HomeMy WebLinkAboutCSE-20-61 Viola Fresno RedactedApplication Type
Social Equity Criteria
Applicant (Entity) Information
Social Equity Cannabis Business
Permit Application
CSE-20-61
Submitted On: Nov 13, 2020
Applicant
Jamil Taylor
jamil@violabrands.com
In order to qualify as a social equity applicant, applicants must
satisfy at least one of the following criteria:
1. Low income household and either:
a. A past conviction for a cannabis crime, or
b. Immediate family member with a past conviction for a
cannabis crime.
2. Low income household in a zip code identified as at least
60% according to the CalEnviroScreen for five (5) consecutive
year period and either:
a. A past conviction for a cannabis crime, or
b. Immediate family member with a past conviction for a
cannabis crime.
3. Low income household and either:
a. Five (5) years cumulative residency in a zip code identified as
at least 70% according to the CalEnviroScreen, or
b. Ten (10) years cumulative residency in a zip code identified
by CalEnviroScreen.
4. Business with no less than fifty-one percent (51%) ownership
by individuals who meet Criteria 1 and 2 above.
5. Cannabis social enterprise with no less than fifty-one percent
(51%) ownership by individuals who meet Criteria 1 and 2
above.
6. An individual with a membership interest in a cannabis
business formed as a cooperative.
Do you meet the above criteria, and want to apply as a Social
Equity Applicant?
Yes
Please state your annual income:
0
Do you have a past cannabis conviction?
No
Do you claim eligibility based on a family member past
cannabis conviction?
No
Do you represent a cannabis social enterprise?
No
Do you have a membership interest in a cannabis cooperative?
No
Application Type
Proposed Location
Supporting Information
Applicant (Entity) Name:
VCA-Ops, Inc.
DBA:
Village Fresno / Viola Fresno
Physical Address:
420 W. Huron St., #224
City:
Chicago
State:
IL
Zip Code:
60654
Primary Contact Same as Above?
Yes
Primary Contact Name:
Jamil Taylor
Primary Contact Title:
Director of Operations
Primary Contact Phone:
Primary Contact Email:
jamil@violabrands.com
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.
Permit Type
Cultivation
Business Formation Documentation:
Corporation
Property Owner Name:
--
Proposed Location Address:
--
City:
--
State:
--
Zip Code:
--
Property Owner Phone:
--
Property Owner Email:
--
Assessor's Parcel Number (APN):
--
Proposed Location Square Footage:
--
List all fictitious business names the applicant is operating under including the address where each business is located:
--
Application Certification
Owner Information
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?
Yes
If so, please list and explain:
Village is the largest 100% black owned cannabis company. Our owners are involved in cultivating, processing and dispensing high
quality cannabis in six states. Members of our Fresno team have pending cannabis applications in Illinois, New Jersey and Virginia.
Our applications in other states (jurisdictions) will not interfere with our Fresno opportunity. We are excited to assist and partner with
Mr. Delanno Hopkins, a long time Fresno citizen, an advocate of social equality and a qualified social equity resident.
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.I understand that a misrepresentation of the facts is
cause for rejection of this application, denial of a license or
revocation of an issued license.
Name and Digital Signature
true
Title
Director of Operations
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.
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.
Owner Name:
Daniel Pettigrew
Owner Title:
COO
Owner Address:
3432 Blake St., #203
Owner City:
Denver
Owner State:
CO
Owner Zip:
80205
Location TRADE SECRET
Appendix A: Evaluation Criteria
Our proposed property, 2861 E. Dorothy Ave., Fresno, CA 93706, is currently vacant
land. Our real estate business, Tilstar, LLC plans on leasing the land from the owner Pickett’s
Ponderosa Construction and assigning the lease to our operating business. Given our experience
we believe separating the real estate and operating business gives our team greater business
flexibility if cannabis is legalized at the federal level. The owner Pickett’s Ponderosa
Construction will build out our facility and the preliminary drawings and site plans are attached
within this exhibit. The land is roughly 1.69+/- acres and we plan on starting our phase I build
with 25,695 square feet of steel frame warehouse with four garage style doors for delivery, 20+
feet ceilings and 2,912 square feet of office space. The land is zoned Industrial and is properly
zoned for the use of cannabis cultivation. We expect to successfully receive our Zoning Inquiry
Letter (ZIL) and if selected, we can start our project immediately.
The property will be fully equipped with ADA access for those workers that are disabled,
and we will have over 30 parking spaces for our employees with dedicated handicap spaces
nearest to the entrance. The neighboring business will NOT be negatively affected as they are
mainly industrial, trucking and manufacturing companies that surround our facility. We outline
these companies visually in this exhibit and mention their names below:
1. Parc Environmental - Environmental contracting Company
2. Chick’s Frame & Wheel Services – Auto Repair Shop
3. Barrier Roofing & Solar
4. New England Sheet Metal – Sheet Metal Manufacturing
5. Granite Construction Company & Supply
6. Loomis Armored – Armored Truck Service
7. Pepe Kenworth – Truck Dealer
Since the project is a ground up build and the owner of the land will build to specification
of our needs, we feel we can be operational well within the City Manager timeline. This project
will bring over of construction jobs to Fresno and we will proudly work with the City
of Fresno to build a state-of-the-art cannabis cultivation facility.
2861 E. Dorothy Ave., Fresno, CA 93706
Business Plan
Appendix A: Evaluation Criteria
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
1
1.1 Owner Qualifications
Viola is the largest African American owned cannabis company in the industry. Our
Fresno Commercial Cannabis Business (“CCB”) is an organic and authentic 100% African
American and Minority owned business. Our entity is genuinely majority owned and led locally
by Mr. Hopkins, who suffered and was targeted by the War on Drugs and served 18 months in
Fresno prison, long standing Fresno resident. Viola is providing Mr. Hopkins an opportunity to
partner and learn from one of the premier cannabis brands in the industry. Our operating business
is a certified Minority Business Enterprise (MBE) in multiple states, and diversity is represented
throughout our company in ownership, management and employment. Viola and affiliates
currently operate in the following cannabis markets, California, Oregon, Michigan, Colorado and
have licenses in Maryland and Missouri.
Our local Fresno team is excited about the opportunity to apply for a cannabis business
license in a city where our CEO was convicted of a non-violent cannabis trafficking crime. Our
CCB will leverage Violas business experience and cannabis operations through funding,
employee training, production capabilities, cannabis education and executive salary synergy. Our
CCB Executive team has over 100 years combined operating safe secured cannabis facilities.
Our Board Member and Co-Founder is one of the most experienced cannabis operators,
funders and brand ambassadors in the industry. He has led a team of operators that have
successfully cultivated, processed and dispensed the Viola brand in heavily regulated markets.
Our President has close to a decade experience operating vertically integrated secured cannabis
businesses across the country. Our COO was the former interim CEO of an Illinois medical
cultivation and processing facility, served as the CEO of a vertically integrated medical cannabis
business in New Jersey and served as the COO of medical cannabis dispensaries in
Pennsylvania. Our Director of Cannabis Operations (includes cultivation, processing and
dispensary) has more than eight years’ operating vertical medical cannabis business in Nevada
and Colorado, before joining our Fresno team. That only scratches the surface of our teams’
experience in properly operating and securing cannabis facilities without incident.
Our facilities across the United States include a 12,000 square foot cultivation and
processing facility in Colorado, a 40-acre outdoor cultivation grow in Oregon, a 46,000 square
feet cultivation and processing facility in Michigan, and soon to be 66,000 square foot cultivation
facility in Maryland and 78,700 square foot cultivation and processing facility in Missouri. These
facilities have a combined annual cultivation and processing capacity of over 50,000 pounds.
Our retail facilities include a medical and adult-use cannabis dispensary in Detroit,
Michigan and two medical cannabis dispensaries in the heart of St. Louis, Missouri. These
locations have the ability to serve over 1,000 customers daily.
Our owners have overseen multiple medical cannabis facility designs and build outs in
some of the most regulated medical and adult-use markets, including Michigan, Pennsylvania,
California, New Jersey, Colorado, Nevada, Illinois and Missouri. We designed our Fresno floor
plan in a way to use space in the most efficient way and the size is an ideal fit for the safety of
our employees and the local community. The facilities our team have built have been as small as
1,900 square feet dispensaries and as large as 100,000 square feet cultivation / processing
businesses, passed all inspections with flying colors and our COO’s architecture designs have
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
3
Please see map above with our current operations and licenses, pending licenses and
potential pipeline for future growth.
COLORADO: We launched our first cannabis operation in 2014. Al Harrington and
Daniel Pettigrew took their first steps in creating their vision, which was unprecedented, in one
of the largest, toughest and stringent medical and adult-use cannabis markets in the country.
The state of Colorado has over 500 cannabis companies and just as many “brands”, many do not
last past 18 months of inception, but with proper operation protocols, hard work and training, our
founders were able to outlast the competition.
Our Colorado operation is an integrated medical and adult-use cultivation and processing
facility. We built our facility in the heart of Denver. The operation cultivates, processes,
packages, and distributes our branded products, which only includes selling cannabis oil
products. Our agents are led by our Director of Cultivation and Director of Processing, both
having over 10 years of cultivation, horticultural and processing experience. All products are
independent laboratory tested and receive great online reviews from consumers.
Key metrics that show our operational success include, increased same-store-sales by
31%, increased production capacity by 51% - through operational efficiencies, increased retail
penetration by 165% while expanding our operating margin from 21% to 33%. While many
operators are focused on “cool” brands, we focus our efforts on consistency and medicinal value,
which increases our product footprint. Our Colorado operations is a perfect example of how to
use a smaller sized facility and produce high quality cannabis products while making a profit.
MICHIGAN. One of the largest medical cannabis markets in the country. We recently
won a vertically integrated license to cultivate and process medical cannabis in one the most
blighted communities in Detroit and operate a state-of-the-art retail dispensary in the same city.
We have finalized construction of a 46,000 square foot cultivation and processing facility with
estimated capacity of over 10,000 pounds annually. We will provide a wide portfolio of products
including flower, extracts, vapes and tinctures. We launched our operations in Q2 2020 and
expect to be profitable shortly after. We own and operate a dispensary in Detroit, that has the
capacity to serve over 400 customers daily.
CALIFORNIA. The many factors that attracted our Company to the California market
was the ability to have brand penetration in the largest cannabis market in the country. We
launched our brand in August 2018 and partnered with Continuum and HERBL, some of the
largest distributors in the State. Within a few months our products had retail penetration in 25%
of all dispensaries, successfully launched 22 SKUs across three product categories. Our team is
excited to potentially operate a cultivation facility in Fresno, where we can cultivate our own
custom strains rather than rely on other producers to white label our dried flower.
OREGON. We completed our first harvest in December of 2017 on an outdoor
cultivation property. The property sits on 40 acres in Falls City, with a little over 40,000 square
feet of canopy. Annual capacity is more than 12,000 pounds. Our lead cultivator has over 15
years cultivating in outdoor environments.
MARYLAND. Our team scored the highest ranked application in Maryland’s medical
cultivation application process. Our facility will be approximately 66,000 square feet and we are
currently in advanced discussions to purchase and operate two dispensary businesses nearby. We
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
4
expect to immediately start cultivating in a medical market that is close to $550 million in total
sales.
MISSOURI. These are the newest licenses added to our business. Our team won a very
competitive license process to cultivate and process in a 78,700 square foot facility in one of the
most disadvantaged neighborhoods in Missouri. Our two dispensaries will be located in the heart
of two “up and coming” neighborhoods in St. Louis and will include a team of pharmacist and
medical professionals operating the business.
Many of the mega multi-state operators started with winning licenses and are struggling
to build a national brand, our Company started with a brand and learned how to successfully
OPERATE the brand, setting us apart from our competition. Given our diversity and local
Fresno ownership, we will be ready to fund, operate and begin our Commercial Cannabis
Business.
These facilities are perfect comparable to our proposed Georgia facility. Our team of
experienced operators have designed and built 10+ large scale cultivation and processing
facilities. Our Company will draw heavily on the experience of our Director of Cultivation to
design our cultivation, irrigation, fertigation, drying and curing rooms; Our Director of
Cannabis Operations and COO will work with architects and engineers to design our clean
room / locker room facilities, our post-production / downstream areas. Our Director of Security
will help prevent internal threats, security fencing and provide security guards to minimize
threats of theft or diversion. We are fully prepared and well-funded to build a customized state-
of-the-art facility, without cutting corners and eliminating “dead space”. Our proposed facility in
Fresno is ideal for the cultivation of high quality cannabis.
Viola’s Business History
Our founders possess the vision and passion to create the largest African American
owned cannabis operating company in the country. Founded in 2013 by 16-year professional
basketball player and his savvy business partner, Al Harrington and Daniel Pettigrew,
respectively, they have created one of the most well-respected cannabis brands in a very
fragmented industry. Viola has built a nationally known medical and adult-use cannabis brand
with a strong track record of providing high quality products to patients and consumers. Viola’s
owners are dedicated to provide resources for social equity individuals that suffered from the
War on Drugs and our history of being on the forefront of that movement is shown through our
actions, our marketing, our social media and our website. Our business is stronger when we can
truly build partnership with those negatively impacted or targeted by the Ware on Drugs.
Mr. Harrington, endured to survive an NBA playing career, while fighting off the effects
of 12 surgeries. He traded in a dangerous pile of prescription pain medications on a doctor’s
recommendation for the wide-spread health benefits derived from the cannabis plant, and it
worked wonders. The founders saw this as a viable opportunity to empower a community that
was negatively affected by the War on Drugs.
His grandmother, who has glaucoma, could finally read her bible again after trying
cannabis for the first time. The namesake of the company is in honor of his grandmother, who
encouraged him to learn more about the positive medical effects of cannabis. Our combined
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
5
medical and adult-use cannabis licenses are in five states including Colorado, Oregon, Michigan,
Missouri, and Maryland.
Currently, our company has over 50,000 pounds of annual cultivation and processing
capacity. Our cultivation team has one of the most robust catalogs of over 200 strains of flower
and multiple varieties of extract, concentrate and processed products. Our team has successfully
launched over 40 cannabis SKU’s across four product categories. Our team consists of retail and
sales experience in some of the most regulated markets in the country.
Our Company is in an amazing position within the cannabis industry. While being
licensed in multiple regulated states, we continue to be well funded and we operate and
understand all phases of the cannabis industry. We have organically created strong best-in-class
brands to serve all markets, patients and customers -- THC based Viola Brands and CBD based
Harrington Wellness and Hemp based RePlay. We have sold over 1,000,000 grams of medical
and adult-use cannabis, something we are extremely proud of. We are TRULY MINORITY
OWNED and our Fresno CCB is TRULY LOCALLY OWNED.
We are the definition of being an outlier in the cannabis industry. We are not among the
novice applicants who lack experience or expertise. We are who we are. Our founders have
invested millions of their own capital, betting on themselves. In only a few short years our
Company has built a dynamic, fast-growing, revenue producing cannabis company.
We are a proven entity as we have been trusted by multiple States to operate medical
cannabis businesses with adherence to comprehensive rules and regulations, and in so doing, we
have developed successful “pharmacy-like” protocols, procedures and best practices.
Within this application, the Fresno City Manager placed a heavy emphasis on diversity
and real partnership with social equity applicants. In most markets, we are the ONLY company
with diversity in all parts of our company. We are NOT a white owned operating company
partnering with a minority Fresno resident to gain points on this application. We have been a
successful minority owned company since the beginning. Viola is a minority owned cannabis
company partnering with minority Fresno resident. If the City Manager is serious about awarding
licenses to experienced, Fresno majority owned, minority owned and well-funded companies,
then we feel we are the most qualified.
We are excited about the opportunity to bring our vertical operating experience to Fresno.
Management Biographies and Relevant Experience
Below we not only outline our Owners and Executive Team. We also showcase Key
Personnel that will be integral to our mobilization and training plan, helping train and day-to-day
operations in Fresno. The agents who run these operations have considerable expertise, including
multiple decades of collective knowledge and real-world experience in retail dispensing,
cultivation and branding. Our Company’s success derives from the adept professionals that
operate the business day in and day out. Cannabis is unique as many companies have people
from all walks of life that come together to create a winning team, something we have embraced
and is part of our corporate identity.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
15
responsible for managing our 40-acre outdoor cultivation site in Oregon, which has production
capacity over 12,000 pounds of cannabis.
Mr. Saunders never graduated from college, but he knows as much about the botany,
horticulture, and phytochemistry associated with cultivating cannabis than anyone else we’ve
met, and he serves as a resource for everyone in all our locations. Mr. Saunders knowledge
includes all aspects of cannabis gardens, including training employees on the use of the
fertilizers and injection system, safety, and energy use. He has helped develop and implement the
integrated pest management program and supervised the application of pesticides and fungicides
within that program. He has designed and built light deprivation systems for numerous
greenhouses and installed environmental systems allowing a healthier crop and increasing
harvests. He also has considerable experience in seed propagation, plant sexing, phenotype
selection, genetic breeding, nursery propagation and flower production.
He helped develop our Company training program and will be a member of our
mobilization team to train our Fresno agents.
As you can see from our bios and headshots, we are not a white majority owned business
with an African American social equity figure head owner in order to win points on an
application. We are the exact opposite of many of our competitors as we strive for true diversity
at every level of our business.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
19
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.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
20
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
21
Timeline of Operations
Set forth in our timeline below, we will have an immediate advantage to start
construction as we have built government relationships throughout Fresno. Our COO will further
work toward finalizing all designs with architects to prepare for the possibility that we will be
selected. This plan advances the construction timetable by initiating these processes before we
are actually awarded a license. We will have the appropriate staff to complete the build out.
We can move as quickly as possible and be successful because we are the most
experienced 100% minority owned cannabis company in the US, we are self-funded which
provides a competitive advantage to avoid delays needed to raise money and we have created
supplier relationships to help with beginning inventory.
Immediately after winning a license and local construction approval, we will have our
property and begin construction immediately, below are key dates in our construction timeline.
We will have operations up and running within twelve months of being awarded a Fresno
cultivation license.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
22
Fresno Operational Timetable - Cultivation
Estimated Date
1 Finalize all drawings and site plan May 1, 2021
2 Schedule Special Use meeting to be heard in May / June 2021 May 1, 2021
Awarded Cultivation License May 1, 2021
3 Submit site design, engineering drawings and construction drawings to local buildings department for special use permit May 6, 2021
4 Local permitting process completed; Architectural drawings approved; Contractors secured to begin construction May 31, 2021
Construction Begins June 1, 2021
5 Prepare the site: Order all Greenhouse equipment, install erosion control fencing around the site to eliminate loose soil and
matting over exposed earth
June 5, 2021
6 Begin facility site work and utilities work (MEP) (installation of new transformers etc)June 7, 2021
7 Site Layout, mark ou the location of the building on the site and location of the underground electrical, water and gas piping June 6, 2021
8 Take down top layer of soil and expose the ground where the building is going to be erected June 8, 2021
9 Install water lines that will feed the cultivation and processing buildings June 12, 2021
10 Install underground waste lines that will feed the facility June 16, 2021
11 Pour concrete footings and foundations for new building June 23, 2021
12 Install and finalize all underground waste lines, storm water, natural gas and water service lines July 11, 2021
13 Install the tilt in place, insulated precast concrete building panels July 17, 2021
14 Install steel roof bar joists for main building and weld them into the tops of the precast concrete wall panels for structure July 21, 2021
15 Install steel roof decking on top of the steel bar joists to create to create the roof surface July 25, 2021
16 Pour interior concrete floor slab July 27, 2021
17 Install 10 foot security fencing around perimeter of the site July 31, 2021
18 Begin walls, partition separators, framing (w/ steel studs)August 9, 2021
19 Begin mechanical rough-ins (plumbing, electrical and HVAC)August 24, 2021
20 Finish mechanical rough-ins (plumbing, electrical and HVAC) and framing September 3, 2021
21 Begin installation of all wiring (security, surveillance, IT planning and network)September 13, 2021
22 Install fertilization system, irrigation and water filtration system September 23, 2021
23 Run underground electrical, water and waste lines to new greenhouse locations September 25, 2021
24 Begin millwork, trim, hardware, doors and fixtures (start paint and floor finishes)September 25, 2021
25 Begin IT storage, security cameras, video surveillance, October 3, 2021
26 Finish millwork, trim, hardware, doors and fixtures (paint and floor finishes)October 16, 2021
27 Install acoustic grid ceiling in the areas outside the cultivation rooms October 21, 2021
28 Trim all electrical work with switches and outlets, install plumbing fixtures, grills and registers November 2, 2021
29 Begin installation of grow room equipment (lights, racks, CO2 enrichment)November 4, 2021
30 Finish and install all IT storage, security cameras, video surveillance, electric locks, network patch panel and back up system November 9, 2021
31 Security IT / Access control system testing and adjusting November 11, 2021
32 Install approved METRC and any software or electronic logs November 11, 2021
33 HVAC start up and testing to make sure all grow room and greenhouse units work properly November 11, 2021
34 Finish installation of all growing equipment (lights, racks, tables, pots etc)November 26, 2021
35 Test all growing equipment November 27, 2021
36 Clean property and apply for final building and City Manager inspections November 28, 2021
1 Germinate Seeds / Tagging Plants December 7, 2021
• Begin to germinate seeds in 4 inch pots with soil, keep under florescent lights
• Seed germination, seeds should be sprouted and showing leaves
2 Pre Vegetative / Transplant December 14, 2021
• Transplant into 1 gallon pots when roots develop. Plants should not be allowed to become root bound but also should be able to
maintain structure during transplant.
3 Vegetative Stage December 25, 2021
• When plants have reached their 4th-5th node they need to be sexed. Increase nutrient mix, increase wattage to 900 watts,
decrease light cycle to 18 hours. Maintain temperature but lower humidity to 60-70%. If sex is not showing decrease to 14 hours
or 2-3 days.
• After males have been culled the female plants can be transplanted into pots they will flower in. Use nutrients during transplant
and irrigate with compost tea. Massage root balls gently to loosen them up during this transplant. Inspect for brown roots or a
sour smell indicating root rot. Inspect for soil born pests.
Activity
Construction:
Cultivation Timeline (From Seeds):
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
23
• Take cutting from all plants tracking strain and pheno type. We will determine which pheno we want to keep as moms during the
4 Flowering Stage February 23, 2022
• Increase spectrum lights and increase nutrient mix to adult vegetative plant ratios. Spread out into the flower space, add drip
system and trellis
• Change lights to 12 hours on 12 hours off
• Prune any underbrush, leave 5-7 nodes of each main branch, continue to train out into the trellis. Remove any dead, dying or
decaying leaves. Inspect all plants to insure no male plants made it into the garden
• Bud sites should be obvious. Increase bloom mix. Decrease humidity 50-60%
• Canopy will be getting dense. Ensure proper airflow both above and below the canopy. Should see leaves moving gently in all
sections of the garden but not getting damaged by too much wind. Add fans to dead zones. Pay attention below the canopy.
Keeping air movement below the canopy is important to prevent higher humidity causing powdery mildew. Inspect regularly for
signs of mildew and pay attention to where the canopy is dense.
• Increase to max bloom ratio. Heavy feeding strains may require a little more or an extra feed in the cycle.
• Begin flush. Start cutting sun leaves away, never taking them all and focus on removing yellowing leaves.
5 Harvest - Move to Drying Room March 25, 2022
• Havest, monitor trichomes for 20% amber, 80% milky, little to no clear. Can vary this depending on strain or desired results. Can
be sped up depending on health of the crop. Remove all sun leaves, leaving smaller leaves with trichomes to be trimmed away
and used in manufacturing. Remove all brown leaves. Inspect for pests or disease. Cut to appropriate size for hanging or drying
racks.
6 Bulk Cure April 5, 2022
• Dry and cure, humidity 50-60%, temperature 60 degrees or below. Break down dense branches, no overlapping or sitting on top
of each other. Maintain airflow in the dry space to break humidity pockets. Buck off branches into totes for finishing. Small
branches should snap when bent, outer leaves should be crisp, not crunchy. Moisture content should be 15-20% for trimmers to
avoid damaging flowers. Final moisture contenct can be achieved after trimming before packaging. Totes should be burped and
turned daily until proper moisture content is reached.
7 • Independent laboratory testing April 19, 2022
8 • Package and label cured cannabis (ready for shipment)April 26, 2022
1 Cultivation & Processing staff hired October 23, 2021
2 Security staff identified from 3rd party Georgia Company October 23, 2021
3 Begin training of all cultivation and processing agents and third party security team (including cultivation, processing SOPs,
METRC, tracking, handling, inventory management and security protocols)
October 25, 2021
4 Simulate delivery of product with safety procedures November 4, 2021
5 Finalize training and work simulations for all cultivation and processing agents November 11, 2021
6 Start cultivation of medical cannabis December 7, 2021
Note: This timeline allows for delays in our construction or cultivation process to have cannabis products on shelves by April 2022. The cultivation timeline will be expedited using clones vs seeds
Staffing:
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
25
Five Year Pro Forma Income Statement, Cap Ex and EBITDA / Cash Flow Returns:
Please see our detailed financial model, attached in this exhibit, with our quarterly pro
forma operating assumptions and production financials.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
26
1.5 FULLY DESCRIBE HOURS OF OPERATION AND OPENING AND CLOSING
PROCEDURES.
Hours of Operation
Cultivation: We are applying for a retail dispensary and cultivation license. The facilities
will NOT share the same property and will NOT share access among our dispensary or
cultivation facility. If we are successful in winning both, ONLY the CEO, COO and Security
Manager will share access. We plan to operate our cultivation with two daily shifts Monday
through Friday and one daily shift on Saturday and Sunday. If we realize that demand is high, we
can adjust our hours to ensure our facility is meeting the demand. In no instance will we be open
earlier than 6:00am and close later than 10:00pm, per SEC 9-3310(a)(1). Our proposed schedule
has our cultivation open for 9 hours every day on average. We fully understand that a cultivator
may operate 24 hours a day and operations will be subject to the provisions of the Noise
Ordinance, Article 1 of Chapter 10 of this Code, as may be amended, per SEC 9-3312(a)(1).
Please see our expected hours below:
Our CEO will ensure that all full-time employees received at least 35 hours per week and
part-time employees receive at least 15 hours per week.
If our CCB closes, either temporarily or permanently, 30 days prior to the date, our
owners will: (1) notify the City Manager, (2) send written notifications to employees, and (3)
post a notice on the window or door of the facility. Exceptions to the public notice will be
approved by the City Manager and may include sudden closing due to fire, destruction, natural
disaster, death, property seizure, eviction, bankruptcy or other emergency circumstances. If our
facility is not able to meet the notification requirements, our owners will ensure that the City
Manager and public are properly notified as soon as our owners knows of the closure and will
disclose the emergency circumstances preventing the notification within the required deadlines.
Opening & Closing Procedures
Cultivation: Our CEO, Facility Manager and Security Manager will ensure all procedures
are followed when opening the facility for the day. At no time will our CCB be open or in
operation, unless the CEO or Facility Manager and security guard is on premise and directly
supervising the activity within the facility. The CEO or Facility Manager will ALWAYS open
the facility with a security guard on site. Each employee that enters will have to check in using
their limited access keycard and show ID, all hourly paid employees must “clock” or “punch” in
Fresno Cultivation Hours of Operation
Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Open 9:00 AM 8:00 AM 8:00 AM 8:00 AM 8:00 AM 8:00 AM 9:00 AM
Close 1:00 PM 6:00 PM 6:00 PM 6:00 PM 6:00 PM 6:00 PM 4:00 PM
Hours Open 4 hours 10 hours 10 hours 10 hours 10 hours 10 hours 7 hours
Total Hours 61 hours
Average Hours 9 hours
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
27
before entering any part of the facility. The CEO or Facility Manager will inspect all cultivation
rooms and downstream areas before any employee starts their shift.
At close, all hourly paid employees much “clock” or “punch” out before leaving at the
end of the business day. Our CEO will follow the procedures outlined: (i) ensure all working
stations are cleaned and sanitized, (ii) remove all cannabis, cannabis products from the open, (iii)
lock all storage areas containing cannabis or cannabis products, (iv) shut down all computers and
turn off all lights (not cultivation lights – as those are on timers based on the plants growth
cycle), and (v) activate the security alarm, leave as a team (security guard is always last to leave)
and make sure all entrance doors are locked. If a production process cannot be completed at the
end of the working day, the agent will securely lock the areas, or tanks, vessels, bins or bulk
containers containing Cannabis, including the seeds, parts of plants, inside an area or building
that affords adequate security. Our CEO, Facility Manager and Security Manager will monitor
all employees to ensure adherence to all closing procedures.
We will train all employees on our Standard Operating Procedures regarding detailed
opening and closing of our facility. Each employee will understand the importance of how to
properly complete each task meticulously for opening and closing safely and securely.
Clock in and Clock Out Procedures: To ensure our agents, employees and staff are
compensated for time worked, each area manager will keep accurate record of employee’s work
schedules in the back office. Employees will be trained properly on how to use our electronic
punch-in and punch-out system. All employees must punch-in at the start of their shift, punch-
out for lunch breaks, punch-in once returned from lunch and punch-out at the end of their shift. If
working more than six hours in a shift, all employees will be required to take a 30-minute lunch.
All employees will receive 15-minute breaks for every four hours worked. We plan on using an
electronic Timelogix TL50 Smart Punch In/Out system that tracks all daily employee data on our
secure servers. The system allows employees to clock in and out using their personal mobile
devices (within 50 feet of our system) and the system sends alerts regarding breaks and
employee hourly data. Each employee will have a unique user and password to punch in and out.
The system can also integrate with agent access cards so employees that forget their user and
password can record their time in and time out by swiping with the machine. All employees will
receive their paycheck every 2 weeks on a Thursday. We will have payment options of direct
deposit or a mailed check, we advise all employees to request direct deposit, but it will be the
employee’s choice.
COVID-19 Procedures: Our facility will ensure all employees and visitors are safe and
follow all COVID-19 protocols, including wearing a mask, that is covering the nose and mouth,
upon entry, receiving a temperature check directly within entry, and staying 6 feet away from
other employees while in the waiting area and in production areas. If an employee or visitor has a
fever or high temperature or flu like symptoms, our CEO will ask they immediately leave the
facility and seek immediate medical attention. If a customer does not have a mask, we will have
a box of medial grade masks to be provided upon entry. All items share items that employees can
access (floors, chairs, desks, tablets, countertops) will be wiped down and sprayed with paraben
and phthalate free sanitizer. We will have hand sanitization stations spread throughout our
facility. All production employees will wear, protective color-coded jumpsuits, hairnets, face
mask and gloves to prevent the spread of disease and pests to our plants.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
28
STRENGTHS, WEAKNESSES, OPPORTUNITY, THREAT (SWOT) ANALYSIS
A Business Plan is not complete without a Strengths, Weaknesses, Opportunities and
Threats (SWOT) analysis. This analysis is important, so our executive team understands the
positives and negatives of our Fresno business venture. It serves as the backbone of our decision
to enter into a cannabis market. Given our long-standing operational experience, we have many
STRENGTHS in the cannabis industry that will benefit the Fresno market. Due to experience
from our team, mostly all the topics within this application are considered our strengths. The fact
of the matter is we operate in multiple highly regulated states. We feel WEAKNESSES from
lack of experiences no longer exist within our Company and our team turned those early
mistakes into learning experiences that are now strengths.
Fresno will be a large market, there is OPPORTUNITY to increase our brand awareness
and serve customers with high-quality consistent products. We plan on being first to market
taking advantage of low supply and high demand of product. We will not price our products
based on supply and demand economics; we think first-to-market creates brand loyalty amongst
customers. We believe our biggest THREAT is mass-consolidation among the larger cultivators.
Cannabis companies are selling equity for millions and billions of dollars, the stakes are higher
than ever before, and many applicants create loopholes to control and own more licenses than
legally allowed, especially when it comes to social equity licenses.
Strengths:
National Brand – Our brand is very well recognized as we are the largest African
American cannabis brand in the US. The celebrity nature of our brand gives us access to a
network of intelligent, well respected business minds to further our brands’ presence in existing
and new markets. Our brand is a major strength to any new market, it represents high-quality,
consistent, competitively priced, minority-owned community focused ideals.
Well Capitalized – We have liquid assets and cash on hand, ready to capitalize our
business and start immediately. We set aside more than $10 million in liquid assets. Our liquid
capital on hand exceed our projected costs/capital burn, thereby allowing us to begin our
operations immediately.
Proven Standard Operating Procedures – Our COO honed a first-class step-by-step SOP
and application that will make our products effective, efficient and safe to every customer. Our
SOPs are outlined throughout this application, which proves the success of the business. Our
facilities have NEVER had a criminal incident, NEVER experienced internal diversion and
ALWAYS maintained an adequate supply of product.
Strong Executive Team – One of the strongest business, marketing, branding, legal,
financial, operating, community relations and cannabis industry teams in the business. Many of
our team members have been involved in the cannabis industry since the beginning of
legalization in most states and have formal and informal cannabis training.
Cultivation Experience – Most of our team members have experience designing,
constructing and operating large scale facilities in regulated states. Our team has overseen 10+
cultivation projects in high barrier to entry cannabis markets. Ranging in size from 12,000 square
feet of canopy to 100,000 square feet of canopy.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
29
Community Impact & Engagement – Our Company is majority owned by resident that
has deep community roots in local low-income communities. We will build relationships with
community leaders and government relations and cannabis officials to provide economic
development, jobs and opportunity for all residents in Fresno, not just the wealthy.
Diversity and Inclusion – Less than 5% of all cannabis companies have majority minority
participation in ownership and California lacks majority minority owned cannabis businesses.
Our Company has 100% of the equity held by minorities as commonly defined. Our diversity
gives our Company a unique perspective when analyzing new products.
Weaknesses:
Illegal Market Keeping Prices Low – Our team does not cultivate, process or dispensary
in California. Our relationships in California might not like us cultivating our own product and
make pricing difficult if we are competing for shelf space at the same dispensaries. The flower
market in California has a lot of illegal producers and bad players that keep prices low and make
it hard for licensed cultivators to make appropriate margins. The licensed operators are lowering
their prices, which is great for the customer, but typically cut corners in other ways to maintain
profit margins. We plan to mitigate by selling our flower to Fresno dispensaries first and then
expanding and distributing to other markets. With our strong brand we should have no issues
selling our products.
Opportunity:
First to Market / New Industry in Fresno – Because of our strong brand recognition we
want to be first to market to create customer loyalty and take advantage of initial high demand.
Limited Supply and High Demand – We have the capital to start construction
immediately and the experience to dispense without interruption. We plan to have products ready
for sale shortly after being awarded a license. This creates brand and product loyalty amongst
customers. Our relationships will allow us to sell branded products immediately to serve the
Fresno residents.
Economic Development – location of our cultivation facility is a green field project that
will provide construction jobs as well as permanent jobs for our operations. We will fill positions
not only at our facility, but also within ancillary industries such as – marketing, accounting, real
estate, sales, packaging etc. We will commit to targeting low-income communities for at least
33% of our workforce.
LOW Minority Ownership: Currently in California less than 5% of dispensaries are
African American majority owned. Being the largest African American cannabis brand in the
industry, many African American customers see our brand and feel connected visiting,
purchasing and using our products. Our business will be a model business for Fresno’s social
equity program and we will not disappoint.
Threats:
Misleading Social Equity – Companies that are non-minority owned will create predatory
partnerships with social equity applicants. Large companies will put a social equity applicant as
the figure head owner and buy their equity for pennies on the dollar. We do not want to see
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
30
predatory agreements (i.e. companies doing applications for “free” because they suddenly care
about diversity). The City Manager will have to sift through all applications to ensure these are
real partnerships and authentic long-term minority Social Equity Applicants.
Vertical Integration – With cultivators, processors, and dispensaries all under the
management of one parent company. Many of the vertical integrated businesses tend to sell only
to their dispensary and can use transfer-pricing methods to drive out competing operations.
Essentially blocking all new companies from competing with their dispensaries. Our CCB is also
applying for a dispensary license and we want our strong brand to be in ALL Fresno stores and
our dispensary will carry other local Fresno products.
We feel we have the perfect team and perfect location to mitigate these issues presented
in our SWOT analysis.
Signage, Marketing and Advertising
Our CCB will follow all rules and regulations regarding marketing our products. We
believe our location will be a “destination” location, meaning that we do not need to have
elaborate signage or lights pointing to our location.
Exterior Signage: All outdoor signage if visible to the public, must comply with all local
township ordinances for signs or advertising and will not display any text other than our
facility’s business name, address, phone number, website or social media handles. We will not
utilize images or visual representations that indicate the presence of cannabis plants, products or
paraphernalia, such as smoke. Our discrete signage will consist of purple text on a white
background and signage will only be illuminated during business hours. We will not display any
paraphernalia from the exterior of our building or any cannabis leaves or “Vegas style” or neon
flashing lights. We will follow all local signage and lighting rules, outlined in SEC 9-3309(d).
No cannabis or cannabis products or graphics depicting cannabis or cannabis products will be
visible from the exterior of any property issued a commercial cannabis business permit. No
outdoor storage of cannabis or cannabis products is permitted at any time.
Marketing & Advertising: We will NOT market or advertise to minors and all marketing
materials, billboards, flyers or any marketing campaigns will not advertise or be marketed within
1,000 feet of K-12 schools, daycares or playgrounds. Our Director of Marketing & Branding will
submit all marketing materials to the City Manager, before use all materials must be approved by
the City Manager.
Our market plan was developed by our experienced Director of Sales, Director of
Marketing & Branding and CEO. We plan to use all forms of Direct Marketing and limited or
strategic Mass Marketing. We realize the sensitivity of mass marketing as more eyes and ears are
focused on the positives and negatives of a cannabis program, potentially children that do not
qualify for the program. Direct marketing is a form of communicating where organizations
communicate directly to a pre-selected customer and supply a method for a direct response. Our
professional team budgeted 15% of revenue, equating to $3.967 million annually on marketing
and advertising.
We will direct market through extensive customer education. Our team will host a series
of monthly townhall style Cannabis Education events in our Community Education & Training
Center (CETC). These events will cover many topics, including but not limited to; Introduction
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
31
to Cannabis “101”, Rules and Regulations of Fresno Cannabis Program, Introduction of our
Company and Brand, THC vs CBD, Cultivation and Processing Brand Introductions and Forms
of Use: Inhalation, Edible and Topical, Sativa, Indica and Hybrid. We will collect names, emails
and phone numbers, as well ask all customers to register for our mobile application.
These forms of contact will allow our Marketing & Branding team to directly contact
those individuals that showed interest in the cannabis program and our business. These
educational events will be great for customers to meet our team members, ask questions to
educated agents regarding the program and learn our Company’s corporate values. These events
will serve as our marketing outreach to the community and it’s a way to eliminate marketing to
minors or those not interested in using cannabis in our respective neighborhood.
Along with these community education events, we plan to market using strategic
traditional marketing. We will speak with and market to hospice services, local nursing homes,
palliative care facilities, hospitals and other facilities where their customers would significantly
benefit for the use of cannabis.
We feel direct marketing to individuals that have interest in using cannabis is the best
place to start as we do not want to market or reach minors with a message to use cannabis, unless
it’s for medicinal purposes. We plan on hosting Brand Appreciation events at dispensaries,
where our cultivation brand and marketing agents will meet with customers and showcase our
high-quality products. The goal is to introduce smaller, microbusinesses to and Fresno cultivators
and processors to our customers. We will use our social media following and branding to
promote our local Fresno products.
Regulatory Compliance
We have extensive experience operating cannabis facilities in highly regulated states. We
have an impeccable record in compliance. Never failing an inspection and have always
maintained regulatory compliance rules and regulations. Our regulatory team is composed of
three ideals of complete regulatory compliance: (i) Operating Compliance, (ii) Legal Regulatory
Compliance and (iii) Government Affair Regulatory Compliance. We will assign a Quality
Assurance Manager to oversee any cultivation facility we own in Fresno, to ensure our CCB
complies with Fresno, State and Federal rules and regulations.
Adam Day, serves as our Chief Compliance Officer. He is responsible for making sure
ALL our operations follow local, state and national regulatory compliance codes. He has over 5
years of medical and adult-use cannabis regulatory compliance experience. Under Mr. Day’s
guidance our Company has never failed an inspection and has never faced a disciplinary action
by any regulatory body. He will be a key member of our Fresno mobilization plan.
Kevin Slaughter, JD, serves as our Company legal counsel. He has over 2 years working
as general counsel for our affiliated cannabis businesses. He is currently an attorney at Levenfeld
Pearlstein, he helped start their cannabis practice and is the lead counsel to all their cannabis
clients. His experience in navigating state-wide rules and regulations for limited license cannabis
proves as an invaluable resource to our Company’s growth in the industry.
Fawn Pettigrew, serves as our Director of Government & Regulatory Affairs. She has
over 18 years of government regulatory affairs experience. She utilizes grassroot strategies to
protect and enhance our Company’s brand image when dealing with local government officials.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
32
All products that are sold to dispensaries will have been tested by an independent
laboratory approved by the City Manager and State of California. All test results will be
available for customer display at the dispensary that holds our products. This maintains
transparency between the dispensary and those that are looking for various forms of relief for
cannabis.
Our in-house regulatory compliance team is one of the best in the cannabis industry and
has always steered our business to being fully compliant, no matter the state. In every
jurisdiction, our Company has exceeded regulatory mandates to gain entry into a licensed market
and has maintained licensure by elevating its facilities to be the gold standard in cannabis
business operations. All will take continuing education courses, to understand any compliance
rule changes. We will be a market leader in Fresno in terms of product, compliance and customer
satisfaction.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
33
1.9 FULLY DESCRIBE THE DAY-TO-DAY OPERATIONS IF YOU ARE
APPLYING FOR A CULTIVATION PERMIT.
Per SEC9-3312(a)(8), all applicants for a cultivation permit shall submit the following in
addition to the information generally otherwise required for a community cannabis business
permit:
(i) A cultivation and operations plan that meets or exceeds minimum legal standards for
water usage, conservation and use; drainage, runoff, and erosion control; watershed
and habitat protection; and proper storage of fertilizers, pesticides and other regulated
products to be used on the parcel, and a description of the cultivation activities
(indoor, mixed-light) and schedule of activities during each month of growing and
harvesting, or explanation of growth cycles and anticipated harvesting schedules for
all-season harvesting (indoor, mixed light).
(ii) A description of a legal water source, irrigation plan, and projected water use.
(iii) Identification of the source of electrical power and plan for compliance with
applicable Building Codes and related codes
(iv) Plan for addressing public nuisances that may derive from the cultivation site
Cultivation Spaces and Environmental Controls
The following represents the overall approach of our cultivation operations. We strive to
create a growing environment tailored to the needs of our various cannabis cultivars. Typical
controllable environmental factors include:
Atmospheric CO2 rates
• Vegetative plants should maintain a CO2 level of 400-600 PPMs.
• Flowering should achieve 600-1500 PPMs, dependent on phase in cycle.
Temperature
• Temperatures should be kept between 72-78 degrees Fahrenheit.
Humidity
• Humidity must be maintained between 30-60% depending on stage of growth.
Adequate light levels
• Vegetative plants should maintain a schedule of 18 hours of light/ 6 hours of darkness.
• Vegetative plants should maintain a light level of 600 PAR – 1200 PAR depending on
stage of growth.
• Flowering plants should maintain a schedule of 12 hours of light/ 12 hours of darkness.
• Flowering plants should maintain a light level of 1200 PAR – 1700 PAR depending on
stage of growth.
Airflow
• Adequate airflow within a grow area should maintain constant loop action under a
positive pressure atmosphere.
Irrigation/ Fertilization plants are to be:
• Irrigated to maintain a proper PH balance of 6.8.
• Irrigated to ensure even moisture content throughout substrate.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
34
• Fertigated in accordance to phase of growth.
The maintenance of these parameters, and the ability to adjust them to address specific
plant needs, is essential for the healthy growth of cannabis. Based on similar systems, our
Company has created at our other grow facilities, we will implement state-of-the-art technology
to monitor and control these variables, including the atmospheric, temperature, humidity, light,
airflow, and irrigation aspects of the proposed growing areas. This technology will consist of
both software and hardware, with advanced functions to remotely and automatically control
fully-integrated equipment, coupled with monitoring and alarming system functionality and the
ability to comprehensively acquire, manage, and act upon collected data points.
In particular, in Fresno we plan to implement a Link 4 ionic controls system for multi-
feed fertigation and environmental monitoring and controls. Developed for large scale
commercial greenhouses, the iPonic 600 Series (unlike many alternatives in the market) controls
all grow room functions at once in a single intelligent controller. We will use the iPonic to
monitor, record and to regulate temperature, humidity, ventilation, lighting and water supply.
All regulators and environmental control systems for carbon dioxide emissions will be
inspected regularly to ensure good working order. All airflow into the growing spaces will be
filtered to remove rogue pollen, insects and airborne contaminants. To control potential
contamination with pathogenic organisms, we will use a mechanically propelled air intake
system with a filter capable of removing 99.7% of particles in diameter of 0.3 micrometers.
Propagation and Cloning Methods
Initial propagation and phenotypical selection: Within 30 days of being deemed
operational by the City Manager, we will obtain seeds or immature plants from our other
licensed and certified cultivation facilities for the purpose of securing our start-up inventory.
Sourcing some from our own operations and other reliable breeders with whom we have worked
will help us ensure the integrity and genetics of our seeds and immature plants.
Plants will be free of pests and disease to ensure healthy growth and will be inspected
weekly by a cultivation agent. Each production area will be maintained free of debris.
At the time of planting, all seedlings, clones and plants will be accounted for as a batch
with a unique batch number that will remain with the batch through final packaging. A batch
number will be assigned at the time of planting for a specific number of plants. When our plants
reach 6 inches in height, a specific number will be assigned for each plant within that batch and
the individual tag will be recorded electronically (RFID) or kept in an electronic file until harvest
or destruction. The batch number will remain with the segregated plants through harvest to final
packaging. The batch number will be included on the label of the package distributed for the
purchaser.
We will start off our strain base by germinating seeds of specific cultivars. When
producing new genetics from seed, we will germinate 100 or more seedlings to ensure desirable
phenotypical variety. Assuming half the planted seeds will be male, our trained cultivation
agents will be knowledgeable on propagation procedures, will still have a large number of
female plants to pheno-hunt, choosing the phenotypes with the most desirable traits. The latter is
key to successful and profitable products. Factors to be considered when selecting phenotypes
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
35
are plant structure; resistance to pests and
diseases; potency value; consistent terpene
profile; and length of flowering cycle.
Once the optimal phenotypes have
been selected from each strain, we will
designate five mother plants per strain, and
begin structuring them for the cloning
process. These plants will also be officially
documented as a cloning source in METRC
or BioTrackTHC – our Inventory Tracking
Systems (ITS) and assigned a unique barcode
identifier, which will help trace the lineage of
all clone batches produced from the mother plant. All mother plants will be transplanted into 10-
inch smart pots. These pots are designed to use air pruning technology to continuously expose
the tips of the roots to air, preventing the plant from becoming root bound.
When the mother plants reach a mature age and size such that cuttings are readily
available, the cloning process can begin. At this point, each mother plant will receive biweekly
“Trims” to ensure healthy vegetative production in large enough quantities to create a whole
batch of 115 clones. This includes practices such as pruning, FIMing, Topping, and plant-
specific structuring. To maintain the integrity of each phenotype and avoid genetic drift, mother
plants will be regenerated and replaced on a six-month basis.
Cuttings from lower branches of select female plants will be used for vegetative
propagation using a fresh segment of a branch containing at least 3 nodal segments. For soil
propagation, the cut should be from a soft apical branch at a 45 degree angle, directly below the
node, then immediately dipped in distilled water to avoid any air bubbles from traveling up the
stem, then dipped in a hormone solution and planted directly into the medium. Micropropagation
of shoot tips, axillary buds and nodal cuttings generally maintain their genetic fidelity. Care is
taken because use of plant growth regulators and prolonged cultivation of the plant can result in
somaclonal variation.
Cloning: Based on experience operating
comparable operations, we have chosen cloning
as our method of propagation for the production
of plants. This best achieves a consistent end
product consumers can depend on. Genetically
identical clones also have well-characterized
growth habits and output, ensuring steady and
predictable harvests.
We will utilize aeroponic cultivation or
similar methods (for example, humidity dome,
plant tissue culture method, etc.) to create our
cannabis clones. Aeroponics will be our main method of propagation, although we may employ
other methods as needed. Aeroponic plant cloning machines, such as the EZ cloner “Low Pro
Clones in Clonex Machine
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
36
128,” which can house a whole batch of clones, will be used to incubate clones. (Please see
example pictures within this section).
The propagation area will be set up with racks that support suspended lighting about 18
inches over the aeroponic machine. Four-foot LED bulbs will be used because their light
spectrum is most conducive for root development and vegetative growth. Lights will be placed
on a 18-24-hour light cycle using a timing apparatus.
The clone machines will be filled with dechlorinated/dechloraminated water and Clonex
rooting hormone solution at 200 parts per million (ppm) and aerated with bubblers. The pH
levels will be strictly monitored and maintained at 5.5. Once a machine is set up, an agent will
take cuttings from the desired mother plant. Each cutting should be approximately 3 to 5 inches
long with 2 to 4 leaves on the top. If the leaves are medium to large in size, the cultivation agent
will trim off half of each leaf. This is because the cutting only requires a small leaf area to absorb
a sufficient amount of light to keep it alive.
Also, because the cutting will not yet have a root
structure, the leaves are sustained by the amount of
moisture held in the stem. If the leaves are smaller, the
cutting does not have to work as hard to supply moisture,
allowing the cutting to focus its energy on “producing
roots.”
After the cuttings have been taken, they will be
immediately placed into the plugs, or small holes on the
lid of the cloning machine. Daily maintenance will be
required to check water level inside of aeroponics box.
Cultivation agents will monitor and note observations
daily in the “Batch Production logbook” or our iPad
equivalent. The cloning machines will be cleaned
regularly, including in between each clone batch, to
prevent the spread of disease and pathogens.
As batches of clones are physically created, they will be entered in our ITS. The entire
batch will receive a unique barcode number. This number will correlate the batch back to the
mother plant from which the cuttings were taken. Data entry from this stage forward will follow
each individual plant through processing, the analysis of which allows us to optimize
productivity. To that end, Cultivation Agents will input information about the plant’s cultivation
history into our Inventory Tracking System, which will document, among other things, testing
and data collection for all plants and containers on a weekly basis.
The operational process of cultivating the plant from its clone phase into vegetative
growth will take approximately 1-2 weeks. During this time, the clones will be quarantined from
all other plants to avoid transmission of any potential disease or pest. When the Cultivation
Agents observe that the clones are displaying sufficient root growth to graduate out of the clone
machine, they will transfer the clones into a soil medium and securely move them to the grow
rooms designated for vegetative growth. The clones selected for transfer to the vegetative grow
room will designate a particular “Batch” and will be assigned a unique Batch identifier that shall
Clone Plugs
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
37
remain final packaging. That unique Batch identifier will be documented in our inventory
management system.
MATERIALS, SETUPS, AND METHODS FOR VEGETATIVE AND FLOWER
GROWTH
I. Vegetative Growth
Once a batch of clones has developed roots, it will be transplanted to 4-inch plastic pots,
and each plant will become an individual entity. At this time, each individual plant will be tagged
with a unique identifier assigned by our Inventory Tracking System. This identifying number
allows us to track plants throughout their life cycle from the mother plant to the finished product.
Growing Medium: Cannabis prefers neutral to alkaline loamy and sandy soils with good
water-retention, not subject to water logging. We can enhance the plants nutrients by using a
customized mix of Coco Coir or Expanded Clay Pellets with majority soil. The ideal pH is 6.5-
7.2, lowering for clones that do not yet have roots established. Hydroponic systems call for a 5.5-
5.8 pH range depending on varietal. Once the immature plants have developed roots they will be
placed in an organically certified soil container less than 4-inch.
From our experience, soil has a broad spectrum of nutrients contributing to the health and
growth rate of the plants. It also provides a home for microflora and microfauna not found in
other mediums; these organisms enhance soil aggregation and porosity, thereby increasing
nutrient infiltration and reducing runoff. We plan to use an automatic nutrient injection system,
where we can carefully administer nutrients, discussed further below, together with regular soil-
testing such that our Cultivation Agents adjust the nutrient levels to maximize both the plant yield
at the harvest stage, and the terpene profile that results in optimum potency efficacy. Our agents
will be able to recycle soil for future cultivation cycles, ultimately saving on soil expenses and
implementing our environmental plan. Our automatic nutrient injector system eliminates human
error and ensures consistent delivery of proper nutrients at all times. Coupled with proprietary
fertilizer concentrates, these fertigation systems are, in our experience, one of the most efficient
and cost-effective solutions in the industry. Every soil test and application of fertilizer is logged
and saved in our system for review at any time by our staff or the City Manager or other
agencies. To save on soil disposal and waste, we plant to recycle as much as we can and provide
our local urban farming partner, Eden Place, with our used soil for the development of their
crops.
Lighting: Once clone batches are broken out into groups of individual plants, they will be
moved from propagation rooms to vegetative rooms. These rooms will be equipped with high
quality LED bulbs, placed 5 feet apart, in four to five rows of 5 each. LED bulbs emit a
preferable spectrum of light for vegetative growing and are a sustainable alternative.
Lights will be suspended from height adjustable beams directly over growing tables,
allowing cultivation agents to adjust the light intensity as the canopy height grows taller. Light
intensity will also be adjustable per ballast via the Link4 control system.
To encourage proper growth habits during the vegetative phase, the Cultivation Agents
will control light and temperature conditions to mimic natural summertime growth. Agents will
aim to maintain approximately 18 hours of light and 6 hours of darkness (the “vegetative
photoperiod”) for 3-6 weeks to maximize the plants’ growth potential. The effect of long days
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
38
and short nights on the plant’s hormone balance will ensure the vegetative growth habit. We
expect to have approximately 1/6th of the grow spaces in the facility at any one time devoted to
the creation and maintenance of this vegetative growth habit.
Containers: As their root systems continue to develop during the vegetative growth
phase, plants will be transplanted into a series of different sized pots roughly every 2-3 weeks.
This method is called plant staging and allows the plant to receive adequate volumes of water
while maintaining quick and healthy root development. Initially the plants will be placed from
the cloning machine into 4-inch pots until they develop four nodes worth of new vegetative
growth (2 weeks). From there, cultivation agents will inspect the root development; if the plant
has matured properly, it will be transplanted into 1-gallon pots. Each week, the concentration of
nutrients used will increase with the increase in plant size, described below. After the plant has
had sufficient root development such that roots are reaching the bottom of the pot (2 weeks),
they will be transplanted into their third and final container, the 8-10-gallon smart pots in the
indoor systems.
Irrigation: Irrigation will be controlled and only applied according to the actual needs of
the cannabis plant. Overwatering will be avoided because we will use an automated water drip
system with automatic shut off once soil moisture levels are oversaturate, all controlled by our
iPonic 600 system. The optimal amount and frequency of watering depends on various factors,
including environment, variety and growth stage.
Soil will be kept evenly moist during early seedling and vegetative stages. In mature
plants, the top layer of soil should be allowed to dry out before watering. The water used will
contain as few contaminants as possible including metals, and other toxicologically hazardous
substances sometimes present in historically
agricultural dominated regions. Thorough
water analysis will be performed seasonally
to continually assess water quality.
We intend to utilize a water filtration
system, such as a HyperLogic reverse
osmosis and/or charcoal filtration system to
improve water quality and ensure that
nutrients will be available to the plants
during all stages of growth. Once water
enters these systems, it continues to loop
between filtration/cleaning and usage to the
best of the facility’s ability to achieve the
quality needed to be reused in subsequent
watering rounds. This will allow our
cultivation facility to save over 80% in water
consumption -- close to 5.8 million
gallons/year. For production wastes that
cannot be eliminated, we will make every
attempt to recycle to the extent it is
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
39
economically feasible. All wastes that leave the facility will be disposed of in a manner
consistent with state and federal law. Please see a diagram of our water filtration system.
Our fertigation system will be automated and controlled by the iPonic 600 environmental
system. It will utilize a dual injection system for efficient uptake of nutrients within each grow
room, as well as large reservoir mixing tanks for fertilizer to be ready made. Reservoirs will be
connected to an A B valve system, allowing cultivators to choose between fertigation and
irrigation, depending on the plant’s needs. Moisture sensors and pick emitters will work
simultaneously to ensure plants are obtaining moisture when necessary and are evenly watered
on a plant by plant basis.
We will utilize the automated feature of the iPonic 600 system to consistently water at
proper times in the day to ensure enough dry time, lowering risk of pest and disease problems
while ensuring healthy growth. The system will also use temperature gauges in all water tanks to
ensure proper mixture of hot and cold water before applying to grow media.
The water source is tested regularly, including:
• a comprehensive analysis of the water quality by a local water consultant prior to the
commencement of full-scale operations, and then subsequently on a weekly basis, to
ensure acceptable levels (ppm) of among other things: microbes; sodium; nitrates;
fluoride; hardness; lead; heavy metals; and
• monitoring of temperature and pH of water in the mobile water collection tanks,
conducted by Cultivation Agents prior to plant watering.
Irrigation lines will be regularly flushed to avoid buildup of nutrients and other materials.
Floor drains will be lined with material resistant to molds/mildew to prevent plant contamination.
The drains will be covered but allow easy access for regular cleaning. Our facility will have
water supply that is sufficient for the operations to cultivate cannabis products and will be
derived from a regulated water system. Private water supplies will be derived from a water
source that is capable of providing a safe, potable and adequate supply of water to meet the
facility’s needs. All plumbing will be of adequate size and design and adequately installed and
maintained to carry sufficient quantities of water to required for our facility. Our COO and
construction team will ensure our sewage is properly conveyed for liquid disposable waste and
there will be NO cross-connections between the potable and wastewater lines, pursuant to the
Fresno or California Plumbing Code.
Structuring: Vegetative plants will be structured or trained based on the specific strain
and its growth structure. Typically, all plants will be pinched of FIMed at least once during the
vegetative phase to deter apical dominance. This method leads to more conducive trellising or
plant structuring during the flowering phase. Instead of each plant having one main cola, it will
have multiple, allowing for a larger yield per plant. Structuring is implemented to utilize the
entire growing area and to ensure that plants have as much exposure to the grow lights as
possible.
II. Flowering Growth
Once the plants have reached the optimal height, root growth, and stalk thickness,
Agents will securely transfer satisfactory plants from vegetative grow rooms to flower grow
rooms, or, alternatively, modify the room control to accommodate flower growth. All transfers
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
40
will be logged in METRC. The timing of this graduation varies by strain and intended plant and
canopy shape (e.g., “sea of green” vs. “screen of green”).
Because each grow room is independently controlled, the transfer of a Batch from a
vegetative grow room to a flowering grow room – or, in the alternative, the calibration of timers
and controls transforming a vegetative grow room into a flowering room without the movement
of plants – will be individually determined by the Cultivation Agents according to each batch’s
respective need. Batches will not be intermingled within any grow room or growth phase.
Integrated Pest Management: At this phase of growth, cultivation agents will conduct
pest inspections every day to ensure there is no visible mold, mildew, pests, rot, or grey or black
plant material greater than an acceptable level. We will utilize pest cards or insect “sticky cards”
that are changed out every 5 days or as needed, to gain better understanding of pests and their
population developments. Our rule of thumb is one card will be used per every four plants.
Each inspection and all action to detect pests and pathogens, as well as appropriate
remedial measures, if any, will be logged and recorded into our system. Aggressive pest
inspection and detection is required, as the window for applying approved products, and non-
chemical treatments closes during the flowering phase. This is because the flowers develop a
sticky residue around 3-5 weeks into flowering, making it impossible to wash off residue without
increasing susceptibility to molds. Appropriately treated plants and early pest detection are the
key to integrated pest management. We further explain our IPM in greater detail in this Exhibit
below.
Lighting: As they did in the vegetative grow rooms, Cultivation Agents will again
manipulate light and temperature conditions in the flower grow rooms that mimic the seasonal
conditions, which allow the plants to begin exhibiting their flowering growth habit (i.e., when the
days become shorter and nights longer). Cultivation Agents will aim to create and maintain
conditions generally following an alternating pattern of 12 hours of light followed by 12 hours of
darkness, allowing plants to flower to maturity and reach their full potential.
Nutrients and Feeding Schedules: We will be utilizing all Organic Materials Review
Institute (ORMI) certified liquid fertilizers, such as the “West Coast Horticulture” line of liquid
nutrients. We will supplement fertilization with regular application of all-natural and organic
compost tea. The compost tea will be brewed onsite weekly in a specific brewing area, away
from contaminants. Compost tea and extracts can be applied by both hand-watering or foliar
feeding, depending on conditions.
Feeding schedules for each strain or grow room will be planned at the beginning of their
vegetative phase to ensure the plants receive proper nutrients at every given point in their life
cycle. We will be using phase-specific nutrients, so during the vegetative phase we will
implement a feeding regimen that uses higher levels of nitrogen to support plant and root growth.
During the flower phase, we will switch to a feeding regimen that supports the development of
flower buds, as opposed to the growth of the total plant.
Every watering or fertilization will be logged daily by cultivation agents into the “Plant
Input log.” Information such as volume of water used, time of watering, length of irrigation
period, amendments used, and quantity applied will all be logged and filed on site for a minimum
of five years, in both physical and digital formats.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
41
The initial feeding schedule, determined by the Cultivation Manager, will be used as a
guide by all Agents. Schedules are always subject to change given the plants developmental rate
and different environmental factors. We will be able to tailor each feeding to the plant’s specific
needs as necessary. A record of all crop inputs will be maintained for five years in our facility
and records will include: the date of application; the name of the individual making the
application; the product that was applied; the section, including the square footage, that receive
the application (by group number); the amount of product that was applied; and a copy of the
label of the product applied.
Fertigation: During the life cycle, Cultivation Agents will inspect and test the soil pH,
micronutrient and nutrient levels at regular intervals during the week. If they determine that the
pH of the root zone is excessive, they will raise or lower the pH of the water to shift the root
zone pH gradually closer to 6.4. This can be done with diatomaceous earth which allows us to
avoid the use of chemicals as well as provide pest relief. The nutrient uptake changes when the
plants move to the flower stage, and it is critical to ensure the biology of the soil is suitable for
that stage of growth. The nutritional needs of the plant will change as the plants progress in their
life cycle.
Canopy Management: Cultivation Agents working in the flower grow rooms will monitor
and shape the canopy to capture all available light, thereby ensuring maximum growth, quality,
and production. We will trellis our plants appropriately, depending on the cultivar. Certain
cultivars of cannabis produce higher yield when managed under the “Sea of Green” (SOG)
methodology, while other strains yield better when managed under the “Screen of Green”
(SCROG) methodology or via individual trellising. Under SOG, there is high plant density, with
around one plant per square foot.
Humidity: Relative humidity plays a crucial role in plant growth. Immature plants require
high humidity upwards of 75% Relative Humidity (RH). Vegetative cuttings require regular
foliar feeds to maintain a high humidity in their microclimates until they are well rooted. The
active and vegetative flowering stages typically require 55%-60% RH, while flowering plants
entering the last 2-3 weeks of bloom require varying degrees of humidity. Indica dominated
varieties need 40%-55% RH, while sativas can tolerate more moisture.
Temperature and Carbon Dioxide: Within indoor systems, it is ideal to cultivate between
73-77 degrees Fahrenheit; realistically, however given environmental and economic factors, the
range can be 63-85 degrees.
Increased ambient carbon dioxide levels stimulate both photosynthesis and water use
efficiency in cannabis, resulting in increased growth. CO2 enrichments will be made in our
indoor environment. These methods can also increase batch yield by up to 50% compared to
utilizing the plants natural growing structure. Recycled plastic or hemp plastic netting is used to
train plant growth to fill out canopy space.
Plants will vegetate for approximately 3-6 weeks and flowered at a density of around 1
plant per 2-3 square feet. Plant branches are trained to form a nice even canopy, maximizing the
amount of artificial light that can be absorbed by plant canopy.
Harvest: Cannabis plants will remain in the Flower Grow Rooms for approximately 7-12
weeks, depending on the strain and its necessary environment. During that time, they will grow
to the appropriate point for harvest. The best way to determine a plant’s harvest window (i.e., the
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
42
most opportune time in the plant’s development) is by checking the color and development of the
trichomes, or plant glands. At early stages, the trichomes will appear to be clear, but as they get
closer to harvest time, they will gain a milky white appearance. Often times if the trichomes turn
an amber or brown color, the plants have over-developed and the cannabinoid and terpene
contents will begin to diminish. The Cultivation Manger will use trichome development to
determine the best time to initiate the flushing period. Approximately one week from harvest,
Agents will pull large fan leaves from every plant to ensure even drying without mold
development.
We never use any additional active ingredients or materials that alter the color,
appearance, smell, taste, effect or weight of the cannabis plants. To properly harvest our plants
and to have access to our entire canopy we will make sure each production area will maintain an
open aisle on all sides of each plant group to allow for unobstructed travel, observation and
inventory of each plant group. Our grow rooms will have rolling benches that our agents can
easily move to ensure access and reach to all plants in production areas.
On the day of harvest, our cultivation team will remove netting from SOG or SCROG
growing material. During this phase, agents will work in the Flower Grow Rooms to cut the plant
down at the base of the stalk. After taking the weights of the whole wet plants and tagging each
stalk, they then securely transport the plant to a Drying Room.
Wet weights will be recorded in both our batch production records and METRC.
Consistent with the plants’ segregation and maintenance in uniquely identified Batches in the
Vegetative and Flower Grow Rooms, Batch-determined segregation will also be maintained in
the plants’ transfer to their respective Drying Rooms. Having Batch-determined segregation in
separate Rooms serves to prevent any potential contaminants across Batches.
Harvest is accomplished by clipping a bud-filled stem from a plant, removing the bud
from the stem, and then removing the large leaves from the bud followed by the smaller leaves
and stems. Agents will visually inspect the harvested plant material to ensure there is no visible
mold, mildew, pests, rot, or grey or black plant material greater than an acceptable level as
determined by the City Manager.
Drying, Curing and Trimming
Drying: Our facility will feature specially designed climate controlled Drying Rooms. In
our facility’s life cycle, we will have multiple Drying Rooms to separate our harvest cycles due to the
amount of product we plan to produce right away. The Drying Rooms are specifically designed to
prevent the development of mold, mildew, fungus, and cross-contamination between plants, i.e.,
by permitting us to maintain a constant temperature and humidity to slow dry plant material over
seven to ten days, which also helps preserve the qualities of the plant matter. The net effect is
accomplished through a combination of mechanical units and is unique because it allows our
cultivators to observe the plant matter and determine appropriate dryness, responding and
adjusting accordingly.
Specifically, the drying rooms will be equipped with a mini-split air conditioner system for
cooling, controlled by a factory thermostat. The evaporation fan will operate continuously when
the drying room contains a Batch of cannabis. The cooling unit is designed in a way to cycle on
and off as needed to maintain the space temperature between 68 to 72 degrees Fahrenheit. To
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
43
maintain proper humidity, a dehumidification system will be utilized to cycle on and off to
maintain the room relative humidity below 45:1 ratio, or 40% to 50% relative humidity. This
system is also controllable by our cultivation agents. To balance the temperature of the drying
room, an electric heater will be mounted to cycle heat into the room, as needed. The heater fan
will cycle on and off to reach the desired temperature. The heater is adjustable as well, allowing
our cultivation agents to respond accordingly, if needed. Finally, the Drying Rooms are outfitted
with moisture resistant wallboard, further enhancing their climate control capabilities. Cultivation
agents will document the drying process using the inventory management function of METRC.
Curing: The particular extraction method used for a given Batch will determine whether
curing is necessary. When it is, cultivation agents will remove the flowers and buds from the
plants and then transfer them into the curing process, which will employ large glass containers.
The cultivation employees will then seal the containers and initiate the curing process,
which will take approximately one to two weeks. At the conclusion of the curing, the output of
each Batch will be weighed and inventoried, and then forwarded to the Trimming Rooms for
further processing.
Trimming: Removal of dead or fan leaves will generally occur during pruning in the
vegetative and harvest phases. Our harvest staff will separate the bi-product (stems, disease
material or pest ridden material) from the soon to be packaged material, and process the flowers
by freezing or processing immediately. All our flower will be hand trimmed, allowing each
flowering bud to be handled and inspected before final storage and packaging. We plan to hire full
time and part time downstream agents to hand-trim all flowers, depending on volume and staff
capacity.
Pre-processing
We will only process the parts of the cannabis plant that are free of seeds and stems, dirt,
sand, debris and other foreign matter and that do not contain a level of mold, rot or other fungus
or bacterial diseases acceptable to the City Manager. We will only process cannabis plants in a
safe and sanitary manner. Please see our processing procedures further in this Exhibit.
Products Offered
We plan on operating an efficient premiere Fresno CCB that produces a broad range of
premium, high quality cannabis products, including: dried flower, vapes (pre-loaded and
disposable), edibles, topicals, oils, concentrates, transdermal patches in CBD and THC products
and any other allowable form of product. Our staff will be knowledgeable about all forms and
will be trained about the pros and cons of each form.
We will only sell our products to Fresno licensed dispensaries after being tested and
meeting all general testing requirements. With the City Manager’s approval, we will offer for
sale, or provide to dispensaries an online Customer Relationship Management platform where
licensed dispensaries can see our inventory and dates of what products will be on our menu. Not
only will we sell cannabis products, we will also sell Viola branded merchandise such as t-shirts,
sweatshirts, hoodies, hats so our brand supports can support our business and brand without
using. We will donate 5% to 10% of all Company merchandise sold to local community
organizations as part of our Fresno Community Impact Fund (FCIF).
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
44
Products Produced from the Various Strains: We will provide a variety of cannabis
products, taking advantage of differing properties of the Sativa and Indica plants. Sativas tend to
produce stimulating and energizing feelings and can have the following therapeutic effects:
increased sense of well-being; focus; creativity; reduced depression; elevated mood; relief from
headaches/migraines/nausea; and, increased appetite. Indicas tend to produce sedated feelings,
and many refer it for nighttime use. Some therapeutic effects include: relaxation/reduces stress;
relaxed muscles/spasms; reduced pain/inflammation/headaches/migraines; help with sleep;
reduced anxiety; reduced nausea; stimulated appetite; reduced intraocular pressure; reduced
seizure frequency/anti-convulsant.
Individual strains have differing cannabinoid and terpene content that will produce
noticeably different effects. There are more than 100 cannabinoids found in cannabis.
Cannabinoids like THC and CBD are usually present in the highest concentrations and are
therefore the most recognized and studied. CBD and THC levels tend to vary among different
plants and they each have their own unique medical benefits.
Terpenes are the aromatic oils secreted in cannabis resin that impact the effects of the
cannabinoids. They have their own set of benefits as well. We plan to highlight terpene ratios on
our packaging, allowing customers to see all percentages and ratios. We will use a variety of
cultivars to create products that have been shown to have the most benefit for the Fresno market.
As our business develops, we will be able to tailor our plants to closely align with the needs and
desires of our purchaser base. For example, if there is a great need for Indicas or CBD dominant
strains, we will be able to produce what is in the highest demand.
Strains We Plan on Cultivating: To produce a high-quality product and to get maximum
yields we will source great genetics. Many times genetics will determine total yield as certain
cultivar’s tend to produce more yield that others, just as various strains produce different levels
of THCA and CBD from others. The flower must be of utmost quality and is evaluated by the
purchaser by a few organoleptic characterizations including aroma, color, taste and mouth feel.
Unlike other crops which may be eaten but not smoked or dried but never consumed, raw
cannabis can be consumed via inhalation and digestion. Hence, it’s imperative the crop be clean,
organic and all natural.
Cultivar profiles can be found below and once fully operational we will produce an
assortment of cannabis products from these genetics.
Our first grow cycle will produce 5 strains of cannabis, while our seed bank will consist
of 100 strain types. Having a robust seed bank allows variety for purchasers and for our research
team to conduct customer trails on what strains help for various issues.
We will produce a variety of THC and CBD strains. We want to cultivate strains that are
proven to be successful in our other locations as well as fill in product gaps that the others do not
cultivate.
Below is a list of strains with their cannabinoid profile and conditions to help with relief.
Our research and development team noticed strain gaps in the market and will introduce 10
strains in our first 3 to 4 harvest and 5 at a time per harvest.
• Banana Kush (THC/THCA 18%-20% / Indica): Used for pain relief, appetite
stimulation and anti-inflammatory.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
45
• Sour Diesel (THC/THCA 20%-25% Sativa): Used for pain relief, appetite
stimulation and anti-inflammatory.
• Calabasas Kush (THC/THCA 20%-24% Indica): Used for appetite stimulation and
pain relief, migraines, muscle spasms and pain relief.
• Cali Cake (THC/THCA 23%-27% Hybrid): Used for pain relief and appetite
stimulation.
• Chocolate Glue (THC/THCA 26%-30% Hybrid): Used for pain relief, muscle
spasms and anti-inflammatory.
• Orange Cream (THC/THCA 18%-22% Hybrid / Indica dominant): Used for pain
relief and migraines.
• Purple Punch (THC/THCA 18%-20%, CBD 1% Hybrid / Indica dominant): Used
for pain relief, appetite stimulation and anti-inflammatory.
• Super Jack (THC/THCA 22%-26% Sativa): Used for pain relief and appetite
stimulation.
• Harle-Tsu – (THC/THCA 1%, CBD 20%-24% Hybrid): Used for pain relief and
anxiety.
• ACDC – (THC/THCA 1%, CBD 18-22% Hybrid / Sativa dominant): Used for pain
relief, anxiety and anti-inflammatory.
We will take a scientific approach to strain selection; we will NOT select strains based
on “cool” names, popular marketing campaigns or only select strains with the highest amounts of
THC. Strains will be selected by how well that strain responds to the Fresno climate, consistency
of the genetics and how much a strain can yield per plant.
While we cannot market our products as medicine, our consumers will understand the
medicinal values of our products. We believe many cultivators will not produce CBD products
because of the limited canopy space and its typically a lower margin product. Viola owns two
CBD / Hemp brands that we will introduce to the Fresno market. A significant proportion of our
canopy space (roughly 20%) will be devoted to the production of high-quality CBD
(cannabidiol) plants, with the other 80% consisting of high-quality THC plants. All of our strains
will be submitted to the City Manager and will be grown subject to approval.
CBD Dominant Strains: Our Company has cultivated and produced multiple CBD strains
in at our facilities in Colorado and Oregon, and we have gravitated toward those associated with
the most potency, quality and value. As with the THC strains, we have developed mastery in
cultivating these strains, meaning we will have high-quality cannabis in production at all times.
Our CBD brands Harrington Wellness and Replay are very popular to customers with active
lifestyles, based on quicker recovery. Our co-founder, Al Harrington, used many of these
products while recovering from knee surgeries and other ailments while playing professional
basketball.
We believe in categorizing our CBD dominant strains in three major tiers (Upper,
Middle, Lower) based on the total CBD, CBD-A, CBN percentages and ratios to THC. As with
the THC strains, this categorization allows consumers at the dispensary to select cannabis
products based on quality as opposed to enticing names. No matter the tier all our products will
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
46
be produced with the same quality standards. We believe the above strains have superior potency
levels, along with desirable aromas, taste, and terpene ratios.
THC Dominant Strains: We categorize our THC dominant strains in three major tiers,
(Upper, Middle, Lower) based on the total THC (Delta-9) and THC-A percentages. No matter
the tier, all our products will be produced to the same high-quality standards.
We have cultivated numerous THC strains, and we have focused over time and become
experts in cultivating those described below. We believe all the above strains have dominant
values along with great aromas, taste, and terpene ratios, make excellent cannabis products and
are unique to our genetics.
Nutrient Introduction
Our Company’s nutrient management plan was developed by our COO and Director of
Cultivation, and it aims to minimize adverse effects on the environment and to optimize
production and maximize profit. We understand that mismanagement of nutrients can lead to
contamination of ground water, contamination of surface water, undesired changed in soil
nutrient status, nutrient application to non-target land, accumulation of non-nutrient impurities in
the soil profile, excess stocking rate, and poor cultivation methods. We will seek out a local
licensed engineer to design our wastewater treatment plan as well as our water management plan.
By focusing on the biology of the soil and monitoring our water to make sure that it is
free of contaminants we can mitigate costs that would otherwise be devoted to conventional
fertilizers. We find that by focusing on starting with good healthy soil full of balanced microbial
life, compost teas and extracts and careful observation we can produce a cleaner finished product
for our consumer and the environment, keep costs low to pass those saving to our consumers.
Nevertheless, a commercial size cultivation facility will naturally have larger amounts of
amendments, soil, organic fertilizers like glacial rock dust and fish emulsion that if mismanaged
can present a threat to the ecosystem and local community. By keeping careful stock of our
inventory and ordering limited amounts in smaller batches we are able to store less on site. These
products are stored in a secure location, more than 50 feet from any drain or waterway access
point, in water safe containers.
As described in more detail below, it is our experience that cannabis plant nutrition is a
complicated but vital component to the development of high-quality products. As we have done
with our branded products, we will implement in Fresno a comprehensive, safe, organic and
effective cannabis nutrient and additive program for safe and effective plant growth, and that
meets all of the requirements for cultivation and processing of cannabis.
Soil and Plant Testing: Establishing and maintaining the right balance of mineral
nutrients is key to achieving the optimum biological and physical condition for the soil and
plants. Without the use of scientifically proven protocols to reliably monitor and assess soil
health it is easy to use either too little or too much fertilizer. Too much fertilizer is a waste of
money and can be damaging to the environment, too little may restrict our productivity. We aim
to monitor the soils biology so that we can ensure natural nutrient cycling and move away from
reliance on amendments and fertilizers. This is done through effective staff and agent training,
identification and specific compost tea blends and compost extracts. Using synthetic or salt-
based fertilizers begins to break down this sensitive balance.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
47
Soil test results can vary, and a single result can be misleading. The best information is
gathered by regular ongoing testing so as to monitor patterns, trends and long-term impacts of
cultivation management decisions.
The following testing methods can be used to assess the soil and plants:
Correct sampling methods are essential. Soil sampling will be conducted prior to planting
and upon selecting new vendors.
Our nutrient and additive practices that take into account the viability and healthy growth
of our cannabis plants, as well as agricultural and environmental sustainability, and the safety of
our facility, of our employees, and of our products. To this end, Viola will utilize only Organic
Materials Review Institute certified liquid fertilizers/nutrients, such as the “West Coast
Horticulture” line of liquid fertilizers/nutrients. We have chosen this line of nutrients because in
our experience organic fertilizers provide exactly what the cannabis plant needs to ensure both a
high yield and a high terpene profile, thus assuring a safe and quality product. Our nutrient and
additive plan involves the administration of a custom blend of OMRI certified fertilizers
throughout the cannabis plant lifecycle. This is done to provide needed nutrients to support the
vigorous and healthy growth of our cannabis plants.
We also supplement fertilization with regular application of all-natural and organic
compost tea up to twice a week, which actually decreases the use of fertilizers available in the
soil for the root system. In our experience, compost tea provides beneficial microbes to the soil,
allowing it to build up a natural defense to pests and diseases while at the same time ensuring
that our cannabis plants are provided with enough nutrients for their entire lifecycle. Compost tea
can be applied by both hand watering, or by foliar feeding, with the head cultivator deciding
which method is most appropriate dependent on a number of variables.
Once our facility is operational, the compost tea will be brewed onsite on a weekly basis
in a specific brewing area away from any contaminants. The tea will be applied every third week
of feeding to ensure a healthy root zone. If it is determined that any cannabis plant or plants
require supplemental feeding – for example, for stem strengthening or for improving root zone
health – the Cultivation Manager can choose to add other OMRI certified additives, such as
silica, to the fertilizing schedule.
Below are details of all nutrient and growth additives that will be utilized at our Fresno
facility. However, with permission of our COO, in consultation with our Director of Cultivation
and Horticulturalists and/or the Cultivation Manager, additional nutrients allowable under the
relevant Fresno rules and regulations, may be included when necessary. We DO NOT believe in
using pesticides as we cultivated using all natural procedures, but if we decide or need to use
pesticides we will follow all state Authorized Pesticides. Our Director of Cultivation and
Soil Assessment Testing Methods
Chemical Tests Physical Tests Biological Tests
pH Aggregate size and stability Soil Organic Matter
Nutrient Status Infiltration Rate Microbial Biomass
Water holding capacity
Soil depth
Texture and drainage
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
48
Cultivation Manger will be familiar with the Fresno approved pesticide list. Below is a list of
natural nutrients and additives our agents may use.
1. Clonex nutrient solution or gel: This rooting hormone can be provided during the early
vegetative stage, such as when taking clones. Parts per million (ppm) should never be
higher than 200 at this stage.
2. Biotiene Rooting powder: The cultivator will simply dip the clone into the powder to
help initial root formation. This should only be used during propagation.
3. West Coast Horticulture Grow 2-1-3: This nutrient will be utilized through the plants
vegetative stage as well as its early flowering stage. It will provide the plant with the
nitrogen, phosphorous, and potassium needed to thrive within its vegetative stage. (Salt
concentrations can be within 100-800ppm)
4. West Coast Horticulture Micronutrients: This mix of liquid micronutrients will be
provided on a monthly basis to ensure that all optimal nutrient levels are achieved.
5. Synergy Compost Tea - Part A and Part B: This two-part mix will be utilized throughout
the entire life cycle of the cannabis plants. It should be provided during transplanting for
easy transition in their new containers. This will also be utilized every third week of the
plants’ growth to ensure a healthy root zone. Compost tea provides roots with beneficial
microbes and bacteria that work to fight against disease and pest problems.
6. CalMag: OMRI certified CalMag is necessary through the vegetative stages to ensure all
nutrients are being provided. This can be utilized following the nutrients’ own feeding
schedule, to maintain healthy levels of Calcium and Magnesium throughout the plant’s
life.
7. West Coast Horticulture Bloom: This fertilizer will be provided when the plant has been
flipped to its flowering stage. The plants will be in need of high potassium and
phosphorous levels that the Bloom can provide. The salt concentrations should be
increased until the first day of flushing. The salt concentrations can reach anywhere
between 800-1500ppm for healthy flower formation.
8. West Coast Horticulture Bloom Booster: Bloom Booster can be utilized when in need. If
the Lead cultivator believes the plants are not taking up enough Phosphorous or
potassium, this nutrient will boost levels to their optimal level.
9. Hygrozyme: This can be utilized if the root zone has reached a stressed stage. This is a
great additive to clean root zones and provide healthy root growth.
Nutrient Feeding Practices
Feeding schedules for each strain or grow room will be planned at the beginning of each
separate vegetative phase. This is done to ensure that all plants, regardless of where they are in
the growth phase, receive the proper nutrients for that particular phase of the life cycle. Based on
our cultivation experience, this phase specific nutrient feeding best supports the healthy growth
of cannabis plants. Briefly, phase specific nutrient feeding works as follows:
• Vegetative Phase: during this phase we implement a feeding regimen that uses higher
levels of Nitrogen to support plant and root growth;
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
49
• Flower Phase: during this phase we switch to a feeding regimen with high
concentrations of phosphorous and potassium for proper flower formation (as
opposed to the growth of the total plant).
The initial feeding schedule, as determined by our Cultivation Manager, will be used as a
guide by all of our Fresno cultivators. Below is a table of the nutrient feeding schedule.
However, it should be noted that varieties and environments, seasonal water quality changes,
temperature and drafts, all act as variables and may require more or less nutrient support.
This initial feeding schedule is subject to change depending on the differing
developmental rates of cannabis plants and on changing environmental factors. Our team has
cultivated upwards of 105 different varieties and have found that Indicas, Sativas and Hybrids
varieties all have slightly different nutritional demands in order to develop into their full
expression. For example, Indica varieties typically require additional magnesium and
phosphorous in bloom. Sativas are prone to rapid growth in the vegetative state and continue to
develop vertically into bloom and therefore silica may be in higher demands for these varieties.
As such, if necessary, our cultivation team will be able to tailor each feeding to the specific
needs of our plants.
In accordance with best nutrient feeding practices, all feeding regimens may be adjusted
to address existing conditions related to any plant or group of plants if such an adjustment is
determined to be required by the cultivation team. Of course, our cultivation team will ensure
that any new feeding elements/nutrients are allowable under the applicable Fresno rules and
regulations. Our Company will ensure that no additional active ingredients or materials will be
added to our cannabis that in any way alters the color, appearance, smell, taste, effect or weight
of the cannabis unless prior written approval is obtained from the City Manager.
Fertigation Practices
Fertigation is the process of injecting fertilizers, soil amendments, nutrients, or other
water-soluble products into an irrigation system. In our experience, a fertigation system is the
most environmentally friendly and sustainable method cultivating high quality and safe cananbis.
We intend to utilize a water filtration system, such as a HyperLogic reverse osmosis system
and/or a charcoal filtration system, to improve water quality and to ensure that nutrients will be
available to the plants during all stages of growth. We will work with a local licensed engineer to
design wastewater treatment plan. As stated above, we plan to send run off or grey water to
reservoirs, and to filter it for re-use in the facility, thereby cutting down on overall cost while at
the same time providing a sustainable alternative to traditional water filtration systems or to
chemical irrigation systems. A licensed hydrologist will work with us to design our wastewater
treatment plan.
Our fertigation system will be automated and controlled using an Argus advanced
environmental control system (a highly customizable system of hardware and software for
irrigation control and nutrient management). It will also utilize a dual injection system for
efficient uptake of nutrients within each grow room, as well as large reservoir mixing tanks that
allow for fertilizer to be ready made. Reservoirs will be connected to an A-B valve system,
allowing cultivators to choose between fertigation and irrigation, depending on the needs of the
particular plants. Moisture sensors and pick emitters will work simultaneously to ensure that
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
50
plants are obtaining moisture when necessary and that they are evenly watered on a plant-by-
plant basis. The automated features of the Argus advanced environmental system will allow our
cultivators to consistently water at proper times during the day, thus ensuring enough dry time,
and thereby not only lowering the risk of disease or pest infestation, but also ensuring healthy
plant growth. The system will also allow for the use of temperature gauges in all water tanks to
ensure proper water temperature before the water is applied.
Irrigation lines will be regularly flushed with natural enzymes to avoid buildup of
nutrients and other materials. Floor drains will be lined with material that is resistant to mold and
mildew to prevent any contamination of our plants. While these drains will be covered, they will
be constructed in such a way as to allow for easy access for regular cleaning. To further prevent
pest and disease problems from entering the facility, these drains will be cleaned out on a weekly
basis, including being disinfected with hydrogen peroxide or another certified natural
disinfectant. Hoses will be provided in each room to allow for hand watering and sanitation when
needed.
During the flower phase, at regular intervals throughout the week, cultivation agents will
inspect and test soil pH, as well as micronutrient and nutrient levels. If a cultivation agent
determines that the pH of the root zone is excessive, they will raise or lower the pH of the water
to shift the root zone pH gradually closer to the optimal level of 6.4. Because the nutrient uptake
changes when cannabis plants move to the flower stage, and it is critical to ensure the biology of
the soil is suitable for that stage of growth, the concentration of fertilizer used will increase as the
plants progress in their life cycle.
All batches of cannabis plants will be flushed for approximately 2 weeks before harvest.
This entails only watering with pH adjusted water for an extended period of time allowing
enough run off to remove any residual fertilizers from the plant structure, roots, and substrate.
Flushing the plants in this way will ensure no residual fertilizer in any of our products and will
eliminate the risk of potential side effects from interactions with un-flushed cannabis flowers,
thus providing the consumer with a safer and more desirable end product.
Record Keeping & Inventory
We will maintain records of the type and amounts of fertilizer and of any growth
additives used in the cultivation process. To this end, our cultivation team will utilize our ITS to
log all additives and nutrients that have been applied to our plants during each phase of the
growth life cycle. In addition to this, every watering or fertilization will be logged daily by a
cultivation agent into the “Plant Input Log,” including information like volume of water used,
time of watering, length of irrigation period, amendments used, pH and salt measurements, and
quantity applied. A “Nutrient Log” will also be formulated by the cultivation agent to ensure that
proper compost tea brewing is occurring. All plants, regardless of accounting strategy, will be
physically inventoried on a weekly basis and records of the inventory will be kept at the facility
for at least 5 years. All records will be made available to the City Manager upon request. Any
removal of plants from the batch will be recorded on a permanent record within our Inventory
Tracking System and maintained on site.
We will keep a record of all crop inputs will be maintained for at least 5 years at the
facility and records will include: the date of application; the name of the individual making the
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
51
application; the product that was applied; the section, including the square footage, that receive
the application (by group number); the amount of product that was applied; and a copy of the
label of the product applied. All records described above will be retained on file at the facility in
both hardcopy and digital formats.
Safe Handling of Fertilizers and Other Chemicals
As indicated above, our nutrient management plan was created based on years of
cultivation experience with an eye to product safety, employee safety, and environmental safety.
As such, our standard operating procedures require that all members of our cultivation team
follow the Safety Data Sheets (SDS) for every product on site. This is required not only to ensure
employee safety but to also ensure the proper and safe distribution of these materials to our
plants, thereby ensuring the safety of our products.
Similarly, all fertilizers, nutrients, additives, and chemicals will be stored in a dry and
cool environment, each in its own fireproof cabinet. All bottles of fertilizer or of plant additive
will be properly labeled per OSHA regulations. Anyone handling fertilizers or other chemicals
will be required to wear protective layers, gloves, a mask, and goggles if needed. We will keep a
record of all crop inputs will be maintained for at least 5 years at the facility and records will
include: the date of application; the name of the individual making the application; the product
that was applied; the section, including the square footage, that receive the application (by group
number); the amount of product that was applied; and a copy of the label of the product applied.
Products are available in different units, and when possible, the precise amount will be
ordered and used immediately for application. Storing large amounts of nutrients, amendments
and soil will be prohibited.
Foliar Applications: Cannabis uptakes a large portion of its nutritional needs from her
leaves. Foliar feeds are very effective in supplementing micronutrients to the crop. Controlling
droplet size and deposition is an art of the applicator. Spray droplet disposition is influenced by
droplet size, the force and volume of the air and the speed of travel of the application equipment.
Droplet size depends on nozzle size, style, and condition, spray volume, spray pressure and light.
Once a sprayer has been calibrated its output rate is determined for a specific speed.
There may be times when this output rate needs to be changed to respond to variations in foliage,
density or space. The simplest way to alter the volume of spray being applied to an area is to
change the travel of the sprayer. A slower speed results in more liquid being applied while a
faster speed reduces the application rate. Operating application equipment too fast is a common
error and will result in poor coverage. Operating it too slow results in waste, possible over
application, and an increase in application time and cost. A limited range of adjustments can be
made so the applicator will need to map out their route prior to ensure even coverage.
Personal protective equipment for mixing products will be listed in the precautionary
statements section of the label. To avoid illegal over-application, measuring the products before
putting them into the tank will be ensured by the cultivation supervisor. Utensils for weighing,
measuring or mixing will be cleaned and stored in a safe area. Products will be measured and
poured below eye level. To prevent siphoning of product mixtures in the spray tank into the
water supply after the water flow has stopped staff will use a check valve or air gap.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
52
Fertilizer and Nutrient Emergencies: Accidents may occur while when handling
fertilizers and amendments. These products can be hazardous in concentrated amounts for staff
and the ecosystem. Emergencies such as leaks, spills, fires, thefts, misapplication, or lack of care
in storage handling must be planned for and prevented. If a regency situation arises and staff are
exposed, they are to seek medical care immediately. If others are exposed and have adverse
reactions, they will also be supported in seeking medical care.
In short, just as we have done in states like Colorado and Oregon, we will implement safe
and effective standards operating procedures in Fresno.
In addition to all of the discussion above, application of our knowledge of botany,
horticulture, and phytochemistry at all of our various cultivation facilities is further demonstrated
by the summary of our cultivation practices, policies, and procedures that we’ve described.
Everything about our practices, policies and procedures derives from all of the aforementioned
collective knowledge of our Director of Cultivation, Director of Outdoor and Mixed Light
Cultivation, our CEO and COO.
BIOSECURITY, SANITATION, PURITY & CONSISTENCY OF PRODUCTS
We will avoid the use of pesticides by implementing an Integrated Pest Management
system and follow the guidelines set forth by FIFRA section 25 (b). We will only use products
that contain active ingredients considered exempt and approved for food use according to FIFRA
section 25(b).
Our Integrated Pest Management, a sustainable approach to managing pests by
combining biological, cultural, and physical tools in a way that minimizes adverse health and
environmental impacts. No single pest control method is 100% effective; thus, a successful IPM
strategy consists of simultaneous implementation of several methods.
At our other facilities, our IPM methods are proven to be effective, environmentally safe,
and appropriate for controlling pests and pathogens in the production of cannabis for dried
flower use. This approach to pest management has been developed by agricultural professionals
committed to reducing the use of chemical products. IPM programs are based on current,
comprehensive information regarding the life cycles of pests and their interaction with the
environment. The protocols for IPM adhere to the following action principles and address our
cultural efforts to manage pests and diseases, starting with facility-culture solutions.
• Monitor and Identify Pests: Not all insects, weeds, and other living organisms require
control. Many organisms are innocuous, and some are even beneficial. IPM programs
work to monitor for pests and identify them accurately, so that appropriate control
decisions can be made in conjunction with action thresholds.
• Set Action Thresholds: IPM relies on preset action thresholds to determine whether a
product will be used. The threshold is set based on information about pest populations
growth for a given invader as well as environmental conditions. Sighting a single pest
does not always mean control is needed. The level at which pests will become an
actual threat must be assessed.
• Prevention: As a first line of pest control, IPM programs work to manage the space to
prevent pests from becoming a threat. Preventive methods we will employ include
using genetically strong and pest and disease-free plants. Methods include: cutting
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
53
clones from immature plants pre-flowering; replacing mother plants regularly as older
plants are prone to pass on diseases; and maintaining balanced levels of nitrogen to
ensure maximum plant nutrient uptake. These control methods can be very effective.
• Control: Once monitoring, identification, and action thresholds indicate that pest
control is required and preventive methods are no longer effective, IPM programs
evaluate the proper control method both for effectiveness and risk. Effective, less risky
pest controls are chosen first, including highly targeted chemicals, such as pheromones
to disrupt pest mating, or mechanical control, such as trapping or weeding. We also
plan to utilize bio-based products and naturally occurring substances that control pests
(minimum-risk product exempt from Federal regulation), microorganisms that control
pests, and pesticidal substances produced by plants containing added genetic material
Plant-Incorporated Protectants or (PIPs).
Only if further monitoring indicates that we are exceeding action thresholds despite the
use of less risky controls will we being employing additional pest control methods such as
targeted spraying of exempt and minimum risk products, with broadcast spraying as a last resort.
Weather conditions will also be a consideration in product application, specifically windy
conditions, high humidity, dew, fog and high rainfall. Sometimes a product application will
cause an outbreak of another pest, such as mites, because the product has destroyed natural
enemies or has lowered competition for the target crop. Cultivators will be familiar with
secondary pests that may be a result of the treatment.
Beneficial insects will be identified prior to planting and considerations will be made
throughout the seasons to ensure sensitive species like bees are not adversely affected by pest
management practices. We will first attempt to control pests through naturally occurring
substances, beneficial insects and cultural practices.
Biosecurity
One of the most effective ways to control insects in a growing environment is through
preventative measures. Strict biosecurity practices will be followed at all times to deter the
possibility of pest infestations to crops.
Structural biosecurity is imperative to bio-security and the necessary controls are inherit
to the cultivation facility itself. All our agents working in direct contact with cannabis will
conform to hygienic practices while on duty, including but not limited to: 1) Litter and waste will
be properly removed and the operating systems for waste disposal will be maintained in an
adequate manner so they do not constitute a source of contamination in areas where cannabis
plants are exposed; 2) Floors, walls and ceilings will be constructed in a manner that they will be
kept adequately clean and in good repair; 3) there will be adequate lighting in all areas where
cannabis is stored and where equipment or utensils are cleaned; 4) there will be adequate
screening or other protection, mentioned all throughout this Exhibit, against the entry of pests.
Rubbish will be disposed of so as to minimize the development of odor and minimize the
potential for the waste becoming an attractant, harborage or breeding place for pests; 5) any
buildings, fixtures and other facilities will be maintained in a sanitary condition; 6) toxic
cleaning compounds, sanitizing agents, solvents used in the production of cannabis concentrates,
and pesticide chemicals will be identified, held, and stored in a manner that protects against
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
54
contamination of cannabis and is in accordance with any applicable local, State or federal law,
rule, regulation or ordinance; 7) Only sanitizing agents registered with the City Manager
pursuant to any California Pesticide Act will be used in our facility, and they will be used in
accordance with labeled instructions; 8) the water supply will be sufficient for the operations
intended and will be derived from a source that is a regulated water system. Private water
supplies will be derived from a water source that is capable of providing a safe, potable and
adequate supply of water to meet the facility’s needs; 9) Plumbing will be of adequate size and
design and adequately installed and maintained to carry sufficient quantities of water to required
locations throughout the cultivation center, and it will properly convey sewage and liquid
disposable waste from the facility. There will be no cross-connections between the potable and
waste water lines, pursuant to the Fresno or California Plumbing Code; 10) All operations in the
receiving, inspecting, transporting, segregating, preparing, production, packaging and storing of
cannabis product will be conducted in accordance with adequate sanitation principles; and 11)
Cannabis that can support the rapid growth of undesirable microorganisms will be held in a
manner that prevents the growth of these microorganisms.
Not only will we follow the aforementioned regulations we will implement the following
guidelines to fully secure our grow rooms, processing rooms and our food grade kitchen: 1)
Cultivation areas will be in a separate zone of the building from administrative, post production,
lab, packaging and storage areas; 2) Entrances, exits and loading areas will all have several
sanitation barriers before allowing access to the rest of the building; 3) All grow rooms will be
sealed and self-contained to prevent cross contamination of plant batches; 4) Quarantine areas
will have sealed, but direct access points to outside areas, so any biological matter (i.e. seeds and
clones) entering the building will not pass through the rest of the facility until they have been
monitored, tested and deemed not a contamination risk by our head grower; 5) Each of these
areas will have separate filtered HVAC systems designed to prevent any type of pest from being
able to enter the room; 6) Additionally, there will be sanitation areas where all shipments of
cultivation supplies such as substrate, containers, fertilizers, tools etc. can be inspected and
disinfected before being brought into the cultivation zone; 7) Grow rooms and propagation areas
will be positively pressurized to prevent entrance of any unwanted pests; and 8) There will be no
gaps in the facility which could allow pests to enter. All openings in the building, such as
penetrations for utilities will be appropriately sealed to prevent the entrance of insects.
Screening and Monitoring: All employees will be properly trained in the identification
and living habits of all pests that pose a threat to cannabis plants. They will utilize tools such as
yellow/blue double-sided pest cards to monitor and track any pest activity in the grow rooms.
Routine checks of plant substrate, stalks and undersides of leaves will be conducted, and any
suspicions will be investigated and documented properly.
Accurate Identification and Diagnosis of the Pest: It is necessary to understand the
biology of the pest and the interaction with the environment. All management decisions will be
based on the proper identification of the pest.
Monitoring Pest Populations: Cultivators will regularly inspect plants to ensure there are
no pests, or, in the instance pests are detected, to monitor the development of their populations.
They will be trained to look for both insect habitats and distress signs from the plants. Visual
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
55
inspection is key. Cultivators will be equipped with hand microscopes with lights for in depth
inspections. As well as tabletop microscopes for further inspection when necessary.
It is essential for the employees to understand target behaviors and developmental/reproductive
cycles of these insects because many are not apparent to the human eye until the final stages of
their lives. Many pests have several life phases, including egg, larvae, pupa, and mature. Each
phase may require a different treatment plan, or a multistep effort to deter further development.
Biological Controls: One of the best methods of defense against unwanted pests is the
controlled release of other insects that are natural enemies of the unwanted pests. This type of
biological control is commonly used in greenhouses and other indoor growing environments
where it is difficult for pests to leave an area. Predatory insects are often bread for commercial
use and there is an abundance of variety available. In some instances, it is most effective to use
several varieties at the same time to target an infesting pest at multiple stages of its life.
There are many specific carnivorous insects that prey on the harmful pests. For example,
we have found the entomopathogenic nematode Steinernema feltiae to be broadly effective at
insect control, Orius insidiosus, Amblyseius cucumeris and Amblyseius swirskii to be very
effective at controlling thrips and mites, and Stratiolaelaps scimitus effective at controlling thrips
and various soil pests. Our Cultivation Manager will implement a strategic method of regularly
and proactively applying beneficial insects to plants to prevent and combat the pests in all
developmental stages of their life cycle.
Contingency Plan: If infestation or contamination of pests or disease were to occur, our
Cultivation Manager would determine the risk posed and create an action plan from there,
considering both biological and mechanical controls previously discussed. If necessary, plants
can be held in quarantine and observed, or in severe situations, culled to prevent the further
spread of said pest. All culled plants or effected plant material will be bagged, sealed and
removed from the facility immediately. Any cultivator handling said material will disrobe and
place contaminated uniform into sealed bag for immediate washing, shower and change into a
new clean uniform before returning to work.
Material Safety Training and Management: It is important to us that our staff are trained
at the highest level and understand how to safely work with products in the marketplace. Our
staff are trained to recognize restricted pesticides and how to apply active ingredients that are
exempt from federal pesticide regulation. They will be trained to handle oils and other non-toxic
products in high volumes, allowing them to supervise staff safely. Staff are responsible for
ensuring their continuing education credits and accommodations will be made to the work
schedule to support their efforts.
All of our products will be tested for microbial, fungal and residuals. Tolerance limits for
microbial and fungal contamination in cannabis are some of the lowest of herbal and produce
products. For our consumers with compromised immune systems the stringent testing offers
ensures their additional safety and offers comfort. It is important to understand that microbial
and fungal values do not represent pass or fail criteria. They are recommended levels when
plants are produced under normal circumstances and growing conditions. Herbs like mint that
have higher concentrations of trichomes on the leaves typically prone to higher levels of molds.
Cannabis also has high levels of trichomes in the finished flower and while the state currently
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
56
tests for product threshold limits, we may find that this measurement becomes more conservative
or less as additional research and testing is done.
When grown in contaminated soil, cannabis accumulates heavy metals in such an
effective way it has been proposed as a means of bioremediation of toxic waste sites. Our
Company will source organic soil from local producers and we test our soil regularly to ensure
its integrity.
In an effort to minimize product use and based on our consortium of cultivators’
extensive experience with pest management practices, we will use Integrated Pest Management
(IPM) protocol. Our use of IPM will ensure compliance with the requirements concerning
product application and use as set forth in the Act and accompanying rules and regulations. Our
team has been cultivating in accord with the American Herbal Pharmacopeias Cannabis
Inflorescence: Standards of Identity, Analysis and Quality Control monograph since 2014.
Product and Application Recordkeeping
A record of all product applications will be maintained at the cultivation center for at
least five years and be made available to the City Manager or other state agencies upon request.
Records will be created at the time of application. The application record will document the
following information: Date and time of application; Date and time safe to re-enter the site; Date
of start of vegetative stage of growth; Application site (the site shall be identified by the location
legend maintained by the facility); The crop treated, including the specific block, section, or
immature cannabis plants or cannabis plants treated; Size of the application area; Product name
of each product used; The US EPA Product registration number; Amount applied to the treated
area measured by pounds, ounces, gallons or liters as appropriate; The dosage or rate of
application of every product used; The employee id number of anyone involved in making the
product, where relevant, and the name and permit number of the certified applicator making the
application; Copies of product labels and Safety Data Sheets for the product used; Comments or
special conditions related to the application.
Training Employees in the Proper Use of Materials and On-Site Products: Worker
training and safety is of utmost importance to us. Employees will be adequately trained to work
with products before handling and be given refresher courses each year to ensure retention.
Safety training topics will include; Working Safely on Farms, Storing Nutrients and
Amendments, Working in Closed Systems and Enclosed Cabs, Water-Soluble Packaging, First
Aid, Washing Product Work Clothing, Safety Rules for Product Handlers on Farms, Product
Safety Rules for Farmworkers, and Safety Rules. Product application will be supervised by a
certified private applicator.
All employees will be trained on safety related to product use, using EPA-approved
materials. We will provide training in a language that all workers can understand and will use a
translator when necessary. Employees who apply minimum risk products will be trained
pursuant to obtaining and maintaining their application licenses. These employees and our
management will also keep up to date with best practices.
Handlers will be trained about general product safety and correct ways to handle
minimum risk products. Workers will be trained about general product safety. This training will
occur before a worker or handler begins performing job duties and will be repeated annually. The
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
57
training will use the WPS training materials developed by EPA, we will provide the basic
product safety information in a manner that workers can understand, and will include:
information on soil, irrigation water, or drifting from nearby applications; following directions
and signs about keeping out of treated or restricted areas; washing before eating, drinking, using
chewing gum or tobacco, or using the toilet; wearing clothing to protect from product residue;
washing or showering with soap and water, shampooing hair, and putting on clean clothes after
work; washing work clothes separately from other clothes before wearing them again; washing
immediately in the nearest clean water if nutrients or amendments are spilled or sprayed on your
body and then—as soon as possible — shower, shampoo, and change into clean clothes.
Trainings will be performed by a certified applicator. The training will include written or
audio/video materials and use nontechnical terms and trainers will respond to questions. Training
will be provided in every necessary language.
Training for fieldworkers will include the following information and be given to all
workers who enter product-treated areas for 30 days following expiration of a restricted-entry
interval. Training will be provided to workers when an area has been treated with any type of
product, herbicides, fungicides, and insecticides. Even though pesticides will not be used in this
cultivation facility, oil, bio-based chemicals and other products made up of exempt active
ingredients can still present unsafe scenarios for staff. It is important to us that staff receive
adequate training on all of the products they will come into contact with in the workplace. The
training will cover the following:
• Where and how workers may come in contact with chemicals and materials during
work, including hazards from chemigation and drift.
• Importance of routine decontamination and washing after exposure.
• The routes by which minimum risk products can enter the body (skin, mouth,
inhalation, and eyes).
• Symptoms of acute product poisoning or injury, and long-term and delayed health
effects from exposure, including sensitization.
• First aid for product injury and poisoning, and emergency decontamination.
• How workers can protect themselves from exposure-clothing, avoiding skin, eye,
and mouth contact; personal hygiene.
• Obtaining medical help.
• After-work care of contaminated work clothes.
• Warnings about taking home chemicals or product containers.
• An explanation of the entry restrictions, application limitations, posting, oral
warnings, access to product use information, and protection from employer
retaliation.
• Hazard communication program requirements and employee rights
Worker Protection Standards (WPS)
All individuals applying nutrients, amendments or pest control products will adhere to the
agricultural use requirements of the label and will employ all personal protective equipment
prescribed by the label. Worker protection standards will comply with EPA regulations as
described in EPA publication “How to Comply with Worker Protection Standard for Agricultural
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
58
Products: What Employers Need to Know”, it will be used to protect workers and product
handlers, both of which are defined terms under WPS regulations. This will include maintaining
required information at a central location; conducting product safety training; decontamination
supplies; emergency assistance; providing appropriate notices before, during, and after
application; special application restrictions for greenhouses; compliance with early entry
protections; restrictions during applications and monitoring handlers; specific instructions for
handlers; equipment safety; and personal protective equipment and exceptions.
The following information will be continuously displayed, at a central location in our
cultivation facility where it is readily accessible and can be easily seen and read by workers and
handlers, before a product is applied and for 30 days after the restricted-entry interval expires or
if there is no restricted-entry interval for 30 days after the application ends:
• Product-specific application information, which will include: the location and
description of the area to be treated, product name, and active ingredient(s) of the
product, time and date the product is scheduled to be applied, and restricted-entry
interval for the product.
• Emergency information, which will include the name, telephone number and address
of the nearest emergency medical facility.
• The WPS safety poster developed by EPA, which will state that there are federal rules
to protect workers and handlers, including a requirement for safety training.
We will inform all cultivation agents where the information is located, allow unhampered
access to the information, be sure the poster, emergency information and application information
remain legible while posted, and promptly inform worker of any change in the information and
update the emergency information listed in the poster.
Biosecurity
As mentioned in the above section and throughout this Exhibit, one of the most effective
ways to control pathogens and pests in a growing environment is through preventative measures.
Strict biosecurity practices will be followed at all times to deter the possibility of pest
infestations to crops.
1. Cultivation areas will be in a separate zone of the building from administrative,
postproduction, laboratory, packaging and storage areas.
2. Entrances, exits and loading areas will all have several sanitation barriers, including
cleanroom mats, before allowing access to the rest of the building.
3. All grow rooms will be sealed and self-contained to prevent cross contamination of plant
batches.
a. Quarantine areas will have sealed, but direct access points to outside areas, so any
biological matter (i.e. seeds and clones) entering the building will not pass
through the rest of the facility until they have been monitored, tested and deemed
not a contamination risk by our head grower.
b. Each of these areas will have separate filtered HVAC systems designed to prevent
any type of pest from being able to enter the room.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
59
c. Additionally, there will be sanitation areas where all shipments of cultivation
supplies such as substrate, containers, fertilizers, tools etc. can be inspected and
disinfected before being brought into the cultivation zone.
4. Grow rooms and propagation areas will be positively pressurized to prevent entrance of
any unwanted pests.
5. There will be no gaps in the facility which could allow pests or spores to enter. All
openings in the building, such as penetrations for utilities will be appropriately sealed to
prevent the entrance of insects.
Biosecure Cultural Practices
Cleanliness and good handling practices will be taken into consideration during the day
to day functions at our facility.
1. Each cultivation area and all supplies must be sanitized accordingly.
a. Propagation and grow rooms will be cleaned with ethanol on a daily basis and
sanitized completely in between batches of plants being grown in them.
i. Tables and drains will be sanitized regularly.
b. All tools and equipment will be sanitized with ethanol both immediately before
and after each use and stored in the proper location.
c. There will be one set of tools and sanitation materials per room and they will
never leave said room to prevent any type of cross contamination.
d. Waste and plant material generated in each room will be immediately sealed in a
bag and then removed from the facility via the most direct route and stored in
proper location until destroyed or removed from the premise, after inventory
procedures are followed.
e. Hallways and walkways will be sanitized throughout the day on a daily basis.
f. Sticky mats will be placed outside of every door, preventing spread of pests via
foot traffic. These will be replaced daily at a minimum and whenever heavy use
creates additional need.
2. Since rotting plant material is a major attractant and food source for pests mold and
disease, plants will be groomed regularly and all dying or dried leaves will be removed
immediately. Cultivators will ensure that the tables and pots remain free from rotting
material as well.
3. Employees will practice good hygiene and take preventative measures when handling
plants or plant material.
a. Each employee must take a full shower before entering the cultivation or
production zones.
b. Every employee will be given a clean color-coded biosecurity uniform to wear
after they have showered.
i. These uniforms are washed every day and never leave the facility,
reducing the risk of bringing in outside contaminants.
c. Employees will keep shoes at the facility specifically to be worn only in the
cultivation and production zones.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
60
d. Employees will don hair nets and employees with facial hair shall wear beard
nets.
e. Employees will don gloves anytime they are handling plants or plant material.
f. Authorized visitors must wear hygienic coveralls such as Tyvek suits when on
premise.
g. Employees will wash their hands upon entering the facility, after using the
lavatory and before returning from breaks.
4. Dried flowers will be stored in airtight containers off the ground to prevent insects from
contaminating material when in final storage.
In order to actively prevent plant disease and promote purity, it is necessary to know what
the risk factors and well as the signs of disease are. Just like any other crop cultivated, cannabis
is subject to a wide range of pests and diseases that can distress plants. Before an agent can make
an informed decision about how best to solve a problem, it is necessary to be able to identify the
cause of the plant stressor by its symptoms. Like cannabis plants that have fallen victim to a pest
infestation, diseased cannabis plants will have visual symptoms as well.
Diseases of cannabis come as the result of three main pathogens: bacteria, viruses, or
fungi. Control of these is very different for each type, so it is important to be able to identify the
symptoms of each. However, the most common plant diseases affecting cannabis plants are
caused by fungi. Fungal outbreaks in the grow room are usually caused by a combination of poor
air circulation, high humidity levels, overcrowding of plants, wrong temperatures, and starting
off with unhealthy clones or seedlings.
Fungal diseases can also be spread by pests, or contaminates that hitch a ride into the
grow room from unsanitary equipment, pets, a grower's clothing, etc.
Environmental Controls: Fungal diseases are often caused by environments that are too
damp or humid, or places which lack airflow. Fungal spores float around in the air looking for a
suitably damp place to root down and if the environment is right, that suitably damp place might
be on a cannabis plant.
The best treatment for plant diseases is to invest in prevention efforts. One easy way to
prevent the transfer of fungi or bacteria is to ensure plants are appropriately spaced. Not only do
crowded plants fail to get enough light, but they also become warmer and moister. This
facilitates the growth and spread of blight-causing pathogens.
In addition to spreading plants apart, it is important to consider air quality in your
growing environment. Keeping humidity within acceptable ranges (45-55% in veg, 40-50% in
flower) will reduce the incidence of these pathogens and minimize their spread.
Given our long experience in cultivating high quality, contaminant and disease free
cannabis, we are fully confident the steps outlined in this exhibit can product some of the best-in-
class cannabis in the Fresno market.
Adequate Cannabis Supply: We will have multi-tiered grow rooms, totaling 30,000
square feet of flowering canopy. Each grow room will average approximately 100 flowering
lights per room (1 light per 25 square feet), producing 5.5 harvest annually, we can yield 1.5 to
2.0 pounds per harvesting light and up to 1,100 pounds of raw flower each month. We will have
the ability to harvest every nine weeks. We estimate supplying Fresno and California will over
13,200 pounds of raw material annually, at full capacity. We will have the opportunity to expand
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
62
ecosystem. Emergencies such as leaks, spills, fires, thefts, misapplication, or lack of care in
storage handling will be planned for and prevented. If a regency situation arises and staff are
exposed, they are to seek medical care immediately. Only certified applicators can apply
fertilizers or nutrients.
Safe Handling of Fertilizers and Other Chemicals: As indicated above, our nutrient
management plan was created based on years of cultivation experience with an eye to product
safety, employee safety, and environmental safety. As such, our standard operating procedures
require that all members of our cultivation team follow the safety data sheets for every product
on site. This is required not only to ensure employee safety but to also ensure the proper and safe
distribution of these materials to our plants, thereby ensuring the safety of our products.
Similarly, all fertilizers, nutrients, additives, and chemicals will be stored and locked in a
NFPA and OSHA cabinet. All bottles of fertilizer or of plant additive will be properly labeled
per OSHA regulations. Anyone handling fertilizers or other chemicals will be required to wear
protective layers, gloves, a mask, and goggles if needed.
Mixing Location: The mixing location can be cleaned easily should an accident occur.
We have considered the surroundings and the environmental impact of the mixing site. The
mixing site is more than 100 yards from a riparian region and more than 50 feet from a drain or
access point to a waterway. In the event of a spill, a spill kit will be provided adjacent to the
mixing zone. A sump pump and 5-gallon bucket will also be available to absorb liquids and the
mixing tanks will sit on a spill well to catch any fluids in the event of an accident. Staff will wear
dust/mist respirator or cartridge respirator approved when weighing and mixing products to
prevent inhaling dust. Waterproof gloves, appropriate footwear, and a rubber apron will also be
required to be worn by nutrient handlers.
Foliar Applications: Even though we are cultivating cannabis indoors, we will always
monitor foliar applications. Cannabis uptakes a large portion of its nutritional needs from her
leaves. Foliar feeds are very effective in supplementing micronutrients to the crop. Controlling
droplet size and deposition is an art of the applicator. Spray droplet disposition is influenced by
droplet size, the force and volume of the air and the speed of travel of the application equipment.
Droplet size depends on nozzle size, style, and condition, spray volume, spray pressure and light.
Personal protective equipment for mixing products will be listed in the precautionary
statements section of the label. To avoid illegal over-application, measuring the products before
putting them into the tank will be ensured by the Director of Cultivation and COO. Utensils for
weighing, measuring or mixing will be cleaned and stored in a safe area. Products will be
measured and poured below eye level. To prevent siphoning of product mixtures in the spray
tank into the water supply after the water flow has stopped staff will use a check valve or air gap.
The following practices will be implemented to ensure the environmental integrity of our
neighborhood is not degraded by the agricultural practices. Protecting waterways and sensitive
habitats is central to these practices and we will adopt new methods of conservation as we
investigate the hydrology, geology and biology of the site. The below practices will serve as
guidelines for our standard operating procedures.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
63
Water Use
We will conduct all operations on a size and scale that considers available water sources
and other water use and users in the planning watershed; Our technology systems, Argus and
iPonic, create real-time data including tracking all water usage and volume will be documented
in our daily logs. Our irrigation system will have an automated drip irrigation and flood tables to
irrigate our crops. Water conservation measures such as rainwater catchment systems, drip
irrigation, mulching, or irrigation water recycling will be implemented; Measures to minimize
water diversion during low flow periods will be taken; The company will provide options for
documentation of water diversions and/or water usage such as the use of water meter devices and
date-stamped photographs of water meter readings; Hauled water utilized for irrigation will be
documented via receipt or similar, and shot the date, name, and license plate of the water hauler,
and the quantity of water purchased; and Water will be applied at agronomic rates.
Water Storage
Water storage tanks will not be located in a flood plain or next to equipment that
generates heat. The tank will be located such that it will be easy to install, access, and maintain;
Vertical tanks will be installed according to manufacturer’s specifications and placed on firm,
compacted soil that is free of rocks/sharp objects and capable of bearing the weight of the tank
and its maximum contents. In addition, a sand or pea gravel base with provisions for preventing
erosion will be used. Tanks 8,000 gallons or larger will be supported by a reinforced concrete
pad and attached to a tank restraint system; Horizontal tanks will be secured with bands/hoops to
prevent tank movement; Storage ponds will be designed and constructed in properly sited
locations, off-stream. Vegetation will be planted along the perimeter of the pond. Berms or extra
freeboard space will be constructed around the perimeter of the pond to allow for sheet flow
inputs; If we expand, we will provide adequate outlet drainage for overflow of ponds, which will
be provided, including low impact designs, to promote dispersal and infiltration of flows; and
Proper lining/sealing in ponds will be installed to prevent water loss.
Irrigation Runoff
We will commit to measure runoff from watering events and report all volume in our
water usage technology Argus and iPonic systems and on average, watering events will have no
more than 20% of runoff of water; Agronomic water applications will be used to minimize
runoff; Regular inspections for leaks in mains and laterals, in irrigation connections, or at the
ends of drip tape and feeder lines will be conducted. Any leaks found will be repaired; The
irrigation system will be designed to include redundancy (i.e. safety valves) in the event that
leaks occur, so that waste of water is prevented and minimized; Irrigation runoff will be
recaptured and reused wherever possible, through passive (gravity fed) or active (pumped)
means; Retention basins for tailwater infiltration will be constructed; percolation medium will be
used to reduce pollutant concentration in infiltration water. Constructed treatment wetlands may
be used to reduce nutrient concentrations in water. Drainage and/or infiltration areas will be
located away from unstable or potentially unstable features; Worn, outdated, or inefficient
irrigation components and equipment will be replaced on a regular basis; Much will be used in
cultivation areas that do not have ground cover to prevent erosion and minimize evaporative loss;
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
64
A vegetative barrier will be used along the property boundary and interior watercourses to act as
a pollutant filter; and Rain-triggered shutoff devices will be employed to prevent irrigation after
precipitation.
Fertilizers, Soil Amendments, Pesticides, Petroleum Products, and Other Chemicals
Irrigation water, soils, growth medium, and plant tissue will be evaluated to optimize
plant growth and over-fertilization. All chemicals will be stored in a manner, method, and
location that ensure that there is no threat of discharge to waters of the state; Products will be
properly labeled and applied according to label; Integrated pest management techniques will be
used that apply pesticides only to the area of need, only when there is an economic benefit to the
grower, and at times when runoff losses are least likely, including losses of organic matter from
dead plant material; We plan to never use pesticides, but necessary all pesticide application
equipment will be periodically calibrated; Anti-backflow devices on water supply hoses, and
other mixing/loading practices designed to reduce the risk of runoff and spill will be used;
Petroleum products will be stored with a secondary containment system.
Utilities Usage
Water: Water consumption provides an example where our facility has been designed to
minimize water use in two ways. Using a HyperLogic system, our irrigation lines will operate on
a closed loop water recycling system, once water enters the system it continues to loop between
filtration/cleaning and usage to the best of the facility’s ability to achieve the quality needed to
be reused in subsequent watering rounds. At maximum capacity in 2025, this will allow our
50,000 square foot canopy facility to save 80% in water consumption per year close to 5.841
gallons per year. Our closed loop system also enables us to keep watering plants and avert
disaster in the event of a municipal water system failure. A secondary technique our cultivation
agents use, is to recover and reuse the condensate from the HVAC system to irrigate the plants,
we will save 2%-5% of the irrigation water used per day. This is estimated to save approximately
245,322 gallons per year, small in comparison to overall use, but every drop is helpful. Our site
is equipped with utilities and we will use local commercial water sources.
Electricity: Electrical power is another essential input, and our plan contemplates state-
of-the art systems to minimize energy usage. For example, the heating system utilizes
condensing units that have a 98% thermal efficiency. Taking advantage of Georgia’s mild
winters, the building’s cooling system will be equipped with a “free cooling” chiller that will
operate in a partial economizer mode when the outside air temperature is below 55° F with
higher efficiencies (2,740 hours/year). At our Colorado facility, the result of these systems
translated to 20-30% less energy consumption compared to a traditional HVAC system.
Additionally, our use of a 480 volt /3 phase electrical system allows us to run our grow
lights in more energy efficient 277V configuration as compared to the 120V configuration. Grow
room lighting will reduce electrical distribution costs, eliminate step down transformers, and
reduce the energy used by the lighting system by another 3-4%. We will commit to technology
that creates the most efficiency at our facility. Our Argus system will be designed so our Light
Power Densities (“LPD”) do not exceed an average of 36 watts per gross square foot of active
and growing space canopy. Our lights will meet a photosynthetic photon efficacy (“PPE”) of no
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
65
less than 2.2 micromoles per joule fixture and will be featured on the Design Lights Consortium
(“DLC”) Horticultural Specification Qualified Products List (“QPL”). In the event DLC
requirement for minimum efficacy exceeds 2.2 micromoles per joule fixture, that PPE will
become our new standard. We expect our electricity cost at 50,000+/- square feet to be close to
per year, which includes per year on non-cultivation electricity. Please
see our above Utility Cost breakdown below.
Active Solar Power: Although our plans do not call for starting with solar power, our
building will have the sun facing the south using our 35,000 +/- square feet on the facility’s tilted
roof are particularly amenable to future installation of a photovoltaic system to help offset a
portion of the building’s electrical load. To accommodate the eventual conversion to solar, the
initial construction phase includes plans to install conduit to support the future photovoltaic
system. Overall size of the system will be investigated to provide optimum cost/benefit with
regard to the building’s electrical requirements. Once capacity meets demand, we will expand
canopy in our facility and add more grow rooms. As grow room area is increased, the size of the
photovoltaic system can be adjusted to provide a percentage of the power requirements. Once
awarded a license we will have utility agreements in place, with a local solar panel company.
Our CCB will at all times be operated in such a way as to ensure the health, safety, and
welfare of the public, the employees working at the cultivation site, visitors to the area,
neighboring properties, and the end users of the cannabis being cultivated, to protect the
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
66
environment from harm to streams, fish, and wildlife; to ensure the security of the cannabis
being cultivated; and to safeguard against the diversion of cannabis, per SEC9-3312(a)(7).
1.9.1 Criteria for all cultivation operations:
a. Identify location and procedures for receiving deliveries of seedlings and
immature plants.
Our cultivation is located in a properly zoned area…
When identifying and designing a property we look for the following attributes: enclosed
and private delivery, properly zoned for the use, at least 30,000 square feet of canopy with 2+/-
acres for expansion, easy access to expressways or major thoroughfares, secured private parking
for employees and visitors, compliant with Americans with Disabilities Act (ADA) for
employees and visitors, strong local Fresno law enforcement relationships, proper mechanical
equipment (plumbing, electricity and sprinkler system) and proper buffers from primary schools,
daycares, parks and other designated areas.
Initial propagation and phenotypical selection: Within 30 days of being deemed
operational by the City Manager, we will obtain seeds or immature plants from licensed
California breeders for the purpose of securing our start-up inventory. Sourcing some from our
own operations and other reliable breeders with whom we have worked will help us ensure the
integrity and genetics of our seeds and immature plants.
Plants will be free of pests and disease to ensure healthy growth and will be inspected
weekly by a cultivation agent. Each production area will be maintained free of debris.
At the time of planting, all seedlings, clones and plants will be accounted for as a batch
with a unique batch number that will remain with the batch through final packaging. A batch
number will be assigned at the time of planting for a specific number of plants. When our plants
reach 6 inches in height, a specific number will be assigned for each plant within that batch and
the individual tag will be recorded electronically (RFID) or kept in an electronic file until harvest
or destruction. The batch number will remain with the segregated plants through harvest to final
packaging. The batch number will be included on the label of the package distributed for the
purchaser.
Enclosed Private Delivery: Our COO and lead architect, designed an optimal safe, air
controlled, enclosed delivery system that will provide privacy away from “ordinary public view”
and away from the main road. Per SEC 9-3312(a)(3), cannabis plants will not be visible from a
public or private road, sidewalk, park, or any common public viewing area. Our fully enclosed
Receiving, Shipping and Loading (RSL) will store as many as two sprinter vans and two large
trucks. The RSL will have two roll up doors. There will be a readymade office located with the
RSL, that will also serve as our driver safety checkpoint and delivery manifest processing center.
We plan to have two employees manning our RSL office daily or during all delivery days.
Deliveries will ONLY take place during hours of operation (Monday – Sunday, 9:00 am to 5:00
pm) through our private RSL in our restricted access area, never through the main entrance or
other limited access areas. Our RSL will lead directly to our secured office, then to our
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
67
downstream and storage restricted access area. Once products are properly packaged, they will
be stored in our restricted access area Vault Room for final inventory. Our Vault Room will have
24/7/365 surveillance and will be locked only allowing Level 5 employee access.
Delivery will take place outside of public view and security agents will monitor all
deliveries. The garage doors are closed at all times, operable by the security guard inside the
facility. The area will have a secured locked commercial grade steel door at the Receiving,
Shipping and Loading area leading to our restricted access area, securing the interior of our
facility during all deliveries. Every garage door will have a camera with the ability for a 2-way
video and voice function. Our security guard will be able to see the face of the driver,
communicate verbally and verify visitor credentials using our GB2 Door Monitor and Intercom.
Cannabis will NOT be visible to the public at any time because of our fully enclosed garage
doors.
Receiving, Shipping and Loading Dock
Ordering and Preparation for Delivery: Product ordering of seeds, immature plants and
other products are conducted by our Cultivation Manager. The Cultivation Manager may only
order such quantities and varieties of products as are required to meet the immediate need. The
CEO must confirm each order for it to be valid, needing all responses in written form of
communication. Delivery may only be scheduled for a date/time when the CEO, Cultivation
Manager and a Security Guard are at the facility. We plan to build a seed bank of over 200
strains and will purchase clones and mothers from licensed cultivation nurseries.
The Receiving, Shipping and Loading Area: The Receiving, Shipping and Loading (RSL)
area will consists of a fenced in, enclosed loading area. The privacy gate is 10 feet tall with
barbed wire, making it impossible to climb, breach or see inside. The gate will also have motion
sensors that will detect an intruder touching, cutting or smashing the iron gate. Immediately off
to the rear, includes a mantrap that secures and separates the interior of our facility from all
delivery activity. Our CCB will only accept deliveries using our RSL restricted access area.
Deliveries will NOT be accepted through our main entrance or any limited access area, unless
otherwise approved by the City Manager. All areas of facility were designed to comply with all
State and Fresno building, fire and zoning requirements or regulations, including our RSL area.
Receiving Operations and Staffing: Ideally, we would like to receive delivery of product
in the early am, before opening of business. We understand and will request deliveries to arrive
during business hours before 5:00pm. All persons not specifically involved in the receiving
process will continue to do their daily tasks but will be asked to be vigilant of any suspicious
behavior. Our security team will monitor the Receiving, Shipping and Loading area cameras at
all times during delivery, and the CEO, Facility Manager and security guard overseeing delivery
will maintain situational awareness.
Acceptance Procedures: Upon each delivery, at least two members of our Receiving
Team will immediately conduct a thorough inventory of the cannabis products delivered in order
to compare it to the transport manifest sent the day prior as well as to the transport manifest
provided at the time of delivery. If this inventory is accurate, meaning what has been physically
delivered matches the transport manifests, these employees will then follow our inventory
policies and procedures. Each employee will sign and countersign the manifest to attest to its
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
68
accuracy and print a receipt to provide to the delivery team. All seeds and immature plants will
receive a unique barcode that will follow the plant throughout its life cycle. We will use
handheld barcode scanners in the secure enclosed area to scan the unique barcode of each
cannabis product into the product description module of our ITS. The module will create and
auto-populate unique “Product Descriptions”. Each product description includes seed bank and
origin of the plant, description of the product, batch number, batch date and life stage. Our CEO
can assign security levels so only designated employees have the ability to manually change or
upload results for each plant received.
We will, if requested, provide a copy of a printed transportation manifest (or copies of
our Receiving, Shipping and Loading logbook), and any printed receipts for cannabis being
transported to our CCB, to the City Manager, its authorized agents, or to law enforcement.
STORAGE DESCRIPTION
Sanitation of Storage & Quarantine Areas: ALL STORAGE areas and storage containers
will be maintained in a clean, sanitary and orderly manner that inhibits pests or spoilage. The
Vault Room cannot be accessed by our cleaning contractors, employees with the appropriate
clearance will maintain the cleanliness of this room. Weekly, or more frequently if needed, two
employees with the proper clearance will sweep/dust the room and remove any garbage or
debris. Each will visually inspect the room to ensure it is free from insects, rodents, birds or other
vermin of any kind. All employees cleaning this area will be required to use protective
equipment. We will maintain a Sanitation and Cleaning logbook inside the vault room with the
date, time, and name of employee who cleaned the room. Destruction and quarantine bins will be
properly sanitized after every destruction. This log will be stored with our other business records
and maintained for a minimum of three years.
Storage & Volume Capabilities: Our facility will approach the storage of seeds, immature
plants and cannabis with three main goals: (i) ensuring our storage facilities match the expected
volume of weekly sales; (ii) ensuring that we maintain quality and potency of all products; and
(iii) limiting access to prevent diversion and/or theft. These are critical goals, core to our mission
of providing quality products to all dispensaries, and fully achievable through robust product
storage policies and procedures.
Physical Storage Measures: Useable cannabis products in our facility will be stored only
in one of three locations: (1) the Vault Room; (2) the locked cabinets (safes) in the restricted
access area production areas; or (3) a quarantine container within the Vault Room that stores
recalled or damaged product. Cannabis products will always be stored in plain sight of our
surveillance system. Every time a unit of product is moved from one area to another, we indicate
this in our Inventory Tracking System. This enables management, employees and the City
Manager to know in real-time where each unit of product is located. When product is sold, it is
automatically deducted from the rolling inventory and the product list is updated. We will use
oldest stock method to sell products.
Our COO uses custom formulas that calculates the estimated volume of inventory needed
in the storage at our facility. We typically like to have a Vault Room that can store at least 45
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
69
days of inventory measured by customers in the Fresno program. We estimate the size of our
Vault Room, can store close to 60 days of inventory.
b. Describe the planned square footage/acreage of the cultivation.
Proposed Interior Layout
Our facility was designed
by our Director of Cultivation and
COO with help from our
experienced architect, design and
engineer team. The interior of our
facility is perfectly situated to
have sufficient square footage and
be suitable to provide the Fresno
and California market with over
13,000 pounds of cannabis. Our
facility will be extremely spacious
and adequate as we have more
than enough square footage for
our post-production, cleanroom
facilities, production rooms,
security rooms, delivery, storage
and final vault room protection.
We are fully confident our facility
will have more than enough
suitable space to operate a fully
functional 30,000 square foot
canopy cultivation facility, cutting ZERO corners. Per SEC 9-3312(a)(5) cannabis cultivation
will be conducted in accordance with state and local laws related to land conversion, grading,
electricity, water usage, water quality, woodland and riparian habitat protection, agricultural
discharges, and similar matters.
Our COO will ensure restrict access to other parts of our facility to: (a) a person whose
responsibilities necessitate access to certain sections in our facility and then for only as long as
necessary to perform the person’s job duties.
Design, Architect and Construction: Our Company has partnered with diverse
experienced architects to help us design and build our facility. As you can see from all the above
attributes and design, our facility is sufficient both in the interior and exterior to handle the bulk
agricultural production of cannabis, product handling, storage, packaging, loading, shipping and
transportation. To design our facility, we hired Jaime Magaliff, a Principal Architect at Steep
Architecture Studio, Ms. Magaliff has over five years designing cannabis facilities. She helped
design and build cannabis facilities in the multiple medical cannabis markets – Pennsylvania,
New Jersey, Illinois and Missouri. While working alongside our COO, they were both featured
in Marijuana Ventures magazine as designing an efficient state-of-the-art cannabis facility in
Proposed Size of Each Area of our Facility
Security & Transportation Mechanicals & Destruction
SITR 215 sqft Mechanical 500 sqft
Security Entry 75 sqft Electrical 500 sqft
Dispatch Office 160 sqft Chem Waste 50 sqft
RSL (Shipping)1,190 sqft Quarantine 50 sqft
Locker Room 1,510 sqft Waste 50 sqft
Vault (Processing) 2,000 sqft Disposal 800 sqft
Total 5,150 sqft Total 1,950 sqft
Cultivation / Indoor Post Production & Other
Fertigation & Irrigation 430 sqft Dry Room 1,600 sqft
Clone Room 465 sqft Cure Room 1,370 sqft
Mother Grow 1,600 sqft Break Room 300 sqft
Flower / Veg (1)4,485 sqft Private Office 170 sqft
Flower / Veg (2)4,485 sqft Open Office 740 sqft
Flower / Veg (3)4,485 sqft Storage 1,500 sqft
Flower / Veg (4)4,485 sqft Cooler / Freezer (walk-in) 1,000 sqft
Flower / Veg (5)4,485 sqft Janitor 245 sqft
Flower / Veg (6)4,485 sqft Laundry 245 sqft
Flower / Veg (7)4,485 sqft Visitor Waiting 625 sqft
Flower / Veg (8)4,485 sqft Packaging 2,000 sqft
Total 38,375 sqft Total 9,795 sqft
Note: Totals do not include hallways.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
70
Pennsylvania. She is a very integral part of our team as she designed most of our proposed
cannabis facilities.
Given our professional cannabis experience building and operating 10+ large scale
cannabis facilities, the great condition and readymade specifications of our proposed building
and our experienced architects and construction team, we feel our building best demonstrates a
suitable, effective and safe space to cultivate cannabis in Fresno. We will cut no corners when it
comes to safety of our employees, the safety of our products and the safety of the Fresno
community.
Proposed Facility Blueprint Detail
Cultivation: Our cloning, propagation, and mother rooms will be adequate, and our
indoor cultivation will have 30,000 square feet of canopy for vegetation and flower. Per SEC 9-
3312(a)(4) our cultivation facility will only be allowed to cultivate the square feet of canopy
space permitted by state law. Research and development area will be limited to ten percent of the
total permitted canopy square footage. This is more than enough space to cultivate high-quality
cannabis for Fresno dispensaries. Our rooms will feature a state-of-the-art setup, including
ductless mini-split HVAC units, automated irrigation and nutrient feeding systems, and our
Argus and iPonic humidity, CO2, irrigation controls. We plan on stacking our cultivation as our
ceiling height will have ample height in most areas. Also, grow rooms will include rolling
benches with flood tables, PhysioSpec Indoor spectrum Fluence – SPYDR and SPYDRx Plus
LED, industrial fans for cooling and air circulation and sealed flooring. All rooms will be built to
remove any chance of contamination with the highest level of biosecurity. All cultivation will be
conducted in an indoor facility, as outdoor cultivation including outdoor greenhouse cultivation
is prohibited, per SEC 9-3312(a)(2).
Post-production: Our facility will have proper post-production space, which includes
Drying room, Curing room and Packaging rooms to weight and package all products. The room
will be reserved for product packaging, including ISO calibrated scales to weigh appropriate
amounts of product. The room includes our labeling station and final packaging station. Many of
our post-production areas are near each other to ensure our agents are not accessing off limit
areas of the facility, unless it’s necessary.
Given our structured grow cycle management techniques and the suitability of our post-
production areas, we feel we can adequately downstream our cannabis given our layout.
Shipping, Receiving & Loading area: Our RSL, including dispatch, waste, incoming
quarantine and chemical storage is large enough for multiple sprinter vans or large trucks to load
and unload product, this also includes a dispatch office. Our enclosed delivery system will
provide privacy away from “ordinary public view” and away from the main road. The RSL will
have roll up doors. There will be a dispatch office located with the RSL, that will also serve as
our driver safety checkpoint and delivery manifest processing center.
Offices & Training: Our facility will include office space and room to train our
employees. Our Fresno facility will be our California production headquarters. We will be able
to train our agents in our open office.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
71
Mechanicals: This includes our compressor, fertigation, irrigation, electrical and
mechanical areas. We will reserve space to ensure our engineers and agents can properly manage
and resolve any maintenance issues with our mechanical systems.
Other Areas: Our facility will include a research & development area, where we can test
products for heavy metals and other contaminants. We will also have the ability to come up with
customized formulations for our ingestible products. Our facility will also be properly equipped
with biosecure changing stations and locker rooms. We will have a male and female locker room
where all agents and visitors will change into their respective biosecure color-coded jumpsuits.
Design: Our facility will have stationary windows, meaning they cannot be opened. All
our doors will be sealed with proper weather stripping, keeping air circulating and filtered inside
of our facility. Onsite use and sale of cannabis products, alcohol and tobacco products will be
strictly prohibited, per SEC 9-3309(a), which we believe helps further mitigates any potential
cannabis odors from reaching to our neighbors. Negative air pressure will be maintained inside
the building at all times. Our 50,000+/- square feet of space will be the perfect size space to
cultivate our products all across Fresno. Our team expects demand to outweigh supply and our
facility will be built and ready to serve dispensaries at a moment’s notice.
We are fully confident we can move forward without any issues that may arise. We are
well funded, have operating and construction experience navigating this process, we should not
have any unforeseen or unsolvable issues. We feel our property is best suited for our proposed
use.
Cultivation Room Overview
We will have multi-tiered grow rooms, totaling 30,000 square feet of flowering canopy.
Each grow room will average approximately 100 flowering lights per room (1 light per 25 square
feet), producing 5.5 harvest annually, we can yield 1.5 to 2.0 pounds per harvesting light and up
to 1,100 pounds of raw flower each month. We will have the ability to harvest every nine weeks.
Our facility will have 2.0 additional acres were we will expand our canopy to 50,000 square feet.
Indoor grow rooms will include multi-tiered rolling benches with flood tables,
PhysioSpec Indoor spectrum Fluence – SPYDR and SPYDRx Plus LED, industrial fans for
cooling and air circulation, sealed flooring and CO2 air controls. All rooms will be built to
remove any chance of contamination with the highest level of biosecurity.
Stacked Bench Technology: All grow rooms will include multi-tiered V-Track rolling
benches, given our ceiling height we could tier as high as 4x to 5x, but we will start with two
tiers. These V-Track benches are 100% high-grade aluminum and include continuous flood
tables that are built in slight slop for drainage. The V-Track rolling benches can be easily
connected to run the entire length of our grow rooms. They incorporate V-Groove gauge 12
galvanized solid steel sealed precision ball bearing technology, with a weight capacity of 3,000
pounds. A stacked canopy will allow (i) more flexibility within our cultivation space, (ii)
optimizing the 20 feet vertical height of our building for maximum efficiency and (iii) increases
our plant canopy by 200% over stationary tables while increasing our cannabis yield by 85% to
110% on average.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
73
agents must change into their color-coded biosecure jumpsuits, which include wearing gloves
when handling cannabis or plant material, wearing a hairnet, or hat, a beard net (if applicable),
shoe protectors and mask. These procedures create a clean-room within a clean-room.
c. The estimated number of pounds produced per harvest, and the number
of anticipated harvests per year.
Maintaining Adequate Supply
We will have multi-tiered grow rooms, totaling 30,000 square feet of flowering canopy.
Each grow room will average approximately 100 flowering lights per room (1 light per 25 square
feet), producing 5.5 harvest annually, we can yield 1.5 to 2.0 pounds per harvesting light and up
to 1,100 pounds of raw flower each month. We will have the ability to harvest every nine weeks.
We estimate supplying Fresno and California will over 13,200 pounds of raw material annually,
at full capacity. We will have the opportunity to expand our grow rooms to 50,000 square feet or
more. Our business will phase out the facility as the Fresno market continues to grow.
Our Cultivation Manager and Inventory Manager will work in tandem to control supply
through a comprehensive cultivation, inventory and maintenance plan based on supply and
demand. To maintain an adequate supply, we will have strict grow room cycle management
procedures. Post-harvest, no room will be empty for more than seven days. We hope and expect
to never run out of product. Being well funded and operating with strong grow cycle
management, our plan allows our business to remain a long-term, stable and sustained source
cannabis products for years to come.
Similar Facilities: Our team has built similar size cultivation facilities as our proposed
Fresno facility and we have NEVER experienced a short fall in product due to internal operating
errors rather only when demand for our branded products grossly exceeds supply. We maintain
an adequate supply through strong operation and inventory management controls. Our Fresno
facility will have the maximum capacity to cultivate over 1,100 pounds per month. We will
maintain adequate supply by scaling up or down to maximum capacity depending on the
estimated demand and growth of the Fresno market.
Our operating experience will allow our cultivation agents to control supply. Below is
how we will maintain adequate cannabis supply to the Fresno market.
• Strong Standard Operating Procedures: Our experienced cultivation agents follow our
step-by-step SOPS’s to produced high quality cannabis, consistently. No matter the
environment, our SOP’s are outlined to produce high yielding, consistent food-grade
cannabis products. All high-quality finished products start with having high quality
inputs without deviation and interruptions.
• Grow Cycle Management: We have developed protocols to keeping grow room
turnaround time to no more than seven to ten days between cycles. By reducing the
downtime, we can reduce overhead expenses. Over time, we’ve also been able to
propagate the most robust genetics, which increases yield and reduces resources on
canopy management.
• Integrated Pest Management (“IPM”): It is very important not to lose crops due to
poor pest management or pathogen practices. Operating stringent medical markets for
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
74
5 years and our cultivation agents are proud to have NEVER lost a crop due to poor
pest management. We will implement our IPM plan that manages pests and other
potential contaminants through a combination of biological, cultural, and physical
tools to deter plant disease and pest issues. No cannabidiol oil or low THC oil will
have pesticide chemicals or petroleum-based solvents used during the cultivation,
extraction, production or manufacturing process, except that the Commission may
authorize the use of organic pesticides, certified by OMRI, for purposes of addressing
an infestation that could result in a catastrophic loss of cannabis crops. We believe in
using all-natural and organic products and DO NOT practice the use of pesticides.
• Adequate Facility Size: Our facility is a state-of-the-art design and build out, no
corners have been cut when designing our facility, meaning, we have limited “dead
space”. This includes 30,000 square feet of indoor canopy space. We will also have
another 2+/- acres to expand our canopy or post-production if allowed by the City
Manager and state of California. Ran by an experienced operator, like ourselves, we
can maximize the space using efficient economies of scale to produce a continuous
supply of cannabis.
d. Describe whether the cultivation operation will use natural light, artificial
light, or mixed light
We will use artificial indoor lights for our cultivation facility. Please see below the lights
we plan on using. All grow rooms will be equipped with PhysioSpec Indoor spectrum Fluence –
SPYDR and SPYDRx Plus LED that average light intensity of 1,000 micromoles over canopy.
PhysioSpec Indoor is a full-cycle spectrum optimized for rapid growth and complete plant
development. Tailored for growing plants from propagation to senescence (germination,
clones/cuttings, mothers, vegetative and flowering applications) in indoor environments. With a
CRI rating of 85, PhysioSpec Indoor offers a beautiful work and research environment with vivid
colors and greater contrast to study the health of our crop.
These style lights are ideal for high PPFD cultivation with multi-tier racking as they emit
90%+/- less radiant heat as traditional 1,000 watt HPS lights. Many cultivators will say LED
lights do not cultivate consistent high-quality cannabis, but with research we have found that
Fluence’s LED SPYDR series creates faster cycle management by harvesting is 8 weeks versus
the traditional 9 to 10 weeks – nearly 35 additional days of cultivation per year, (ii) deliver more
energy to the lower portion of the plant, creating higher overall yields, and (iii) lowering overall
energy costs by nearly 25% and a 37% savings in lighting energy. In a recent case study done by
a San Francisco indoor two tiered cultivation facility, they were able to double yield per harvest
room, have an 11% increase in cannabinoids, a 13% increase in terpenes and a 12% decrease in
cycle time. All statistics point to us LED lighting over HPS or HID lights. Given our mindset for
innovation and working toward more environmental friendlier cultivation options, we believe
PhysioSpec LED lighting has all the positive attributes of HPS lighting and removes the
negative, as growth can be controlled for a more sustainable cultivation environment.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
75
For our Clone phase we will use RAZRx lighting fixtures, where we will mount 5” above
plant canopy and the RAZRx was built for multi-tier large scale vertical cloning. These lights
typically average PPFD up to 375 micromoles over canopy.
As seen by the photo above these lights easily fit right into our V-Track racking system
and will be installed without problem.
e. Identify how cultivation waste will be rendered unusable and
unrecognizable, and how it will be stored and disposed of.
We will follow our procedures on waste disposal outlined in this section. Once
production targets are established, the cultivation of cannabis to meet those targets is overseen by
the Cultivation Manager. The growing techniques for our cultivation operations are set out
above. In addition to the growing techniques themselves, we control for quality and safety at
numerous points in the cultivation process using the following mechanisms.
We expect to produce approximately 750 pounds of gross dry biomass per harvest. Dry
flower yield will consist of 250 to 300 pounds, dry sugar leaves (trim) will consist of 75 pounds
and the remaining waste will roughly consist of 375 pounds or 50% of material waste per plant.
We will properly dispose and destroy waste in the following section.
Destruction & Disposal Policy
All cannabis plants, products and waste are accounted for at the Batch/Lot level. Such
waste is weighed at the point of collection and that information is entered into our Inventory
Tracking System. To preserve traceability through our ITS, separate lots of cannabis waste must
not be commingled. All unused cannabis from a given Batch/Lot are stored as a separate unit
from any other cannabis product, weighed and recorded before being rendered unusable. When
the CEO and Facility Manager confirms that the batch waste is ready for destruction, all lots are
given a final weighing by the CEO, and the weight is entered into our ITS in accordance with the
destruction procedure described in our SOPs.
Waste cannabis must be rendered unusable, unrecognizable and indistinguishable from
the components with which it is disposed and incapable of being ingested, inhaled, injected,
swallowed or otherwise used for certified medical use. We accomplish this by grinding cannabis
and incorporating it with other ground materials, so that the resulting mixture is at least 50%
non-cannabis waste by volume. The CEO is responsible for determining the quantity by volume
of non-cannabis material needed to meet or to exceed the 50% threshold.
SPYDRx Series RAZRx Series
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
76
The Inventory Manager will notify the Security Manager and the City Manager at least
48 hours in advance of destruction and schedule a time when the Security Manager can
supervise. The entire destruction process takes place in our designated destruction area, in the
shipping and receiving area, in direct line of site of the surveillance recording cameras,
verification conducted by our CEO.
At the outset of the destruction process, the Inventory Manager will supervise the
transportation of all waste cannabis containers of the designated batch to the shipping area. The
Manager weighs each container’s contents and enters the final weight into our ITS. The cannabis
waste from all of the lots is then ground with the non-cannabis content until the Manager
determines it is no longer usable or recognizable, meaning that it is incapable of being ingested,
inhaled, injected, swallowed or otherwise used for certified use.
The final mix is then weighed, and that weight is entered into our ITS. The post mixture
waste is handled differently based on whether it is compostable or not. Allowable grinding
material for non-compostable destruction include non-cannabis food waste, yard waste, our daily
ground used coffee, vegetable-based grease or oils, paper waste and cardboard waste. Non-
compostable post-mix will be placed in a locked dumpster marked as “Non-compostable Post-
mix”.
Cannabis waste rendered unusable must be promptly disposed. Disposal of any cannabis
wasted rendered unusable will be delivered to a permitted solid waste facility for final
disposition. If we use compostable mixed waste we will schedule for a compost, anaerobic
digester or another facility with approval of our local Department of Health. If we use non-
compostable mixed waste we will schedule for a landfill, incinerator or another facility with
approval of our local Department of Health.
Our CEO, Inventory Manager and other designated agents, will be trained on how to
handle hazardous and non-hazardous waste and which hauler to call to schedule a pickup. Upon
awarding a license we will contact our local waste hauler and build a relationship with their
account manager. Any mix that includes materials which failed a test for heavy metals is also
noted, so the hauler handles it accordingly.
The Inventory Manager will note the destination and date and time of waste transport and
will notify the City Manager with all proper information. An electronic documentation will be
maintained for three years.
Once cannabis byproduct, scrap, cannabis products are incorporated with nonconsumable
solid waste, it will be defined as “cannabis waste”.
We will be sure to keep a detailed record of the date of destruction and how much
cannabis product was destroyed. All cannabis will be weighed before destroyed and after
destruction. The records for destruction and disposal will be maintained for three years.
Cannabis waste will NEVER be sold. Disposal of the cannabis waste rendered unusable
may be delivered to a permitted solid waste facility for final disposition, examples of acceptable
permitted solid waste facilities include:
1. Compostable Mixed Waste: Compost, anaerobic digester, or other facility with
approval of the jurisdictional health department;
2. Noncompostable Mixed Waste: Landfill, incinerator, or other facility with approval
of the jurisdictional health department.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
77
All waste and unusable product will be weighed, recorded and entered into our Inventory
Tracking System prior to mixing and disposal. Verification of this event will be performed by a
supervisor and conducted in our designated destruction area with full video surveillance. Any
nutrient enriched grow medium will be disposed of as required by the State Environmental
Protection Act and the associated rules, or land applied at agronomic rates.
Disposal of Recalled Products: We will coordinate disposal of recalled cannabis with the
City Manager. The City Manager or its authorized agents may oversee the destruction and
disposal to ensure that the recalled cannabis is disposed of in a manner that will not pose a risk to
public health and safety. Product destruction at our facility will take place under CEO and
Security Manager supervision within the Receiving, Shipping and Loading area of our facility.
All destroyed products will be done in accordance with our policy addressing the disposal of
cannabis and cannabis products.
The primary goal of our Recall Plan is to protect public health by removing products
from our supply chain that may present a risk to health or safety. A related goal is to identify root
causes and revise current practices and SOPs to eliminate the problem(s) that lead to serious
adverse events.
f. Describe the use any gases used in the cultivation operation, such as CO2,
including storage, location and monitoring systems for employee safety.
Safe Handling of Fertilizers and Other Chemicals
As indicated above, our nutrient management plan was created based on years of
cultivation experience with an eye to product safety, employee safety, and environmental safety.
As such, our standard operating procedures require that all members of our cultivation team
follow the Safety Data Sheets (SDS) for every product on site. This is required not only to ensure
employee safety but to also ensure the proper and safe distribution of these materials to our
plants, thereby ensuring the safety of our products.
Similarly, all fertilizers, nutrients, additives, and chemicals will be stored in a dry and
cool environment, each in its own fireproof cabinet. All bottles of fertilizer or of plant additive
will be properly labeled per OSHA regulations. Anyone handling fertilizers or other chemicals
will be required to wear protective layers, gloves, a mask, and goggles if needed. We will keep a
record of all crop inputs will be maintained for at least three years at the facility and records will
include: the date of application; the name of the individual making the application; the product
that was applied; the section, including the square footage, that receive the application (by group
number); the amount of product that was applied; and a copy of the label of the product applied.
Products are available in different units, and when possible, the precise amount will be
ordered and used immediately for application. Storing large amounts of nutrients, amendments
and soil will be prohibited.
Foliar Applications: Cannabis uptakes a large portion of its nutritional needs from her
leaves. Foliar feeds are very effective in supplementing micronutrients to the crop. Controlling
droplet size and deposition is an art of the applicator. Spray droplet disposition is influenced by
droplet size, the force and volume of the air and the speed of travel of the application equipment.
Droplet size depends on nozzle size, style, and condition, spray volume, spray pressure and light.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
78
Once a sprayer has been calibrated its output rate is determined for a specific speed.
There may be times when this output rate needs to be changed to respond to variations in foliage,
density or space. The simplest way to alter the volume of spray being applied to an area is to
change the travel of the sprayer. A slower speed results in more liquid being applied while a
faster speed reduces the application rate. Operating application equipment too fast is a common
error and will result in poor coverage. Operating it too slow results in waste, possible over
application, and an increase in application time and cost. A limited range of adjustments can be
made so the applicator will need to map out their route prior to ensure even coverage.
Personal protective equipment for mixing products will be listed in the precautionary
statements section of the label. To avoid illegal over-application, measuring the products before
putting them into the tank will be ensured by the cultivation supervisor. Utensils for weighing,
measuring or mixing will be cleaned and stored in a safe area. Products will be measured and
poured below eye level. To prevent siphoning of product mixtures in the spray tank into the
water supply after the water flow has stopped staff will use a check valve or air gap.
Fertilizer and Nutrient Emergencies: Accidents may occur while when handling
fertilizers and amendments. These products can be hazardous in concentrated amounts for staff
and the ecosystem. Emergencies such as leaks, spills, fires, thefts, misapplication, or lack of care
in storage handling must be planned for and prevented. If a regency situation arises and staff are
exposed, they are to seek medical care immediately. If others are exposed and have adverse
reactions, they will also be supported in seeking medical care. Per SEC 9-3312(a)(6), pesticides
and fertilizers will be properly labeled and stored to avoid contamination through erosion,
leakage or inadvertent damage from pests, rodents or other wildlife.
In short, just as we have done in states like Colorado and Oregon, we will implement safe
and effective standards operating procedures in Fresno.
In addition to all of the discussion above, application of our knowledge of botany,
horticulture, and phytochemistry at all of our various cultivation facilities is further demonstrated
by the summary of our cultivation practices, policies, and procedures that we’ve described.
Everything about our practices, policies and procedures derives from all of the aforementioned
collective knowledge of our Director of Cultivation, our CEO and COO.
Worker Protection Standards (WPS)
All agents handling and applying nutrients, amendments or pest control products will
adhere to the agricultural use requirements of the label and will employ all personal protective
equipment prescribed by the label. Worker protection standards will comply with EPA
regulations as described in EPA publication “How to Comply with Worker Protection Standard
for Agricultural Products: What Employers Need to Know”, it will be used to protect workers
and product handlers, both of which are defined terms under WPS regulations. This will include
maintaining required information at a central location; conducting product safety training;
decontamination supplies; emergency assistance; providing appropriate notices before, during,
and after application; special application restrictions for greenhouses; compliance with early
entry protections; restrictions during applications and monitoring handlers; specific instructions
for handlers; equipment safety; and personal protective equipment and exceptions.
Business Plan TRADE SECRET
Appendix A: Evaluation Criteria
79
The following information will be continuously displayed, at a central location in our
cultivation facility where it is readily accessible and can be easily seen and read by workers and
handlers, before a product is applied and for 30 days after the restricted-entry interval expires or
if there is no restricted-entry interval for 30 days after the application ends:
• Product-specific application information, which will include: the location and
description of the area to be treated, product name, and active ingredient(s) of the
product, time and date the product is scheduled to be applied, and restricted-entry
interval for the product.
• Emergency information, which will include the name, telephone number and address
of the nearest emergency medical facility.
• The WPS safety poster developed by EPA, which will state that there are federal rules
to protect workers and handlers, including a requirement for safety training.
We will inform all cultivation agents where the information is located, allow unhampered
access to the information, be sure the poster, emergency information and application information
remain legible while posted, and promptly inform worker of any change in the information and
update the emergency information listed in the poster.
We will use CO2 to enrich our cannabis plants and maintain the following atmospheric
CO2 rates.
• Vegetative plants should maintain a CO2 level of 400-600 PPMs.
• Flowering should achieve 600-1500 PPMs, dependent on phase in cycle.
All grow rooms will have CO2 controls.
CO2 will be connected to our
grow room individual ventilation system,
thereby allowing our plants to receive
proper CO2 nutrients during life cycle.
Typically, CO2 is absorbed throughout
the day and increases the plants nutrient
cycle, but because the plants reside in an
air-tight sealed environment, we will need
to pump artificial CO2 to boost yields and plant growth. Our iPonic system will allow our
cultivation agents to monitor and manage all of the necessary environmental controls, including
temperature, humidity, ventilation, water supply and CO2. All controlled automatically and
possibly remotely. The system is compatible with many component parts, including a
hygrometer that measures the volumetric moisture levels in the soil and automatically turn on our
irrigation system when it detects the need for additional soil moisture.
Link4 iPonic Duel Zone Environmental Control
Community Benefits and Investment Plan
Appendix A: Evaluation Criteria
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
1
7.1 The CCB Application should describe the social responsibility plan. This should
include all benefits the CCB has provided or plans to provide to the local
community for example by directly aiding, participating in, or funding the work of
local non-profits, community-based organization, civic organization, or social
services organization. Benefits may be in the form of volunteer services, monetary
donations, financial support of City-sponsored activities or organizations, in-kind
donations to the City or other charitable organizations and/or contributions to the
Fresno Community Reinvestment Fun. It may also include, but is not limited to:
7.1.1 Providing funding for or hosting expungement clinics or outreach services.
7.1.2 Incorporating an environmentally sustainable business model including
energy efficient buildings and vehicles.
7.1.3 Utilizing vacant buildings, brownfields land, or blighted areas of the city for
the business
Our Company operates as a leading national branded cannabis company under our
flagship Viola. We feel we best represent the challenges of being targeted by the War on Drugs
as being minority owned in the cannabis industry which is 97% owned by white males. Our
Fresno team consists of many owners, managers and employees that were born, raised or
currently live in some of the most economically disadvantaged neighborhoods in the country. We
are majority owned by Mr. Delanno Hopkins, he was convicted of a non-violent cannabis drug
trafficking offense and served 18 months in Fresno prison. He is the best representation of Viola
partnering with individuals that were negatively affected by the War on Drugs and now have an
opportunity to participate as an owner and operator of a Commercial Cannabis Business.
As a team we acknowledged our passion of social economic empowerment and how it
can be realized through business ownership and having strong ties to our local communities. Our
Company is looking forward for the opportunity to provide high quality cannabis relief to
customers in Fresno suffering from some of the most challenging diseases and symptoms. Once
established in Fresno, we will allocate time to meet with directors, officers, executives and
founders of community organizations, which allows us to gain insight on how we can best
impact the immediate needs of the local community and organization. Our local Director
Community Outreach – Laneesha Senegal, is currently the CEO of HOPE, a 5013C non-profit
vocational training and entrepreneurship program that targets low-income communities.
Given the diversity of our team we have the perfect formula to give Fresno best-in-class
community service, not providing “lip service” to provide resources to the community. Our
Compassionate Benefits and Investment Plan (“CBIP”) mission is based on four pillars, (i)
providing affordable medicine for ALL, (ii) providing financial assistance to our local partners
that provide substance abuse programs in our Community Education and Training Center, (iii)
creating recidivism, expungement and job reentry programs, and (iv) have ample square footage
at our facility to demonstrate a commitment to community engagement.
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
2
We have begun to show community commitment, not for points on this application, but
because we care about disadvantaged communities, because they mirror or remind our owners
and employees of the communities they were born, raised and/or currently live. Our Company
has created a Community Impact Fund (“CIF”). The CIF will use proceeds from our operations
to donate and invest back into the community where we operate. We anticipate budgeting more
than or more, annually. Before applying for Fresno licenses, most recently we already
donated to the Association of the Advancement of Minorities Owners in Cannabis, an
organization that supports minority ownership in cannabis. We show our advocacy and
community engagement by actions.
Fresno Demographics: Community impact is a core value for our Company and our team
members. We believe when municipalities enact cannabis programs, those programs typically
create opportunities for wealthy individuals to amass more wealth and leave out the individuals
and communities that were affected most by the War on Drugs and opioid addiction. Fresno has
a 26% poverty rate, according to datausa census data and an unemployment rate of 10.1%
according the Bureau of Labor Statistics. Median household income in Fresno is , more
than below the California median household income of , per US Census. Our
CCB will bring more than 50 jobs, economic development through construction and tax revenue
through the sales of cannabis products.
COMMUNITY EDUCATION AND TRAINING CENTER (“CETC”)
Given our strong commitment to community engagement, our CEO, COO and architects
designed our proposed facility with a Community Education and Training Center (“CETC”).
This space will be separate of our facility, with its own entrance and exit and does not have
entrance access to any part of our production or storage areas. We will seek to educate
community members on responsible cannabis use and how to cope with substance addiction. We
will help facilitate counseling services, as our local
partners will have the experience in providing much
needed human services programs to underserved
populations and people living with an array of health and
human service needs.
Our partnered curriculum will include (i)
Alcohol/Substance Abuse Treatment, (ii) Mental Health
Services, (iii) Disability Services, (iv) Violence
Prevention and Trauma; and (v) Coping Strategies. Their
informational pamphlets will be in our CETC. We will
also work with other substance abuse service companies
located across Fresno. Fresno and surrounding cities,
like many other cities, has seen the devastating effects of
Floor Plan of our CETC
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
3
the opioid epidemic. If a non-profit or counselor needs to have a private counseling session, our
CETC will be fully built out and equipped with state-of-the-art technology, a cannabis education
library (with take home brochures), bathrooms, a kitchen and private consultation offices.
Community organizations will have access to our Community Education and Training Center to
host these events at no to little cost.
We will plan to host a series of year-round information sessions, at our Community
Education and Training Center. The topics and dates will be scheduled, advertised, and listed on
our website giving customers the opportunity to plan their attendance in advance and receive the
information that is most valuable to them.
We will create informational brochures and place them in highly visible common areas.
Topics include alternative methods and forms of consumption or inhalation by which one can use
cannabis, signs and symptoms of substance abuse, opportunities to participate in substance abuse
programs and information on tolerance, dependence and withdrawal. This will allow customers
to quickly obtain valuable information that they can review on their own time, refer to, and share
with other potential customers. All materials will be available for inspection by the City Manager
upon request.
Veteran and Indigent Services: Some of our team members have served in the military or
come from military families. We will support our veterans with mental, physical and social
services. In partnership with other local organizations our Director of Community Outreach will
host the following services and events at our CETC: (i) Periodic social worker consultations.
Many homeless veterans and other indigents have difficulty accessing public services because of
the lack of “simple” things like a state-issued ID or bus fare. One way we can help is by funding
social workers to guide them through these processes as well as the paperwork necessary to
begin receiving more substantial public services. (ii) Pet therapy. For many, pet therapy has
been shown to be an effective treatment for anxiety and PTSD. It also helps build community for
the veterans and indigent participants, many of whom have become reclusive because of mental
conditions. (iii) Addiction counseling. Substance abuse of all types often creates a vicious cycle
for suffering veterans and others and (iv) Resume writing and career preparation. All services
conducted in our CETC will be free of charge.
RECIDIVISM, EXPUNGEMENT AND JOB REENTRY PROGRAMS
Expungement and Job Reentry Programs is one of the major initiatives of our CEO – Mr.
Delanno Hopkins. Through this opportunity he will have a chance to have majority ownership in
a successful cannabis operation and help those negatively affected by the War on Drugs.
Members of our team have spoken with Fresno business owners and council members who want
to see skilled labor jobs in technology, agriculture and retail newly introduced but also provide
recidivism and job re-entry programs for those residents with non-violent cannabis criminal
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
4
records. All the community engagement that we have done and plan to do is in line with the
wants and need of local government officials.
As community partners we will offer our CETC to be used to encourage effective
wraparound services that will be provided to assist individuals previously arrested for nonviolent
cannabis offenses and traumatized to the experience of incarceration. Our Company has
committed financial and volunteer resources to Job Reentry Initiatives across the country. These
services include health screening, rehabilitative services, substance use treatment, mental health
services, training and care coordination services, thus also addressing key social determinants of
health which may lead to high rates of recidivism for our targeted population.
These services increase the individual’s employability and productivity. One of our
targeted approaches is helping the recently expunged with Post Traumatic Stress Disorder
(“PTSD”). According to research conducted by the Illinois Criminal Justice Information
Authority (2018), recognizing trauma histories within incarcerated individuals is important
because prison itself can exacerbate PTSD symptoms. Further, prevalence rate of PTSD is higher
among those in correctional facilities than those in the general population and are often as high
or higher than those individuals that served in the military. Wraparound services are needed to
find housing, employment, treatment and other services to reintegrate those individuals into our
communities. We will also create programs around life skills, such as job readiness, resume and
interview training, money management and community engagement. We plan to provide
periodic social worker consultations. Many homeless or veterans and other indigents have
difficulty accessing public services because of the lack of “simple” things like a state-issued ID
or bus fare. One way we can help is by funding social workers to guide them through these
processes as well as the paperwork necessary to begin receiving more substantial public services.
Most recently, in 2020, we launched “Viola Cares” with a partnership with a national
nonprofit organization “Rood & Rebound”. Our Company, in conjunction with Root & Rebound,
will produce a first-of-its-kind toolkit designed specifically for people with non-violent cannabis-
related convictions, to be entitled: “A New Leaf: A How-To Guide for Successful Reentry After
a Cannabis Conviction.” An excerpt from the February 2020 article written in Cannabis Business
Times:
“Viola’s first strategic alliance within its Viola Cares program kicks-off with Root &
Rebound. Root & Rebound is home to lawyers and advocates committed to restoring power and
resources to the communities most harmed by mass incarceration and the War on Drugs. Their
work combines direct legal services with systems-changing policy advocacy and public
education, in an effort to move society toward greater racial and economic equity, justice,
collective liberation and intergenerational healing. Their educational resources like the
California Roadmap to Reentry, the Reentry Planning Toolkit, the National Fair Chance
Housing Toolkit, and others have supported thousands of people as they work to navigate the
collateral consequences of an arrest or conviction history.” – Patrick Williams, Cannabis
Business Times
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
5
We fully understand that the Fresno’s unemployment rate is at an all-time high around
10.1%, according to the Bureau of Labor Statistics, September 2020. Many Fresno residents are
without jobs due to COVID-19 shutdowns, major corporations looking to cut expenses and
squeeze profit margin given the pandemic, but in ALL states that operate cannabis programs,
they deem cannabis an essential business. If our Company is awarded a CCB license, we plan on
staffing our facility immediately. We plan on creating a Layoff Reemployment Program,
where if an individual has been recently laid off due to “big industry or industrialization” our
Director of Human Resources will place their resume near the top of the pile when looking to
staff our locations. Every month, California publishes a WARN Activity Listing, that outlines
massive layoffs by companies due to closing or budget cuts. We realized that many of these
layoffs are targeted at minorities and women. Our Compassionate Benefits and Investment Plan
would like to help those individuals by providing and training those individuals with new skills
to be candidates for jobs in cannabis in Fresno.
OTHER COMMUNITY ENGAGEMENT INITIATIVES
It is very important that our Company empower and educate local community members
about the following: (i) the science, history and health benefits of cannabis, (ii) empowerment
through voting registration expressing your right to vote and (iii) community training on law
enforcement interactions. The War on Drugs not only negatively impacted families of color
through incarceration, the opioid epidemic has done huge harm to the fabric of American
families and how Schedule II-IV drugs that are prescribed can be considered “gateway drugs” to
cocaine, methamphetamine or heroin and other illegal substances.
Without proper education many residents despise the use of cannabis as an alternative to
opioids or other addictive / abusive drugs. Often times, the lack of cannabis education can
project a valid sense of ignorance, but after speaking with knowledgeable agents that understand
the community needs, community members become more receptive to cannabis use. We will
conduct community meetings to educate those individuals on the positive health benefits of using
cannabis within one’s daily lifestyle. We will also discuss the Fresno rules and regulations, to
make sure our community members are not misinformed on consumption and possession laws.
During education sessions we will use our Fresno law enforcement relationship to
provide information on how to interact with police when stopped with medical cannabis in
possession. We do not want any of our customers to think decriminalization means disregard for
the law. Our Company promotes safe and responsible use of medical cannabis at all times. Led
by our Director of Community Outreach, we will inform customers on the “do’s and don’ts” of a
traffic stop, hopefully reducing the amount of criminal offenses because of cannabis possession.
Not only will we meet with community members, but we will also educate local law enforcement
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
6
officers on things to look for when confirming possession of cannabis. We believe everyone
wants to see all communities policed in a responsible, safe and respectful manner.
The diversity of our team is proven through actual diversity of our actions. In 2020 we
partnered with a non-profit, Yo Soy Ella Inc., which is a woman owned, operated and funded
organization that provides mental and emotional wellness services, and holistic healing to
marginalized Latinx women. Yo Soy Ella has served over 300 Latinx women annually. The
founder is first generation American and her parents fled financial instability from their native
country of Panama to seek refuge in America. Yo Soy Ella was founded in 2012 and served a
need in the Latinx neighborhoods as Latinx women were being marginalized and not provided
culturally appropriate services to deal with physical and mental abusive households. Our
Company has developed a partnership with Yo Soy Ella, to lead cannabis education classes in
Spanish and the founder will serve as our Heritage Liaison, bridging the gap between the Latinx
culture and the positives of cannabis in majority Latinx neighborhoods. Fresno has a large Latinx
community consisting of 49.6% of the total population. We will partner and collaborate with
Fresno Latinx community organization to provide financial assistance and cannabis education.
The level of our commitment to local community can be seen anywhere we operate. For
example, in Detroit we hosted a Turkey Giveaway Drive for those families in need of providing
food for their Thanksgiving. We gave away more than turkeys and sides to more than 2,000
families in need, we spent on the event and signed up more than 500 volunteers. The
event was co-sponsored by Viola, local radio station, local hip hop entertainers and athletes.
Community engagement is a serious pledge within our Company, so serious that Al Harrington,
our founding partner personally hosted, and hand delivered turkeys. In Fresno, we plan to
provide turkey giveaways, community branding campaigns, neighborhood beautification
projects, sponsoring local youth athletic teams, sponsoring health and fitness days and
sponsoring a back to school drive, giving away backpacks to those parents in need of assistance.
An excerpt from the December 2019 article written in Forbes:
“The event, a result of a partnership between Harrington’s cannabis brand, Viola, and Motown
Records (the legendary label that put out records by some of the biggest names in music history,
from Stevie Wonder and Marvin Gaye, to Diana Ross, the Jackson 5 and Bruno Mars) saw
Detroit Mayor Mike Duggan and the celebs come together to gift people 2,000 turkeys and diner
sides for Thanksgiving.” – Javier Hasse, Senior Contributor, Forbes
All community programs will be funded using proceeds from our operations placed in
our Community Impact Fund. Upon being hired all agents must commit to 8 hours of local
community service. We expect to have well over annually in our Community Impact
Fund and all funds will be spent on the local community and for our customers. Given our
national brand, our celebrity ownership and our homegrown workforce we believe our
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
8
Facilitator for the Mayor’s Citizen’s Academy Laneesha was a visionary who championed the
citywide effort to forge a partnership between non-profits and parks and recreation centers.
Ms. Senegal received a Bachelor of Arts in Organizational Leadership from Fresno
Pacific University.
Per SEC 9-3309(m), during our first year of operations, our Director of Community
Outreach will attend meeting with the City Manager and other interested parties as deemed
appropriate by the City Manager to discuss costs, benefits and other community issues arising as
a result of implementation of this Article. After the first year of operation our owners and
community relations teams will meet with the City Manager as requested.
Alternative Energy Usage
Active Solar Power: Although our plans do not call for starting with solar power, the
facility’s roof will be particularly amenable to future installation of a photovoltaic system to help
offset a portion of the building’s electrical load. To accommodate the eventual conversion to
solar, the initial construction phase includes plans to install conduit to support the future
photovoltaic system. Overall size of the system will be investigated to provide optimum
cost/benefit with regard to the building’s electrical requirements. If capacity meets demand, we
would like to expand canopy in our facility and add more grow rooms. As grow room area is
increased, the size of the photovoltaic system can be adjusted to provide a percentage of the
power requirements. Once awarded a license we will have utility agreements in place, with a
local solar panel company.
Passive Solar Heating: We plan to employ passive solar heating. Passive solar design
allows us to reduce heating and cooling loads by taking advantage of the site, climate, and
materials to minimize energy use. We will explore the possibility of supplementing our electric
with solar panels to cover our lighting and low-voltage needs. The building will utilize control
strategies such as roof overhangs and low-emissivity (low-e) blinds to shade office windows in
the summer and operable vents and dampers to restrict or allow heat flow. We will insulate with
high “r” value, bio-based foam insulation to further reduce thermal loss.
Geo-Thermal Heating: In addition to passive solar heat, a geo-thermal heating and
cooling system can be installed to harness the thermal differential from the earth and take
advantage of the constant ground temperature instead of the fluctuating outside air temperature.
This will allow us to heat, cool, and supply hot water to the building more efficiently. To
increase the cooling potential of the air conditioning system, we will use air circulators during
the warm summer months (outside of the separate storage area climate controls). We are
currently discussing Geo-Thermal Heating options with engineers and receiving pricing.
Lower Energy Consumption: We will install low-e windows with low U-factors/U-
Values and low air leakage ratings to control heat transfer. Low-e windows have been proven to
reduce energy costs by as much as 15% to 20%. We will also consider the Solar Heat Gain
Coefficient (SHGC) for each window based on climate, orientation, and shading to better control
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
9
the amount of solar radiation admitted to the
building. To assist in cooling the interior of the
building we will install tinted film on all exterior
windows.
We will use natural lighting technology,
in any room where cannabis is not cultivated,
dried or cured, provided by Solatube “SkyVault”
tubular daylighting devices (TDDs). Solatube
SkyVault Series is a line of modular, high output
tubular daylighting devices that deliver massive
amounts of daylight to large volume spaces with high, open ceilings. Luckily our building has
ceiling heights as high has 25 feet. Sunlight enters the Solatube device and that energy is turned
into natural light to be used inside our facility.
TDDs are useful to bring daylight into interior spaces without sacrificing security as
compared to traditional skylights. Additional lighting will be provided by LED lights. All lights
in less-used areas, such as bathrooms and breakrooms, will be on timers.
We will rely on Energy Star ratings for equipment, fixtures and kitchen area appliances to
find the most efficient items. This includes installing water-efficient plumbing and appliances,
such as low-flow toilets and sensor-based hand washing faucets. We will have the ability to add
tablets for all our daily log books and training materials. All equipment unnecessary to security
and product storage will be turned off in the evenings. We expressed our interest in working with
salvaged fixtures, such as shelving, countertops and tables with our design team. Repurposed
furniture cuts out manufacturing and shipping and will also lend the space a more comfortable
feel. We want our employees to be comfortable and their experience to be empowering for our
community to start thinking “green”.
ySolatube–SkyVault tubular daylighting devices
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
10
7.2 Describe the Commercial Cannabis Business plan to develop a public health
outreach and educational program that outlines the risks of youth use of cannabis
and that identifies resources available to youth related to drugs and drug addiction.
Given our strong commitment to community engagement, our CEO, COO and architects
designed our proposed facility with a Community Education and Training Center (“CETC”).
This space will be separate of our facility, with its own entrance and exit and does not have
entrance access to any part of our production or storage areas. We will seek to educate
community members on responsible cannabis use and how to cope with substance addiction. We
will help facilitate counseling services, as our local partners will have the experience in
providing much needed human services programs to underserved populations and people living
with an array of health and human service needs. We will develop a city approved public health
outreach and educational program for youth organizations and educational institutions that
outlines the risks of youth use of cannabis and that identifies resources available to you related
drugs and drug addition.
Our partnered curriculum will include (i)
Alcohol/Substance Abuse Treatment, (ii) Mental Health
Services, (iii) Disability Services, (iv) Violence
Prevention and Trauma; and (v) Coping Strategies. Their
informational pamphlets will be in our CETC. We will
also work with other substance abuse service companies
located across Fresno. Fresno and surrounding cities,
like many other cities, has seen the devastating effects of
the opioid epidemic. If a non-profit or counselor needs
to have a private counseling session, our CETC will be
fully built out and equipped with state-of-the-art
technology, a cannabis education library (with take
home brochures), bathrooms, a kitchen and private
consultation offices. Community organizations will have access to our Community Education
and Training Center to host these events at no to little cost.
Addiction & Drug Abuse Support: We will also seek to educate at risk youth on the risks
of early cannabis use and addiction. We will facilitate counseling services through a local Fresno
human services agency that uses a continuum of care approach to provide much-needed
programs to underserved populations and people living with an array of health and human
service needs. We will work in partnership to develop a curriculum regarding (i)
Alcohol/Substance Abuse Treatment, (ii) Mental Health Services, (iii) Disability Services, (iv)
Violence Prevention and Trauma; and (v) Coping Strategies.
Floor Plan of our CETC
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
11
At Risk Youth Programs
We will us our celebrity platform to speak with at risk Fresno youth regarding risks of
youth use of cannabis, early addiction and prevention. We will offer a few programs that include:
• Mentoring program designed to empower young adults and teenagers into becoming
leaders by encouraging positive relationships with adults to make positive impacts.
Desired outcomes include participating youth will have better school attendance,
higher academic performance and improved social and emotional skills. These
outcomes typically lower engagement in unhealthy behaviors like drug and substance
abuse or violence.
• Creative learning and entrepreneurship programs to identify the gifts of teenagers and
young adults and bring their talents to the forefront.
• Multi-faceted youth development program. Its purpose is to instill in youth the core
elements and needed competencies for healthy human development.
Along with the above programs, many of our team members grew up on D.A.R.E. (Drug
Abuse Resistance Education) programs in elementary schools which taught us that drugs are
harmful, addictive and can lead to incarceration or death. This had a positive lasting impact when
faced with drug interactions as a youth in middle or high school or even college. While many
D.A.R.E. programs are obsolete, we plan to partner with the local Public Schools’ Department of
Social and Emotional Learning to initiate conversations of drug awareness. Many public schools
sponsor Red Ribbon Week, which is a weeklong program that implements drug awareness,
similar to D.A.R.E., by allowing parents, teachers, educators and community organizations to
raise awareness of the problems caused by drug abuse.
Our Director of Community Outreach will sponsor Red Ribbon Week in all communities
where we operate, typically partnering with local elementary and middle schools. Red Ribbon
Week is a curriculum that teaches the destructive effects of drug abuse and opioid abuse. Action
can be taken by the smallest and largest of events, such as sponsoring an anti-drug poster and
essay contest, creating an anti-drug Public Service Announcement (PSA) to be posted on our
Company social media account, hosting community drug awareness events, such as health and
wellness days, bike-a-thons, classroom decorating contest and taking the pledge to promote
living a healthy, drug-free lifestyle. Our team has reached out Chicago Public Schools about
sponsoring these programs and we look forward to sponsoring in all areas where we operate.
Proceeds from our Company’s operations will be used for our Community Impact Fund which
will be used to sponsor and host drug awareness events.
Photo: Jorge Meza Viola Launches Viola Cares with National Nonprofit Organization Root & Rebound
The social impact initiative aims to destigmatize minority representation and increase
social equity within the cannabis industry.
SUBSCRIBE
February 28, 2020
Posted by Patrick Williams
Vendor News
On Feb. 26, Viola, a nationwide leader in the production and sale of premium quality
cannabis products, founded by NBA veteran Al Harrington, announced the official
launch of its social equity initiative, Viola Cares. Through education, equitable offerings,
expungement, and incubation programs, the initiative will result in more than 10,000
jobs, hundreds of new business owners and expanded industry diversity by increasing
representation, facilitating community building and providing employment opportunities.
Viola’s first strategic alliance within its Viola Cares program kicks-off with Root &
Rebound. Root & Rebound is home to lawyers and advocates committed to restoring
power and resources to the communities most harmed by mass incarceration and the
War on Drugs. Their work combines direct legal services with systems-changing policy
advocacy and public education, in an effort to move society toward greater racial and
economic equity, justice, collective liberation and intergenerational healing. Their
educational resources like the California Roadmap to Reentry, the Reentry Planning
Toolkit, the National Fair Chance Housing Toolkit, and others have supported
thousands of people as they work to navigate the collateral consequences of an arrest
or conviction history.
Viola, in conjunction with Root & Rebound, will produce a first-of-its-kind toolkit
designed specifically for people with cannabis-related convictions, to be entitled: “A New
Leaf: A ‘How-To Guide’ for Successful Reentry After A Cannabis Conviction.”
“At Viola, we live and breathe the belief that a cannabis conviction should never be
considered a life sentence,” said Al Harrington, founder, Viola. “In joining forces with
Root & Rebound, we will look to help those communities of color who have historically
been the victims of cannabis-related incarceration and who have fallen on hard times,
and turn those struggles into opportunities for success within this rapidly growing
industry.”
Opportunity within the cannabis industry only continues to grow as legalization
progresses and passes into law across the country, and Viola is breaking the barrier of
entry for minorities to contribute to that growth through cultivation and entrepreneurship.
“We’re honored to be working side-by-side with Viola on such an important initiative--
one that positively impacts thousands who have been unfairly stigmatized by their prior
cannabis-related incarceration,” Katherine Katcher, founder and executive director of
Root & Rebound. “Together we’re changing that conversation, leveling the playing field
for minorities and creating opportunities for those deserving of a second chance.”
Viola hosted the official launch of Viola Cares on the evening of Feb. 26 at its Hollywood
HQ.
The evening commenced with Viola CMO Ericka Pittman, who welcomed guests with
opening remarks.
Viola co-founder Al Harrington then introduced the partnership sharing how Viola plans
to use their platform to amplify the work and impact of Root & Rebound.
Root & Rebound team Eliana Green and Sandra Johnson led by founder and Director
Katherine Katcher joined Harrington to kick off the moderated panel. The fireside chat,
“The Effect of Social Impact and the Path Forward,” dove into the current issues our
country currently faces with mass incarceration. Sandra candidly shared her first-hand
experiences being collateral damage from the war on drugs and disclosed her re-entry
journey through Root & Rebound. Sandra tearfully explained how the system had held
her hostage to her past as she struggled to find and hold jobs despite doing everything
right.
Al Harrington opened up about the brand legacy that has shaped the New Leaf initiative
and the ways in which it will alter the trajectory of social equity moving forward. Both
Viola and Root & Rebound shared with the room the victorious outcome they envision
through the alliance: the ability to employ every person that returns from incarceration
as they reintegrate back into society.
https://www.cannabisbusinesstimes.com/article/viola-launches-viola-cares-root-and-
rebound-social-equity/
Multi-State Operator Cannabis Business
Social Equity Policies in Cannabis Industry
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 1/7
Vices
A column about cannabis, hemp, CBD and psychedelics.
Why Kash Doll And Vezzo
Partnered Up With Al
Harrington’s Weed Company,
Even Though They Don’t Smoke
EDITORS PICK 932 views Dec 6, 2019, 04:09pm EST
Javier Hasse Senior Contributor
It was a festive occasion in Detroit as people gathered to meet rappers
Kash Doll and Vezzo, as well as NBA star Al Harrington – and get a free
turkey ahead of Thanksgiving out of it all!
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 2/7
Vezzo takes a sel e with a child and
mother. BREANN WH E
Vezzo, Kash Doll, Al Harrington (L-R) BREANN WH E
The event, a result of a partnership between Harrington’s cannabis brand,
Viola, and Motown Records (the legendary label that put out records by
some of the biggest names in music history, from Stevie Wonder and Marvin
Gaye, to Diana Ross, the Jackson 5 and Bruno Mars) saw Detroit Mayor
Mike Duggan and the celebs come together to gift people 2,000 turkeys and
diner sides for Thanksgiving.
The giveaway coincided with the opening of Viola’s first flagship retail store
in the Motor City.
A Smoke-Free Environment
Beyond the obvious relevance of such a generous act and the joy these
celebrities brought to the good people of Detroit, what makes this
partnership really interesting is the fact that neither Kash Doll nor Vezzo
consume cannabis.
Yes, you read right: rappers Kash Doll
and Vezzo are not into weed – at all. In
fact, both lead lives that are pretty much
free of all mind-altering substances.
Vezzo never drinks, while Kash might
have a few glasses of champagne a
month, tops.
MORE FOR YOU
Even The Bookies Want The Election To Be Over—And The Betting To Stop
Masters 2020 Final Results: Favorites, Longshots & Legends
Could President Joe Biden Legalize Marijuana? Not Really—And The
Marijuana Industry Doesn’t Want Him To Try.
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 3/7
“I don’t like to smoke weed or take pills. I don’t have an issue with people
who do, but I don’t,” Kash explained.
Vezzo added, “I don’t consume cannabis either. Ever. But I’m not against
other people consuming cannabis.”
He also called for more research around marijuana and explained he
understands the difference between this plant and other dangerous things
like cocaine, heroin or guns. These should remain outlawed, he noted. But
cannabis: we have to make up our minds; “we either want it legalized or
not.”
“This is a gray area and, for me, there’s no balance in gray areas – you know
what I’m saying? How is it possible that some people can have rooms full of
legal plants while others go to jail for the rest of their lives for the same
plant?” Vezzo continued.
See Also: Eric B. & Rakim’s ‘Follow The Leader’ Reimagined
Displaced Michael Bublé From His #1 Billboard Spot—And
Cannabis Played A Big Role
“I believe cannabis should be legal on the federal level. You look at
Michigan, you look at all of the states that have legalized recreational
marijuana, and you see an impact on the [employment, fiscal revenue, etc.]
numbers.”
So, what in the world made them want to partner with a weed company, of
all businesses in Michigan?
“I take my hat off to Vezzo and Kash Doll for
being open minded enough to partner with a
cannabis company even though they don’t
consume themselves.”
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 4/7
An Unexpected Partnership
When asked about this unexpected partnership, Kash Doll explained, “Viola
and Al are bringing new business and jobs to Detroit… I’m happy to partner
with anyone that’s investing back into the city and helping give new positive
opportunities to the people of Detroit.”
DETROIT, MI HIGAN MAR H 09 Detroit rapper Kash Doll performs in support of The Motivation Tour
at ... [+] GE Y MAGES
She repeated: it’s all about picking good people to collaborate with. Period.
“I don't care what you’ve done in the past, who you are, or whatever. I love
to just collaborate with people trying to do something great for the people,
so I was honored that they wanted to work with me,” Kash went on.
Al didn’t mind Kash and Vezzo’s position either. “We wanted to do
something good and partner with local rappers, entertainers, even athletes,
to make an real impact on the community,” he explained. “Being from
Detroit, Kash and Vezzo helped us, out-of-towners, really get the job done.
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 5/7
Al Harrington and Vezzo in Detroit.
BREANN WH E
See Also: Key Committee In Congress Approves Marijuana
Legalization Bill
“Kash and Vezzo really made a difference. A lot of people showed up and I
feel like they are going to have a better holiday because of them,” Harrington
continued.
Vezzo was first and foremost drawn to
Viola because of Al Harrington’s
history of involvement with the Detroit
community. But there was another
component to the Motown-Viola
partnership: willingness to help.
“What’s really sad is I went to many
companies and brands, and nobody
else wanted to help,” he said. “It’s crazy
that it takes a cannabis brand to help
these people.”
For readers who are not particularly
familiar with the cannabis industry,
there’s one thing you should know:
cannabis brands are already exposed to
extremely high taxes when compared to any other business out there, and
many of these charitable donations cannot be deducted from their taxes
either, due to provisions in Section 280E of the Internal Revenue Code.
“What’s really sad is I went to many
companies and brands, and nobody else
wanted to help... It’s crazy that it takes a
cannabis brand to help these people.”
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 6/7
“I take my hat off to Vezzo and Kash Doll for being open minded enough to
partner with a cannabis company even though they don’t consume
themselves,” Al concluded. “I think it’s admirable that they realize that this
is bigger than if they use the product or not… What we need to realize as
blacks and minorities is that this is a unique opportunity for us to
participate in an industry that pretty much was built on our backs. So it’s
great that we can break these barriers, change the stigma,
Sharing The Green
Vezzo said he went to all kinds of companies, from the food to the clothing
space, looking for partners to help him bring some joy to people during the
holidays. “Nobody wanted to help with this giveaway,” he disclosed. “We
have so many big businesses and corporations just in Detroit alone that it’s
crazy it takes a small cannabis business to actually want to give out to the
community.
“I asked myself this question many times… On top of not helping anyone,
many companies out here are making people work for 60 hours, making
them build an entire car, but not offering health insurance and things like
that. They just leave their employees to figure out things on their own, even
Christmas and Thanksgiving. Even though they know many can’t provide a
nice meal for their families, they won’t lift a finger to help. But Viola did.”
Vezzo, Kash Doll and Al Harrington all seemed extremely moved with the
Thanksgiving event and turnout. “It feels great,” they said once and again.
“I feel it’s a blessing to be in a position where we could provide many
families a full Thanksgiving meal, which is not cheap,” Vezzo said.
“It was just amazing, it made my heart happy.
This was one of my favorite things to do.”
Neighborhood Compatibility Plan
Appendix A: Evaluation Criteria
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
1
3.1 Describe how the CCB will proactively address and respond to complaints related to
noise, light, odor, litter, vehicles and pedestrian traffic
Our Commercial Cannabis Business (CCB) will have a Neighborhood Committee (NC),
that consists of the CEO, Facility Manager and designated cultivation agents. If there are any
issues with noise, light, odor or trash, our neighbors can contact our committee through our
website, or social media. Along with our public information, our CCB will provide the name,
telephone number and email address of our Neighborhood Committee contact to whom notice of
problems associated with the business can be provided. We will provide our contact information
to all businesses and residences located within one hundred (100) feet of our business. SEC 9-
3309(m)(1). Our Neighborhood Committee will receive complaints, review complaints and
provide solutions for the compliant. Please see below how we prevent noise, light, odor and
waste management
Loitering, Nuisance Prevention & Onsite Parking
Our Company believes in being good neighbors and complying with all rules and
regulations. Our facility will operate like any other law-abiding business. Unlike many other
local businesses, we will have security officer(s) roaming the exterior of the facility, preventing
loitering from visitors or others. Our facility will have a no loitering policy and “NO
LOITERING” sign will be visibly placed at our entry door and near all parking spaces.
Employees are expected to leave the parking lot promptly after work. A security guard roaming
our building will consistently and systematically prevent individuals from remaining on the
premises if they are not engaging in activity permitted by the Act or rules, which includes
preventing loitering in and around our property. If individuals are loitering, our security staff will
ask them to leave our property and record any information regarding license plate or physical
description of the individuals. If we see the individuals loitering multiple times, we will notify
Fresno law enforcement. Per SEC 9-3309(l) our CCB will prohibit loitering by persons outside
the facility both on the premises and within fifty (50) feet of the premises.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
Our building will have all the necessary attributes to serve employees and the
community. We will have a large, private and dedicated onsite parking lot that provides handicap
Americans with Disability Act (ADA) spaces. Our security staff would monitor our parking lot
and we would comply with our typical surveillance plan. The parking lot will have dedicated
security surveillance, including 1 camera and exterior light for every 5 parking spaces. Cameras
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
2
will be equipped with license plate recognition and low light high definition capabilities to over
100 feet from the exterior of the building.
Our facility will provide law enforcement and neighbors within 100 feet of our building
with the name, phone number and email of our CEO and Security Manager to notify during and
after operating hours whom they can report problems if they were to arise.
Lighting
Our CCB will keep the outside perimeter well-lit. All cameras are equipped with infrared
illuminators, in the event that lighting is compromised; these infrared illuminators will produce
clear visible video data in absolute darkness.
Our facility will be well lit during all hours of the day
using smart lighting. Exterior lighting will not distract or
hinder the local neighborhood activities but will make visible
any intruder trying to divert product. Our design will comply
with Fresno Outdoor Lighting Ordinance rules as well as
Fresno lighting for security code. Our lighting system will
provide sufficient illumination and clear visibility to all
outdoor areas of premises, including all points of ingress /
egress and parking lots, reduce light pollution and will not
trespass onto adjacent properties.
We plan on installing LED Cobra Head Lights in all parking areas. These style lights are
often used for street lighting because they’re shaped in such a way that diffuses light to cover a
wide area of ground. Our delivery doors will also include LED lights that will monitor the
receiving, shipping and loading area during all hours of the day. Our Cobra Head Lights will be
maximum heights of 16 feet with compact housings emitting 120-277 watt lights. For safety and
security, during business hours, all parking areas and heavy pedestrian areas will be equipped
with Cobra Head Lights that will provide a minimum one-foot candle of light at ground level
during the hours of darkness. We plan to install one exterior light for every 5 parking spaces. Our
lights will be shielded or recessed to reduce light bleed to adjoining properties. Our local
construction partners will make sure light bulbs are not visible from off the site and check for
glares and reflections within boundaries of our facility.
All of our exterior lights will face downward and away from adjoining properties and
public rights-of-way so that no on-site light fixture directly illuminates an area off the site. None
of our exterior lights will permanently blink, flash or be of unusually high intensity or brightness.
All exterior lights will be sufficient to deter nuisance and criminal activity and facilitate
surveillance and must not disturb surrounding businesses or neighbors.
LED Cobra Light -Example
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
3
Community Involvement
We believe the detection of nuisance and cannabis odors from outside our facility will be
a team effort with our surrounding neighbors. As experienced cannabis operators, many times we
become “nose-blind” to the odor of cannabis. We will regularly monitor the site and point
sources of odor generation. By forming the Neighborhood Committee, we will validate that our
technology, maintenance and testing are all functioning properly. Finally, given our proximity to
neighboring buildings we will have a process for the reporting of odor detection by staff and the
public to facilitate immediate response. Every business and resident within one hundred (100)
feet will be given the contact information of our Neighborhood Committee. If any issues arise
the local neighbors can contact our facility directly.
Proactive communication through the NC is an excellent way to promote the emergence
of communication between the employees of our facility and nearby businesses and residents. In
the process of setting up the NC, a group of volunteers from the community are trained to
recognize and quantify odors and how to report odors in a consistent manner. The NC provides
an effective communication channel between members of the community and our CCB
employees.
Our security staff will constantly remind our employees and visitors to be mindful of our
neighbors and our neighborhood to ensure they are entering and leaving our facility quietly,
parking in designated spaces and not being a nuisance in and around our CCB.
This helps to convey the odor mitigation plans objectives and odor observations relevant
for environmental monitoring and management operations. On a regular basis, members of the
NC are invited to review the results of their participatory monitoring and actions implemented by
our CCB.
The Neighborhood Nuisance Form will be provided on our website. The form can be
downloaded submitted by email, in person at our facility or mailed to our facility.
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
4
3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having
impacts on its neighbors and the surrounding community
Our Company believes in being good neighbors and complying with all rules and
regulations. Our facility will operate like any other law-abiding business. Unlike many other
local businesses, we will have security officer(s) roaming the exterior of the facility during
business hours, preventing loitering or negative impacts from visitors or others. Having security
onsite will prevent many of these issues and typically cannabis businesses tend to have positive
impacts on communities because of the constant security presence. Our facility will be managed
with local Fresno residents. We feel this is important because local residents tend to care about
their neighborhoods and this has proven to be true in our other facilities. We will have a
Neighborhood Committee that will be provide solutions if our CCB becomes a nuisance to the
community.
Our facility will have a no loitering policy and “NO LOITERING” sign will be visibly
placed at our entry door and near all parking spaces. Employees are expected to leave the
parking lot promptly after work. A security guard roaming our building will consistently and
systematically prevent individuals from remaining on the premises if they are not engaging in
activity permitted by the Act or rules, which includes preventing loitering in and around our
property. If individuals are loitering, our security staff will ask them to leave our property and
record any information regarding license plate or physical description of the individuals. If we
see the individuals loitering multiple times, we will notify Fresno law enforcement. Per SEC 9-
3309(l) our CCB will prohibit loitering by persons outside the facility both on the premises and
within fifty (50) feet of the premises.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
Our building will have all the necessary attributes to serve employees and the
community. We will have a large, private and dedicated onsite parking lot that provides handicap
Americans with Disability Act (ADA) spaces. Our security staff would monitor our parking lot
and we would comply with our typical surveillance plan. The parking lot will have dedicated
security surveillance, including 1 camera and exterior light for every 5 parking spaces. Cameras
will be equipped with license plate recognition and low light high-definition capabilities to over
100 feet from the exterior of the building.
Our facility will provide law enforcement and neighbors within 100 feet of our building
with the name, phone number and email of our CEO and Security Manager to notify during and
after operating hours whom they can report problems if they were to arise.
Our CCB will continually maintain the premises and its infrastructure so that it is visually
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
5
attractive and not dangerous to the health, safety and general welfare of employees, patrons,
surrounding properties and the general public. The premises will not be maintained in a manner
that causes public or private nuisance. Litter will be removed daily from the premises, including
adjacent public sidewalks and all parking lots under the control of the cannabis retail business or
commercial cannabis business. All areas will be swept or cleaned daily, on a weekly basis to
control debris and upkeep and operating characteristics will be compatible with abutting
properties and the surrounding neighborhood, per SEC 9-3309(n).
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
6
3.3 Describe odor mitigation practices
Our facility will operate 7 days a week, using our odor mitigation plan and other
environmentally friendly procedures we will minimize our impact to the community. We
understand that cannabis odor could be a major concern for all residents nearby our facility. Our
Company is prepared to take preventative measures to ensure that our facility does not disturb
the environment or culture in the neighborhood. We will do our best to comply with local
ordinance and odor prevention rules and regulations. Our odor mitigation plan will outline the
steps that will be taken to mitigate cannabis odors and establish a responsible plan of action if
cannabis odors are detected outside our facility.
It is important to our management that our various community plans remain transparent
so all community members understand the importance of mitigated cannabis odors. Thus, our
mitigation plan and records will be made available to the public and documents can be requested
at our facility. We plan on presenting our findings and methods of prevention at monthly
community meetings, if necessary. Communicating this plan to our neighbors, Fresno residents
and local community members is a key component to our Neighborhood Compatibility Plan.
Establishing a Neighborhood Committee (NC) will be tasked at the first community meeting.
Volunteers from the community will be asked to participate in the detection and relay of odor
observations. The NC will volunteer and designate one of the local business / homeowners,
within one hundred (100) feet of our facility, to be the individual that files formal complaints or
comments to our Company and to the City Manager.
Occasionally the cultivation of cannabis products will produce an odor outside the
facility, if the building is not equipped with proper odor reducing technology then odors will be
susceptible to the community.
To be on the safe side, our Company will take extra measures to prevent undesirable
odors by utilizing various bio-filtration systems to reduce the odor, air-sealed storage techniques
and technological monitoring tools.
Prevention
Our Company believes odor prevention and mitigation helps protect our local
community and better the environment. We will design our Fresno facility putting procedures
in place to prevent the smell of cannabis odors from escaping our premises into the rest of the
building. To follow SEC 9-3309(j)(1)(2), we will have the best available odor control
technology and devices will be incorporated in our CCB to ensure that odors from cannabis are
not detectable off-site. A sufficient odor absorbing ventilation and exhaust system will be
provided so that odor generate inside the premises that is distinctive to its operation is not
detected outside the facility, anywhere on adjacent property or public rights-of-ways, on or
about the exterior or interior common area walkways, hallways, breezeways, foyers, lobby
areas, or any other areas available for use by common tenants or the visiting public, or within
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
7
any other unit located inside the same buildings as the CCB. The following equipment, or any
other equipment which the Planning and Development Director or his/her designee(s)
determine is a more effective method or technology must be installed and maintained:
1. An exhaust air filtration system with odor control that prevents internal odors and
pollen from being emitted externally;
2. An air system that creates negative air pressure between the premises’ interior and
exterior, so that the odors generated inside the premises are not detectable outside
the premises.
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents. These steps detect, mitigate and prevent odors from
reaching the public.
Charcoal Air Filters and HVAC: We will install a charcoal air purifier or charcoal filter,
also commonly known as an activated carbon air filter, works by absorbing the gases and odors
in the air. The charcoal pellets are activated carbon that has been treated with oxygen to open up
millions of pores in between the carbon atoms. This works so well because the millions of tiny
cells that are in the charcoal in addition to being very porous also attract and capture odors and
gases. Charcoal filters help clean air of particles as to reduce airborne odors, all the while our
HVAC will consist of a carbon filtration system to circulate and remove odors and toxic
chemicals.
Our facility will have multiple new energy
efficient HVAC systems that will include charcoal
air filters and monitoring tools that will be utilized
to clean and reduce smells. The filtration system
will consist of one or more fans, activated carbon
filters and be capable of scrubbing the air. At a
minimum, the fan(s) will be sized for cubic feet
per minute (“CFM”) equivalent to the volume of
the building (length multiplied by width
multiplied by height) divided by three. The
filter(s) will be rated for the applicable CFM.
Bulk carbon filters will attach directly to the exhaust of each air handling unit. Carbon
filters make use of active carbon that is equipped with highly porous charcoal that allows air to
pass through, but the odor is trapped, preventing smells from circulating the facility. Our carbon
filters will use 1050+ IAV charcoal, which is one of the most absorbent charcoals available. The
filters will be made out of heavy-duty galvanized stainless steel for maximum durability and
longevity with perforations at 53% open to maximize airflow and odor management. Our
engineers suggest we use EnviroKlenz filters. The EnviroKlenz technology is a highly effective
“destructive absorbent” material designed for chemical containment and neutralization. We will
ensure our EnviroKlenz system is in good working order with monthly inspections from our
Charcoal Carbon Filter
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
8
certified engineer. We also plan to use ozone generators that will be utilized when necessary to
measure Dilution to Threshold (“D/T”) ratios indicated by the HVAC’s D/T sensors. All controls
will be monitored in such a way to know how efficient and effective our facility is mitigating
odors.
Controlled Storage: All cannabis products will be securely stored in our Vault Room. As
detailed in our Security Plan the Vault Room will comply with all rules and regulations. The
Vault Room will be temperature controlled, maintaining 55-65 degrees. All products will be
vacuum sealed and placed on shelves for final inventory. Our COO believes in vacuum sealing
our inventory to prevent cannabis odors, meanwhile keeping the product fresh from oxidation,
which maintains the products medicinal qualities. All flower raw material will be maintained in
vacuum sealed bags.
Design: Our facility will have stationary windows, meaning they cannot be opened. All
our doors will be sealed with proper weather stripping, keeping air circulating and filtered inside
of our facility. Onsite use of cannabis products will be strictly prohibited, which we believe helps
further mitigates any potential cannabis odors from reaching to our neighbors. Negative air
pressure will be maintained inside the building.
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
9
3.4 Identify potential sources of odor
The main source of odor includes cultivating cannabis within our grow rooms, drying and
curing raw cannabis. We will store cannabis in vacuum sealed containers to prevent odor and
oxidation. Our facility will be designed to have stationary windows, meaning they cannot be
opened. All our doors will be sealed with proper weather stripping, keeping air circulating and
filtered inside of our facility. Onsite use of cannabis products will be strictly prohibited, which
we believe helps further mitigates any potential cannabis odors from reaching to our neighbors.
Negative air pressure will be maintained inside the building.
Mentioned within this application, we mentioned the following to prevent odors: charcoal
filters and HVAC, controlled storage, design and pre-packaged products.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents. These steps detect, mitigate and prevent odors from
reaching the public.
No outdoor storage of cannabis or cannabis products is permitted at any time, per SEC 9-
3309(d).
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
10
3.5 Describe odor control devices and techniques employed to ensure that odors from
cannabis are not detectable beyond the permitted premises
We fully understand the importance of cannabis odor mitigation and will do our best to
prevent the issue, but if odors were to be detected outside our facility we have a plan to monitor,
detect and remediate. Our devices and techniques are below:
Monitor: Each day the CEO and Facility
Manager will assess the on-site and off-site odors for
potential release of objectionable odors. While
driving in the facility each day we will be able to
physically monitor odors from outside the facility.
The CEO will designate an agent to be responsible
for assessing and documenting odor impacts daily.
To enhance our odor detection, we plan on
purchasing the Nasal Ranger. The Nasal Ranger is
an ISO 9001 certified device, based on a scientific
method, which can quantify odor strength in terms
of Dilution to Threshold (“D/T”) ratios.
Detect: Studies have determined that a 7:1 D/T ratio was a detectable level of cannabis
odor. Our Company will use a 6:1 D/T ratio for a measurable maximum threshold. The Nasal
Ranger also has a subscription web-based application that provides electronic repository for all
odor data.
For example the Odor Track'r™ permanently stores odor inspection data, such as
date/time; location code numbers, descriptions, and GPS data; odor strength as D/T from the
Nasal Ranger, butanol intensity or word scale intensity; odor character descriptors; and
meteorological data (temperature, humidity, barometric pressure, wind direction, wind speed,
precipitation and sky cover). If we decide to use the subscription web-based application. Our
CEO or designated agent will input that data into our Inventory Tracking System and make
available to the City Manager. The City Manager will have the ability to visually track and
monitor cannabis odor outside our facility in real time.
If necessary, the sensors in our HVAC will be able to read, record and store D/T levels as
well. We will use all data received to adjust our Odor Plan accordingly. Most likely and the most
effective way to detect the smell of cannabis odors outside our facility will be: outside personnel,
delivery drivers, the public and other neighboring businesses.
Remediate: If highly questionable or objectionable off-site cannabis odors are detected by
local residents, the following protocols will be put into immediate action: (i) Investigate the
likely source of the odor; (ii) Utilize on site management practices to resolve the odor event
including monitoring tools to document D/T; (iii) Take steps to reduce the odor-generating
source; (iv) Determine if the odor traveled off-site by surveying the perimeter and making
Nasal Ranger
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
11
observations of existing wind patterns; and (v) Document the event for further operational
review and the formulation of a corrective action plan. If employees are not able to take steps to
reduce the odor-generating source, they are to immediately notify the CEO. All communication
will be documented, and our team will come up with a proper solution, if applicable. All
employees will be trained on how to detect, prevent and remediate cannabis odors. Our odor
mitigation plan and records related to odor mitigation will be maintained at our facility and will
be available to any of our neighboring buildings upon request, to ensure our community
members are engaged with eliminating odors.
Design: Our facility will have stationary windows, meaning they cannot be opened. All
our doors will be sealed with proper weather stripping, keeping air circulating and filtered inside
of our facility. Onsite use of cannabis products will be strictly prohibited, which we believe helps
further mitigates any potential cannabis odors from reaching to our neighbors. Negative air
pressure will be maintained inside the building.
While other applicants may see an environmental plan as an option, we see it as
necessary to our operations. We feel it is our Company duty to educate the residents and lead by
example to eliminate odor and lower our carbon footprint and positively impact our local
environment. A well-engineered facility that properly employs well-maintained carbon filtration
technology (and ozone generation if this is insufficient) can then operate without imparting
offensive odors on the community.
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
12
3.6 Describe all proposed staff odor training and system maintenance
We will train our agents to detect odors when they enter our CCB and we budgeted for a
maintenance engineer, which will allow us maintain our HVAC and filtration system in good
working order. As mentioned in this section we will follow all rules and regulations outlined in
SEC 9-3309(j)(1)(2).
We will have the best available odor control technology and devices will be incorporated
in our CCB to ensure that odors from cannabis are not detectable off-site. A sufficient odor
absorbing ventilation and exhaust system will be provided so that odor generate inside the
premises that is distinctive to its operation is not detected outside the facility, anywhere eon
adjacent property or public rights-of-ways, on or about the exterior or interior common area
walkways, hallways, breezeways, foyers, lobby areas, or any other areas available for use by
common tenants or the visiting public, or within any other unit located inside the same buildings
as the CCB. The following equipment, or any other equipment which the Planning and
Development Director or his/her designee(s) determine is a more effective method or technology
must be installed and maintained:
3. An exhaust air filtration system with odor control that prevents internal odors and
pollen from being emitted externally;
4. An air system that creates negative air pressure between the premises’ interior and
exterior, so that the odors generated inside the premises are not detectable outside
the premises.
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents.
Charcoal Air Filters and HVAC: A
charcoal air purifier or charcoal filter, also
commonly known as an activated carbon air filter,
works by absorbing the gases and odors in the air.
The charcoal pellets are activated carbon that has
been treated with oxygen to open up millions of
pores in between the carbon atoms. This works so
well because the millions of tiny cells that ar e in
the charcoal in addition to being very porous also
attract and capture odors and gases. Charcoal
filters help clean air of particles as to reduce
airborne odors, all the while our HVAC will consist of a carbon filtration system to circulate and
remove odors and toxic chemicals.
Our facility will have multiple new energy efficient HVAC systems that will include
charcoal air filters and monitoring tools that will be utilized to clean and reduce smells. The
filtration system will consist of one or more fans, activated carbon filters and be capable of
Charcoal Carbon Filter
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
13
scrubbing the air. At a minimum, the fan(s) will be sized for cubic feet per minute (“CFM”)
equivalent to the volume of the building (length multiplied by width multiplied by height)
divided by three. The filter(s) will be rated for the applicable CFM.
Bulk carbon filters will attach directly to the exhaust of each air handling unit. Carbon
filters make use of active carbon that is equipped with highly porous charcoal that allows air to
pass through, but the odor is trapped, preventing smells from circulating the facility. Our carbon
filters will use 1050+ IAV charcoal, which is one of the most absorbent charcoals available. The
filters will be made out of heavy-duty galvanized stainless steel for maximum durability and
longevity with perforations at 53% open to maximize airflow and odor management. Our
engineers suggest we use EnviroKlenz filters. The EnviroKlenz technology is a highly effective
“destructive absorbent” material designed for chemical containment and neutralization. We will
ensure our EnviroKlenz system is in good working order with monthly inspections from our
certified engineer. We also plan to use ozone generators that will be utilized when necessary to
measure Dilution to Threshold (“D/T”) ratios indicated by the HVAC’s D/T sensors. All controls
will be monitored in such a way to know how efficient and effective our facility is mitigating
odors.
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
14
3.7 Describe the waste management plan
Waste Disposal: We have developed a strict policy for tracking, storing and disposing of
cannabis waste to ensure that no useable cannabis or cannabis oil is diverted or poses a threat to
our biosecurity. Our CEO will provide the City Manager with notice to dispose of cannabis
products waste at least 48 hours prior to the date of destruction and seek approval. The notice
will identify the items to be destroyed, whether the destruction will be compostable or non-
compostable, the landfill or incinerator that will receive it, and the date and time that the grinding
will occur. The notice will also include the weight and quantity data that is tracked in our
Inventory Tracking System (ITS). We will follow all destruction procedures as the City Manager
sees appropriate. Upon the request of the City Manager, the destruction will be rescheduled to an
alternative time. We will schedule the destruction for a date and time when the pertinent
personnel will be present and the destruction will be completed so that it is viewable by our
surveillance cameras system. Until destroyed, we will store the cannabis and cannabis product
intended for destruction in a locked container marked “Waste Cannabis Material. DO NOT
DISPENSE. Content Scheduled for Destruction.” The container will be located within a
segregated area in the Vault Room designated for product to be destroyed.
Maintaining Garbage: Our Waste Area will be located in our Receiving, Shipping and
Loading area. Garbage room area is very vulnerable to bacterial contamination. The agents
should follow the cleaning and disposal standards to prevent widespread bacterial contamination
of the garbage room and the area around the garbage room. Our facility will have a dedicated
garbage area, away from any cannabis storage or production areas.
1. Cleaning to be done regularly to avoid dirt and also to prevent the spread of bacteria.
2. Must be cleaned at least every day.
3. Garbage collection should be done every day (dry garbage and wet garbage).
4. Cleaning should be done after transporting garbage from the garbage room.
5. Cleaning to be done after garbage transportation.
These steps will provide safety of products and all agents will be trained on these SOPs.
Other effective cleaning standards include maintaining a high standard of cleanliness and regular
disinfection as it’s essential to ensure that cannabis is protected from physical and microbial
contamination and to prevent the accumulation of material which would attract pests.
Destruction Policy: When the Inventory Manager confirms waste is ready for destruction,
all products are given a final weighing by the CEO, and the weight is entered into our ITS in
accordance with the destruction procedure described in our SOPs.
Waste cannabis must be rendered unusable, unrecognizable and indistinguishable from
the components with which it is disposed and incapable of being ingested, inhaled, injected,
swallowed or otherwise used for certified use. We accomplish this by grinding cannabis and
incorporating it with other ground materials, so that the resulting mixture is at least 51% non-
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
15
cannabis waste by volume. The CEO is responsible for determining the quantity by volume of
non-cannabis material needed to meet or to exceed the 51% threshold.
The Inventory Manager will notify the Security Manager and the City Manager at least
48 hours in advance of destruction and schedule a time when the Security Manager can
supervise. The entire destruction process takes place in our designated destruction area, in the
shipping and receiving area, in direct line of site of the surveillance recording cameras,
verification conducted by our CEO.
At the outset of the destruction process, the Inventory Manager will supervise the
transportation of all waste cannabis containers of the designated “destruction” area. The Manager
weighs each container’s contents and enters the final weight into our ITS. The cannabis waste
from all products is then ground with the non-cannabis content until the Manager determines it is
no longer usable or recognizable, meaning that it is incapable of being ingested, inhaled,
injected, swallowed or otherwise used for certified use.
The final mix is then weighed, and that weight is entered into our ITS. The post mixture
waste is handled differently based on whether it is compostable or not. Allowable grinding
material for non-compostable destruction include non-cannabis food waste, yard waste, our daily
ground used coffee, vegetable-based grease or oils, paper waste and cardboard waste. Non-
compostable post-mix will be placed in a locked dumpster marked as “Non-compostable Post-
mix”.
Cannabis waste rendered unusable must be promptly disposed. Disposal of any cannabis
wasted rendered unusable will be delivered to a permitted solid waste facility for final
disposition. If we use compostable mixed waste we will schedule for a compost, anaerobic
digester or another facility with approval of Fresno’s Department of Health. If we use non-
compostable mixed waste we will schedule for a landfill, incinerator or another facility with
approval of Fresno’s Department of Health.
The Inventory Manager will note the destination and date and time of waste transport and
will notify the City Manager with all proper information. An electronic documentation will be
maintained for three years.
Disposal of Recalled Products: We will coordinate disposal of recalled cannabis with the
City Manager. The City Manager or its authorized agents may oversee the disposal to ensure that
the recalled cannabis is disposed of in a manner that will not pose a risk to public health and
safety. Product destruction at our facility will take place under CEO and Security Manager
supervision within the Receiving, Shipping and Loading area of our CCB. All destroyed
products will be done in accordance with our policy addressing the disposal of cannabis and
cannabis products.
Social Policy and Local Enterprise Plan
Appendix A: Evaluation Criteria
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
1
2.1 Describe whether the Commercial Cannabis Business is committed to offering
employees a Living Wage
Our Commercial Cannabis Business (CCB) is fully committed to providing our employees
with a Living Wage, as defined by the Fresno Living Wage Calculator researched by to Dr. Amy K.
Glasmeier, Ph.D. Our Company believes in using wage models to fully understand what’s needed
for families to properly provide for their families that draws upon geographically specific
expenditure data related to food, childcare, health insurance, housing, transportation and other basic
necessities. We understand that we will not be able to provide all of our employees with six figure
salaries, but we will look at the below formula to properly come up with salaries that provide Fresno
residents with career opportunities that involve bonuses, healthcare benefits and other perks so our
employees can be proud of their success.
We looked at how the living wage is defined and came up with hourly rates and salaries that
provide employees with a Living Wage according to the City of Fresno:
Living Wage = Basic needs budget + (basic needs budget * tax rate)
Viola has always paid employees above average wages, no employee will make less than
per year and that’s an entry level position. After reviewing this section you will see wages
ranging from depending on the position and experience of the employee.
To show our commitment to empowering and partnering with our workers, our COO signed
a Labor Peace Agreement (“LPA”) with the Local 8-Golden State United Food & Commercial
Workers (“UFCW”), and our meeting with the union representatives Aidan Coffey, left our COO
very encouraged that the union is going to be a valuable resource in terms of helping us hire and
protect talented local residents of Fresno. Our signed LPA is attached within this exhibit. If
selected for Fresno, we will look into signing a Project Labor Agreement (“PLA”). Our PLA will
demand our construction project “…includes requirements as to minorities, women and local
resident hiring on the Project, any negotiated PLA shall be supportive of these requirements.”
A proper labor compliance plan starts with human resource management and compliance
teams that are knowledgeable about federal, state and local labor laws. Our Director of Human
Resource (“DHR”), Teresa Saucedo, has nine years navigating human resource management
techniques and complying to labor laws. Prior to the cannabis industry, Mrs. Saucedo was the lead
human resources recruitment director for LJ Consulting Group. She provided client centric solutions
in the areas of talent acquisition and human resource strategy consulting. Our Chief Compliance
Officer, Adam Day, will support Mrs. Saucedo in her task of making sure we are in full compliance
of labor laws. Given the planned diversity of our workforce and the minority makeup of our team,
all labor compliance training and employee handbooks can be provided in English and Spanish.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
2
STAFFING FOR LONG-TERM OPERATIONS
One of our core values include hiring more minorities and racial disadvantaged
individuals in an industry that has been dominated mainly by white males. One of our principal
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
3
owners, Al Harrington, wants to provide over 100 jobs nationwide to minorities in legalized
cannabis by 2023, we are close to a quarter way there. Mr. Harrington also wants to create
wealth for 100 black minorities within the cannabis industry, through ownership in legalized
cannabis businesses across the country.
One of our foundations include corporate and social responsibility which can be shown
by the diversity of our owners, investors, management, employees, local partners and
contractors.
We want our CCB to represent the diversity of Fresno’s population in particular near
neighborhoods and communities that need economic development. Our founders believe in
social equality for all, including promotion of discrimination-free workplace, fair wages,
diversity and community involvement. We have consistently exemplified the best of those values
as majority of our owners, investors and management is a member of a racially disadvantaged
group, which include African American, Latinx and Native American. Given our history of
working with groups from diverse racial, ethnic, cultural, socio-economically disadvantage
backgrounds and the inclusion of small businesses, we expect to be among the leading applicants
when it comes to diversity, providing a diverse workforce and creating long-term staffing with
living wages.
Job Creation Plan: Many members of our current management have been with Viola
since the beginning. Most began as entry-level employees and worked their way to managers,
directors, supervisors and owners. We strongly believe in hiring from local communities,
promoting those that work hard and show leadership, providing training for our employees to
begin a career in cannabis not just a job in cannabis and paying above average wages, all keeping
long-term employees. Our employees tend to respond well to good wages and benefits with
loyalty and hard work, with everyone aligning themselves with the interests of the CCB.
Many applicants will make promises and build partnerships to try to earn points on an
application, but our actions have been organic since inception. For example, our team built our
Michigan facility in a very economically distressed region of Detroit, and we plan to pay our
workers above-average wages, plus year-end bonuses. Our pending application in New Jersey is
located in Penns Grove, which has a poverty rate six times the national average. Our soon to be
state-of-the-art cultivation and processing facility in Missouri is located in the heart of St. Louis,
where unemployment is close to 25% and 40% of the zip code’s population live in poverty.
Again, exemplifying we are NOT afraid to operate and hire where most applicants will not.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in the
cannabis industry. In Fresno, our entry wage will not be below (well above the $12.00 per
hour California minimum wage), plus year-end bonus, plus benefits and participation in our
employee equity plan. 100% of our employees will be provided a livable wage. We estimate over
million in annual salaries for our CCB, which includes 50 new job opportunities for Fresno
residents.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
4
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
Our CCB will provide all employees with full benefits. Due to our experience in
providing benefits in other cannabis markets, we have relationships and partnerships with United
Healthcare and Blue Cross Blue Shield, that will provide our Fresno employees with full health,
dental and vision coverage. Our employees will have the ability to select between two HMO and
one PPO full-service health plans, which include coverage on pre-existing conditions, low
deductibles, full coverage for dependents and spouses and 100% coverage of preventative care,
including OB/GYN, mammograms, childcare and immunizations. We offer three dental plans,
Delta Dental PPO Dentist, Delta Dental Premier Dentist and Non-Participating Dentist. All
dental coverage options range between 90%-100% (oral exams, cleanings, sealants, x-rays,
fluoride etc.) for diagnostic & preventative services, 80% coverage for basic services (fillings,
simple extractions, oral surgery etc.) and 50% coverage for major services (denture repair,
crowns, implants, bridges). We also provide vision care, in-network services exams, glasses lens
enhancement and discounts on our laser vision care program.
We understand a large barrier to entry in the cannabis industry for single parents is to
receive flexible employment hours, so we will provide assistance for our employers in need of
subsidized childcare or early-education. We do not want any of our single parents to be
burdened, especially while employed, when it comes to affording best-in-class childcare
services. Our subsidized childcare program will include daycare, pre-school, early education
(pre-Kindergarten) and any after school programs that are paid out of pocket. All employees will
receive Paid Time Off, at least two weeks vacation and proper medical leave benefits. With our
relationships and LPA with UFCW we will ensure our employees are provided proper benefits
and healthcare.
Union Protection and Retirement Benefits: The great thing about partnering with the
Local 8-Golden State UFCW is they also provide benefits through a UFCW Industry Pension
Fund and a UFCW National Health and Welfare Fund. Both will keep our plans competitive and
market rate. While many cannabis companies have not implemented retirement plans, especially
since many of these businesses have only been around 5 years, we will work with UFCW and
participate in their Industry Pension Fund. Currently the fund has 300 contributing employers,
10-15 cannabis employers, 100,000 active participants and 70,000 retirees and beneficiaries.
Some of these opportunities are currently in cultivation and process, which like most industries
has a moderate turnover ratio, but after 10 years all participants are fully vested. We plan on
operating a long-term business plan and would love to have Fresno employees fully vested by
experiencing career growth within our Company.
The UFCW National Health and Welfare Fund (Fund) is governed by a joint board of
trustees on which labor and management are equally represented. The Fund is financed by
employer contributions fixed by Collective Bargaining or other written agreement and
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
5
investment of its pooled reserves. The Fund is mostly self-funded – that its benefits are paid by
the Fund from its pooled assets, rather than by an insurance company. The Fund does carry “stop
loss” insurance to spread the risk of catastrophic claims. The Fund is self-administered: that is, it
employs an in-house staff to perform all of the administrative functions such as collecting
contributions, contracting with insurers or other organizations that maintain provider networks or
group purchasing networks, determining eligibility, processing and paying benefit claims,
handling appeals, record-keeping and reporting and disclosure. All of the Fund’s administrative
costs are paid from the Fund’s pool of assets.
The Fund has endeavored to develop innovative means for cost containment including
negotiating contracts with providers such as prescription benefit managers and preferred provider
organizations, promoting preventive care and wellness, engaging in disease management and
forming group purchasing coalitions to maximize bargaining power. As social equality
advocates, we fully support the efforts of the Local 8-Golden State UFCW.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
6
2.3 Describe compensation to and opportunities for continuing education and employee
training
Employee Training Overview
Our experience operating vertically integrated (cultivation, processing and dispensaries)
cannabis businesses in regulated states allowed our executive team to develop a best-in-class
approach to employee training. We work directly in collaboration with regulators, resulting in
the creation, implementation and partnership to provide highly effective training protocols that
ensure all of our employees are thoroughly trained to understand the rules and regulations of
Fresno CCB organization, have knowledge of any security measures and operating procedures
and advise customers on product offerings and how to safely consume cannabis. Led by our
Director of Cannabis Operations, our COO and various members of our team in other states, our
training curriculum includes separate and specialized training for our customer facing agents so
they are fully prepared to provide customers with the most current evidence based information
regarding cannabis brands, products and use. If we have the space, our facility will have space,
labeled Community Education and Training where we will host classroom training. This space
can be used to conduct mock training sessions but allows our agents to be trained separate from
our sales floor during the construction of our facility and hours of operation, once open.
Not only will our agents be trained using our internal procedures, they will have the
opportunity to receive training from Hemp Staff or other advanced cannabis training. All
advanced training will be paid by our CCB and employees will be paid during training.
Operations Manual: Because we currently operate cultivation, processing and dispensing
facilities in other regulated states, we have successfully developed and implemented operations
manuals aimed at standardizing procedures and at maintaining our Standard Operating
Procedures that are complete, accurate and confidential. Our operations manual will be located in
our facility, two printed copies and an electronic version will be available as a resource to our
employees and agents. All employees will be trained knowing our cultivation SOPs mentioned in
our operations manual.
Training Experience & Staff
Our ongoing cultivation, processing and dispensary operations in Colorado, Oregon,
Michigan, Missouri and Maryland has led to broad company knowledge on the continuing
development of cannabis.
These operations have also exposed us to new strains and formulations of cannabis, as
well as to new information and procedures on how best to interact with our customers. We share
Fresno’s view on the importance of training customer-facing agents to interact with and to
educate our customers, and our training in this regard is meant to equip all agents and staff
members with the information and knowledge necessary to interact with customers in a
professional and ethical manner. We envision our agents will act as a resource to our customers
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
7
not only on the positives and negatives of cannabis use, but on new science-based research as
well. To that end, we will rely on the following people and procedures to educate our customer-
facing employees.
Chief Operating Officer: Jamil Taylor, operated cannabis facilities in Illinois, California
and Pennsylvania. Served as the CEO of a vertically integrated cannabis business in New Jersey,
was the former COO of some of the highest grossing dispensaries in Northeast Pennsylvania and
led application team for identifying new markets.
Chief Compliance Officer: Adam Day, one of the first employees of the national
Company and developed and oversees all Compliance Programs in each state where we operate.
He has over 6 years of cannabis compliance experience and maintains a near perfect record of
being rules and regulation compliant in one of the most regulated, fast evolving industries in the
county.
Director of Cultivation: Jeff Hulsing, is considered an expert in horticulture and
agricultural cannabis crop management as he was the Cultivation Director with his previous
companies, Natural Remedies and Binske, two very well-respected Colorado cultivation
companies. With expertise in cannabis horticulture, his experiences allowed him to gain a
fundamental understanding of cultivation and training. Within 5 years of professional cannabis
industry cultivation, Mr. Hulsing has trained over 35 Grower Agents, with the majority of them
having little to no prior cultivation, horticulture or agriculture experience.
Director of Cannabis Operations: Marques Moore, is a 7-year military veteran that owns
and operates 5 medical and adult-use cannabis facilities in Colorado and Nevada. Through his
operational expertise and marketing and branding efforts, he increased revenue in a tough Las
Vegas cannabis market by 200%.
Internal Company Training
Our CCB will conduct an internal employee training program, which was developed and
implemented by our CEO, our COO, our Director of Cultivation, our Director of Cannabis
Operations and our Chief Compliance Officer, consists of an initial on-boarding training course
for new employees as well regular continuing education training courses. Prior to beginning the
training of any employee, our COO, in conjunction with our Director of Cultivation and
Director of Cannabis Operations, will review all of our training materials to ensure that they
comply with all Fresno rules and regulations and with City Manager training requirements, and
that they reflect the most up-to-date information on customer care.
Prior to the beginning of their training, each new employee is provided with written
course materials related to the topics described in this section. These materials are provided in
advance of training and new employees are expected to have familiarized themselves with these
materials prior to beginning the on-boarding training process. All course materials, along with
certificates of completion, which include the employee’s name, course title, course content, dates
of training, and signatures of both the employee and instructor, are maintained for a minimum of
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
8
three years and are available to the City Manager for inspection upon request. Employees must
complete an extensive training that includes 80 hours (2 week) of classroom on-boarding
training, cultivation, delivery, security, safety and sanitation, theft and diversion prevention,
packaging, labeling and inventory training, a two to five day live training at our facility in
Michigan, which includes a walkthrough of our cultivation and processing facility.
On the job training is the Company’s most effective used method of training. Generally,
only qualified managers may provide agents with structured training. All managers must be
trained on the job for two to three cultivation cycles to fully understand the cultivation process.
A manager must demonstrate proficiency and complete an approved Train-the-Trainer program.
The benefits for trainer managers themselves include enhanced skills and knowledge, mastery of
materials and knowledge and workforce that continually engages and operates in a training-based
environment. Our COO will review these training programs regularly to determine if they are
sufficient for the Company’s needs.
Our mandatory on-boarding training course for all new managers, employees and agents
includes the following topics:
I. Company & Regulatory Training
All employees will complete a two-week foundational training, including reviewing the
Employee Handbook and our Standard Operations Procedures, learning about our Company
mission/vision, and discussion of the following: a) Professional and ethical conduct in the
workplace; b) Informational developments in the field of cannabis; c) The proper use of facility
security measures and controls; d) Emergency response, including robberies and/or other forms
of workplace violence; e) Best practice security procedures including how to prevent and detect
the diversion of cannabis; f) Fresno rules and regulations for cannabis use, including local
regulatory requirements of operating a cannabis business in the various local jurisdiction; h)
Authorized uses of cannabis; i) Different forms, brands, methods of administration and strains of
cannabis; j) Verification of identification; k) Proper handling of cannabis; l) Proper inventory
and recordkeeping; m) Best practice safety procedures; n) our Company policies for an alcohol,
smoke, and drug-free workplace; and o) sexual harassment, workplace violence and diversity
training. As part of this process, all new employees must sign off on their review of the
Employee Handbook and our Standard Operating Procedures. All employees are also expected to
review these documents annually with the same signature requirement. These confirmation of
review documents are maintained in the employment files of each employee.
II. Security Training
Our in-house training is pertinent to our facility operating in a safe and secure manor. Our
security training is conducted by our Security Manager during the on-boarding process and
consists of introducing employees to our surveillance devices, the various types of alarms that
we employ, and our access limitations and controls. This includes training in the use of our
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
9
keypads, panic alarms, hold-up alarms, smoke and fire alarms, motion detectors, surveillance
cameras, glass breakers and door sensors. Security training for new employees also consists of
reviewing all of our security policies and procedures, including procedures for a security breach,
our ZERO tolerance diversion policy and situational awareness in the event of an intrusion.
Security agents will be classroom trained for 8 hours, mock trained for 8 hours and must pass a
Safety and Security exam in order to further employment. Facility agents will be classroom
trained for 4 hours, mock trained for 2 hours and must pass a Safety and Security exam in order
to further employment. All safety training and security training materials and attendance records
will be kept on file for three years and be available for inspection by the City Manager.
We will make sure our physical security vendor commits to a minimum of 8 hours total
of Initial Training on all systems so that all Level 3, Level 4 and Level 5 employees are familiar
with the operation and maintenance of all systems. Our alarm company will lead the training of
all security alarm, surveillance and access systems. Employees will be provided with emergency
contact information and are trained on what steps to take in the event of various types of
emergency situations (invasions, robbery, “smash and grab”) and/or natural disasters. Once
employees have been successfully on-boarded, management will consistently remind them of
their duties to be aware of and report any security concerns they observe. All security procedures
and training will be approved by the City Manager. Our CEO and COO will conduct quarter
safety and security meetings with Fresno law enforcement and they can walk our facility to
ensure we are meeting are security protocols.
III. Workplace Health and Safety Training
The safety of our employees is of utmost importance to us. We provide all new
employees with OSHA training completed directly by a third-party OSHA-certified trainer. As
part of this training, all employees are encouraged to exercise their rights under OSHA, including
filing an OSHA complaint, participating in an inspection, and reporting injuries or health
hazards. Indeed, all employees are trained that the reporting of hazardous conditions, regardless
of their nature, is mandatory. We also provide all new employees with CPR and first-aid training,
as well as training related to evacuation and emergency planning. This includes training in how
to recognize and/or handle a variety of safety and/or medical emergencies that may arise at our
facility. In terms of medical issues, per our standard operating procedure on “Medical
Emergencies,” all of our employees are trained to: 1) Assess the situation with the utmost care
and caution; 2) If the individual is conscious, ask them if anything hurts and to describe the
injury as best as possible. If unconscious, gently inspect the individual for any obvious signs of
injury; 3) Not to move the individual, especially if they are in pain or have experienced a severe
injury, unless the individual is in imminent danger of further injury (e.g. approaching fire); 4)
Call 911; 5) Call the manager if not present to inform them of the situation; 6) Perform first aid if
knowledgeable and willing; and 7) Not to come into contact with blood, vomit, or other bodily
fluids without the proper protective equipment like single-use medical-grade gloves.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
10
All employees are also trained to recognize serious medical emergencies, and to call 911
or otherwise seek the assistance of emergency medical personnel if they witness any of the
following: Shortness of breath, No breath or pulse, Chest or upper abdominal pain,
Unconsciousness, Spinal or neck injury, Disorientation, Sudden severe pain, Uncontrolled
bleeding, and Major injury or trauma. All employees will be provided testing for the coronavirus
or other viruses that can affect the plant quality. All employees are trained in disaster recovery.
For example, in case of a fire, employees are trained to: 1) Remove all persons from immediate
danger without placing themselves at risk; 2) Activate the fire alarm system; 3) Call 911 in order
to provide their name, exact location, phone number, and type of fire; 4) Close all doors in the
fire area and in the halls as needed (to contain the fire) without placing themselves at risk; and 5)
Evacuate all employees to an area of refuge.
To facilitate the actions of our personnel to address emergency situations, including, but
not limited to, medical emergencies, our facility will be equipped with the following: fully
stocked first-aid kits, CPR and first-aid instructional posters and materials, signs or other
materials identifying the contact information for local emergency personnel, smoke detectors,
fire alarms, and fire extinguishers, carbon dioxide detectors, signs or other materials identifying
the quickest escape route(s) from the facility in the event of a fire or other emergency requiring
evacuation.
IV. Inventory Management & Recordkeeping Training
Our experience operating vertically integrated facilities taught us that our employee and
continuing education training programs are crucial to maintaining accurate inventory and proper
recordkeeping. As such, as part of our onboarding process, we provide our employees with
comprehensive training on our Inventory Tracking System and our Customer Relationship
Management system (for applicable employees). We also provide continuing education training
to all employees at least once a year or whenever those platforms have software updates. These
trainings may include having those platform representatives on site, virtually or otherwise, to
ensure that we are properly using all features and functions of the software. This training
includes live simulations of, among other things, inventory receipt, product recall, dispensary
contact upon recall, transportation manifest creation for the return of recalled product and proper
recordkeeping of all the upon items within our facility.
V. Cultivation Overview Training
Employee training is a critical part of our success as a Company. We are committed to
being an industry leader in the cultivation, processing and infusing of cannabis, providing a safe
and productive work environment and ensuring the safety of our products. We will ensure that all
employees receive professional and appropriate training on compliance with regulation, the use
of cannabis and cannabinoid science. All of our cultivation agents will be trained by our Director
of Cultivation. No employee will work on-site prior to receiving training. Our Directors and
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
11
COO will approve any third-party training and certification programs for agents. Outside training
and audit programs utilized by the Company include: Agricultural & Health Training (Cal State
University – Fresno). All agents will be given a “Training Binder” for their respective production
areas, this will serve as their “Cannabis Bible”. All materials will be reviewed bi-annually to
ensure materials are updated. All agents must read and understand all training materials and if
agents do not fully understand the material being taught, they are to ask questions and our
trainers can provide real world explanations. Agents will demonstrate proficiency in all topics by
taking and passing quizzes, test and simulated test, all agents must pass with a score of 80% in
order to move on to the next stage of training.
Our Director of Cultivation will conduct an overview training that includes:
Cannabis Training: Cannabis Research and Clinical Data, Cannabis-Based Products,
Quality of Care and Legal Rights.
Federal and National Cannabis Standards, Best Practices and Rules: Good Cultivation
Practices, Pesticide guidance (if applicable), facility needs, water management, recordkeeping,
product safety recall systems, adverse event reporting, information disclosure, best practices and
safe handling procedures for post-production and downstream management and delivery
standards.
Cannabis Plant Health and Life Cycle: a) Cultivation stages; b) General information of
each state of a cannabis plant’s growth, including mothers, cloning, seedlings, vegetative,
flowering, harvesting, drying, curing, trimming, testing, packaging and proper storage
techniques; c) understanding lighting, nutrient management, feeding schedules, pest
management, canopy management, humidity, temperatures, carbon dioxide, batch and lot
management and pre-processing; d) The cannabis plant and its various strains including
associated cannabinoids (i.e. THC and CBD) and terpenes; e) the use and proper implementation
of our iPonic and Argus automated plant monitoring system – tracking soil conditions, humidity,
temperature and water cycles; and f) Federal and state cannabis laws and regulations. All plants
will be monitored daily using iPonic and Argus cultivation technology. All plants will be
monitored using a unique tag system for recordkeeping.
Sanitation and Biosecurity Procedures: Agents will be trained on proper sanitation
procedures including cleaning all areas daily, maintaining proper Integrated Pest Management
procedures and changing into their color-coded biosecure jumpsuits. All agents must wear
gloves, a hairnet or hat, beard net (if necessary) and shoe protectors when present in all
production areas.
Standards for Safe Operation and Maintenance of Equipment: Agents will undergo
necessary education, tools and training to successfully learn how to operate all equipment. How
to include safety regulations, how to clean work environment and proper biosecurity.
All Directors will train agents on safe use of all equipment and tools and environmentally
conscience practices. All trainers will be available for phone, email, skype/facetime video calls if
any questions were to arise during cultivation.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
12
With so much industry experience to train our staff, we are fully confident our leadership
team will be more than acceptable to the City Manager. With consultation from our leadership
team, we will establish and oversee our training program, ensuring that our trainers and materials
receive approval of the City Manager as required.
VI. Continuing Education
Education of our agents does not end once they are trained to work in our facility.
Education is ongoing as studies are published every day, providing greater insight into
appropriate forms and dosage of cannabis to help enhance knowledge of the plant. Our Area
Managers are charged with keeping up to date on new data and relaying it to our facility agent
staff on a regular and ongoing basis. Our agents will have team meetings weekly to review and
disseminate new information and to discuss how best to integrate that information into new
products.
Our Director of Cannabis Operations will conduct internal yearly continuing education
courses, using a web-based portal with test materials after each section. All agents must score an
80% on all test materials to continue employment. We will also follow continuing education
regulations from the Act, as all agents must complete continuing education and our internal
training. All facility agents must complete a minimum of 8 hours of continuing education during
each calendar year, per our Company policy. Our continuing education program will cover such
topics as: updates to Fresno rules and regulations related to the cannabis program; cannabis
industry trends; new research related to cannabinoids and terpenes, as well as on the overall
efficacy of cannabis in treating various conditions; recognizing signs of product diversion; and
safe handling of cannabis products, including common industry hazards, current health and
safety standards, and best practices.
VII. Other Training Courses
Other training that our Company sees as very important to our core values, but often
times gets overlooked, include Diversity Training, Sexual Harassment Training, Work Place
Violence and HIPAA training.
Diversity Training: All employees will receive diversity and cultural awareness training
as part of the on-boarding process. We will outsource and provide our agents a course on
Diversity in the Workplace. We take diversity and inclusion training very seriously, so we look
to partner with the best and brightest minds regarding cultural, sexual harassment, and workplace
violence awareness. The course is a lecture with group discussions, including problem solving
and team building exercises. Topics include the following: Gender, Cultural and Generational
Differences, Communication, Teambuilding and Conflict Resolution. The goal is to increase
awareness for those working in diverse work environments as well as preventing any issues with
diversity and cultural differences among customers.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
13
Even as a minority-owned cannabis company, we plan to adopt an Affirmative Action
Plan for ensuring a diverse workforce as well as implement diversity training amongst all levels
of employees. We will conduct annual analyses to measure our diversity plans’ effectiveness,
and the degree to which its objectives have been attained and its obligations fulfilled. We will
monitor and update these analyses each quarter, implementing any necessary actions to increase
its effectiveness. These training tools will create cultural awareness in an industry dominated by
non-minorities and we believe all our agents will benefit and demonstrate proper skills in
resolving diversity and cultural awareness conflict or confrontation with customers and other
employees.
Sexual Harassment: We will include training on sexual harassment identification and
prevention, as part of the on-boarding process. The course is an online, interactive tool, which
includes a back-end tracking system to ensure all employees have completed and have been
tested. Topics include: Inappropriate Physical Conduct, Inappropriate Verbal Conduct,
Inappropriate Non-Verbal Conduct, Complaint Procedures, Sanctions and Disciplinary
Measures, Data Security, and Implementation of our Sexual Harassment Policy. All agents must
take a 1-hour exam on the topics discussed and pass with an 80% or better. Our policy will be
included in the staff handbook and we will require all employees to attend an annual continuing
education training course on content of our policy.
Furthermore, as managers are promoted, they ALL must take an online training course
that discusses sexual harassment laws from a management to employee perspective. The goal of
our sexual harassment training is to increase awareness for those working in diverse work
environments as well as preventing any issues that make any employee, vendor and customer
uncomfortable.
Workplace Violence: All employees will receive OSHA standard training on workplace
violence identification and prevention, as part of the on-boarding process. All agents will be
trained by a certified instructor on Violence in the Workplace.
The course will be a lecture with group discussions, including problem solving and team
building exercises. Topics include: Defining Workplace Violence, Statistics on Violence,
Economic Impact of Workplace Violence, OSHA Guidelines, Administrative Controls, Post-
Incident Response and Recordkeeping. To prevent workplace violence, employees will be
trained on our 5 successful points: (i) create supportive environment, (ii) understand workplace
violence policy, (iii) commit to a non-violence (verbal and non-verbal) workplace, (iv) create
and practice action plans and (v) creation of a zero-tolerance plan.
Furthermore, as managers are promoted, they ALL must take an online training course
that discusses sexual harassment laws from a management to employee perspective. The goal of
our sexual harassment training is to increase awareness for those working in diverse work
environments as well as preventing any issues that make any employee and vendor
uncomfortable.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
14
VIII. Emergency Procedures and Training
Our Emergency and Prevention Plan includes regular training for our employees on our
standard operating procedures in the event of a crisis/disaster. This training includes scenario
planning and live drills for fire, hurricane, and flooding procedures. This training also includes
live drills for dealing with active intruders (see Security Plan for more detail). We also provide
all new employees with CPR and first-aid training, as well as training related to emergency
evacuation procedures (including quarterly evacuation drills).
Our crisis/disaster preparedness training is conducted by the members of our Emergency
Response Team (ERT). Per our standard operating procedures, each member of our ERT – CEO,
Security Manager, and Facility Manager – is mandated to take FEMA Emergency Management
Institute (EMI) online courses, including, at a minimum, in emergency response (EMI-IS 317),
and to successfully complete the final exam for this course with a score of 90% or better. Our
crisis/disaster preparedness training includes:
Basic Crisis/Disaster Preparedness: Per our standard operating procedures, all facility
employees will be trained to take the following basic steps should our facility experience a crisis,
disaster or other event that severely disrupts our operations:
• To evacuate the facility if necessary.
• To help evacuate customers, and other members of the public at our facility if doing
so would not put themselves at risk of harm.
• If evacuation is necessary, to evacuate to a pre-determined area of refuge (if
possible).
• To direct any evacuated members of the public (non-employees) to a pre-determined
area of refuge (if so doing would not put themselves at risk of harm).
• To call emergency responders and/or 911.
• If the disaster and/or emergency requires sheltering in place, to:
o Determine best location in the facility to take shelter
o Direct any non-employees to the shelter location
o Collect all disaster preparedness kits
o Activate NOAA Weather Radio (if necessary)
• To notify a member of our Emergency Response Team of the ongoing emergency
and/or disaster as soon as possible (as long as doing so would not put themselves at
risk of harm).
Severe Weather Preparedness: In the event of severe weather, including tornado or
hurricane, per our standard operating procedures, all facility employees will be trained:
• To activate a facility NOAA Weather Radio to receive important updates regarding
weather conditions
• To evacuate the facility if advised to do so by local authorities (or by a member of our
ERT who has received instructions from local authorities)
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
15
• To help evacuate patients, caregivers, and other members of the public at our facility
if doing so would not put themselves at risk of harm
• If remaining and/or sheltering in place, to:
o Determine best location in the facility to take shelter
o Direct any non-employees to the shelter location
o To stay away from doors and windows
o To Collect all disaster preparedness kits
o To transfer at least one of the facility NOAA Weather Radios to the place of
shelter
• To call emergency responders and/or 911 (if necessary)
• To notify a member of our Emergency Response Team of the ongoing emergency
and/or disaster as soon as possible (as long as doing so would not put themselves at
risk of harm).
Our severe weather preparedness training also includes educating our employees on the
severe weather-related terms used by the National Weather Service to indicate the severity
and/or potential danger of predicted severe weather, including:
• Advisory: Conditions to cause significant inconveniences that may be hazardous. If
caution is used, these situations should not be life-threatening
• Watch: Issued when severe weather is possible within 48 hours. Tune into NOAA
Weather Radio All Hazards to monitor alerts
• Warning: Issued when severe weather is expected within 36 hours. Tune into NOAA
Weather Radio All Hazards to determine if evacuation required
Our severe weather preparedness training also incorporates instructional materials from
FEMA’s “Turn Around, Don’t Drown” program which explains in detail the drowning danger
posed by walking or driving on flooded roads or through floodwaters. All employees will be
provided with an evacuation information sheet that will list evacuation routes recommended by
the Department of Transportation and the Office of Emergency Management.
Fire Safety: In the event of a fire, per our standard operating procedures, all facility
employees will be trained to do the following:
• Remove all persons from immediate danger without placing themselves at risk;
• Activate the fire alarm;
• Dial 911 and provide their name, exact location, phone number and the type of fire;
• Close all doors in the fire area and in the halls as needed (to contain the fire) without
putting themselves at risk; and
• Evacuate all employees to a pre-determined area of refuge (if possible).
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
16
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
Our CCB will be committed to Social Policy Section 9-3316(b)(1)(i-vii) when it comes to
employing more than 33% of our work staff that (i) has an annual family income below 80%
AMI; (ii) convicted for a cannabis related crime that could have been prosecuted as a
misdemeanor or citation under current State law; (iii) lived in a low to moderate income census
tract in the city for a minimum of three years; (iv) veteran ; (v) former foster home youth who
was in foster care as a minor; (vi) unemployed; or (viii) receiving public assistance. Our business
is majority owned by an individual that was convicted for a cannabis related crime and now has
the opportunity to learn from one of the premier cannabis brands in the industry. This
opportunity will create generation wealth for Mr. Hopkins and his family.
Internal Goals and Benchmarks: Our CCB will adopt the current local percentage of
minorities, women, veterans, indigent and people with disabilities in the civilian labor force as its
hiring benchmark for these disadvantaged groups. Our Company will update our hiring
benchmark as new data is published and updated via the US Census. The hiring benchmarks
apply to the available workforce and not just in particular job groups. Our Director of Human
Resources has collected data and conducted analyses to identify areas of opportunity in the
employment of minorities, women, veterans, indigent and individuals with disabilities. Our
Director of Human Resources will continue to monitor and update these analyses during each
year. We will be looking to hire full-time and part-time employees for the following job groups:
management, supervisors, agents, packaging, delivery, inventory, security, maintenance, finance,
research and development, community outreach and marketing and sales.
We plan on hiring and maintaining the following benchmark goals succeeding many of
Fresno’s available demographics, per SEC 9-3316(b)(1):
Currently, Fresno has a 26.9% poverty rate of its citizens and we believe our team will
have no issues hiring 33% of more of our staff that qualify as (i) has an annual family income
below 80% AMI; (ii) convicted for a cannabis related crime that could have been prosecuted as a
misdemeanor or citation under current State law; (iii) lived in a low to moderate income census
Our Fresno
Protected Group Placement Goals Availability
Minorities - Non-White (racially disadvantaged) 45.0%39.5%
Women 50.0%50.8%
Veteran 5.0%3.6%
Individuals w/ Disabilities 10.5%10.5%
People living in Poverty 30.0%26.9%
Source: US Census demographic information
Our Company used local census and demographic statistics to calculate available population in Fresno.
We will look to hire people in the local community, local county and meet these goals.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
17
tract in the city for a minimum of three years; (iv) veteran ; (v) former foster home youth who
was in foster care as a minor; (vi) unemployed; or (viii) receiving public assistance.
People with disabilities are a particularly challenging area for recruitment, for most
manufacturing facilities. Such people can face discrimination in the form of undervaluing of their
skills, but many of the job positions at any of our facility types can be performed completely by
disabled individuals as all of our facilities will be fully American Disability Act (“ADA”)
compliant. We will partner with a full-service non-profit community organization that will
provide services for persons with developmental disabilities, mental illness and substance abuse
challenges, among other youth programs. We will work together to provide the able-disabled
with job opportunities.
We plan to adopt an Affirmative Action Plan for ensuring a diverse workforce as well as
implement diversity training amongst all employees. Our Director of Human Resources will
conduct annual analyses to measure its effectiveness, and the degree to which its objectives have
been attained and its obligations fulfilled. Our DHR will monitor and update these analyses each
quarter during each year, implementing any necessary actions to increase its effectiveness to
meet our goals.
Workforce Diversity Outreach Initiatives: Consistent with our diversity values and
building community trust, we will reach out to Fresno business owners regarding hosting
community events to introduce our CCB, Company and team members. We will support a
variety of Fresno service programs, including those designed to improve the employment
opportunities of disadvantaged groups mentioned in Social Policy Section 9-3316(b)(1).
We are committed to fair wages in all states where we operate. To show our commitment
to long-term staffing employees nationwide, we signed a Labor Peace Agreement and Project
Labor Agreement for our pending New Jersey application, and we are under contract with the
UFCW for our Maryland cultivation operations and will partner with UFCW for our national
company.
We will train for long-term success and many employees will be cross trained among job
groups, allowing team members to have well-rounded career experiences. Our goal is to build a
workforce with careers in cannabis and not “jobs” in cannabis.
Many of our competitors hire or place minority figureheads on these type of applications
ONLY to win points or “show diversity”, not hiring or allowing diversity for long-term staffing
needs. Many applicants will provide “lip service” to their staffing practices regarding hiring a
diverse workforce, but our President and COO has experience in executing our Diverse Long-
Term Staffing Plan and looks forward to bringing our ideas to better serve the Fresno workforce.
Other Examples of Advocacy for Social Responsibility in Cannabis: Our team
demonstrates many past and present experiences that promote economic development and
empowerment in disadvantaged areas. Not only in Fresno, but also in other areas where we
operate or plan to operate. These experiences are done by members of our team organically and
not forced due to win points on an application. We truly believe in servicing undeveloped
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
19
excerpt from Sustainable Brands that mentioned Viola’s commitment to providing job
opportunities to those that need it most.
Timing of Hiring: We want to be the standard for diversity hiring and maintaining our
diversity goals for the Fresno cannabis industry. After being awarded a Fresno CCB license we
plan to immediately reach our diversity hiring goals through everything outlined in this plan.
Once operations commence, a utilization analysis of the employment of women, minorities,
veterans, indigent and individuals with disabilities by job group is conducted. The utilization
analysis requires estimating the number of qualified minorities, women, veterans, indigent and
individuals with disabilities available for employment in each job group, expressed as the
percentage of all qualified persons available for employment in the job group.
We estimate that 100% of our workforce will be from Fresno and the surrounding
areas. Our team will collect and revise data annually indicating the number and percentages of
employees in each department by designated job group from various minority groups. Under data
reported to the DHR, our executive team will analyze annually the number and percentages of
employees in each department by designated pay grade and minority classification (women,
minority, veterans, indigent, disabled) levels from various minority groups.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
20
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
Our CCB will be locally managed by Mr. Delanno Hopkins, he is the majority owner and
CEO of the Fresno business. Mr. Hopkins will be the day-to-day operator helping operate our
cultivation facility and having executive control of all operations. He will be trained by our
executive team and go through the same training as our agents. Mr. Hopkins has been a lifelong
Fresno resident, he currently resides in, Fresno, California and
Being locally owned and operated is very
important as it provides a local perspective to our CCB.
Given the partnership of Viola and Mr. Hopkins, we are committed to providing local
management with opportunities for ownership. Our team is proud that Mr. Hopkins has the
ability to own, operate and profit from an industry that is majority white owned after serving
time for cannabis trafficking. Mr. Hopkins is looking forward to managing and owning a local
business and partnering with a majority African American owned vertically integrated cannabis
business.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
21
2.6 Describe the number of employees, title/position and their respected responsibilities
Job Creation Plan: Many members of our current management have been with our
National Company since the beginning. Most began as entry-level employees and worked their
way to managers, directors, supervisors and owners. We strongly believe in hiring from local
communities, promoting those that work hard and show leadership, providing training for our
employees to begin a career in cannabis not just a job in cannabis and paying above average
wages, all keeping long-term employees. Our employees tend to respond well to good wages and
benefits with loyalty and hard work, with everyone aligning themselves with the interests of the
company.
Many applicants will make promises and build partnerships to try to earn points on an
application, but our actions have been organic since inception. For example, our team built our
Michigan facility in a very economically distressed region of Detroit, and we plan to pay our
workers above-average wages, plus year-end bonuses. Our pending application in New Jersey is
located in Penns Grove, which has a poverty rate six times the national average. Our soon to be
state-of-the-art cultivation and processing facility in Missouri is located in the heart of St. Louis,
where unemployment is close to 25% and 40% of the zip code’s population live in poverty.
Again, exemplifying we are NOT afraid to operate and hire where most pharmaceutical
processor applicants will not.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in medical
cannabis. In Fresno, our entry wage will not be below $20.00 (well above the $12.00 per hour
California minimum wage), plus year-end bonus, plus benefits and participation in our employee
equity plan. 100% of our employees will be provided a livable wage.
Our employee benefits will include workers’ compensation, subsidized health care and
dental coverage, with coverage of preventative care, including ob-gyn, mammograms and
immunizations. All employees, including part-timers, will earn paid time off (“PTO”) and
receive paid holidays. We will reserve 10% in our Company cash flow to allocate to our Fresno
employee profit sharing/equity plan, this allows our managers and employees to receive upside
when the Company does well and incentivizes our employees for long term operational success.
If we decide to award equity, our owners will dilute accordingly to maintain our social equity
status.
In 2022, our CCB operation will provide between 35 to 40 full-time part-time jobs in one
of the fastest growing industries. Consistent with all the above benefits. In 2026, our CCB
operation will grow to 50 full-time and part-time jobs.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
22
Administrative and local executive positions will provide 20 to 25 full-time jobs.
Consistent with all the above benefits.
The above charts represent a summary of our anticipated salaries to our Fresno operations
team, administrative and executives that split salary expenses with other operating states, the net
result of which will provide, on average, million annually in well-paid unionized jobs
with full benefits. As you can see, we pay well above typical cannabis wages and no employee is
scheduled to make less than annually or per hour (Executive Administration).
100% of our employees will pe paid livable wages and 75% of our staff will be full-time. All
our agents will have the ability to earn upward of per year, including annually or hourly
pay, year-end bonuses and participation in our company cash flow/equity program. If we want to
attract the highest level of talent, our agents will receive market level compensation with bonuses
and participation in our Company equity program.
We feel this provides a sustainable living wage for all individuals. If we feel these wages
are not “Fresno market” we will adjust, even if the result lowers our profit margin.
Ensure Employee Representation from the Local Community: We are targeting to hire
our entire CCB staff locally with Fresno residents. For example, if we are awarded a license
Fresno we will first look to hire within the city of Fresno before reaching to outside resources, all
done without discriminating any applicant. In addition, the need to hire local vendor firms for
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
23
construction, architecture and design, our facility will bring over 20 well-paying jobs with good
benefits in areas that could benefit from an economic infusion.
We believe strongly that treating and compensating people fairly is not only the right thing
to do, but it is the only way to run a successful business. Our teams have confirmed that providing
generous wages/benefits builds trust, reduces costly turn-over, and promotes loyalty to the
company. Our above-average compensation will attract top local talent.
Our plans do NOT call for bringing out-of-towners to run a local cultivation facility - like
many of our competing multi-state operators looking to capitalize on California’s cannabis market,
essentially providing out-of-towners with wealth while they file personal taxes elsewhere. We will
build a talented workforce from scratch in Fresno. It also helps that we already operate our
corporate headquarters in California. Unlike some of the corporate public companies vying for more
licenses, we will need to staff up vertically all of the relevant positions with local residents, just as
we have done at our other operations where most of our managers and staff was hired from the
surrounding communities. We not only write about what we are going to do, but back it up by
actions.
Speaking of actions, our Company signed a Labor Peace Agreement with the United Food
& Commercial Workers (UFCW) Local 8-Golden State. The UFCW will be a valuable resources
from the identifying, staffing and hiring local talent.
Our executive team will continue to meet with government officials, hold town hall
meetings at various community and religious centers to cultivate personal contacts with members
of the community, target qualified labor in communities with higher than average minority
populations; and placing job advertisements, when appropriate, in local online job boards and
print media aimed at local residents. We will also look to partner with local Veteran Affair
offices to post job opportunities for veterans, many have a hard time applying for jobs that aren’t
violent in nature (i.e. police and security jobs). Our Company’s business model ensures that local
talent will be hired as majority ownership resides in Fresno.
As themed throughout our Social Policy and Local Enterprise Plan, hiring locally and
hiring a diverse team are core principles of our CCB. We do not consider ourselves “opportunist”
or “outsiders” that are trying to take advantage of the so-called California “Green Rush”. Many
of our owners, managers and employees represent the state of California in many ways. Our
roots in California and Fresno ownerships means we will hire, train and include employees that
live in Fresno for long-term success. We will need to fill approximately 50+/- full-time/part-time
positions, that include managers, agents, security, finance, marketing and sales. Below are the
following key positions in our cultivation along with positions that will be open for hire. Any
employee we hire or have on pay roll or consulting is making above livable wages, typically
above market for their position.
We will submit a list to the City Manager of the names of all service professionals that
will work at our facility. Our list will include a description of the type of business or service
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
24
provided. Changes to our list of service professionals will be sent to the City Manager
immediately.
Below is description of positions for our CCB.
Chief Executive Officer: Delanno Hopkins, is the ultimate authority for overall decision-
making for our cultivation operations. Externally, he is responsible for developing business
relationships for the CCB with Fresno dispensaries and increasing sales. Together with the COO
and Facility Manager, the CEO develops realistic product acquisition and sales goals and refines
the company’s mission culture and operators as necessary to achieve those goals. The CEO is
also responsible for, together with the COO, approving all operating policies and procedures as
well as all training programs for employees, and updating these quarterly. The CEO will be
trained by our team of experienced operators. This position reports to the Board of Directors.
Chief Operating Officer: Jamil Taylor, serves as our operations expert. The position is
responsible for the operation and business aspects of our day-to-day business operations and
decision making. In consultation with the various area Directors/Managers and the Facility
Manager, the COO will assist the CEO in business decision and determine overall business
strategy. Together with the Facility Manager, the COO develops all Standard Operating
Procedures. He is responsible for ensuring that we are following our stated policies and
procedures in our Standard Operating Procedures. He works collaboratively with the CEO to
ensure that sales and product targets are being met and to solve more challenging financial
operating problems. The COO reports to the CEO.
Facility Manager(s): To Be Hired Locally, will run the facility on a day-to-day basis
sharing responsibility to fulfill oversight requirements during business hours. S/he will have
oversight of the agents, including by consulting with the COO and Directors regarding all
aspects of cultivation and post-production. S/he will help train and develop agent training
materials and ensure every agent is fully compliant. This role reports to the COO.
Cultivation Manager & Agents: To Be Hired Locally, will work within our production
facility and will be fully involved in all cultivation aspects of our facility. They will be trained on
all aspects of soil management, propagation, cloning, flowering, harvest and drying. The agent
will report to our Director of Cultivation.
Harvest Managers & Shift Agents: To Be Hired Locally, will be in charge of our
downstream and post-production activities. They will handle all harvest, drying, curing,
weighing and packaging of finished cannabis. This role reports to the Facility Manger.
Inventory Manager & Agents: To Be Hired Locally, will work with our COO to order and
track all inventory in our Vault, receiving, product ordering, recall and destruction. Inventory
Manager will count and physically scan each product and confirm the product’s name, strain
name, weight and identification number on the manifest matches the information on the cannabis
products label and package. The Inventory Manager will also conduct daily, monthly and annual
comprehensive inventories, which include opening and closing accounts of product. This role
reports to the COO.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
25
Sales Supervisor & Sales Agents: To Be Hired Locally, will be in charge of all wholesale
ordering and knowing our Customer Relationship Management software. S/he will manage
vendor relationships, understand all product brands and make sure dispensaries have our product
represented in their inventory. The Sales Supervisor reports to the Facility Manager.
Security Manager: To Be Hired Locally, will train and educate staff on all day-to-day
aspects of security and will be responsible for reporting violations or potential violations to the
City Manager and Fresno law enforcement agencies. The Security Manager will also oversee our
product receiving, shipping and loading area procedures. He/she reports to our CEO and COO.
Security Guards: To Be Hired Locally, will carry out the policies, procedures and
protocols of our stringent security plans in accordance with all applicable laws, rules, and
regulations. They are responsible for, among other things: screening visitors, customers and
employees at the entrance; handling perimeter security, site surveillance, access control and
product movement compliance. They report to the Security Manager.
Executive Administration: To Be Hired Locally, S/he will assist our Management staff
with all administrative tasks. S/he will be involved in organizing, recordkeeping and oversight
within our CCB. S/he will report to the Facility Manager.
Controller: To Be Hired Locally, this position is responsible for day-to-day accounting /
bookkeeping and recordkeeping functions of the organization in Fresno. The Controller must
have a finance or accounting background, a bachelor’s degree with at a minimum of five years
and efficient in Microsoft Excel and fully trained in QuickBooks. The Controller reports to the
CEO and COO.
Director of Cannabis Operations: Marques Moore – will work with the Cultivation
Manager to educate staff on the different cannabis strains, methods of ingestion and use, and
effectiveness and recommendations for specific uses. He will lead our agent training program
along with the Director of Cultivation and others from our national team. Along with training our
staff, she will reach out and help educate the local residents of Fresno on local cannabis rules and
laws. With him being our National Director, the goal is to train a local team member to be our
Fresno instructor. The Director of Cannabis Operations reports to the COO and Director of
Cultivation.
Director of Community Outreach: To Be Hired Locally, will be responsible for
developing relationships with the local community, including to provide outreach programs to
bridge the community with our Company, provide educational information regarding cannabis
and serve as our Veteran Affair liaison. S/he will coordinate free seminars for customer, family,
healthcare professionals and the general public on subjects such as: understanding cannabis; the
laws and regulations governing the Fresno cannabis program. S/he will also help lead social
events the CCB sponsors in our Community Education & Training Center (CETC), including
fitness classes, substance abuse and community impact, family intervention groups, cannabis
expungement assistance and voting registration assistance. The Director of Community Outreach
reports to the COO.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
26
Director of Technology and Facility Maintenance: To Be Hired Locally, devises the
strategic design, acquisition, management, and implementation of our technology infrastructure
including, without limitation, the Company’s cyber security protocols, Security Information
Technology Room (SITR), ITS/CRM/POS platform software interface with the Department’s
System, security systems and technology training. Any issues with our internal or external
technology systems will be monitored by our Director of Technology and Facility Maintenance
(DTFM) and must have three years of Information Technology experience and a bachelor’s
Information Technology or Computer Science. The DTFM reports to the COO.
All employees will be offered healthcare packages with benefits and an opportunity to
invest in our Company equity plan. We believe in hiring local and using local resources to
accomplish our goal of being the best cultivator in Fresno. Entry level positions will range from
per year and managerial positions ranging from per year,
with end of year performance bonuses. We are paying our employees well above comparable
National retail averages. We plan to inject more than of new salaries into the Fresno
community.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
27
2.7 Describe whether the CCB has five or more employees and whether it has signed a
labor peace agreement allowing employees to unionize without interference
The CCB currently does not have five employees as the business is not operating. Upon
winning a license we hire a local Fresno staff. To show our commitment to empowering and
partnering with our workers, our COO signed a Labor Peace Agreement (“LPA”) with the Local 8-
Golden State United Food & Commercial Workers (“UFCW”), and our meeting with the union
representatives Aidan Coffey, left our COO very encouraged that the union is going to be a
valuable resource in terms of helping us hire and protect talented local residents of Fresno. Our
signed LPA and UFCW Cannabis Diversity Plan is attached within this exhibit. If selected
for Fresno, we plan to sign a Project Labor Agreement (“PLA”). Our PLA will demand our
construction project “…includes requirements as to minorities, women and local resident hiring
on the Project, any negotiated PLA shall be supportive of these requirements.”
A proper labor compliance plan starts with human resource management and compliance
teams that are knowledgeable about federal, state and local labor laws. Our Director of Human
Resource (“DHR”), Teresa Saucedo, has nine years navigating human resource management
techniques and complying to labor laws. Prior to the cannabis industry, Mrs. Saucedo was the lead
human resources recruitment director for LJ Consulting Group. She provided client centric solutions
in the areas of talent acquisition and human resource strategy consulting. Our Chief Compliance
Officer, Adam Day, will support Mrs. Saucedo in her task of making sure we are in full compliance
of labor laws. Given the planned diversity of our workforce and the minority makeup of our team,
all labor compliance training and employee handbooks can be provided in English and Spanish.
Please find attached our executed Labor Peace Agreement
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
28
2.8 Provide a workforce plan that includes at a minimum the following provisions:
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
Ensure Employee Representation from the Local Community: We are targeting to hire
our entire CCB staff locally with Fresno residents. For example, if we are awarded a license
Fresno we will first look to hire within the city of Fresno before reaching to outside resources, all
done without discriminating any applicant. In addition, the need to hire local vendor firms for
construction, architecture and design, our facility will bring over 20 well-paying jobs with good
benefits in areas that could benefit from an economic infusion.
We believe strongly that treating and compensating people fairly is not only the right thing
to do, but it is the only way to run a successful business. Our teams have confirmed that providing
generous wages/benefits builds trust, reduces costly turn-over, and promotes loyalty to the
company. Our above-average compensation will attract top local talent.
Our plans do NOT call for bringing out-of-towners to run a local cultivation facility - like
many of our competing multi-state operators looking to capitalize on California’s cannabis market,
essentially providing out-of-towners with wealth while they file personal taxes elsewhere. We will
build a talented workforce from scratch in Fresno. Unlike some of the corporate public companies
vying for more licenses, we will need to staff up vertically all of the relevant positions with local
residents, just as we have done at our other operations where most of our managers and staff was
hired from the surrounding communities. We not only write about what we are going to do, but
back it up by actions.
Speaking of actions, our Company signed a Labor Peace Agreement with the United Food
& Commercial Workers (UFCW) Local 8-Golden State. The UFCW will be a valuable resources
from the identifying, staffing and hiring local talent.
Our executive team will continue to meet with government officials, hold town hall
meetings at various community and religious centers to cultivate personal contacts with members
of the community, target qualified labor in communities with higher than average minority
populations; and placing job advertisements, when appropriate, in local online job boards and
print media aimed at local residents. We will also look to partner with local Veteran Affair
offices to post job opportunities for veterans, many have a hard time applying for jobs that aren’t
violent in nature (i.e. police and security jobs). Our Company’s business model ensures that local
talent will be hired as majority ownership resides in Fresno.
As themed throughout our Social Policy and Local Enterprise Plan, hiring locally and
hiring a diverse team are core principles of our CCB. We do not consider ourselves “opportunist”
or “outsiders” that are trying to take advantage of the so-called California “Green Rush”. Many
of our owners, managers and employees represent the state of California in many ways. Our
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
29
roots in California and Fresno ownerships means we will hire, train and include employees that
live in Fresno for long-term success. We will need to fill approximately 50+/- full-time/part-time
positions, that include managers, agents, security, finance, marketing and sales. Any employee
we hire or have on pay roll or consulting is making above livable wages, typically above market
for their position.
We will submit a list to the City Manager of the names of all service professionals that
will work at our facility. Our list will include a description of the type of business or service
provided. Changes to our list of service professionals will be sent to the City Manager
immediately.
2.8.2 Commitment to offer apprenticeships and /or compensation for continuing
education in the field
Incubation: Our goal is to train and incubate cultivation agents, so they have the
wherewithal to apply and manage their own Fresno or California CCB. Many of our previous
employees in other states started as entry level employees and have continued a career in
cannabis as managers or moved on to other businesses to generate successful careers. One of the
main reasons why individuals cannot “break” into the cannabis industry is because of lack of
cannabis cultivation or management experience.
Our incubation program Incubate to Ownership, will incubate our managers and
supervisors by giving them real-time and real-world experience in the cannabis industry. Often
times, people of color or minorities are denied access to ownership because they have ZERO
cannabis experience and their lives were negatively affected by the War on Drugs. If you live in
a state without cannabis opportunities, it’s nearly impossible to enter the industry. If you do enter
the industry, many people of color and minorities are resorted to low level entry jobs that pay
$11.00 - $13.00 per hour and never have a chance to own a cannabis business. Currently, in
California less than 3% of cannabis cultivators are majority owned by African Americans. This
does not reflect the diversity of California and in particular Fresno. We hope to change those
statistics and give people of color a chance at ownership and not just “jobs”.
Our Incubate to Ownership program will select top level managers and supervisors that
qualify as Social Equity Applicants and train, educate and provide resources to those individuals
for the next wave of licenses. This program is designed to ensure that all managers and
supervisors have the skills, knowledge and opportunity to own and operate a CCB in the very
near future. The training course will be designed by our experienced Director of Cannabis
Operations, Director of Cultivation and our COO – all have first-hand operating and ownership
experience. The course will consist of our typical 80-hour training material and also include
continuing education on Cultivation Techniques, Inventory Management, Recordkeeping,
Security & Surveillance, Financial Statement Analysis, Cash Management, Capital Raising, 1-
on-1 Managerial training and Application Assistance.
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
30
This incubation program will prepare managers for ownership of a CCB no matter the
state.
2.8.3 Commitment to pay a living wage to its employees
Our Commercial Cannabis Business (CCB) is fully committed to providing our employees
with a Living Wage, as defined by the Fresno Living Wage Calculator researched by to Dr. Amy K.
Glasmeier, Ph.D. Our Company believes in using wage models to fully understand what’s needed
for families to properly provide for their families that draws upon geographically specific
expenditure data related to food, childcare, health insurance, housing, transportation and other basic
necessities. We understand that we will not be able to provide all of our employees with six figure
salaries, but we will look at the below formula to properly come up with salaries that provide Fresno
residents with career opportunities that involve bonuses, healthcare benefits and other perks so our
employees can be proud of their success.
We looked at how the living wage is defined and came up with hourly rates and salaries that
provide employees with a Living Wage according to the City of Fresno:
Living Wage = Basic needs budget + (basic needs budget * tax rate)
Viola has always paid employees above average wages, no employee will make less than
per year and that’s an entry level position. After reviewing this section you will see wages
ranging from depending on the position and experience of the employee.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in medical
cannabis. In Fresno, our entry wage will not be below (well above the $12.00 per hour
California minimum wage), plus year-end bonus, plus benefits and participation in our employee
equity plan. 100% of our employees will be provided a livable wage.
Our employee benefits will include workers’ compensation, subsidized health care and
dental coverage, with coverage of preventative care, including ob-gyn, mammograms and
immunizations. All employees, including part-timers, will earn paid time off (“PTO”) and
receive paid holidays. We will reserve 10% in our Company cash flow to allocate to our Fresno
employee profit sharing/equity plan, this allows our managers and employees to receive upside
when the Company does well and incentivizes our employees for long term operational success.
If we decide to award equity, our owners will dilute accordingly to maintain our social equity
status.
The net result of our operations, administrative and executive team will provide
million annually in well-paid unionized jobs with full benefits. As you can see, we pay well
Social Policy and Local Enterprise Plan TRADE SECRET
Appendix A: Evaluation Criteria
31
above typical cannabis wages and no employee is scheduled to make less than annually
or $20.00 per hour (Executive Administration). 100% of our employees will pe paid livable
wages and 75% of our staff will be full-time. All our agents will have the ability to earn
upward of per year, including annually or hourly pay, year-end bonuses and
participation in our company cash flow/equity program. If we want to attract the highest level of
talent, our agents will receive market level compensation with bonuses and participation in our
Company equity program.
Mr. Delanno Hopkins has lived in a low income household zip code
of Fresno, CA for close to a decade that is identified as at least
70% by CalEnviroScreen.The follow page shows that Mr.Hopkins
address is in an area that is 81-90%. Mr. Hopkins is currently
unemployed and meets the low-income qualification.
Mr. Hopkins, like many other social equity candidates he did not
realized that he can apply as a social equity applicant. Upon
learning of his qualification he reached out to our Company on
Thursday November 12, 2020 and he has begun to gather his
proof of residency documents. We hope the City of Fresno will
grant Mr. Hopkins more time to get his documents in order to
submit a timely qualified application.
If we partner with Mr. Hopkins, he will receive majority ownership
(51%), he will be well funded, he will work on a serious business
plan, he will be trained and incubated by our team to operate a
successful vertically integrated cannabis company in Fresno. Given
the address on his Driver’s License we are confident his address
qualifies and we hope we will receive time to summit all
documentation, especially since the application is due in January
2021.
Please feel free to contact –Jamil Taylor
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
February 5, 2021 Please reply to:
Rob Holt
(559) 621-8056
Jamil Taylor
Viola Fresno
420 W Huron St, Ste 224
Chicago, IL 60654
Dear Applicant:
SUBJECT: ZONING INQUIRY NUMBER P21-00559 REQUESTING INFORMATION
REGARDING COMMERCIAL CANNABIS USES (CULTIVATION) FOR
PROPERTY LOCATED AT 2861 EAST DOROTHY AVENUE
(APN 328-200-84S)
Thank you for your inquiry regarding the allowance of commercial cannabis uses. The
requested information about a cannabis business for cultivation 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 commercial cannabis business on
the subject property conveys the following:
1. All cannabis cultivators must be located on property within the Cannabis Innovation
Zone, inside a Cannabis Innovation Hub, or within one-half (½) mile of State Route 99
between Shaw Avenue and Clinton Avenue, one (1) mile of State Route 99 north of
Shaw Avenue, or south of Clinton Avenue, or within one (1) mile of State Route 180
west of State Route 99, must be zoned IL (Light Industrial) or IH (Heavy Industrial), and
must meet all of the requirements for development in these zones. If not located within
the Cannabis Innovation Zone, any building in which a cultivator is located shall be no
closer than 1,000 feet from any property boundary containing any of the following:
(a) Any residentially zoned parcel in the city, including any legal non-conforming
residential uses as of the date a complete commercial cannabis business permit
application is submitted;
(b) A school providing instruction for any grades pre-school through 12 (whether public,
private, or charter, including pre-school, transitional kindergarten, and K-12);
(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; or,
(d) A youth center that is in existence at the time a complete commercial cannabis
business permit application is submitted.
Zoning Inquiry P21-00559
2861 East Dorothy Avenue
Page 2
February 5, 2021
The subject property located at 2861 East Dorothy Avenue (vacant) is located within 1
mile of State Route 99 south of Clinton Avenue, is zoned IH, which is one of the
allowable zone districts for commercial cannabis businesses, and is not located within
1,000 feet of the aforementioned sensitive uses. Development standards of the IH zone
district are available in Sections 15-1303, 15-1304, and 15-1305 of the FMC. The
subject location meets the location restriction requirements, per Section 15-
2739.C.1.b of the FMC, for a commercial cannabis business.
2. Prior to commencing operations, a commercial cannabis business must obtain a
Cannabis Conditional Use Permit from the Planning and Development Department per
Section 15-2739.N of the FMC.
3. There shall be permitted 8 cultivators, distributors, or manufacturers located within the
Cannabis Innovation Zone, and there shall be permitted 8 cultivators, distributors, or
manufacturers located inside a Cannabis Innovation Hub or within ½ mile of State Route
99 between Shaw Avenue and Clinton Avenue, one mile of State Route 99 north of
Shaw Avenue or south of Clinton Avenue, or within one mile of State Route 180 west of
State Route 99.
Currently, there are 0 cultivators, distributors, or manufacturers located in the City of
Fresno. This location requirement is satisfied for a commercial cannabis 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 commercial cannabis businesses, including but not limited to,
application requirements, façade design, 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 559-621-8056 or at Robert.Holt@fresno.gov.
Cordially,
Rob Holt, Planner III
Development Services Division
Planning and Development Department
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
February 5, 2021 Please reply to:
Rob Holt
(559) 621-8056
Jamil Taylor
Viola Fresno
420 W Huron St, Ste 224
Chicago, IL 60654
Dear Applicant:
SUBJECT: ZONING INQUIRY NUMBER P21-00559 REQUESTING INFORMATION
REGARDING COMMERCIAL CANNABIS USES (CULTIVATION) FOR
PROPERTY LOCATED AT 2861 EAST DOROTHY AVENUE
(APN 328-200-84S)
Thank you for your inquiry regarding the allowance of commercial cannabis uses. The
requested information about a cannabis business for cultivation 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 commercial cannabis business on
the subject property conveys the following:
1. All cannabis cultivators must be located on property within the Cannabis Innovation
Zone, inside a Cannabis Innovation Hub, or within one-half (½) mile of State Route 99
between Shaw Avenue and Clinton Avenue, one (1) mile of State Route 99 north of
Shaw Avenue, or south of Clinton Avenue, or within one (1) mile of State Route 180
west of State Route 99, must be zoned IL (Light Industrial) or IH (Heavy Industrial), and
must meet all of the requirements for development in these zones. If not located within
the Cannabis Innovation Zone, any building in which a cultivator is located shall be no
closer than 1,000 feet from any property boundary containing any of the following:
(a) Any residentially zoned parcel in the city, including any legal non-conforming
residential uses as of the date a complete commercial cannabis business permit
application is submitted;
(b) A school providing instruction for any grades pre-school through 12 (whether public,
private, or charter, including pre-school, transitional kindergarten, and K-12);
(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; or,
(d) A youth center that is in existence at the time a complete commercial cannabis
business permit application is submitted.
Zoning Inquiry P21-00559
2861 East Dorothy Avenue
Page 2
February 5, 2021
The subject property located at 2861 East Dorothy Avenue (vacant) is located within 1
mile of State Route 99 south of Clinton Avenue, is zoned IH, which is one of the
allowable zone districts for commercial cannabis businesses, and is not located within
1,000 feet of the aforementioned sensitive uses. Development standards of the IH zone
district are available in Sections 15-1303, 15-1304, and 15-1305 of the FMC. The
subject location meets the location restriction requirements, per Section 15-
2739.C.1.b of the FMC, for a commercial cannabis business.
2. Prior to commencing operations, a commercial cannabis business must obtain a
Cannabis Conditional Use Permit from the Planning and Development Department per
Section 15-2739.N of the FMC.
3. There shall be permitted 8 cultivators, distributors, or manufacturers located within the
Cannabis Innovation Zone, and there shall be permitted 8 cultivators, distributors, or
manufacturers located inside a Cannabis Innovation Hub or within ½ mile of State Route
99 between Shaw Avenue and Clinton Avenue, one mile of State Route 99 north of
Shaw Avenue or south of Clinton Avenue, or within one mile of State Route 180 west of
State Route 99.
Currently, there are 0 cultivators, distributors, or manufacturers located in the City of
Fresno. This location requirement is satisfied for a commercial cannabis 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 commercial cannabis businesses, including but not limited to,
application requirements, façade design, 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 559-621-8056 or at Robert.Holt@fresno.gov.
Cordially,
Rob Holt, Planner III
Development Services Division
Planning and Development Department