in Chinatown has become personal for our
owners for several reasons.Given the fact that our Chief Executive Officer is of Chinese descent
and that we are choosing to operate our cannabis business in Chinatown,we have directly tied
the success of our cannabis business alongside the success of Fresno’s vibrant Chinatown.
Simply put,if the community does not prosper and businesses are failing,our business cannot
hope to profit.Because of this,we have chosen to be directly involved with the Chinatown
Fresno Foundation as active donators,contributors and volunteers.We will construct an
important company program that pays our employees to actively participate and volunteer in
helping this organization thrive.
Fresno Center for Nonviolence
Description:This local organization was created to help the people of Fresno thrive.Anyone
involved in this program is actively seeking ways to better their own social policies in order to
serve the community of Fresno.Our company is dedicated to donating and volunteering for this
organization.To enter into affiliation with the Fresno Center for Nonviolence implies a
commitment to examining and altering one’s life toward the achievement of these basic goals.
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●Justice:Actively seeking to create a world where decent living conditions are available
to all,and where the decision-making processes,methods of production,distribution of
wealth,and accountability to society are equitable,giving priority to guaranteeing the
basic needs and rights of the most vulnerable.
●Inclusiveness:Actively seeking to understand the situation and point-of-view of others,
maintaining readiness to ally with other communities-of-interest or -belief that are
committed to similar principles.Acting to protect the biological diversity and natural
resources that sustain life.
●Non-injury:Pledging to use methods to attain our ends that do not contradict those ends;
acting with compassion and an understanding of shared humanity toward those we
oppose,and utilizing only those means which do not put others at greater risk than
ourselves. Promoting a culture of tolerance, cooperation and peaceful problem resolution.
Association with the Center also implies an understanding that,if we are to preserve the viability
of our living environment and the hope for a safe,democratic society,there is an urgent need to
make changes related to our goals.These changes are substantial,need to begin at once,and start
with ourselves. This organization has been actively involved in various activities, which include:
1.Seeking to understand and minimize our own fears,identifying the sources and
investigating the consequences of our own violent anger.
2.Learning to resolve personal conflicts in more constructive,mutually satisfying ways.
3.Learning to live more simply,with less heedless material consumption and less
dependence on the fruits of exploitative labor,and with more consideration for the
environment.
4.Gaining awareness of the harmful effects on others of habits and expectations
unthinkingly adopted,and of economic and social systems we participate in without
analysis “because that’s how things are done.”
5.Investing time and energy into creating and strengthening personal and community
support networks.
6.Crossing boundaries to encounter people of a different age/class/ethnicity/value system.
7.Involving ourselves constructively with young people.
8.Exploring the philosophical dimensions of living through the perennial wisdom of the
great religious traditions as well as the teachings of contemporary figures like Gandhi,
Krishnamurti and Peace Pilgrim who address the part.
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Fresno Economic Opportunities Commision (“EOC”)
Description:The Fresno EOC has provided a number of various services,particularly by those
impacted by the COVID-19 pandemic.Since the implementation of their COVID-19 response,
over 1.45 million meals have been delivered to individuals in need,in addition to over 156,000
snacks,close to one million diapers,provided 14,660 rides for passengers as well as outreach
services for 1,183 homeless people in Fresno,and has served 10,528 households at rural food
distributions.
In addition,the EOC has an Adolescent Family Life Program (“AFLP”),which addresses the
social,health,educational,and economic consequences of adolescent pregnancy by providing
comprehensive case management services to pregnant and parenting teens and their children.
AFLP emphasizes the promotion of Positive Youth Development (“PYD”),focusing on and
building upon the adolescents’ strengths and resources to work toward:
1.Improving the health of the pregnant and parenting teens,thus supporting the health of
their children;
2.Improving educational and vocational advancement;
3.Reducing repeat pregnancies; and
4.Improving linkages and creating networks of support for pregnant and parenting teens.
The amount of work this commission has done for those suffering in Fresno due to poverty and
other socioeconomic status issues cannot be overstated.We strongly believe in their integral goal
of helping those truly in need in the City of Fresno,and pledge to donate a percent of our
revenue to ensure programs such as the ones offered by the EOC continue to help those who
became most vulnerable due to COVID-19.
Expungement Clinics & Outreach Services
The Applicant will assist employees and community members in understanding the process,
filing petitions for expungement,and preparing should the court decide to hold a hearing to
determine whether to grant the petition.To help facilitate this,we will seek a donation-based
partnership with the various organizations listed below,which provide free legal help throughout
Fresno and California as a whole to low-income persons.In light of this,we will provide
fund-raising opportunities for these various organizations and commit a percentage of our
revenue to help promote an equitable industry.
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We will ultimately work with employees and community members at large to help erase past
convictions of cannabis crimes.We will work with individuals to ensure that their expungements
are on record.Equally,we will also have an employment program set in place where we will
specifically vet and hire those impacted by the War on Drugs.Cannabis has long been a means to
disproportionately impact people of color above all else,and we want to ensure that the same
industry that once criminalized them will be the means of developing careers that can make them
industry leaders.This mission is of particular importance to our Chief Compliance Officer and
Part-Owner,Nicole Albright,who has a brother who was negatively impacted by the war on
drugs.
Last Prisoner Project (Cannabis Expungement)
Description:The Last Prisoner Projects consists of cannabis industry leaders,criminal and
social justice advocates,policy and education experts,and leaders in social justice and drug
policy reform who are committed to freeing every last prisoner of the unjust war on drugs,
starting with 40,000 people in prison for cannabis offenses legal in most states.The Last Prisoner
Project was ultimately formed by a coalition of cannabis industry leaders,executives,and artists
dedicated to bringing restorative justice to the cannabis industry.The organization was founded
out of the belief that if anyone is able to profit and build wealth in the legal cannabis industry,
those individuals must also work to release and rebuild the lives of those who have suffered from
cannabis criminalization.
Our Chief Compliance Officer,Nicole Albright,began her involvement in cannabis as an
advocacy manager tasked with signature gathering for various ballot initiatives at both the state
and local level,as well as participating in the organization of various local cannabis reform
demonstrations in her home town of Eugene,Oregon.This experience established her lifelong
commitment to cannabis reform,and would be ultimately solidified when her elder brother was
convicted and sentenced to 84 months in United States Federal Prison for illicit cannabis
production and distribution.
During her brother ’s years in federal prison,Nichole continued to work towards her goal of
operating a legal cannabis business that would exemplify the values of her family,friends,and
community.Nicole’s commitment to overcoming social stigmas through responsible business
practices of education,professionalism,and community involvement continues to underlie her
participation in a responsible,regulated cannabis industry.This is why our company chooses to
support The Last Prisoner Project,as to ensure everyone who was impacted by the
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disproportionate war on drugs receives a fair and equitable chance to blossom in this new,
profitable industry.
The National Diversity & Cannabis Inclusion Alliance
Description:The National Diversity &Cannabis Inclusion Alliance (“NDICA”)is a 501(c)(3)
organization whose mission is to create an ethical and equitable cannabis industry to reduce
barriers contributing to the lack of representation of those most impacted by the War on Drugs,
including people of color and other marginalized community members.Their team aligns with
innovative thinkers and leaders to create guidance and mentorship for the markets they serve.By
bringing together government agencies,industry leaders,practitioners and intellectuals through
forums,expungement clinics,training,think tanks,and a thriving online community,NDICA
provides the necessary technical expertise and resources to succeed in the cannabis and
non-cannabis industries.NDICA has a Fresno chapter of which we will donate a portion of our
net-revenue towards monthly to ensure their mission continues and prospers.
The Fresno County Hispanic Commission on Alcohol and Drug Abuse Services, Inc.
Description:The Fresno County Hispanic Commission on Alcohol and Drug Abuse Services,
Inc.(formerly Fresno County Commission on Alcoholism for the Spanish speaking,1977
through 1986)is a 501 (c)(3)nonprofit corporation governed by a nine (9)member Board of
Directors.Administrative Offices are located at 1803 Broadway Street,Fresno,CA 93721.The
Hispanic Commission is a one million dollar operation with the largest DUI program in Fresno
County providing services in urban and rural areas,along with an adult (18yr.+)Men's Spanish
Speaking Residential facility "Nuestra Casa Recovery Home."Both programs are licensed and
certified by the Department of Health Care Services (“DHCS”)in Sacramento to provide
Alcohol and Drug Counseling services.
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The Commission was originally founded to provide information and referral services to the
Spanish speaking population in Fresno County.Thus,in their growth and development,they
have made their Alcohol and Drug Abuse Counseling services available to all English and
Spanish speaking individuals and their families.The history of the Commission began in the
summer of 1977 wherein a group of concerned community members realized that there were no
local services for Spanish speaking people suffering from alcoholism.A proposal was submitted
to the Fresno Employment and Training Project Title VI,to establish an alcoholism drop-in
center in the Fresno area.The contract was awarded and the Commission began to provide
alcoholism information and referral services to the bilingual/bicultural and especially the Spanish
speaking person seeking assistance.
Environmentally Sustainable Business Model
We have developed this plan as a means for us to minimize our carbon carbon footprint,
environmental impact,and resource needs to operate our dispensary.In order for us to achieve
this,we divided our Environmental Plan into two separate approaches we believe are necessary
for achieving this goal.The first approach involves key considerations to the design of the
facility as well as the required materials and equipment needed to conduct day-to-day operations.
In the following subsections,we describe how we will design our facility,what materials we will
use, and ultimately, how it will enhance our policy for sustainability.
Whereas the first approach describes our physical measures,the second details our
environmental policies that we deemed necessary for minimizing our environmental impact.This
includes descriptions of our plans to donate a percent of our profits to environmental
organizations,commitment to purchasing carbon off-sets,our recycling policy,and daily
operational policies related to minimizing energy use.Lastly,we commit to an environmental
impact assessment by a relevant third-party organization prior to conducting operations,as to
ensure all our measures adequately reduce our environmental impact.
Internal Environmental Policies:We will implement various environmental policies to reduce
its environmental footprint and promote good corporate citizenship,while protecting the safety
of cannabis and cannabis-derived products.One percent of net profits will be donated to
environmental non-profit organizations.Additionally,we will host annual meetings with our staff
to discuss environmental policies to determine if corrective actions are required.The build-out of
the facility will provide an excellent opportunity to use green building materials and techniques.
Green,low-volatile organic compound (“VOC”)emitting building materials,furnishings,and
wall coverings will be used whenever possible.Aerator faucets and ultra-low-flush or
high-efficiency toilets will be installed in the facility to conserve water.
The facility will also be designed to prevent and filter any potential cannabis odors from
escaping the building and being detected by the surrounding neighborhood,and preventing the
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infiltration of pests into the building.This risk of odor is quite rare as all products are in
airtight-sealed containers prior to arriving on-site.The air system will generate negative pressure
between the building interior and exterior to prevent odors from escaping the building.The
exhaust system will utilize an air filtration system with carbon filters,ozone generators,or vapor
barriers to mitigate odors.
We will reduce energy consumption in several different ways.The building will be properly
insulated and window film will be applied to the windows.The company will purchase
energy-efficient equipment and appliances (e.g.,Energy Star or EPEAT certified).Compact
fluorescent or LED lighting with dimmable ballasts and occupancy sensors will be used.
Computers and monitors will be set to hibernate when not in use.Lighting,computers,and other
electrical devices will be turned off during non-business hours.
All our systems will be equipped with smart-software capabilities,in that they will shut off when
not active during non-operational hours.We will work to reduce phantom loads and will utilize
solar-hot water as much as possible to reduce energy usage.We will install solar panels that may
help offload some of the energy and create local clean power.We will install no-flush urinals in
the men’s bathroom,which will also be equipped with towelless drying equipment that is
certified as eco-friendly. Further sustainable business practices will include the following:
●Lighting and electrical system timers will ensure that power is turned off or minimized
during non-business hours;
●Employee break rooms will include composting and recycling,reusable dishes and
utensils,and provide refrigerators and cooking appliances that encourage employees to
prepare their own meals rather than depending on take-out services;
●Sustainable office and breakroom supplies will be provided,including paper products
(printer paper,envelopes,notebooks,paper towels,toilet tissue,etc.)that are made out of
a minimum 50%recycled content,soy or plant-based printer inks,and cleaning supplies
that are non-toxic, organic, and biodegradable;
●Biodegradable materials for consumer packaging (hemp-based or other similar material);
ink used for printing will be non-hazardous and based on milk proteins or similar
material;
●The default for printers will be set to print double-sided;
●The facility waste management program will include recycling and composting,and will
recycle electronics,batteries,ink cartridges,and hazardous materials while following safe
disposal guidelines;
●An employee incentive program will be implemented to encourage employees to adopt
sustainable behaviors,including eco-friendly transportation (i.e.,walking,biking,public
transportation,or ride-share),practicing reduce,reuse,and recycling habits,limiting
office printing and participating in environmental volunteer programs; and
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●Managers and employees will form a voluntary sustainability committee to continuously
educate staff on our environmental policies,as well as look for new and creative ways to
continuously improve on our sustainable business practices.
Commitment to Carbon Offsets:We will hire a third-party team to keep track of carbon
emissions and effectively work to reduce them by both optimizing processes and by purchasing
these carbon offsets,which should balance the number of carbon emissions produced.U.S.
Carbon Offsets represent projects that reduce greenhouse gas emissions across the United States.
These projects capture,destroy,or reduce harmful greenhouse gases emitted from sources such
as animal waste,landfills,fossil fuel use,or refrigerants.Ultimately,we will purchase U.S.
Carbon Offsets to directly support a wide range of innovative carbon reduction projects
throughout the United States at an affordable price—which effectively balances out our own own
carbon emissions.
Recycling Policy:We are committed to establishing a recycling program and purchasing
products that contain recycled materials,whenever possible.Paper,letterhead,envelopes,
business cards,and marketing materials will all have a content of at least 50%post-consumer
waste (“PCW”).Toilet tissue will contain a minimum of 20%PCW and paper towels will
contain a minimum of 40%PCW.Shopping bags provided to customers will either be reusable,
certified compostable,or paper bags made with a minimum of 40%PCW content.All consumer
packaging will be minimalistic and use high-quality,bio-plastic material (hemp-based),as
packaging can be a significant waste and environmental issue given it is often discharged.Paper,
plastic containers,and aluminum cans will be recycled.Old office equipment will be taken to an
electronics recycling company.Food waste and other non-cannabis waste will be composted to
avoid overburdening landfills.Finally,all-natural,preferably organic cleaning supplies will be
used to sanitize the building.All exit packaging will be manufactured by Sana,who utilize
ocean-waste plastic and hemp for environmental sustainability.
Facility Design Features:The first component of minimizing resources needed for the
dispensary deals with its construction.By buying recycled and reclaimed local building
materials,gently-used office furniture and fixtures as opposed to purchasing new ones,we
effectively reduce energy and materials consumption in building an efficient,safe,and functional
facility for the community.Our interior and exterior design team will incorporate a
comprehensive suite of green design elements in the construction of its facility,including
significant improvements to the existing building infrastructure.The design team will also be
guided by LEED green building criteria,and we intend to seek LEED certification for its retail
facility if feasible based on retrofit options for the existing building (if applicable).Our facility
interior design elements will work to include:
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●A “living wall”comprised of indoor non-cannabis plants placed under air-conditioning
vents to ultimately improve air quality;
●Local purchasing plan to reduce carbon footprint and locally-sourced products;
●Plumbing that conserves water,including water-efficient faucets and fountains,dual-flush
toilets, and other fixtures; tankless water heaters;and insulated hot water piping;
●Insulation that exceeds Energy Code requirements,including energy-efficient and
noise-reducing cellulose or cotton batt insulation in walls and ceilings;
●HVAC systems with programmable thermostats and Energy Star certified heating/cooling
equipment that exceeds Energy Code requirements by at least 10%;
●Energy-efficient lighting systems fitted with Energy Star certified fixtures with dimmable
ballasts,compact fluorescent or light-emitting diode (“LED”)bulbs,occupancy and
photosensors, and timers;
●Indoor air quality enhancements including high-efficiency HVAC filters,hard surface
flooring with no or minimal use of carpeting,no-VOC paints,low-VOC sealants and
adhesives,and furniture and finishes that are free of toxins including urea and
formaldehyde;
●Furniture, countertops, and other finishes made from recycled and reclaimed content;
●Durable, low-maintenance exterior finishes made of recycled material;
●Exterior shading devices on south-and west-facing windows;
●Weather protection and moisture control for building exterior walls,foundations,exterior
doors, and entryways;
●Customer and employee parking that includes designated parking for alternative fuel
vehicles, EV charging space(s), and secure bicycle parking;
●A waste collection area including space for recyclables and compostable material;
●Installation of a rooftop photovoltaic (“PV”)system,or electrical conduit for future PV
(potentially and only if permitted by the City); and
●Comparison of Energy Star ratings when purchasing new equipment,as advised by
Jennifer Kaplan,author of Greening Your Small Business and owner of Greenhance
consulting firm.
In addition,we will select a local contractor for facility build-out who is committed to following
the mandatory and voluntary green construction practices including stormwater pollution
prevention and erosion control best management practices (“BMPs”);construction waste
reduction and recycling (minimum 80%diversion from landfills);implementing a construction
air quality plan;using low-impact development (“LID”)strategies to improve rainwater
infiltration;employing construction techniques to maximize material conservation and resource
efficiency;choosing durable and low-maintenance construction materials;and other green
construction practices as applicable.
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FSC-Certified Wood:The following step towards environmental sustainability involves
ensuring building materials are eco-friendly.The lumber used for construction,for instance,will
be Forest Stewardship Council (“FSC”)certified.By implementing this measure,we would be
committed to helping protect fragile ecosystems,preventing illegal logging,helping restrict
clear-cutting (i.e.,removing all trees in a tract),and more importantly,respecting native cultures
and economies that these logs are sourced from.This measure is important for us to not only help
sustain the environment in the area we operate,but to help ecologies and native populations
worldwide.
Cradle-to-Cradle Certified Products:In addition to utilizing eco-friendly building materials,
we also commit to utilizing furnishings that are also eco-friendly.Cradle-to-Cradle certified
products are the furnishing equivalents of FSC-certified lumber and building materials.Equally,
Cradle-to-Cradle furnishing consists of recycled furniture that are repurposed for use,equally
giving us a means to recycle our furniture as opposed to overburdening landfills.Each of our
EcoWorx carpet tile products that we will be using,for instance,list the number to call for 500
yards or more of carpet to be picked up and recycled at no charge.These steps ensure both cost
and waste efficiency at our dispensary.We will further use as many environmentally friendly,
biodegradable products as possible to reduce waste from plastics and other harmful materials.
Parking Design:Another vital design element is parking.Something as affordable as having
bike racks can be an effective means of promoting locals to come to the storefront via cycling
versus through a motor vehicle.Our dispensary will also have spare bike locks to temporarily
provide to customers upon request.Reduced greenhouse gas emissions,energy efficiency,and
reduced traffic fatalities and injuries are significant benefits attributable to cycling.This is why it
is imperative for us as well as all operators to ensure cyclists are tailored to in respective
businesses.Aside from installing bike racks,we will also have a parking spot dedicated to
electric vehicles readily available with a charging station,as well as additional spots for hybrid
vehicles near our facility in accordance with local jurisdiction regulations.
As time progresses and individuals become more eco-friendly,we will expand the number of
these charging stations in the parking lot to further help promote fewer carbon emissions.
Considering the impact something as affordable as a charging station can have,it is well worth
the associated costs.Exterior lighting on the business and parking area lighting will be balanced,
will not result in glare on adjoining properties,will complement the cannabis business security
system to ensure that all areas of the business are visible,and will provide increased,yet
conservative lighting at all entrances to the facility.Additionally,the lighting mentioned in this
section will be turned on from dusk to dawn.Local shade trees will further be added.In the
image added further below,we show the parking space we will eventually own on the left,in
addition to the front street parking.We will absolutely have ample parking for all our customers
in addition to ADA compliant spaces and bike racks.
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Energy Efficient Vehicles for Delivery:The Applicant will likely utilize the either the Ford
Transit Cargo Van modified with the XLH™ Hybrid Electric upfit (more details provided below)
or Chevy Bolt EV to transport all cannabis products to consumers; the Ford Transit Cargo Van
vehicle has been chosen because of its fuel efficiency, cargo volume capacity, storage security
features, and ability to seamlessly add the electric upfit system mentioned below, and the Chevy
Bolt EV was chosen to its compact size, fully electric features, and efficiency. The XLH™
Hybrid Electric upfit modification improves this particular vehicle’s miles per gallon (“mpg”) by
25%, and subsequently reduces its CO2 emissions by 20%. As a hybrid vehicle due to the
installation of the XLH™ hybrid electric system, the vehicle would utilize gasoline, ethanol (due
to its already-installed flex-fuel system, described more below), and electricity.
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The XLH™hybrid electric system seamlessly installs onto the Ford powertrain,transforming it
into a hybrid electric vehicle with the same acceleration as the original vehicle,better braking,
and allows for the original Ford warranty to remain intact—demonstrating its compatibility and
integrative features.This hybrid electric technology is fully charge-sustaining,meaning it saves
fuel through regenerative braking,a process by which the electric motor helps slow the vehicle
during braking to charge the hybrid battery.As the driver accelerates,the hybrid battery releases
the stored energy to the electric motor, helping to propel the vehicle.
The Ford Transit Cargo Van is a commercial vehicle designed specifically for medium to large
scale transportation and distribution operations and features approximately 275 cubic feet of
cargo space behind the driver and passenger seats.Maximum payload rating for the Ford Transit
Cargo Van is approximately 2,960 lbs,with an additional 350 lbs added when installing the
electric upfit—accumulating to a total of only 3,310 lbs.The Applicant will likely utilize two to
three vehicles and possibly expand to four after a few months of operation,depending on
demand.The Ford Transit Cargo Van is equipped with a flex-fuel system that allows the use of
traditional gasoline and advanced fuel options such as Compressed Natural Gas and E85,an
ethanol-based fuel.These advanced fuels offer reduced greenhouse gas emissions over
traditional gasoline or diesel fuels.Advanced fuels,additionally,are manufactured using U.S.
based materials,and help limit our country’s dependency from offshore energy producers and
providers.With the flex-fuel system combined with the electric upfit system described above,we
can expect to significantly reduce CO2 emissions and inherently save fuel costs.
Further modifications will be implemented on the van to ensure optimal security.As seen in the
images further below,we will install steel-framed interior cages inside the cargo area (seen in
picture below)to further prevent unauthorized access to our cargo,in addition to the powered
doors that provide an additional layer of security.Our chosen delivery vehicle is equipped with a
flex-fuel system that allows for the usage of E85,traditional gasoline,or any mixture of E85 and
gasoline.E85 is a renewable,ethanol-based fuel consisting of 85%ethanol and 15%gasoline.
Per American Society for Testing and Materials (“ASTM”5798 requirements,E85 may contain
anywhere between 51%and 83%ethanol by volume.E85 is readily available at gas and truck
stations throughout the state of California and produces lower emissions than traditional
gasoline.Ethanol,the main component of E85,is produced from the biomass of plants such as
corn and sugarcane.Carbon emissions from the use of E85,therefore,are offset by the amount of
carbon dioxide that is captured by the feedstock crops required to produce ethanol.That is,the
amount of carbon emissions from E85 are offset by the crops grown to produce ethanol.No
emissions are offset when traditional gasoline or petroleum products are being used,according to
the U.S.Department of Energy.Lifecycle analyses of E85 reveal that greenhouse gas emissions
are reduced by an average of 34 to 108-percent compared to traditional gasoline and diesel
production and usage.According to the U.S.Department of Energy,the total amount of
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greenhouse gas emissions being reduced depends on the feedstock or source of the biomass
being used for the production of ethanol.
Ford Transit Cargo Van w/ Interior Steel Cages |Source: Ford®
Ford Transit Cargo Van w/ XLH™ Hybrid Electric Upfit | Source: XLH™
Another vehicle we may use for delivery could be the Chevy Bolt EV given its fuel efficiency
and compact,discrete nature.Further specifications regarding this vehicle are listed below.
Although the Ford Transit Cargo is exceptionally ideal for transport,we would like to expand on
our vehicle diversity by including both large and small vehicle types optimal for transport.This
vehicle is fully electric and can drive for up to 259 miles on a single charge.The Applicant will
likely utilize this vehicle prior to the Ford Transit Cargo Van for the first years of operation.With
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the COVID-19 pandemic expanding delivery operations more than ever, we may elect to utilize
the larger Front Transit Cargo Van vehicle to keep up with consumer demand.
Utilizing Vacant Buildings, Brownfields Lands, or Blighted Areas
Our proposed facility is located in an area that seeks continuous structural and community
development, as it is located within Fresno’s Chinatown. Revitalization efforts are especially
important here given that California’s High Speed Rail (HSR) hub station will be built just across
the street. Making a commitment to revitalizing Chinatown, gives a great opportunity to make a
lasting impression for those arriving for the first time, as well as long-time residents to fall in
love all over again with our great city. The City’s vision includes the creation of the “Station
District” which we commit full support of and pledge to be a major contributor in these efforts to
promote, build, and thrive in. In doing so, we stand to help create an amazingly dynamic
community. Those revitalization efforts have already been discussed regarding our community.
At it’s best, Chinatown was a lively, thriving and inclusive area that offered goods, services and
entertainment day and night. Outcast immigrants from around the world were entrepreneurs who
ran shops, hotels, theaters, restaurants, and service businesses. They were farmers of figs, grapes,
cotton and wheat. From the late 1800s to the mid 1950s, Chinatown was a vibrant live-work play
environment. Today, the scene is characterized by damaged signs and worn down buildings.
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With urban renewal in the 1960s,Chinatown lost both businesses and residents.Historic
buildings were demolished.Buildings became vacant.Vagrants began to congregate.Other
attempts for improvement have been haphazard and poorly funded.Chinatown has suffered
decades of neglect,it’s true,but if you look closely,along streets and through alleyways,you’ll
notice evidence of a once thriving entertainment district filled with nearly a dozen diverse
minority groups,helping build the City of Fresno more than a century ago.Fresno’s Chinatown
contains hundreds of people whose families have lived and worked in the area for generations,
and some businesses are as old as 100 years.Between Highway 99 and the iconic Fresno skyline,
you find Chinatown,home to 18 blocks containing dozens of landmark buildings that stand as
monuments to the rich cultural heritage and fascinating history of the neighborhood.These
include the iconic Bow On Tong Joss House at 930-934 F Street and Bing Kong Association
Building at 821 China Alley.Other points of interest include the mission revival styled Industrial
Bank of Fresno,the art deco Azteca Theatre,author William Saroyan’s revered Dick’s Shoes and
Men’s Wear building,and the very interesting and somewhat mysterious (and one of our
favorites) Komoto’s Department Store.
We have been in communication with Morgan Doizaki,a General Manager at Central Fish Co.in
Chinatown.He works alongside Jan Minami,the executive director of the Chinatown Fresno
Foundation,a group working to revitalize and preserve its history.Part of their process is to
provide start up business classes and seminars.With that,they can match potential start up
businesses with locations.The following message was sent on December 1st,2020 to Morgan
Doizaki to ensure they fully understand our commitment to the revitalization of Fresno’s
Chinatown:
“Good morning Mr. Doizaki,
My name is Robyn Kale.I am part of a team that's just signed a lease with Nora,Ben,and
Jennifer (property manager and owners of Komoto's,across the street from Central Fish).We are
vying for one of the few (14)permits that the City of Fresno is granting for cannabis retail.We
hope to be your new neighbor after this application process is complete.I wanted to introduce
myself and let you know that we intend to be a major contributor to revitalizing Fresno's historic
Chinatown.I am a Fresno native,and my husband fell in love with Fresno while doing his
surgical residency here at UCSF-Fresno.He is currently a vascular surgeon here in town.We are
fully vested in seeing this project through,and aim to help bring Chinatown back to the bustling
destination it once was.Should we be granted a permit,we have grand visions for creating a
tastefully designed, secure and safe environment for patrons that we may share.
Currently we are in the design and planning stages for how we will use the space at Komoto's,
while we wait (excitedly and impatiently)for the outcome of the permit application process.We
are aware that the current parking spaces in front of our leased building will not suffice for the
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clientele we anticipate. We understand that you may own some parking spaces that are not
always full. Would you have any interest in discussing the possibility of some of your spaces
being available for our (possibly mutual) customers to use for short term parking? Either way,
thank you for your time. We hope to be your future neighbor and friend!”
Robyn Kale, CEO
RKNC LLC
This letter is one example of how we hope to work with our neighbors to ensure our mutual
community’s prosperity. Recently, the Fresno City Council has been set to vote on whether or not
to award a contract to an outside vendor to clean up Fresno’s Chinatown, but some
argue that its work the city could do itself. Fresno City Council President Miguel Arias says the
city is not doing it fast enough and the trash problem is now impacting Chinatown businesses.
Arias is also moving to bypass the standard bidding process, due to the ongoing state of
emergency, and contract the work out to Olympic Property Services, a company owned by
political analyst Jim Verros, who has made a number of appearances on KSEE24.
Aside from the structural issues present in Fresno’s Chinatown, COVID-19 has detrimentally
impacted the area. Many businesses, most of which were discussed earlier in our introductory
paragraph to this section, have been shutting down and barely surviving. This is why
organizations such as Chinatown Fresno Foundation, which we pledged to donate a percentage
of our revenue towards, are crucial in helping those impacted by this virus to not only survive the
pandemic, but to thrive well after it is over.
Given the revitalization efforts for Chinatown, there is no question that our community in our
proposed facility would need significant development over the years to come. By establishing a
compliant, responsible, and socially-conscious licensed cannabis business, we hope to aid in
these revitalization efforts by creating living wage careers for locals, supporting local businesses
by purchasing supplies and equipment from them, and supporting the various non-profit
organizations listed in the previous section to ensure this outcome.
7.2 Public Health Outreach & Educational Program
Educating customers on the proper, safe, and compliant use of cannabis is of particular
importance to us, especially due to the recent vaping epidemic of late that has left some
consumers even hospitalized. Regardless if the cause was due to a mistake by manufacturers or
cultivators, it ultimately falls on the dispensary to ensure each of our customers is secured with
quality-driven, safe products that are used responsibly. In keeping with this mantra, our
purchaser education plan will be designed to help our customers make informed and responsible
choices pertaining to cannabis consumption and use.
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Our comprehensive consumer education program will be delivered through multiple methods,
including verbally by knowledgeable employees,printed materials (such as brochures and
pamphlets),signage,labeling on exit packages,website pages,free information seminars,and
interactive input from purchasers.All these methods will discuss topics such as federal law,
cannabis side effects and health risks,smoking in public,and other appropriate purchaser
education or support materials as described further below.Consumer input and current research
will be used to continuously improve the employee training modules described,all so that
dispensary personnel are equipped with the knowledge to offer superior purchaser support and
customer service.
Scope of Educational:All purchasers will be individually supported and educated to facilitate
informed cannabis use,including the variety of effects from different cannabinoids (i.e.,THC
and CBD);expected physical and psychological effects;the variation in duration and intensity of
effects due to cultivar or strain,concentration or potency,consumption method,and the rate of
absorption;potential adverse reactions;and the types of products and recommended doses that
are typically used.
We will not make any health,medicinal,or therapeutic claims about cannabis goods.Instead,we
will simply advise our purchasers on all applicable information issued by the Department of
Health (and other relevant sources)pertaining to cannabis consumption and responsible-use,and
will make ourselves available to answer any related questions regarding the information provided
by the Department of Health.Our education material goes beyond the topics required by statute
to ensure that our purchasers are as informed as possible.This will help promote responsible use
among our customers and will ensure they maintain their safety.For instance,our education
material will include:
1.Federal law pertaining to the use of cannabis and its current status under federal law;
2.Health risks associated with the use of cannabis;
3.Side effects of cannabis consumption;
4.Prohibitions pertaining to consuming cannabis in public spaces; and
5.Other relevant information, such as:
a.Production information and consumption
b.Penalties surrounding driving under the influence of cannabis;
c.Safely and legally driving with sealed cannabis products present in the vehicle;
d.Recognizing illicit operators;
e.Secure storage of cannabis; and
f.Substance abuse treatment center information.
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Education on Federal Law:We will further ensure that customers are fully informed through
the education material that obtaining legal cannabis in California does not exempt a customer
from prosecution and penalties imposed by federal law;including possessing,transporting,or
using cannabis on any federal property,including but not limited to:federal buildings and
courthouses,federal parks,federal highways,and federal military bases.The education material
will also inform customers that cannabis products cannot be taken across state lines.We will
provide training to all dispensing agents and employees outlining their rights and responsibilities
under federal law.
Health Risks Associated with Cannabis:In addition to distributing any and all educational
information on the health risks associated with cannabis that has and will be issued by the
Department of Public Health,we will provide its own written materials for all customers.The
Applicant will verify all pre-packaged cannabis products to ensure the packaging follows all
labeling requirements.The education material will inform customers of both the short and
long-term health risks associated with the use of cannabis.Short-term effects would include
symptoms such as:
●Altered senses (for example, seeing brighter colors);
●Altered sense of time;
●Changes in mood;
●Impaired body movement;
●Difficulty with thinking and problem-solving;
●Impaired memory;
●Hallucinations (when taken in high doses);
●Delusions (when taken in high doses); and
●Psychosis (risk is highest with regular use of high potency cannabis).
Equally,the long-term effects of cannabis use will be explored,especially when illicitly used
among teenagers and children.These effects can include impairments to brain development,
which can contribute to IQ decline,slower cognitive development,and poor memory retention.
Lastly,the education material will divide the physical and mental effects of consuming cannabis.
Physical effects may include respiratory distress,increased heart rate,child development issues
when consumed during and after pregnancy,and intense feelings of nausea.Mental effects
likewise may include temporary hallucinations and/or paranoia,as well as worsening symptoms
for individuals with schizophrenia.Employees will also review the warning labels discussing
health risks with purchasers prior to purchase. These include:
●Unless modified by rule to strengthen or respond to new evidence and science,the
following warnings will be applied to all cannabis products:"This product contains
cannabis and is intended for use by adults 21 and over.Its use can impair cognition and
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may be habit forming.This product should not be used by pregnant or breastfeeding
women."
●Cannabis that may be smoked will contain a statement that "Smoking is hazardous to
your health.”
●Cannabis-infused products (other than those intended for topical application)will contain
the statement "CAUTION:This product contains cannabis,and intoxication following
use may be delayed 2 or more hours.This product was produced in a facility that
cultivates cannabis, and that may also process common food allergens.”
●Cannabis-infused products intended for topical application will contain a statement "DO
NOT EAT" in bold, capital letters.
All required signage will be posted inside the premises;these signs will further educate
purchasers on the health risks of using and abusing cannabis:
●"Cannabis consumption can impair cognition and driving,is for adult use only,may be
habit forming, and should not be used by pregnant or breastfeeding women;”
●"Edible cannabis-infused products were produced in a kitchen that may also process
common food allergens;” and
●"The effects of cannabis products can vary from person to person,and it can take as long
as two hours to feel the effects of some cannabis-infused products.Carefully review the
portion size information and warnings contained on the product packaging before
consuming.”
Information About Possible Side Effects:One of the most important ways that employees will
support purchasers is to give them information on the varied side effects of different cultivars
(i.e.,strains).Just as different cannabis cultivars have a range of desired effects,they may also
have a variety of unwanted side effects.As such,trained dispensing agents,as well as our
Informed-Use Consultant,will help customers to identify what cultivars may be more or less
likely to cause dizziness,dry eyes,dry mouth,headaches,grogginess,anxiety,paranoia,hunger,
and inattentiveness.
While every individual reacts differently to various cultivars,there are well-documented
tendencies.Employee expertise is critical to help purchasers find what works best both for their
desired effect,and to minimize the undesired side effect of concern to the purchaser.We will
seek information or guidance from the Department of Health to answer these questions,and will
ensure that no dispensing agent makes any baseless claims in an effort to assist the customer
regarding cannabis side effects.
We describe further below each of our individual plans for addressing and educating on the
harms of cannabis use by children and teens,as this is increasingly becoming an issue as of
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today.It is important that we create impactful and effective means of reaching out to these
minors, therefore we will work towards this goal to the best of our ability.
Product Information &Consumption:In addition to the product information contained on
each package (e.g.,terpene profile,CBD/THC profile,active ingredients,etc.),customers will
also have information regarding how to utilize each product safely and responsibly on our
purchaser education material,including various types of paraphernalia associated with each
product.Step-by-step instructions will be provided alongside applicable images for reference.
Additionally,safety information will be included regarding the use of cannabis-related
paraphernalia,such as ensuring that:(1)bongs are securely stored as to not fall and break,(2)
lighters used to ignite cannabis are not in proximity to flammable objects,(3)and customers
avoid contact with hot areas of glass paraphernalia (e.g., bongs, pipes, pieces, rigs).
Reckless Driving or Driving Under the Influence:We will educate all purchasers and our
community through our written education material that it is illegal to operate,navigate,or be in
actual physical control of any motor vehicle,aircraft,heavy machinery,or motorboat while under
the influence of cannabis.If permitted to operate a consumption lounge by the City,dispensing
agents will verbally reiterate this information to customers seeking entry into the lounge area.We
will ensure all customers are aware that nothing in California law prevents the arrest or
prosecution of a registered qualifying patient for operating a motor vehicle under the influence of
cannabis.
Educating Teens &Youth on Cannabis Use:We describe in this section how our educational
material will help children and particularly teengagers on the various effects of utilizing
cannabis.Despite regulations mandating that anyone that consumes cannabis must be 21 years of
age or older,cannabis use among teenagers is still prevalent.This is why we developed various
strategies detailed below on how we will work with these youth groups to ensure their health and
development is not impacted by cannabis abuse.
Social Media
The Applicant will create social media assets to educate children and teens about the potential
harms of cannabis use.As this demographic is likely to skip reading brochures and pamphlets,
the best way to reach them is through their smartphones.In 2018,Pew Research found that 95%
of teens have access to a smartphone,and 45%are online ‘almost constantly,’primarily on
Instagram,YouTube and Snapchat.Social marketing can use the same techniques and strategies
used by commercial advertisers to promote healthful behaviors and to counter some of the
negative effects of conventional media marketing to children and adolescents.;none of these
marketing materials will include images or depictions of minors consuming cannabis.The
challenge in delivering relevancy through these platforms is to break through competing
experiences quickly with smart messaging,short videos,and collaborations with people of
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interest to youth.Our social media identity and activities would not make any reference to our
business’s name, so it could not be a source of marketing or advertising for our brand.
Vaping
One area of high educational need is the potential harm associated with cannabis vaping.As of
October 1,2019,eighteen vaping-related deaths have been confirmed in 15 states.Additionally,
1,080 lung injury cases associated with vaping have been reported to CDC from 48 states and 1
U.S.territory.Thirty seven percent of patients are under 21 years old.Most patients report a
history of using THC-containing vaping products.Although many of the cases documented
involve unregulated vaping products,the investigation is still underway,and the FDA has
recommended that all vaping cease until clear answers are found.Even prior to this outbreak,
there has been concern that the byproducts in both nicotine and THC vaping may be harmful.
According to scientists at Johns Hopkins Bloomberg School of Public Health,significant
amounts of toxic metals,including lead,leak from some e-cigarette heating coils and are present
in the aerosols inhaled by users.As nearly one fifth of high school seniors report vaping in the
month prior,this is an area where engaging,fact-based,rapid response social media education is
greatly needed.
Cannabis Use Disorder
Another area of research to educate youth about is the possibility of cannabis use disorder.
cannabis use disorder occurs when someone experiences clinically significant impairment caused
by the recurrent use of cannabis,including health problems,and failure to meet major
responsibilities at work,school,or home,and persists using it despite ill effects.People who
begin using cannabis before the age of 18 are more likely to develop a cannabis use disorder than
adults.About 1 in 10 cannabis users will develop a cannabis use disorder.For people who begin
using before the age of 18,that number rises to 1 in 6.As such,having simple measures such as
age verification on our website is important to our community engagement.
Cognitive and Physical Effects of Cannabis
Another area of message dissemination is that adolescent cannabis use has been shown to lower
cognitive functioning.In a 2019 study on the neurobiological consequences of adolescent
cannabis use,Canadian scientists linked adolescent Cannabis use to impairments in working
memory and inhibitory control,which is required for self-control.Cannabis use was also linked
to deficits in memory recall and perceptual reasoning.As the principal investigator explained,
“Adolescence is associated with the maturation of cognitive functions,such as working memory,
decision-making,and impulsivity control.This is a highly vulnerable period for the development
of the brain as it represents a critical period wherein regulatory connections between higher-order
regions of the cortex and emotional processing circuits deeper inside the brain are established.It
is a period of strong remodeling,making adolescents highly vulnerable to drug-related
developmental disturbances.”
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The negative effects of smoking in children and teens,based on years of evidence-based
research,have been unanimously agreed upon by a majority of the clinical and scientific
communities.Smoking can greatly impact growth,allergen sensitivity,muscle development,and
physical performance in teens and children.An example of our educational material includes
educating teen athletes on how smoking can significantly inhibit their ability to perform
competitively.Equally,we will also discuss how smoking can promote early wrinkle
development,as well as its negative impact on collagen and elastin.The goal behind exploring
these topics is to find what teens and children are concerned about—such as reduced physical
performance and early aging—and link how early smoking of any substance,be it cannabis or
tobacco, can directly impact their day-to-day lives.
Plan of Action
The Applicant supports adult-use only programming,and will create social media messaging that
reflects these evidence-based reasons why children and teens are subject to harm from cannabis
use whilst adults can benefit from cannabis use.As stated before,pamphlets and brochures
simply will not reach teens and children in an impactful way,therefore the Applicant will be
continuously updating our social media pages with fun,comprehensive educational materials that
are designed to be attention-grabbing.We will collaborate with videographers and social media
figures who have younger demographics as followers to create these educational materials.The
idea is to produce quick,one to two minute videos that highlight the dangers of illicit vaping
products and its impact on growth development.
When it comes to informing customers about the safe and compliant means of consuming or
handling cannabis,we strongly believe that all aspects surrounding these topics should be
covered.This is why our Education Plan includes information not readily discussed by most
dispensary education plans,such as informing customers on how to recognize illicit operators
and recognizing signs of substance abuse.We further dedicate additional resources,such as an
available on-site Informed-Use Consultant,who can engage with customers to understand their
specific goals with consuming cannabis,as well as address any concerns they may have from
both health and compliance standpoints.Ultimately,we fully advocate for informed-use among
cannabis consumers to further the industry into a mature, compliant, and safe market for all.
7.3 Fresno Community Reinvestment Fund
The City of Fresno will establish the Fresno Community Reinvestment Fund (“the Fund”)to
support local equity businesses operating in the City of Fresno under Article 33 Section
9-3315(b)(6).We are fully aware of the sheer impact that such community reinvestment funds
have done for many individuals seeking to save their businesses and find employment
opportunities.These funds work to address social and economic inequity through new financial
34
Trade Secret/Confidential
solutions that help empower people, build sustainable communities and inspire systemic change.
This aligns with our goals to promote community prosperity and development. As such, we
commit 2.5% of our net revenue to the Fresno Community Reinvestment Fund and will likely
expand this number to 3.5% in the near future. In addition, we also are familiar with Fresno’s
various loan programs designated to help revitalize businesses and communities. We further
pledge to also have our own, internal loan program for individuals and business owners in
particularly Fresno’s Chinatown up to on an annual basis.
These individuals or businesses will be vetted, and our Community Outreach Director will
facilitate our own loan program to ensure that struggling businesses have a means of overcoming
the COVID-19 pandemic. Additionally, we further pledge to hold a Labor Peace Agreement with
each of our employees in accordance with FMC Article 33 Section 9-3316(b)(2). The Union
shall be a bona fide labor organization that is the recognized or certified exclusive bargaining
representative of the employees of an employer. We will ensure that the union of our choosing
fulfills the following requirements:
1. It actually represents employees in California as to wages, hours and working conditions;
2. Its officers have been elected by secret ballot or otherwise in a manner consistent with
federal law; and
3. It is free of domination or interference by any employer and has received no improper
assistance or support from any employer.
Lastly, we will further have a Collective Bargaining Agreement with each of employees in
compliance with FMC Article 33 Section 9-3316(b)(4). All employees at our facility will be
entitled to bargain collectively with respect to wages, work hours, and working conditions, and
have the right to decline or accept membership in a collective bargaining unit. All employees
will have the right to express, promote, pursue and/or defend common interests, which will be
discussed during regularly scheduled meetings between employee representatives and
employees. All collective bargaining agreements will be negotiated among and approved by the
Human Resource Manager, executive team, and our employees. These agreements will be
maintained in the company’s internal database, and a copy will be provided and made accessible
to each applicable employee. Further, the collective bargaining agreements will be made
available on request by any regulatory or agency or governing body with appropriate jurisdiction.
35
Trade Secret/Confidential
1
Supplemental Application Requirements
Robyn Kale
Chief Executive Officer of RKNC, LLC
Home Address:
Business Address: 1536 Kern St., Fresno CA 93706
2 December 2020
RKNC, LLC commits to employing one supervisor and one employee who have both completed
the Cal-OSHA industry outreach course offered by a duly authorized training provider as required
by FMC Article 33 9-3316(c). Furthermore, we will provide and compensate our supervisor and
employee any associated costs related to the Cal-OSHA industry outreach course, including both
the 10-hour and 30-hour programs.
We further state, under penalty of perjury, that all information contained in our commercial
cannabis business application is true and correct.
_________________________
Signature
_________________________
Date
DocuSign Envelope ID: 830E23D4-1FC5-433D-B9A1-61301837D410
03 December 2020 | 2:16 PM PST
CONFIDENTIAL
Verification of Ownership, a “Letter of Intention” to Lease, or a Leasing Agreement
1.RKNC LLC (the “operator”) has secured the property located on 1536-1542 Kern Street,
Fresno, CA 93706 (the “property”) to conduct our commercial cannabis business
operations as evidenced by the fully signed and executed lease agreement (attached
hereto as addendum 1). The property is fully compliant with the regulations outlined in
FMC Article 33 Section 9-3307.
2.Property is located in the DTN (Downtown Neighborhood) zone, which is one of the
zones identified in FMC Article 33 Section 9-3307(a)as appropriate for commercial
cannabis businesses. The operator conducted a thorough review of our surrounding area
and determined the property remains compliant with FMC Article 33 Section 9-3307(c),
in that it surpasses the eight-hundred (800) feet setback from:
a.A cannabis retail business, per Section 9-3307(c)(1);
b.A school providing instruction for any grades preschool through 12 (whether
public, private, or charter, including pre-school, transitional kindergarten, and
K-12), per Section 9-3307(c)(2);
c.A day care center licensed by the state Department of Social Services that is in
existence at the time a complete commercial cannabis business permit application
is submitted, per Section 9-3307(c)(3); and
d.A youth center that is in existence at the time a complete commercial cannabis
business permit application is submitted, per Section 9-3307(c)(4).
3.Furthermore, the operator strategically selected the fully enclosed building historically
known as Komotos and was formerly a department store in the soon to be revitalized area
of Chinatown Fresno. Per FMC Article 33 Section 9-3307(d)(1), the building of the
proposed location is structured in a way to make it impossible to visibly see cannabis
from outside of the building and public right-of-way. Given the specific area that we are
located in the DTN zoning area, we fit under the City’s General Plans for infrastructural
development and improvements.
____________________________________________________________________
Attachments:
Addendum 1 -Signed and Executed Lease Agreement
CONFIDENTIAL
1
CONFIDENTIAL
CONFIDENTIAL 2
CONFIDENTIAL
CONFIDENTIAL 3
CONFIDENTIAL
CONFIDENTIAL 4
CONFIDENTIAL
CONFIDENTIAL 5
CONFIDENTIAL
CONFIDENTIAL 6
PLANNING AND DEVELOPMENT DEPARTMENT
2600 Fresno Street • Third Floor Jennifer K. Clark, AICP, Director
Fresno, California 93721-3604
(559) 621-8277 FAX (559) 498-1026
December 4, 2020 Please reply to:
Marisela Martínez
(559) 621-8038
Robyn Kale
RKNC LLC
Dear Applicant:
SUBJECT: ZONING INQUIRY NUMBER P20-04596 REQUESTING INFORMATION
REGARDING CANNABIS RETAIL FOR PROPERTY LOCATED AT 1536 KERN
ST (APN 467-072-01)
Thank you for your inquiry regarding the allowance of new cannabis retail uses. The requested
information about cannabis retail uses was analyzed using Article 27, Chapter 15 of the Fresno
Municipal Code (FMC) of the City of Fresno. Please note, all research for this inquiry is based
on existing land development of the subject property. If there are multiple buildings on the
subject property, this research was based on the address provided in the request. This research
does not take into effect of future development unless provided in your application request. With
that, research of a proposed cannabis retail business on the subject property conveys the
following:
1. All cannabis retail businesses must be located on property zoned DTN (Downtown
Neighborhood), DTG (Downtown General), CMS (Commercial Main Street), CC
(Commercial Community), CR (Commercial Regional), CG (Commercial General), CH
(Commercial Highway), NMX (Neighborhood Mixed-Use), CMX (Corridor/Center Mixed-
Use), RMX (Regional Mixed-Use), and must meet all of the requirements for
development in these zones, including, but not limited to, parking, lighting, building
materials, etc.
The subject property is zoned DTG, which is one of the allowable zone districts for
cannabis retail businesses. Development standards of the DTG zone district are
available in Sections 15-1503, 15-1504, and 15-1505 of the FMC. The subject location
meets the zone district requirement, per Section 15-2739.B.1.a of the FMC, for a
cannabis retail business.
2. All building(s) in which a cannabis retail business is located shall be no closer than 800
feet from any property boundary containing the following: (1) A cannabis retail business;
(2) A school providing instruction for any grades pre-school through 12 (whether public,
private, or charter, including pre-school, transitional kindergarten, and K-12); (3) A day
care center licensed by the state Department of Social Services that is in existence at
the time a complete commercial cannabis business permit application is submitted; and,
(4) A youth center that is in existence at the time a complete commercial cannabis
business permit is submitted.
Zoning Inquiry P20-04596
1536 KERN ST
Page 2
December 4, 2020
The subject property is not located within 800 feet of the property boundary of any of the
above-mentioned uses. The subject building meets the separation requirements,
per Section 15-2739.B.1.b of the FMC, for a cannabis retail business.
3. Prior to commencing operations, a cannabis retail business must obtain a Cannabis
Conditional Use Permit from the Planning and Development Department per Section 15-
2739.N of the FMC.
4. No more than two cannabis retail businesses may be located in any one Council District.
If more than 14 are ever authorized by Council (more than two per Council District), they
shall be dispersed evenly by Council District.
The subject property is in Council District 3. There are currently no cannabis retail
businesses located in Council District 3. This location requirement is satisfied for a
cannabis retail business.
Please review the entirety of Article 33, Chapter 9 (Cannabis Retail Business and
Commercial Cannabis), and Section 15-2739 (Adult Use and Medicinal Cannabis Retail
Business and Commercial Cannabis Business) of the FMC to understand other
requirements of cannabis retail businesses, including but not limited to, application
requirements, signage, etc.
This information was researched by the undersigned per the zoning request. The undersigned
certifies that the above information contained herein is believed to be accurate and is based
upon, or relates to, the information supplied by the requestor. The City of Fresno assumes no
liability for errors and omissions. All information was obtained from public records held by the
Planning and Development Department.
A copy of the Fresno Municipal Code may be obtained by contacting the City Clerk’s office at
559-621-7650. The Fresno Municipal Code may also be searched on the Internet, free of
charge, by going to www.fresno.gov. If you have questions regarding this matter, please
contact me by telephone at 559-621-8038 or at Marisela.Martinez@fresno.gov.
Cordially,
Marisela Martinez, Planner I
Development Services Division
Planning and Development Department
Marisela Martínez 2020.12.04 13:20:16-08'00'