HomeMy WebLinkAboutC-20-62 - 3Bros-Distribution Redacted12/4/2020 3 Bros Grow Mail - Fwd: Submission Receipt - Corporation Registration for 3 Bros Grow Fresno
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Gandalf Gray <gandalf@3brosgrow.com>
Fwd: Submission Receipt - Corporation Registration for 3 Bros Grow Fresno
1 message
Tyler Smith <tyler@3brosgrow.com>Fri, Dec 4, 2020 at 12:49 PM
To: Gandalf Gray <gandalf@3brosgrow.com>
Tyler Smith
CEO of 3 Bros Grow
www.3brosgrow.com
@3brosgrow
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Begin forwarded message:
From: donotreply@sos.ca.gov
Date: December 4, 2020 at 12:47:42 PM PST
To: Tyler@3brosgrow.com
Subject: Submission Receipt - Corporation Registration for 3 Bros Grow Fresno
Reply-To: bizfile@sos.ca.gov
Dear Tyler Smith,
Your submission has been received by our office and is pending review for statutory compliance.
Submission Details:
Proposed Entity Name: 3 Bros Grow Fresno
Submission Type: Corporation Registration
Submission Date: 12/04/2020
Submission ID: MDQ-3P4G
Filing Fee: $
Total Fee: $
What’s next?
You will receive a notification from our office either confirming your filing or providing you with
information related to any necessary corrections that need to be made.
What’s the status of my submission?
Use our Submission Status Lookup tool to check the status of your submission 24 hours a day.
12/4/2020 3 Bros Grow Mail - Fwd: Submission Receipt - Corporation Registration for 3 Bros Grow Fresno
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1.3 Proof of Capitalization
Proof of capitalization for this project are based on the below documents from the ownership
team. The profit and loss summary from the first 6 months of 2020 for the 3 Bros Santa Cruz
operations are included in this section to show the net profits from this business will be use d
for this project’s build out and to cover operational expenses prior to the first harvest. The first
six months of 2020 resulted in a net income of $.
In additions to these funds the ownership team has provided the grant deed for the property
which shows the property is paid off, bank statements from Nelson and account statements
from Ken and Gina’s E-Trade security account.
The grant deed included here is also intended to meet the City’s requirement to provide proof
of ownership.
1.3 Proof of Capitalization
Proof of capitalization for this project are based on the below documents from the ownership
team. The profit and loss summary from the first 6 months of 2020 for the 3 Bros Santa Cruz
operations are included in this section to show the net profits from this business will be use d
for this project’s build out and to cover operational expenses prior to the first harvest. The first
six months of 2020 resulted in a net income of $.
In additions to these funds the ownership team has provided the grant deed for the property
which shows the property is paid off, bank statements from Nelson and account statements
from Ken and Gina’s E-Trade security account.
The grant deed included here is also intended to meet the City’s requirement to provide proof
of ownership.
1. Business Plan
1.1 Owner Qualifications
Nelson Silveira
Nelson Silveira was born and raised in Fresno, CA. He was raised by both parents who
immigrated from Portugal to Fresno in 1970. Both parents were hard workers and who
overcame many obstacles of being immigrants. They taught Nelson the importance of fam ily,
community and to never give up.
Nelson took these life skills and became a successful Fresno business owner. Nelson was a part
owner of Bronze Landscaping of Fresno before having greater aspirations. He then started
Silveira Truckline in 2007, striving for a brighter future. Nelson has built and ran Silveira
Truckline independently from the ground up. He has definitely shown he has a clear
understanding of what it takes to start, run, and grow a profitable business.
His knowledge of what it takes to continue to grow, not only his company but those around him
and the impact on the community; without a doubt shows the positive impact he continues to
provide to his community. Nelson’s overall skills as an entrepreneur, as well as being able to
look at the logistics and pieces involved in running a successful company, he strives to continue
his growth as an individual and a community contributor by building additional successful
businesses within his hometown of Fresno.
Gina Nelson, COO
Gina Nelson is currently a stay at home mother raising and homeschooling a nine -year-old boy
and 7-year-old girl. She was hopeful to rejoin the workforce at the start of 2020, but due to
COVID-19 has remained home tending to the needs of her family. With the great news that we
are about to have a vaccine for COVID and that life will return to normal, Gina is looking
forward to taking the next steps in her career with 3Bros.
Mrs. Nelson is a true “jack of all trades”. She has worked as a professional actress and d irector,
an accountant, a substitute teacher, a sales representative/manager and most recently as a
stay at home mother. Gina is not the type of person to shy away from a challenge. She likes to
simplify problems and streamline work to create the most ef fective environment.
Outside of taking care of her family the past few years Mrs. Nelson has also found time to
volunteer at her children’s elementary school and volunteer with the Central California Food
Bank. Mrs. Nelson and her husband are also support ers of Central Valley Crime Stoppers and
Amor – Alliance for Medical Outreach & Relief.
Kenneth Nelson
Kenneth (Ken) Nelson is the President/CEO and part owner of ThermoKing Central California
and NVB Equipment. ThermoKing provides transport refrigeration units for trucks, trailers,
busses, vans, and rail cars. NVB Equipment is a commercial and agricultura l air conditioning and
fire suppression company. Both companies have three locations throughout the Valley in
Turlock, Fresno, and Bakersfield. NVB stretches down to Riverside, CA as well.
Mr. Nelson started at this family owned company in high school. He worked there throughout
college and has held many positions in the company. Eleven years ago, Mr. Nelson was made
president of the company. Since then the company has grown by leaps and bounds taking on
new product lines and expanding their footprint into Bakersfield and Riverside.
William Shevlin, CEO
William (Bill) Shevlin is the newest member of the 3Bros family. Bill has successfully started
from the ground up several companies in real estate, construction, technology and the cannabis
industry. Bill’s specialty is identifying potential and helping transform companies from small
operations to large regional / multi state companies.
Over the last 15 years he has generated, devel oped and negotiated over $300M in high net
margin business. He’s achieved top 1% national rating for several companies in quality and
volume. Created sales strategies and market approaches that eliminate the competition before
even going into the market.
Bill holds several patents and pending patents in non-penetrating roof top mounts, solar
mounts, technology and cannabis. He’s used IP strategy to create market segments where no
other companies could perform in the space due to efficiencies and regulatio ns. He analyzes
markets and finds highest margin business to help create win / win scenarios with
manufacturing partners and end users to create highest possible margins in market segments
with little or no competition.
Bills professional experience over the last 20 years is summarized below:
Tyler Smith, CEbrO
Tyler Smith was born in his family home on the west side of Santa Cruz and has been a resident
of Santa Cruz his entire life. As Santa Cruz natives, it is no surprise that Mr. Smith and his
brother Russell Smith are avid surfers. However, the Smith brother s were talented, dedicated
and fortunate enough to take their love of surfing to the professional level. The Smith brothers
spent much of their adolescence and early adulthood traveling the world as professional surfers
representing Santa Cruz on a global level. The Smith brothers recall a great sense of
accomplishment and pride in representing their home town in events that reached millions of
people globally.
After his surf career, Mr. Smith worked as a sales representative in the surf industry. With li ttle
experience beyond his surfing career, Mr. Smith won the coveted O’Neill Clothing sales position
for Northern California. Mr. Smith was runner up for representative of the year in his first year
with O’Neill. While Mr. Smith had great success in the next three years with O’Neill, his true
calling and passions lie in the cannabis industry. Mr. Smith had dreamed of owning a cannabis
business in his hometown of Santa Cruz.
In addition to being a Master Cultivator, Mr. Smith brings extensive experience in branding,
marketing, and the building of relationships based on trust, performance and accountability.
Mr. Smith will continue to cultivate relationships to benefit 3Bros Grow Fresno and the
community of Fresno through job opportunities, empowering staff to grow both professionally
and personally while providing a living wage for local community members . Principals Mark
Taylor, Tyler Smith, Russell Smith and William Shevlin have created a successful brand: “3Bros”
operating as a retail microbusiness in Santa Cruz and a cultivation facility in Moss Landing.
3Bros is gaining wide popularity locally and throughout the state. 3Bros takes great pride in
producing clean, organic, high-quality medical cannabis products for California consumers and
patients, while providing education and outreach through its retail operations. Mr. Smith and
the principal’s success at their current retail is based on featuring local products and shifting
the operations to meet the community needs.
Mr. Smith is a family man and has been married to his beautiful wife Mrs. Chelsea Smith for
eleven years. Mrs. Smith is a native of Santa Cruz, born and raised on the west side. Mrs. Smith
served the Santa Cruz community as a nurse at Dominican Hospital for nine years until recently
when she took a leave of absence to be a full -time mom to their four-year old son Greyson and
newborn Riley.
Mark Taylor, CObrO
Mark Taylor is an entrepreneur and small business owner for the past fourteen years. Mr.
Taylor began working in the construction industry at fourteen years of age and has vast
experience in every aspect of construction. Mr. Taylor brings a wealth of knowledge and
experience to the 3Bros Grow Fresno team. Mr. Taylor founded Taylorbuilt Construction in
2006 and had great success in residential and commercial construction. Mr. Taylor along with
principals Tyler Smith and Russell Smith founded 3Bros Grow, a compliant and successful
medical cannabis cultivation operation located in Moss Landing in 2016 and they founded 3Bros
Santa Cruz a licensed retail microbusiness in Santa Cruz in 2018.
Mr. Taylor married his beautiful wife Shoshana Taylor in 2002 and they have a fifteen-year old
daughter Maile.
Mr. Taylor is an avid surfer and is most interested in bringing community benefits to the City of
Fresno through programs that educate youth on protecting our waterways, being good
stewards of our environment and the many health and social benefits of outdoor activities such
as hiking and fishing. Mr. Taylor is an avid freshwater fisherman and looks forward to the
opportunity to volunteer on fishing and outdoor adventures with Mr. Nelson and the Scouts of
America in the Sierra’s. As Santa Cruz natives, the entire 3Bros team can attest to the benefits
they enjoyed in their youth by having a natural playground to engage in healthy activities in the
form of surfing and water sports.
Mr. Taylor and his family are proud to call California’s Bay Area and Central Coast home and
look forward to contributing to the community through 3Bros Grow Fresno.
Russell Smith, CM(meticulous)brO
Russell Smith is an entrepreneur and small business owner. Mr. Smith is the father of two
daughters, Indiana age eleven and Pixie age four; both of whom attend school in the city Santa
Cruz.
After retiring from his prosperous professional surfing career, Mr. Smith became a sales
representative for the Northern California division of Vans shoes. In 2006 Mr. Smith opened the
health and fitness facility Studio 831, on the Westside of Santa Cruz. Studio 831 remains a
prosperous business providing residents of the city health and wellness education and training.
Mr. Smith along with principals Mark Taylor and his brother Tyler founded 3Bros Grow, a
compliant and successful medical cannabis cultivation operation located in Moss Landing in
2016 and they founded 3Bros Santa Cruz a licensed retail microbusiness in Santa Cruz in 2018.
Mr. Smith brings to the 3Bros Grow Fresno team his extensive experience in creating and
running small businesses, both cannabis and non-cannabis, as well as his deep sense of
community involvement
Mr. Smith is very excited to be a part of a team dedicated to providing clean, high -quality
cannabis products to the people of Fresno. Mr. Smith is dedicated to making 3Bros Grow Fresno
a leader in best practices within cannabis industry. Mr. Smith’s meticulous, detail-oriented
approach to life and business has helped the existing business grow and flourish in a complex ,
ever evolving regulatory environment.
Mr. Smith supports music and athletics programs in Santa Cruz and looks forward to increasing
his outreach in the City of Fresno through similar programs, including the Youth Orchestras of
Fresno and the Fresno Police Activities League.
1.2 Budgetary Estimates for Construction, Operations and Maintenance ,
etc.
Construction cost estimates and operational cost estimates have been provided on the
following pages.
1.3 Proof of Capitalization
Proof of capitalization for this project are based on the below documents from the ownership
team. The profit and loss summary from the first 6 months of 2020 for the 3 Bros Santa Cruz
operations are included in this section to show the net profits from this business will be use d
for this project’s build out and to cover operational expenses prior to the first harvest. The first
six months of 2020 resulted in a net income of $.
In additions to these funds the ownership team has provided the grant deed for the property
which shows the property is paid off, bank statements from Nelson and account statements
from Ken and Gina’s E-Trade security account.
The grant deed included here is also intended to meet the City’s requirement to provide proof
of ownership.
1.4 Financial pro forma – Three years of operations
Two financial pro forma’s have been included below. Please note that while we are seeking
two licenses, one for cultivation and one for distribution we have drafted two pro forma s. The
first pro forma is for our ideal license goals which include cultivation and distribution. The
second pro forma covers a cultivation operation only.
The key difference between these two businesses is that a distribution license would allow us
to have all the cannabis grown on site tested. Once testing is complete we would package all
the cannabis flowers in consumer ready containers and be able to sell directly to retailers,
which allows for a higher price and control of the supply chain. Our current prices we can
conservatively sell packaged cannabis for is per pound, while the same bulk cannabis
(selling directly from the cultivator) can be sold for $ per pound. You will see these
differing prices reflected in the pro formas below.
1.5 Hours of Operations – Opening and Closing Operations
The hours of operations for the facility are anticipated to be 7am to 4pm for cultivation
operations and distribution operations are anticipated to be 7am to 7pm. Both operations will
occur Monday through Friday and occasional weekend work will be required for maintenance
and cleaning.
Opening procedures for both cultivation and manufacturing operations will be similar. The
morning manager(s) will arrive on-site and check in with the security guards. One guard will
escort each manager inside and the manager (s) will deactivate the security alarm. Upon
deactivating the alarm the other security guard will check in all the other staff and begin letting
them into the building.
Closing procedures include sweeping the building to ensure no staff remain once both
cultivation and distribution operations have concluded. This includes having all staff of both
operations clock out and check out with the on-site security guards. The last two employees to
leave each operation will include at least one manager who is responsible for completing the
shutdown inspection, which includes: setting the alarms, inspecting the facility to ensure no
staff are present, verifying the limited access storage room doors are locked and shutting off all
the lights. Upon completion of the shutdown inspection the last two employees will clock out
and check out with the on-site security guards. The onsite security guards are responsible for
verifying the employees who checked in have checked out prior to the last two employees
checking out.
Once all employees have checked out the on-site security guards will verify the parking lot is
empty within 30 minutes. The security guards will then lock the perimeter gate and depart.
1.6 Day to Day Operational Procedures
Please note the numbering used in this subsection follows the City’s Commercial Cannabis
Business Application Procedures Guidelines. That is why the numbering may appear out of
order.
1.7.1 Distribution Operations
Distribution operations proposed for this site will be limited to distribution of cannabis plants,
cannabis flower and cannabis trim generated from onsite operations. Operations will consist
of:
• organizing testing of cannabis flower;
• packaging of cannabis flower into consumer ready containers;
• transportation of consumer ready flower to various retail outlets throughout the state;
• transportation of all usable cannabis trim to 3 Bros Santa Cruz (a state licensed
microbusiness) for extraction;
• transportation of juvenile cannabis plants from the facility to various cultivators
throughout the state;
• Importing juvenile cannabis plants to the site (during the build out of the second
proposed building as nursery operations are not proposed to be completed in the
existing building)
1.7.1.i Delivery Drivers and Vehicle information
We will have two drivers for distribution operations throughout the first phase of operations.
Once the new structure is completed we will be adding an additional driver to support the
distribution operations associated with the nursery cultivation operations.
The initial vehicles to be used for the first phase of operations will include two sprinter style
vans such as a Dodge Ram Promaster, a Ford Transit or a Mercedes Sprinter. The vans will be
retrofitted to include all safety measures and ThermoKing refrigeration units. Once nursery
operations begin a third distribution truck will be purchased. The size of the truck will be based
on operational needs but current projections are for a Ford F-450 with a 16 foot box and a
power lift gate or equivalent.
1.7.1.ii Transportation Security Procedures
Transportation security procedures will include a mix of procedures beginning with scheduling
receiving and shipping of goods.
Transportation Receiving Procedures
Due to the limited operations of the site, receiving of cannabis goods will be restricted to the
receiving of juvenile plants. To properly receive juvenile plants, shipments will be scheduled for
delivery from one of our partner companies: Goldenseed, Inc., 3Bros Santa Cruz or Brodeo, Inc.
Further details of receiving operations are described below in section 1.9.1.i the Location and
Procedures for Receiving Deliveries of Immature Plants and Seedlings section.
Transportation Shipping Procedures
Transportation of cannabis goods grown on site wil l only be transported off-site using our own
license. Other third-party distribution companies will not be transporting cannabis goods from
the site, this is an added security measure to further reduce knowledge about the site.
Shipments of cannabis goods will be completed via a roll up door on the eastern side of the
building. This location has been designed to avoid any visibility of receiving operations from the
public right of way. Please see the premise diagram for the exact location. Procedures for
shipping deliveries include the following steps:
1. Distribution manager finalizes an order and arranges a delivery time with a licensed
distributor, microbusiness or retailer;
2. A shipping manifest reflecting the order and delivery time is generated through the
State Metrc system (required California track and trace system);
3. The order will be boxed and verified by the distribution manager and the d elivery driver;
4. The security guard will be notified of the pending shipment approximately 15 minutes
prior to departure;
5. Security guard will sweep the exterior grounds of the facility to ensure no unauthorized
visitors are present;
6. At the same time the delivery vehicle will be loaded by the delivery driver and the
operation will be supervised by the distribution manager;
7. The security guard will notify the staff once the site has been cleared and the security
guard will position themselves at the site perimeter vehicle gate;
8. The distribution driver will depart from the loading area, the roll up door will
immediately be shut and locked by the distribution manager, and the delivery driver will
head to the perimeter vehicle gate ;
9. The security guard will open the perimeter vehicle gate as the delivery driver
approaches and will immediately shut and lock the gate once the driver exits.;
10. The delivery driver will head directly to the receiver following the route instructions
provided on the shipping manifest;
Additional security measures include the delivery driver being equipped with a cell phone to
check in with the distribution manager and the receiving company to report any potential
delays during delivery. The distribution vehicles will be equipped with independent GPS
tracking technology so that the vehicles may be tracked while they are being driven. The
distribution vehicles will be equipped with dashboard cameras to record the surroundings while
the vehicles are driven.
The distribution vehicles will store all cannabis goods behind two layers of security. The first
layer will be the distribution vehicle itself which will be equipped with standard vehicle locks
and will not have any exterior windows in the storage area of the vehicle. The second layer of
security will include a separate secured cage like structure within the vehicle which will be
secured to the body of the vehicle and locked using commercial grade locks. Additionally, the
cab of the distribution vehicle will be isolated from the storage compartment and will have no
visual access to the storage compartment so that cannabis goods will not be visible by looking
into the cab of the vehicle.
The last security procedure includes vehicle fueling. Distribution vehicles will be fueled up prior
to returning to the site. By fueling prior to returning , fueling can nearly be prevented while
transporting cannabis goods. Preventing unnecessary stops while transporting goods is a
priority as stops should only include other cannabis businesses where security is present .
Delivery drivers will be encouraged to use the restroom and take their lunch breaks while at
other cannabis businesses to ensure vehicle security, as is required by our other licensed
distribution operations.
1.7.1.iii Inventory Receiving, Processing, Storage and Inventory Security
The only inventory which shall be received from outside of the operations is juvenile plants
during the first phase of the operations: the procedures for receiving juvenile plants are
detailed in section 1.9.1.i below. Dried cannabis flower and trim will be received from the
cultivation operations on a weekly basis, once the second building is operational. Receiving
from the cultivation operations will include generating a manifest from the State Metrc system
and walking the material from the harvest storage room to the distribution limited access
storage room. The material received from cultivation operations will uploaded to the
distribution inventory upon receiving the material through the State Metrc system.
The distribution operations will use a third-party track and trace system called GrowFlow. This
system is integrated to the State Metrc system using an application programing interface (API)
key. Upon receiving inventory from the cultivation operations and verifying the inventory
amounts have been uploaded to GrowFlow the material will be color coded and stored within
the limited access storage room. The color-coded inventory storage system follows the below
logic:
Color Status
Red Flower not tested by an analytical lab.
Yellow Flower has been sampled and test results are pending.
Green Test results received and ready for packaging.
Once the material has been color-coded we will arrange testing with a licensed third party
analytical lab. We will have a standard weekly testing schedule as we plan to have nine
operational cultivation rooms once the second building construction is finished. Based on our
current growing cycles we will harvest flower every nine weeks from each grow room so there
will be weekly testing needed.
Once test results have been received the bulk cannabis flower will be packaged into consumer
ready containers of various sizes. For packaging details please see the three attached cannabis
flower packaging SOP’s.
The packaged cannabis will then be stored within the limited access storage room until they are
shipped off site. Inventory within the limited access storage room will be regularly reconciled
at a minimum of once per 14 days.
Storage of bulk cannabis and packaged cannabis within the limited access storage room will be
completed within a series of safes. The make and model of the safe may vary but we will likely
use Amsec UL3918 safes. These safes comply with our insurance providers requirements. The
Amsec UL3918 safe has a two hour fire rating, they have recessed doors , weigh 808 pounds, UL
Listed group II safe and can be anchored to the concrete floor. All the safes to be installed will
be anchored to the concrete floor. In addition to the safes the limited access storage room can
only be accessed from the interior of the building. The limited access storage room will be
secured with a steel security door and a commercial grade lock. The limited access storage
room will have security cameras and the network video recorder will be stored within this
room.
Access to the limited access storage room will be limited to the distribution manager and the
company owners. Other employees will complete work in the room but none wil l be allowed in
without a manger or owner being present.
1.7.1.iv Quality Control Procedures for Packaging, Labeling and Testing
Quality control procedures for packaging and labeling procedures are included in the three
packaging SOPs. Quality control procedures for packaging include verifying all required
packaging label information includes:
• Primary panel labels include:
o Identity of the product;
o The net weight of cannabis in the package, listed in both metric and U.S.
customary units;
o Universal cannabis warning symbol
o The UID;
o The licensed cultivator or licensee packaging the product (either the legal
business name or the registered name under which the business will operate
listed on the license certificate), and its contact number or website addres s;
o The date of packaging for retail sale;
o The following statement in bold print: “GOVERNMENT WARNING: THIS PACKAGE
CONTAINS CANNABIS, A SCHEDULE I CONTROLLED SUBSTANCE. KEEP OUT OF
REACH OF CHILDREN AND ANIMALS. CANNABIS MAY ONLY BE POSSESSED OR
CONSUMED BY PERSONS 21 YEARS OF AGE OR OLDER UNLESS THE PERSON IS A
QUALIFIED PATIENT. CANNABIS USE WHILE PREGNANT OR BREASTFEEDING MAY
BE HARMFUL. CONSUMPTION OF CANNABIS IMPAIRS YOUR ABILITY TO DRIVE
AND OPERATE MACHINERY. PLEASE USE EXTREME CAUTION.
o The total cannabinoids per package.
The total cannabinoids and package date will be added to the primary label with a separate
certificate of analysis sticker which is also used as a tamper evident seal. The remainder of the
information will be printed on preformatted labels which must be approved by the distribution
manager or an owner prior to printing.
1.9 Cultivation Operations
The first phase of cultivation operations will include the existing building which will need to be
retrofitted. The second phase of cultivation includes building a new building with an identical
footprint to the existing building. The first phase will include five flowering rooms and no
juvenile plant growth. All juvenile plants will be imported to the site from one of our partner
companies: Goldenseed, Inc., 3Bros Santa Cruz or Brodeo, Inc. The second building will be
constructed and will include six cultivation rooms which will include four rooms dedicated to
flowering operations and two rooms dedicated to nursery operations. Once the second phase
is completed we will not be importing juvenile plants to the sites.
1.9.1.i Location and Procedures for Receiving Deliveries of Immature Plants and Seedlings
We will be receiving juvenile plants through the rollup door on the eastern side of the building
adjacent to distribution operations. This roll up door will be used for receiving plants because it
is not visible to the right of way. Please see the premise diagram for the exact location.
Procedures for receiving deliveries of immature plants include the following steps:
1. Cultivation manager finalizes an order and arranges a delivery time with one of our
partner companies;
2. A shipping manifest reflecting the order and delivery time will be generated through the
State Metrc system (required California track and trace system) by one of our partner
companies and a copy of the manifest is sent to the cultivation manager for verification
of quantities and expected delivery time;
3. The cultivation manager and the delivery driver will be in communication if the delivery
is expected 15 minutes earlier or later than documented on the shipping manifest ;
4. The security guard will be notified of the pending delivery approximately 15 minutes
prior to arrival;
5. Security guard will sweep the exterior grounds of the facility to ensure no unauthorized
visitors are present;
6. The security guard will notify the cultivation manager once the site had been cleared
and the security guard will position themselves at the site perimeter vehicle gate ;
7. The security guard will open the perimeter vehicle gate as the delivery driver
approaches and will immediately shut and lock the gate once the driver e nters;
8. The security guard will confirm the name of the delivery driver and the license of the
company shipping the juvenile plants with the cultivation manager at the eastern roll up
door;
9. The eastern roll up door will be opened;
10. The cultivation manager and the delivery driver will confirm the plant count and the
shipping manifest will be signed and a copy will be made (one copy will be retained by
the delivery driver and the other will be retained on site);
11. The inventory will be accepted on Metrc;
12. Plants will be unloaded into the open area within the building;
13. The security guard will be notified of the pending de livery driver leaving and will sweep
the perimeter;
14. The security guard will head to the vehicle gate; and
15. The delivery driver will depart, the security guard will open and close the gate for the
delivery driver.
1.9.1.ii Description of the Planned Square Footage of Cultivation Activities
The planned square footage of cultivation operations include the use of 11 grow rooms. The
first phase of the operation includes five grow rooms in the existing building and the second
phase includes six grow rooms in the new building. The total size of the grow rooms and the
total canopy size of the grow rooms is included in the tables below. The amount of canopy will
be maximized in each grow room by using rolling tables which minimize the unused space in
each room. Rolling tables allow us to only have one aisle way running the long direction in each
room and two aisles running the short direction in each room while complying with egress path
of travel requirements and the Americans with Disabilities Act.
Existing Building Cultivation Rooms 1, 2, 4 and 5 (all numbers and in feet)
Room
Width
Room
Length
Total Area Canopy
Width
Canopy
Length
Total
Canopy
Total
Canopy
of all 4
rooms
33.5 62 2077 30 58.5 1755 7,020
Existing Building Cultivation Room 3
Room
Width
Room
Length
Total Area Canopy
Width
Canopy
Length
Total
Canopy
33.5 70 2345 30 64.5 1,935
New Building Cultivation Rooms 1-6
Room
Width
Room
Length
Total Area Canopy
Width
Canopy
Length
Total
Canopy
Total
Canopy
of 4
rooms*
33.5 64 2144 30 61.5 1845 7,380
*=six rooms are planned in the second building but only four will be utilized for flowering
operations the other two rooms will be dedicated to vegetative growth.
The total square footage of the cultivation rooms for both buildings will be 23,517. The total
canopy will be 16,335 and 3,690 square feet of cultivation space will be dedicated to nursery
operations.
1.9.1.iii Forecasted Number of Pounds Produced Per Harvest and Harvests Per Year
Current projections for operations at this site include one harvest every nine weeks per grow
room. This nine week cycle includes three days to harvest the plants, clean and decontaminate
the room. We have designed the site so that when it is fully operational the operations will
include 10 harvests every nine weeks. Therefore, we can have full time staff for all aspects of
the operations.
For the purpose of this section and our pro forma we have modeled cultivation rooms 1,2, 4
and 5 from the existing building which are slightly smaller than all other grow rooms. We
anticipate flower yields from these grow rooms to conservatively equal 120 pounds per harvest
every nine weeks. As previously stated, we will have 10 harvests every nine weeks of the year
so we will have 57 harvest at 120 pounds per harvest or 6,840 pounds of cannabis flower per
year. We anticipate generating an additional 60 to 65 pounds per harvest or 3,420 to 3,705
pounds of useable trim per year which we will process at our manufacturing facility in Santa
Cruz.
1.9.1.iv Cultivation Light Sources
We will be using artificial light for cultivation operations. Currently we utilize LED lighting and
high pressure sodium lighting at our existing cultivation operations in Moss Landing and Santa
Cruz. We plan on using LED lighting at this facility but due to the evolving nature of the lighting
industry we are not sure the exact model of LED light we plan to utilize. We currently utilize a
variety of Fluence SPYDR and VYPR lighting LED models.
1.9.1.v Cultivation Waste Plan (Description of how cultivation waste will be made unusable and
unrecognizable)
Cultivation waste will be generated during the plant growth phase and during the trimming and
processing operations. Waste from the plant growth phase will be disposed of by throwing the
leaves in a 55 gallon steel drum. The leaves will be made unrecognizable by chopping them up
in the steel drum with an electric line trimmer (weed wacker). Once the leaves are thoroughly
chopped up they will be transferred to a green waste dumpster. In the green waste dumpster
sawdust will be added to the chopped-up leaf material and manually mixed into the leaf
material to render the cannabis waste unrecognizable.
Cultivation waste generated during trimming operations will be limited to stems from the
cannabis plants. All other materials generated during trimming will be saved and sold to our
manufacturing facility in Santa Cruz. Stems from the trimming operations will be chopped into
pieces 2-3 inches in length at maximum. The chopped-up stems will be deposited directly into
the green waste dumpster where they will be manually mixed into the leaf and sawdust
mixture.
The green waste dumpster will be stored outside of the building and will be locked with a
commercial grade lock. When the green waste is to be picked up the security guard will open
the perimeter vehicle gate for the City Solid Waste Vehicle and unlock the green waste bin for
pick up and disposal.
Cannabis waste is an organic waste as defined by Section 8108 of the California Department of
Food and Agriculture’s final approved regulations. We currently dispose of all of our cannabis
waste in this manner at our other locations.
1.9.1.vi Supplemental Carbon Dioxide Use for Cultivation Operations
Cultivation operations will utilize carbon dioxide (CO2) to improve plant yields. CO2 storage is
anticipated to be a total of 16,000 cubic feet for both buildings. This amount of CO2 is above
the hazardous materials storage reporting threshold; therefore the site will have a hazardous
materials business plan. Compliance with this plan will include that all CO2 storage tanks be
properly installed, which includes being anchored to the concrete floor. The CO2 storage tanks
will be stored inside of the buildings and will have serviceable fill ports on the exterior of the
building.
CO2 will be distributed throughout the grow rooms through a ¾ inch flexible pvc line into each
grow room and from the main line there are individual ¼ inch flexible polyethylene lines which
are run to the circulatory fans positioned around the grow rooms (wall mounted). The ¼ inch
lines emit CO2 to the rear of the circulatory fans which distribute the CO2 throughout the
room. The amount of CO2 in the rooms is regulated using CO2 controller. The CO2 controller
regulates the flow of CO2 into the room while constantly monitoring the CO2 levels within the
room. The CO2 controller will be set at 1500 parts per million (ppm) and if CO2 exceeds 2000
ppm an audible alarm will be triggered notify staff to immediately exit the room.
Cultivation staff will be able to manually stop the flow of CO2 into any room utilizing a shutoff
valve on the tanks. Our CO2 provider and installation contractor, NuCO2, will be notified and
they will be responsible for addressing any problems which arise with the CO2 system.
NuCO2 will assist with the building permitting and the system specifications will be included in
the mechanical design as part of the building permit application. A structural engineer will be
responsible for designing the anchorage bolts for the CO2 tanks.
2 Social Policy and Local Enterprise Plan
2.1 Living Wage Commitment
3Bros Grow Fresno believes that every worker has a right to compensation that is sufficient to
meet basic needs and provide some discretionary income. We are committed to ensuring that
fair labor practices and safe working conditions are upheld throughout our supply chain. This
includes workers’ rights to fair compensation and the development of publicly disclosed fair
compensation strategies.
Currently our minimum compensation package is $ an hour for entry level positions, $
for lead positions and $ to salaried for managers. These wages exceed the MIT living wage
calculator for Fresno County which currently calculates the living wage to be $ for adults.
2.2 Employee Benefit Package
3Bros Grow Fresno will offer a choose your plan style health insurance package for employees
with the company paying for $200 worth of monthly premiums. There will be multiple tiers of
health insurance coverage beginning with plans that meet the California minimum essential
coverage all the way up to plans that mimic the platinum plans offered through Covered
California.
Employees who wish to seek alternative health care coverage through Covered California will
be eligible for a $200 monthly stipend for healthcare.
In addition to healthcare plans employees will be eligible for 40% discounts. Active lifestyle
reimbursements will be available to employees for things such as gym memberships, athletic
teams, athletic clubs, etc. Incentives will be available for carpooling, bicycles and e-bikes,
including zero interest loans and monetary bonuses for avoiding driving.
Full time staff will receive benefit packages which includes paid sick leave of five days per years
and paid vacation time of 10 days per year.
2.3 Employee Growth Program
Employees are compensated at a fair and livable wage and are given opportunities for
advancement as we promote intercompany to ensure cultural adoption and understanding of
values. We hire with growth in mind and ensure to continue growth and education through
education and training programs dedicated to advancement internally and externally. We
strongly emphasize good communications practices and consistently develop and train
employees in good communication with supervisors, peers, employees and customers. Along
with professional training we provide industry specific knowledge on products as well as the
latest cannabis research in order to promote cannabis education throughout our company.
Employees will be eligible for training opportunities outside of our Fresno operations.
Employees who show interest in other aspects of the cannabis marketplace will be provide the
opportunity for up to one week per year of cross training at our other licensed facilities in the
City of Santa Cruz, Moss Landing, or Soquel. Additional opportunities in cannabis
manufacturing and infusion operations may occur if we are awarded additional licenses in the
City of Fairfield.
In addition to cross training at our various location employees will be encouraged to seek
outside growth opportunities including at Fresno City College and California State University
Fresno. We will work with individual employees to gain an understanding of their education
goals and reimburse a portion of or all of their course work which is related to business and
agriculture.
2.4 Social Policy for Hiring
3Bros Grow Fresno will be managed and staffed by local community members. Currently 3Bros
corporate offices are in Sana Cruz but operations are spread out throughout Santa Cruz and
Monterey County with business partners throughout the State. The goal for 3Bros Grow Fresno
operations is to mimic the operations of 3Bros Santa Cruz which includes having a dynamic local
team.
Gina Nelson, an owner and local of Fresno, will act as the Chief Operations Officer for this site.
Her roles will be vast but at a minimum she will oversee all operations and be in charge of hiring
a dynamic local team. Gina will actively recruit staff. Her recruiting efforts will focus on the
local veteran community and the communities adjacent to the site which include people living
in low to moderate income census tract. More details of how we plan to hire locally are
included in section 2.8.1.
Local employees reduce vehicle miles travelled and help drive local sales. Over the last two
years 3Bros Santa Cruz operations have honed their business plan and understand the power of
human capital. Employees are happier when they work close to home. Our current operational
team will play a leading role in helping Gina training local staff and helping develop a solid team
of local employees who can enjoy and take pride in their positions at 3Bros Grow Fresno.
Cultivation operations will be built on a local talent pool. With a talented pool of local
agricultural companies and skilled labor we have confidence we can assemble a cultivation
team from local residents. With the logistics experience of our owners, Nelson Silve ira and Ken
Nelson our distribution operations we are confident in our ability to be efficient. Nelson’s
experience running his own trucking company will play a critical role in the management of our
distribution delivery operations.
Additional analysis has been focused on the City of Fresno 2020-2024 Consolidated Plan and
2020 Action Plan. Based on a review of the available data Pacific Islander populations
experience disproportionately high rates of housing problems, but they do not make up the
disproportionally greater need group above 80% AMI as specified by Section 9-3316 (b)(1). The
Hispanic populations appears to have the greatest need of this group but they represent the
largest population group in the City, followed by White, Asian and Black / African Americans.
Due to the nature of the data it appears difficult to target groups with an annual family income
below 80% of the AMI. We will investigate methods to identify potential hires within this group
but have not completed this as of now.
2.5 Local Management Commitment
The operations will be managed locally with our Chief Operations Officer being part of the
ownership group. The three principal owners Nelson Silveira, Gina Nelson and Ken Nelson all
reside in the Fresno County. Gina is prepared to take responsibility for all operations and act as
COO. She will have the full support and commitment of Bill, Tyler, Mark and Russell. Mark and
Russell will play significant roles in helping Gina start the operations as well as designing and
overseeing construction.
Nelson Silveira’s role will be varied throughout the construction and operational phases. His
entrepreneurial background will play a significant role in oversight of construction and
operations. Nelson’s logistics background will be relied upon to help forecast delivery
schedules, trucking routes and grouping deliveries. Nelson’s trucking business, Silveira Trucking,
is located in Fresno at 192 East Willamette Ave. Nelson currently lives in Fowler at 8434 South
Villa.
Ken Nelson’s role will be the most limited of our local team. He will assist his wife Gina as
needed on the operational side but will mainly be a financial backer of the operations. Ken is a
local business owner with his brother and father. The three of them own the Fresno
ThermoKing dealership (refrigerated trucking) and NvB Equipment (commercial and agricultural
air conditioning and fire suppression systems). ThermoKing and NvB are located in Fresno with
ThermoKing located at 3247 East Annadale Ave and NvB at 3808 East Jenson. Ken and Gina
currently reside in Clovis at 2510 Pico Ave.
All of the owners listed above have owned their non-cannabis business in excess of one year.
2.6 Expected Employees, Their Position and Their Responsibilities
Expected employee population for the cultivation and distribution operations include:
• Chief Operations Officer (oversee all cultivation and distribution operations);
• Cultivation Manager (oversee all cultivation operations and be responsible for
coordinating plant needs for each room to prevent any operational down time );
• Trim Manager (oversee trim operations, perform quality control checks multiple times
per day, and log all cannabis masses before and after trimming for each employee );
• Seven to ten trimmers (responsible for trimming cannabis);
• Three to five cultivation staff (responsible for day to day cultivation operations as
directed by the cultivation manager);
• Distribution Manager (oversee all distribution operations including packaging, ordering
third party testing, inventory reconciliation, and shipping);
• 12 to 15 distribution packagers (responsible for packaging cannabis flower in various
consumer ready containers as directed by the Distribution Manager);
• Two to four distribution driver s (responsible for verifying order quantities, loading and
unloading trucks and driving product to various locations)
• Three to five security guards (security operations as detailed in section 5);
2.7 Commitment to a Labor Peace Agreement
We are committed to allowing our employees unionize via a labor peace agreement as required
by the City and the State. The State requirements are for greater than 20 employees which we
do plan on exceeding by the time of our first harvest. We will allow our initial five employees to
enter into a labor peace agreement.
At this time we do not have a labor peace agreement signed in Fresno. We are committed to
signing a labor peace agreement which complies with the City of Fresno requirements as well as
State requirements of SB 94 and AB 1291.
2.8 Workforce Plan
2.8.1. Commitment for 30% of employees to be local hires
Utilizing online and in person application allows for 3Bros Grow Fresno to ensure we are hiring
locally. Indeed allows for jobs to be listed and filtered by specified zip codes, this will allow us to
target candidates that live in and are residents of the Fresno area. We are committed to
increasing local employment opportunities for every facility we operate and currently employ
85% local residents at our Santa Cruz location. Most employment opportunities at our site are
applicable to entry level positions which will allow for a wide variety of applicants from the
Fresno area. Local community support is what has helped to build our brand and we know and
understand that hiring local citizens supports our mission to promote overall community
wellness and development.
2.8.2. Commitment to offer apprenticeships and/or compensation for continu ing education in the
field
At 3Bros Grow Fresno we believe that growth is an important value for all those involved with
our organization. We plan to support that growth through career development and promotion
from within the company. Most of our current employees have started as entry level workers
and now operate in higher level management of our facility. We always offer new and available
positions to our current employees prior to seeking outside candidates to fill them. We are
committed to the growth of our team and will provide support for their continued growth and
career advancement through internal development and external certifications as needed. We
do more than operate cannabis facilities as we seek to educate our employees on sustainabl e
business practices, meaningful human interaction, and a growth mindset.
Additional details of employee growth opportunities were reviewed in section 2.3 above.
Those opportunities include cross training at our other locations and we will encourage
employees to seek outside growth opportunities including at Fresno City College and California
State University Fresno. We will work with individual employees to gain an understanding of
their education goals and reimburse a portion of or all of their course work which is related to
business and agriculture.
2.8.3 Commitment to Pay a Living Wage
As previously stated in section 2.1 3Bros Grow Fresno is committed to pay its employees a living
wage in excess of the MIT living wage calculator for Fresno County. Starting pay for entry level
positions will be $
2.9 Social Equity Business
We are committing to being a social equity business incubator by offering support to local
social equity businesses in the form of mentorship, technical training on compliance, permitting
for Water Board coverage and additional permit and compliance needs such as hazardous
material business plans, etc. If we receive a distribution license we would also play a role in
helping our social equity businesses obtain shelf space in retail operations by helping open
doors to our established connections.
4 Safety Plan
The safety plan included below covers review criteria section 4 and has been drafted by Rob L.
Campbell, P.E. of CampFire Protection Engineering. Additionally, Mr. Campbell and Leonard
Willis, P.E. of Redwood Engineering have worked together to provide the a ttached safety plan
diagrams.
December 4, 2020
Subject: 3Bros-Fresno, 190 N. Thorne Avenue, Fresno, CA
Commercial Cannabis Business License Application – Section 4 – Safety Plan
The following information and referenced plans address concerns of Section 4 (Safety Plan) of
the Fresno Commercial Cannabis Business (CCB) Permit application for 3Bros Fresno.
The contents of this plan are preliminary, for the purpose of the Commercial Cannabis Business
(CCB) license application. Upon issuance of a CCB license, the applicant will obtain a conditional
use permit and finalize tenant improvement design development for build-out of the leased space
proposed for the CCB (i.e. 190 N. Thorne Avenue). The plans will be reviewed by a contract Fire
Protection Engineer to confirm they adequately address fire protection and life safety elements of
the California Building and Fire Codes, including construction type, fire rated separations, exiting,
fire department apparatus access, fireflow, fire sprinklers/suppression systems, sprinkler
supervision, hazardous materials storage, hazard identification and general fire safety provisions.
All tenant improvement plans will be subject to permit submittal review and approval by the City
of Fresno prior to building or fire code permit issuance.
4. Safety Plan
The Safety Plan should consider all possible fire, medical, and hazardous situations, and shall be
prepared and/or assessed by a professional fire prevention and suppression consultant.
Parts 4.1 through 4.4 are prepared by Robert L. Campbell, PE, a California registered Fire
Protection Engineer and owner of CampFire Protection Engineering, LLC.
Basis of Evaluation
Business operations:
The 3Bros Fresno proposes a commercial cannabis business throughout an existing building
located at 190 N. Thorne Avenue in the City of Fresno. The existing building will be used for
cannabis cultivation. Development plans for the site include construction of a second building, of
equal size and design, for additional cultivation capacity. The proposed business will include
cultivation of cannabis and ancillary functions, consisting about 1/6 of the building area. There is
no intention to conduct cannabis extraction at this site. The proposed business model for the
space anticipates only the following operations:
• Cannabis cultivation (with CO2 enrichment)
• Product drying, trimming
• Packaging and shipping
• Product quality control
• Administrative offices
Based on the proposed activities, the associated fire hazards are consistent with the expected
hazards common to indoor cannabis cultivation. High hazard operations, commonly affiliated with
cannabis extraction and manufacturing, will not be conducted in the proposed facility. As such,
the anticipated fire and life safety hazards consist of:
• Electrical hazards due to distribution and operation of growth lighting
• Asphyxiant hazards consistent with CO2 enrichment activities
• Egress obstruction resulting from plants and frequent grow rack repositioning
• Hazardous materials consistent with cannabis cultivation operations
• storage and processing of ordinary combustible materials
• materials movement/processing/storage facilities and associated equipment
Building Construction:
The existing building consists of two areas separated by an interior, full height concrete masonry
unit (CMU) wall, with a total building area of 15,135 square feet. The tenant space proposed for
the CCB includes the entire building. The project team has intention to construct a second building
of equal size and quality on the parcel to support future expansion of the cannabis cultivation
activities.
The existing building is assumed to be of Type V-B construction, in accordance with the California
Building Code. This assumption is based on the observation of steel primary structural members,
supplemented by wood bracing and roof joists. The building exterior (walls and roof covering)
consist of lightweight corrugated metal panels. Based on the assumed construction type and
proposed F-1 Occupancy, the building exceeds the allowable area permitted by CBC 506, even
accounting for open sides exceeding 20 feet. The proposed addition of fire sprinklers will make
the building compliant with area limitations.
Occupancy Classification:
The tenant space is proposed as Group F-1 Occupancy, with accessory Group B Occupancy
space consisting of less than 10% of the primary F-1 Occupancy. The occupancy classifications
are assumed consistent with the existing building use, and therefore presents no increase in fire
or life safety hazard. The proposed addition of fire sprinklers will reduce the potential fire severity
for the building.
Safety Plan:
4.1. The Safety Plan shall be prepared and/or assessed by a professional fire prevention and
suppression consultant
The content of this report is as evaluated and prepared by a California Licensed Fire Protection
Engineer, experienced in fire and building code review, fire suppression and alarm system design,
and hazardous materials evaluation.
4.2 Accident and incident reporting procedures
This operation is not anticipated to have hazards any greater than the adjacent industrial use
properties. In the event of an emergency condition, notification procedures will be consistent with
similar industrial uses, and include:
• Medical emergency – call 911 and follow advice of dispatch, apply first aid measures,
implement AED per unit instructions as appropriate
• Fire emergency – activate fire alarm (as appropriate), evacuate building and call 911 to
report the event to dispatch the fire department.
• Except for CO2 storage and use, reportable hazardous material quantities (as defined by
the State of California) are not anticipated on site. Liquid product storage will include 50
aggregate gallons of various pesticides and 100 aggregate gallons of three liquid
fertilizers, in separate containers. A variety of other chemicals having corrosive, flammable
and combustible characteristics will be present in individual containers of 1 gallon or less
each. Anticipated spills will be of a minor nature and should be cleaned up with available
supplies and disposed of, as appropriate. Spill control materials such as absorbent will be
maintained on site for this purpose. The use of bulk CO2 storage and distribution will be
subject to a construction permit prior to system installation. The construction permit
application will include all design elements required by the California Fire Code to mitigate
pressure relief and asphyxiation concerns, including gas detection. Activation of the gas
detection system will alert on-site personnel to evacuate, take corrective action, and notify
local and state authorities, as required.
• Police emergency – Call 911 and follow advice of dispatch. On-site security personnel will
be available to assist with such emergencies.
• All signals from the fire sprinkler monitoring system (alarm, trouble, supervisory) will be
transmitted to a UL listed central station. When signal is received, by the central station,
they will dispatch the fire department (for alarm) and notify the 3Bros Fresno
representatives for immediate corrective action.
Building Fire Protection& Life Safety Features
Site Fire Protection Features:
A site plan is included with this submittal to identify location of existing and proposed site fire
protection equipment. The existing building has open yards in excess of 60 feet to the east and
west. A 20-foot-wide fire apparatus access road with gate and fire department key box is located
at the north end of the building. As a result, unobstructed fire department apparatus access is
provided to three sides of the building. A gate and 20-foot access width exist at the south end of
the building, but currently obstructed by vegetation and debris. The existing debris and
obstructions will be removed to allow full, unobstructed fire department access to the building
perimeter. Additional apparatus access is shown for the proposed new building. The fire
department access is sufficient to accommodate exterior fire suppression operations from all
sides of the building. Two municipal fire hydrants are available on the opposite side of Thorne
Avenue to the north and south of the subject address. The existing fire hydrants are within 500
feet of all building openings, as required by Fresno Fire Department policy 403.003.
4.3. Evacuation routes
Egress:
For purposes of CCB license application consideration, a preliminary egress evaluation has been
represented graphically on plans herein. The preliminary plan consists of assumed occupancy
classifications, occupant loads and exit door location. A detailed egress analysis and final
emergency evacuation plans will be prepared and submitted for review and approval during the
building permit process. The approved evacuation plans will be posted at each building exit prior
to occupancy of the tenant space. At this time, the number and distribution of interior exit doors
is deemed sufficient to meet minimum requirements of the 2019 California Building Code. All
egress doors will include the appropriate hardware that allows for free egress from the building
interior, regardless of the security hardware installed. All egress routes will be provided with
normal and emergency egress illumination and exit signage to meet Chapter 10 of the CBC.
Please refer to the attached plans for related egress information.
4.4. The location of fire extinguishers and other fire suppression equipment.
Fire Sprinklers:
The existing building is not currently equipped with a fire sprinkler system. The new, higher hazard
use of the building will require installation of fire sprinklers, in accordance with Section 10-50903.6
of the Fresno Municipal Code. The retrofit fire sprinkler system will be specified to meet NFPA
13 Ordinary Hazard II design basis. The system construction plans will be submitted for review
and approval of Fresno Fire Prevention Division as a deferred submittal to the building permit,
prior to start of work. The new building is also proposed to include fire sprinklers. The fire sprinkler
system will be maintained in operation and verified compliant in accordance with CBC 901.6 and
California Code of Regulations, Title 19, Division 1, §1.14.
Fire Alarm:
A fire alarm system is not required by CFC 907.2.4 for the F-1 Occupancy. A fire alarm control
panel will be installed to monitor the fire sprinkler system for supervisory and alarm conditions, as
required by CFC 903.4. The fire alarm control panel will automatically activate audible notification
upon fire sprinkler waterflow. The fire alarm panel activation will also result in fire department
dispatch, by way of the central monitoring station. Upon development of tenant improvement
plans, fire sprinkler monitoring system will be specified to meet the requirements of the 2019 CFC
and City of Fresno requirements. The system will be monitored by a listed central station, per
CFC 907. The fire sprinkler supervisory panel shall be inspected, tested and maintained in
accordance with CBC 901.6 and California Code of Regulations, Title 19, Division 1, §1.14.
Portable Fire Extinguishers:
Portable fire extinguishers are in accordance with California Code of Regulations, Title 19, the
2019 California Building Code and City of Fresno requirements. At a minimum, 2:A-10:B-C rated
fire extinguishers will be distributed throughout the facility with a maximum of seventy-five feet
(75’) travel distance to an extinguisher from any point within each building. The location of all fire
extinguishers will be clearly identified on the occupant evacuation plans to be posted at exit doors
throughout the facility. All fire extinguishers shall be maintained operable and in current service,
in accordance with CBC 901.6 and California Code of Regulations, Title 19, Division 1, §1.14.
Hazardous Materials:
The proposed activities for this CCB anticipate limited use of hazardous materials consistent with
indoor cannabis cultivation, Including, fertilizers, pesticides, CO2 and common cleaning,
disinfection and sanitization products. The quantities of hazardous materials will be maintained
below the CFC/CBC threshold quantities for H Occupancy. Preliminary information indicates
operational needs of 50 aggregate gallons of various pesticides and 100 aggregate gallons of
three liquid fertilizers. These products and the CO2 constitute the greatest bulk storage of
hazardous materials. All other products will exist in limited quantities, stored in individual
containers. Although the materials associated with the proposed CCB present limited, known
hazards, a complete assessment of hazardous materials will be prepared and submitted for
review during the building permit process. The analysis will show hazardous materials inventories
below the maximum allowable quantities specified by the 2019 California Building and Fire Codes.
All materials will be stored and used in the appropriate fashion. In addition to designated
hazardous materials storage areas, the facility will include a designated location for a complete
collection of all hazardous materials safety data sheets (SDS) and a map of their locations. Staff
will be trained to meet minimum requirements of OSHA for facilities using hazardous materials.
Staff will be trained in required spill response and notification procedures, which will be posted
along with essential emergency notification numbers. Written hazardous materials inventory and
notification procedures will be maintained on site in a location readily accessible to all staff and
emergency personnel
Site Maintenance:
The site will be kept clean as necessary to prevent accumulation of waste, trash and debris. All
waste, trash and debris will be stored in approved containers or in rooms constructed of
noncombustible materials. All waste, trash and debris will be disposed of legally on a regular basis
in a safe, acceptable manner, in accordance with applicable requirements. The facility will comply
with applicable local and state requirements for identification of the presence of hazardous
materials. This will include the posting of NFPA 704 placards to alert responding personnel to
hazardous classifications of materials on site. The facility will maintain a complete collection of all
hazardous materials safety data sheets and a map of their locations.
4.5. Procedures and training for all fire and medical emergencies.
5 Security Plan
6 Location
6.1 Location Description
The proposed location at 190 Thorne is an industrial area of town located amidst a variety of
industrial facilities. The location is south of the Belmont loop between highways 99 and 180
and the train tracks to the east. facilities. This area is fairly isolated due to the highways and
access to the site is limited to Thorne Avenue.
The overall property will look very similar to its current aesthetic . A second butler style building
will be built behind (relative to the street) the existing building which will have the same
footprint and general look. The main change to the exterior of the builind will be security
related improvements including a new perimeter fence, metal bollards around the existing
building egress points and the new building and visible security cameras. The exterior of the
building is typical of the area with a neutral grey-colored exterior.
The proposed floor plan will be significant modification to the existing shell of a building. It will
be an essentially new building within the existing shell. The exterior of the building will largely
remain untouched with the removal of a few doors and the infilling of the windows. The
interior modification will include the installation of five cultivation rooms, a limited access
storage room, an office, a breakroom, new restrooms, a trim room and a harvest storage room.
The new structure will include six cultivation rooms. For additional details please see the
proposed site diagram.
6.2 Street View of the Site
Please see the street view of the proposed site below.
6.3 Premise Diagram
Please see the premise diagram below.
7 Community Relations Plan
7.1 Community Social Responsibility Plan
Mission Statement
We believe it is our responsibility to offer only the highest quality, cannabis products at an
approachable price and in a sustainable manner. Cannabis is medicine but we plan to use it to
heal more than just people; from climate-positive business practices to community care
initiatives, we strive to assist in the healing of our planet.
Vision Statement
We are committed to leaving this planet more beautiful than when we arrived and vow to put
forward our greatest effort in sustainable and community centered operations. .
Company Values
Sustainability, Community, Knowledge, Growth, Empathy, Perspective
Executive Summary
3Bros Grow Fresno is located in a diverse community and we plan to offer good paying stable
jobs with benefits in an new and evolving agricultural market place. We plan on focusing our
efforts for giving back to the community through three organizations principally. We wi ll target
volunteer efforts of our staff to the Community Food Bank and plan to offer paid volunteering
opportunities of up to 8 hours per month for full time staff volunteering at the food bank. If
staff wishes to voulenter at other non-profits we will evaluate them on a case by case basis.
The second and third organizations we wish to target will be with monetary donations from the
ownership team. Those donations will be focused on Valley Childrens Hospitals and efforts to
support children in the Community. LAstley monetary donations will be focused on the Crime
Stoppers Organization. Owners Ken and Gina have been engaged with Crime Stoppers for more
than a decade and they find this to be a very beneficial orginaization within the Community.
7.1.1 Funding for or Hosting Expungement Clinics
At this time we do not have plans to fund or host expungement clinics but we will work with
Crime Stoppers to address these efforts in the City and may fund efforts by that organization or
their partner orginizations.
7.1.2 Environmentally Sustainable Bu siness Model
We will promote low-to-no climate impact business strategies that enable us to operate
sustainably and inform the community on how to continue promoting sustainability in their
everyday lives using the three strategies listed below.
• Strategy #1: Utilizes sustainable resources when developing business and show patrons
how these materials positively impact the environment.
• Strategy #2: Host events that educate the community on how to make climate positive
impacts in their daily lives. Include cannabis vendors as strategic partners that educate
the community on their own actions to create a climate positive impact.
• Strategy #3: Develop and implement a monthly community clean-up to keep the
Fairfield area clean and safe.
•
7.1.3 Utilizing Vacant Buildings, Brownfield Lands or Blighted Areas
We currently feel our projects meets the goals of the City to utilize vacant buildings and the City
may consider this area blighted. We do not feel it’s a blighted area but the building we are
proposing to use has been vacant for sometime and requires sig nificant upgrades to become
operational.
7.2 Community Relations Plan Beliefs
We recognize the responsibility we have to communicate and educate both internal and
external publics on both the positive and negative effects of cannabis as well as ensuring safe
consumption. We also believe (1) we have the responsibility to communicate effectively with
our community; (2) that meaningful public engagement will support our goals, and (3) that
effective communication:
• Helps increase public awareness of our mission and process to achievement of that
mission;
• Is the responsibility of every constituent of the company ; and
• Is a two-way communication process in which feedback provides growth for both the
community and the retailer.F
Goals
This Community Relations and Communications Plan aligns with the City mission for
sustainable operation and development (1). With an understanding that meaningful public
engagement encourages community involvement in education that benefits consumers and
increases public awareness.
Community Relations and Communications Goals
Goal #1
Establish an effective community outreach program to build collaborative relationships and
strengthen support for and confidence in the Fresno Cannabis Market.
Goal #2
Establish an effective employee education program that improves knowledge about safe
cannabis consumption and use throughout the community.
• Strategy #1: Implement a comprehensive training program for all employees prior to
servicing customers. Ensuring we keep them up to date as new information about
cannabis is available through further research and encouraging discussion with their
peers.
• Strategy #2: Identify employees who may need additional training and support them in
their education and development through field tests, quarterly trainings, and monthly
vendor trainings.
• Strategy #3: Develop and establish community level trainings in order to educate the
community members on the medicinal and recreational effects of cannabis as well as
how it can be utilized to promote a sustainable lifestyle.
Goal #3
Promote low-to-no climate impact business strategies that enable us to operate sustainably
and inform the community on how to continue promoting sustainability in their everyday
lives.
• Strategy #1: Utilizes sustainable resources when developing business and show patrons
how these materials positively impact the environment.
• Strategy #2: Host events that educate the community on how to make climate positive
impacts in their daily lives. Include cannabis vendors as strategic partners that educate
the community on their own actions to create a climate positive impact.
• Strategy #3: Develop and implement a monthly community clean-up to keep the
Fairfield area clean and safe.
Goal #4
Educate the community on safe cannabis use and cannabis product efficacy.
• Strategy #1: Research and develop a strategy for effective community engagement in a
program that educates against the stigma of cannabis consumption and promotes safe
and responsible use.
• Strategy #2: Host weekly brand education demos that educate community members on
the products sold in the retail including but not limited to; how and where they are
made, their proper use, method of consumption and recommended dosage.
Goal #5
Establish a strong, disaster relief and awareness program to ensure the safety of community
members.
• Strategy #1: Develop tools and resources to help managers become more effective in
leadership and problem solving in order to adjust to possible changing circumstances.
• Strategy #2: Develop and maintain safety and health requirements as required by local
and state governments in order to promote everyday health and wellness.
7.3 Fresno Community Reinvestment Fund
We are willing to the Fresno Community Reinvestment fund once the operation is established
and operating but at this time we are not willing to commit to a certain percentage of net
revenue for a contribution.
Veterans Outreach (discounts and specials)
Community Outreach (compassion oldest native American settlement in northern California)
Community Education (Cannabis and related sustainable communication)
Climate impact and awareness with events (Touch on young families in Fairfield etc.)
Disaster relief and awareness (I.E. pandemic, health, etc.)
Cannabis Safety Awareness (Safe Consumption and Access)
1- https://www.fairfield.ca.gov/gov/depts/public_works_/utility/sustainability_efforts/defau lt.asp
2- https://worldpopulationreview.com/us-cities/fairfield-ca-population
3 Neighborhood Compatibility Plan
3.1 Commitment to Compliance
Our company and team are highly invested in making a positive impact on our neighbors and
neighborhood. We will ensure loitering on our facility premises is not allowed and will be
enforced by our security personnel. We will also adhere strictly to our hou rs of operation and
work in a manner that reflects compliance of all laws, rules, and regulations on both a local and
state level.
Excessive noise will be minimized and avoided when possible through enforcement of rules that
disallow excessive car stereo volume from our employees and any in facility music being played.
Other than these possible noise issues, we do not anticipate any other issues that will affect the
neighborhood and plan to operate as any other industrial businesses in the area.
No light from cultivation operations will escape the building as all cultivation room can only be
entered from the building interior. Security lighting will not impact the neighbors because of
the make up of the businesses in the area. Additionally, security li ghting will be shielded and
downward facing to prevent light pollution.
Odor will be mitigated as described in section 3.3 below. The keys to odor mitigation are using
high quality carbon filters and negative pressure cultivation rooms.
We encourage sustainable and earth conscious operations throughout our facility, and hope
that these values will be passed onto our staff and reduce the litter and pollution that may be
present in the area. On-top of these efforts we will have security guards make routine checks to
clean up litter in our surrounding area as part of their perimeter inspections through out the
day.
Parking spaces are plentiful at our location and we will not allow staff to park on the street
which should minimize any traffic impact on the area.
3.2 Commitment to Neighborhood Integrity
As a company we recognize the importance and responsibility that is held when becoming a
new business which may be controversial to some community members . We seek to make a
positive impact to the City of Fresno by maintaining strong community relationships and
organizing operations to minimize impacts on the surrounding neighborhood. Nelson has
already begun reaching out to neighboring businesses to develop good relationships and begin
addressing trash issues on the street.
Nelson also plans to work with our neghbors to receive feedback and implement changes when
necessary and in order to ensure we maintain good relationships throughout operation s. Safety
for our employees and our larger neighborhood community is at the top of our priority list and
we hope to show that through our community relations. We believe the presence of our facility
will ensure the health and safety of the neighborhood.
The proactive work of our ownership team with the few neighbors we have is a testament to
how we will continue to engage our neighbors to ensure we avoid becoming a nuisance and
work to better our surrounding community.
3.3 Odor Mitigation Practices
Odor mitigation will be completed through the use of carbon filters. All products will be stored
in a cold room kept at or below 60 degrees F, which will help to mitigate any excess odor
produced by product storage. Odor mitigation of our cultivation rooms will be maintained
through environmental controls which include maintaining negative pressure rooms. By
maintaining negative pressures within the cultivation rooms odors cannot escape the facility.
3.4 Potential Sources of Odor
The distribution, harvest storage and trim room space will be equipped with pleated carbon air
filters that will minimize any odors that may be caused by operations. In addition to these
areas all exhaust ports from the building ventilation system will be equipped with the same
type of pleated carbon air filter.
Odors from the distribution and trim room space will emanate from the cannabis plants.
During trim operations the cannabis plants are exposed to air while the trimmers actively
manicure the plant matter. Odors from the distribution operations will emanate from the
stored bulk cannabis flower and during packaging operations. Drying and curing of cannabis in
the harvest storage room will only emit odors when the doors are opened and closed. The
odors from the drying and curing are mitigated in a similar fashion as the cultivation room s by
maintaining negative pressure in the harvest storage room.
The carbon filtration specified below will be able to mitigated all odors generated during
operations. To ensure mitigation is maintained the odor mitigation equipment will be specified
by a mechanical engineer with experience in this field.
3.5 Odor Control Devices and Techniques to Prevent Odors From
Escaping the Facility
All ventilation exhaust ports will be equipped with a carbon filtration system. These filters are
highly effective at eliminating odor that could be caused from the permeation of cannabis from
cultivation and distribution operations within the facility. The filters will include a powerful fan
that will pull the air towards the filter, pulling it through carbon (a known odor eliminator), and
then reintroduced into the room (scrubbing). Carbon filtration for odors will likely occur using a
combination of AAF Flanders Superflow VC filters housed in AAF Flanders SurePleat housings
based on previous experience. Cut sheets for this equipment is included below.
To further prevent odors from emanating from the building all cultivation rooms and the
harvest storage rooms will be negatively pressurized.
3.6 Staff Odor Training and Odor Control System Maintenance
Carbon Filters will be inspected as instructed by the manufacturer and the mechanical engineer
who helps prepare the building HVAC designs. Any maintenance nee ded will be performed in a
timely manner once a determination of needed maintenance is made.
3.7 Waste Management Plan
It’s essential to recognize cannabis waste is basically any material that contains cannabis in any
form. If there is any detectable THC, the waste must be handled compliantly. “Cannabis waste”
that is not hazardous and solid waste, will follow Public Resources Code section 40191. No
hazardous cannabis waste is anticipated to be generated. 3Bros Grow Fresno will receive
notice from the testing agency or the internal quality control lab that the tested cannabis does
not meet appropriate health standards. When this occurs, 3Bros Grow Fresno will take
corrective measures to properly handle the waste including but not limited to:
1. Gather all failed cannabis batches;
2. Waste must be quarantined for minimum seventy -two (72) hours prior to disposal;
3. Document(s) must be added to each batch with the information and weight from each
batch;
4. The waste must not be moved, handled, or rendered into waste disposal during this
quarantine period;
5. Weigh out the product;
6. Be sure to mix with saw dust after chopping with an electronic line trimmer (following
the cultivation waste management plan specified in section 1.9.1v) so that the resulting
mixture is at least 50% non-cannabis waste:
7. Make sure that the product is rendered unrecognizable and unusable;
8. Store in a secure, locked container (locked green waste dumpster);
9. Document all waste activity:
a. Written operating instructions
b. Records of the dates of disposal, amounts of waste, and types of waste treated.
c. Records shall be maintained and kept for seven (7) years
With waste disposal, 3Bros Grow Fresno will be sure to capture all activity in a waste log and on
video surveillance.
The manager must be present for all on-site destruction and must, along with at least one other
employee acting as witness, sign a printed record of disposal, which will be kept as a hard copy
or electronically as a scanned facsimile for not less than seven (7) years.
PLANNING AND DEVELOPMENT DEPARTMENT
2600 Fresno Street • Third Floor Jennifer K. Clark, AICP, Director
Fresno, California 93721-3604
(559) 621-8277 FAX (559) 498-1026
December 7, 2020 Please reply to:
Rob Holt
(559) 621-8056
Tyler Smith
3Bros Fresno
111 Ingalls St
Santa Cruz, CA 95060
Dear Applicant:
SUBJECT: ZONING INQUIRY NUMBER P20-04346 REQUESTING INFORMATION
REGARDING COMMERCIAL CANNABIS USES (NON-RETAIL CANNABIS
MICROBUSINESS OR , CULTIVATION) FOR PROPERTY LOCATED AT 190
NORTH THORNE AVENUE
(APN 458-250-02)
Thank you for your inquiry regarding the allowance of commercial cannabis uses. The
requested information about a non-retail cannabis microbusiness or 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, distributors, or manufacturers 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,
distributor, or manufacturer 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,
Zoning Inquiry P20-04346
190 North Thorne Avenue
Page 2
December 7, 2020
(d) A youth center that is in existence at the time a complete commercial cannabis
business permit application is submitted.
The subject property located at 190 North Thorne Avenue (existing building) 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
MoU BETWEEN 3 BROS and Nelson Silveira
Intent to establish potential JV
(S This Memorandum of Understanding ("MOU") is made and entered into as of October
, 2020 (the "Effective Date"), by and between 3 Bros ("3 BROS"), with an address at 111 Ingalls
Street, Santa Cruz CA 95060; Nelson Silveira (Nelson) with an address at 190 Thorne Ave,
Fresno, CA
WHEREAS, 3 BROS is a local market leader in the cannabis retail, cultivation, manufacturing,
and distribution. 3 Bros operates in the California legal cannabis market.
WHEREAS, Nelson is a local property owner and commercial developer.
WHEREAS, Nelson controls a facility at 190 Thorne Ave., Fresno, CA
3 BROS desire to open a cannabis cultivation, manufacturing, nursery and distribution at 190
Thorne Ave., Freson, CA. The 3 Bros branded cannabis facility will be owned by 3 Bros Fresno
(Entity to be formed). Ownership of final company to be determined based on 3 Bros, local
operational partners and I or investors. All management, technology, plant supply, oversight, IP
and other required supplies and operations will be provided by BroCo as per operational and
licensing agreements from 3 Bros Brand, LLC and BroCo. Ownership in 3 Bros Fresno
opportunity will be available to Nelson and/ or other parties introduced or as mutually agreed
upon by 3 Bros and Nelson.
3 Bros and Nelson will work towards a mutually beneficial agreement that will create a
reasonable market rate lease of 190 Thorne Ave., Fresno, CA and capitalization of the 3 Bros
Fresno facility/ business. 3 Bros will develop budget, strategy, capitalization, investors and/ or
debt for the 3 Bros Fresno facility. Budgets and plan will be provided to Nelson for review.
Neison will be given the opportunity to participate as an investor, JV partner and / or landlord
depending on structure agreed upon by both parties.
The 3 Bros Facility will be planned as follows:
Phase 1 - Cultivation 5,000 - 10,000 square feet
Phase 1 - Distribution processing, packaging, storage, distribution approximately 2,000 square
feet