CITY OF PASADENA Applicant Name: Marianna Sadikyan ...

CITY OF PASADENA

Applicant Name: Marianna Sadikyan

Reviewer: Mark Lovelace

Date: 04/21/19

OVERALL SCOREMaximum

Points

Points

Awarded

Percent

Score

1,575 1,075 68.25%

SECTION 1: QUALIFICATIONS OF OWNERS/ OPERATORS 750 460 61.33%

100% owned by Marianna Sadikyan, who is the Co-Founder and Co-CEO of Comprehensive Care Management, "one

of the nation’s leading hospital and medical practice management consulting firms". Claims to have worked as an

advocate and consultant for cannabis regulation, but no experience was demonstrated. No listed association with

licensed businesses.

Ms. Sadikyan is the sole listed owner for the proposal. As such, she will be responsible for "Overseeing all daily

operations and compliance to the PMC, she will provide oversight, structure and training for retail operations and

business planning in addition to overall operations and compliance."

GENERAL COMMENTS

Applicant has no demonstrated experience with licensed or unlicensed cannabis businesses, but application was

nonetheless strong in a number of areas and showed good research and preparation. Aside from lack of experience,

other weaknesses were lack of capitalization, poor discussion of community benefits and very slight discussion of

design and neighborhood compatibility. Overall SOPs did not provide sufficient level of detail.

Experience

Cannabis Industry Knowledge

Ownership Team

Did not list, discuss or demonstrate any significant cannabis industry knowledge.

MARIANNA SADIKYAN'S APPLICATION FOR CANNABIS RETAILER LICENSE, CITY OF PASADENA1 OF 92

SECTION 2: BUSINESS PLAN 525 391 74.48%

Standard Operating Procedures (SOP)

Provided a brief walk-through of customer access and purchase procedures, which was reasonably detailed. Included

table of contents for full SOPs, which are shown to be 379 pages long. The "Verification and Accountability

Procedures" included in the business plan are not shown in the table of contents, which is ordered alphabetically.

Financial Plan

Start up budget lacked detail; only listed 3 line items: space improvements, security system, furniture and computer

software. Provided number of separate financial tables that did not appear to correlate, making actual projections

unclear. No discussion of accounting procedures.

Funding/Proof of Capitalization

Provided a bank statement for Comprehensive Care Management, showing in checking. Was not clear if Ms.

Sadikyan is sole owner of CCM, with ability to use all funds for this separate endeavor. Regardless, would be

the smallest amount of capitalization seen in applications.

Records Software

Provided a highly detailed discussion of records software, including specific protocols and procedures.

Track-and-Trace

Provided a highly detailed discussion of track and trace protocols and procedures.

State Testing Requirements

Provided a highly detailed discussion of protocols and procedures to ensure State testing requirements have been

met.

Employee Training

Provided a detailed discussion of employee training, including a long list of topics, learning resources, ongoing

education and testing requirements. Made reference to training materials, but did not include specific samples.


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SECTION 3: NEIGHBORHOOD COMPATIBILITY & ENHANCEMENT 150 98 65.33%

Air Quality/Odor Control

Design Concept Integration

Integration of Security Measures

Customer Education

Exterior Design Concept

Reasonably detailed discussion of customer education. Will provide a patient handbook, but no sample was

provided. Included list and brief discussion of educational topics, and a sample of online educational resources.

Marketing

Discussion of marketing included a list of possible advertising avenues, including outreach to doctors, social media,

online advertising, website, email marketing and cannabis business directories like Leafly and Weedmaps. Did not

include any market analysis to inform methods.

Community Benefits

Provided detailed goals and areas of interest for community support. Listed a number of non-profits and other

programs they desire to work with, but ultimately did not make any specific commitments. Listed local businesses

they intend to work with, but also made no commitments. No discussion of wages, benefits or helping those

disadvantaged by criminalization.

Provided an exterior architectural rendering with no accompanying discussion. Design appears attractive, with living

'green' walls, but no discussion of design considerations other than that they will go through the City's design review

process.

No discussion of this topic.

Discussion of signage, but did not really address this topic.

Reasonably detailed discussion of this topic included HEPA filters, Carbon filters and ozone generators.


SECTION 4: SECURITY PLAN 150 126 84.00%

Product Access Protocols

Product Deliveries

Mentioned 5417 Executive Protection Group and provided a brief bio, but it's unclear whether applicant has actually

worked with the firm or only intends to. No documentation was provided from the listed security firm. Not listed in

BSIS database.

Employees will be required to pass a DOJ livescan and/or DMV H-6 background check. Little additional detail was

provided.

Provided a good overview of safety education, but did not include specific details of how employees will receive this

training.

Discussion included check-in/check-out protocols, audits and other measures, but lacked detailed procedures.

Cash management plan did not include specific, actionable protocols or procedures.

Security Experience

Background Checks

Employee Safety Education

Employee Theft Reduction Measures

Cash Management Plan

Highly detailed discussion of specific electronic locks to be installed for various doors, as well as other access tools

such as

Provided a reasonably detailed discussion of product deliveries.

Will use security guards from5417 EPG or Red Hawk. Provided brief discussion of hiring protocols and number of

guards, but no roles or responsibilities.

Detailed discussion of video monitoring.

Will use an armored car service, but none was named and no protocols were provided.

Security Guards

Video Camera Surveillance

Armored Vehicle


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Section D:

Government-Issued

Identification

Redacted

COMMERCIAL CANNABIS PERMIT APPLICATION

SCREENING APPLICATION PACKET

PREPARED FOR THE CITY OF PASADENA

Confidential and proprietary information.

Drafted to be adapted per city and department guidance and request.

Developed in association with:

TYPE-10 RETAIL STOREFRONT

In regulatory compliance with Pasadena Municipal Code Chapter 5.28, 5.78, 17.50, Title 8, Ballot Measure CC, Ballot

Measure DD, California Law, the Attorney General Guidelines, the Medical Marijuana Regulation and Safety Act and

other such codes for compliance referenced herein.


EMERALD BAY RESERVE – COMMERCIAL CANNABIS PERMIT APPLICATION

1 Confidential and Proprietary Information

TABLE OF CONTENTS

Section 1: Qualifications of Owners/Operators 4

Gayana Mkhitaryan 4

Involvement in Day-to-Day Operations 4

Section 2: Business Plan 5

Sub-section 2A: Operations 5

About the Company 5

Standard Operating Procedures 6

Dispensing Operations 6

Customer Verification 8

Verification & Accountability 8

Attestation by Verified Individual 10

No Recommendations On-Site 10

Enhanced Product Safety 10

Verification Checks 10

Financial Plan 11

Proof of Funding/Capitalization 13

Record Keeping Plans & Software 13

Inventory & Data Systems 13

HIPAA Compliance 15

Records Retention Policy 16

Shipping Records & Receiving Protocols 17

Chain of Custody Records 17

Delivery 17

Electronic Records and ESRs 18

Paper Records 18

Record Maintenance 18

Employee Records 19

Track-and-Trace 19

Business Profile Setup 20

Product Profile Setup 20

Chain of Custody 17

State Testing Requirements 21

Required Testing 21

Phase-in of Required Testing 23

Edibles 24

THC – Edibles 25

THC – Non-eligible Cannabis Products 25

Certificate of Analysis 21

Labeling 26




Labeling 26

Potency Labeling 27

Raw Product 28

Employee Training 28

Operations Training Materials 31

Customer Education 31

One-on-One Sessions 33

Educational Sessions 33

Marketing 33

Compliance in Marketing 34

Business & Profession Code §26151 34




Field Marketing 36

Digital Strategy 36

Email Marketing 37

Sub-Section 2B: Community Benefits 38

Community Rapport 38

Program Development 38

Implementation 38

Expansion 38

Philanthropy 39

Fundraising Events 39

Veteran Work Program 40

Local Non-Profits 40

Local Business Partnerships 40

Sub-section 2C: Product Offerings 41

Selecting Cannabis Strain Varieties 41

Synergies Between Terpenes & Cannabinoids 41

Terpenes 41

Cannabinoids 42

Varieties of Cannabis 43

Product Procurement 44

Receipt of Incoming Material 44

Section 3: Neighborhood Compatibility & Enhancement 45

Good Neighbor Policy 43

Exterior Design Concept 46

Integration with Security Measures 47

Signage 47

Air/Odor Control 49

Air Filtration Protocols 49

HEPA Filters 49

Ozone generator 49




Security Plan: 4A 50

Security Advisor’s Experience 51

Background Checks 51

Facility Security 51

Patient Accessible Areas 52

Inaccessible to Public Areas 51

Lighting 53

Internal Access-Control 53

Security Guards 58

Limited Access to Secured Areas & Visitors 55

Consumer Access 56

Electronic Security System 59

Video Surveillance 60

Third-Party Monitoring 58

Intrusion & Motion Detecting 58

Burglary Alarm System 58

Alarm Testing 59

Panic Buttons & Internal Communications 59

Employee Education 59

Incident Management & Emergency Response 60

Fire Drills 60

Burglary Protocols 61

Product Handling 61

Product Handling 61

Occupational Safety & Health Agency (OSHA) Training 61

Employee Theft Reduction Measures 61

Check IN/OUT Protocols 61

Auditing 62

Additional Measures 62

Cash Management Plan 62

Cash Storage & Transport 62

Deposit System 63

Counterfeit Detection & Prevention 63

Product Access Protocols 64

Identification Badges 64

Product Deliveries 64

Shipment Preparation 65

Delivery Driver Diversion Protocols 65

Armored Car Service 66

ADDENDUM (A) 67

ADDENDUM (B) 71

ADDENDUM (C) 72

ADDENDUM (D) 73




ADDENDUM (E) 74

ADDENDUM (F) 76

ADDENDUM (G) 79

ADDENDUM (H) 80

ADDENDUM (I) 81




Experience & Cannabis Industry Knowledge Marianna Sadikyan: Owner | CEO | Operations Manager Marianna Sadikyan is the Co-Founder and Co-CEO of Comprehensive Care Management, one of the nation’s leading hospital and medical practice management consulting firms. No stranger to highly regulated industries, through Comprehensive Care Management, Marianna has provided uncompromising regulatory, compliance, and day-to-day operational guidance and training for hundreds of regulated and licensed healthcare facilities nationwide. In addition to her work in healthcare compliance, she has extensive knowledge and professional experience working within the cannabis industry. Since the inception of SB 420/PROP 215, Marianna has been an advocate and staunch supporter for a legal and regulated cannabis market to bring an end to black market sales, crime, and the diversion of medicine away from individuals. As a consultant, she has worked with numerous cannabis operators seeking a pathway to legal operations and/or to maintaining compliance in order to better serve individuals and local communities. Her experience in the cannabis industry ranges from multiple capacities within the supply chain – from delivery to cultivation to cooperative care, but her advocacy work and dedication to safe-access to individuals and adults hits closer to home.

she made a personal vow to starting a socially-equitable cannabis company that she could operate responsibly and disseminate education about the risks and benefits of cannabis use through.

cannabis became even more of an apparent reason for her to use her experience, acumen, and strong industry connections to pursue this goal. She understands that cannabis therapies can provide beneficial and cost-effective alternatives to curb the side-effects of traditional medications and reliance on opioids in traditional medication. The passage of MAUCRSA laid the foundation and Pasadena’s progressive regulatory work created the launchpad. Marianna’s qualifications also include avid volunteer work with cancer research hospitals in search for better cures and treatment. Some of which have included work in researching new cannabis technologies that may generate a cure through cannabis products themselves and end of life palliative care. Outside of that, Marianna has a long history of support for City of Hope and often volunteers for other causes unrelated to the cannabis or healthcare industries.

Involvement in Day-to-Day Operations As the Sole-principal responsible for operations for Emerald Bay Reserve, Marianna will take an active hand in the daily operations of the business. She is the only individual that qualifies as an owner based on Business and Professions Code 26001. She will build a quality team and apply the management principles, experience and focus on compliance that have contributed to the industry leadership she developed through Comprehensive Care Management and learned from her experience in the California medical collective environment.

SECTION 1: QUALIFICATIONS OF OWNERS/ OPERATORS


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During lead up to the official opening of Emerald Bay Reserve in Pasadena, Marianna’s vast experience along the entire supply chain from seed to sale including procedures for successful, licensed cannabis retail operations will be invaluable. This experience will allow her to apply the nearly two decades of California healthcare and cannabis industry experience she has acquired in the Pasadena facility. The procedural understanding of working with regulators and accreditation organizations as well as assisting individuals, will reduce launch-time, enhance product quality, streamline communications, enhance quality of new hires, and more effectively serve the local community above and beyond the PMC. Overseeing all daily operations and compliance to the PMC, she will provide oversight, structure and training for retail operations and business planning in addition to overall operations and compliance. Her passion for cannabis as medicine and building community relations though effective oversight, project planning, special events, and quality control utilizing her expansive knowledge of medicinal grade cannabis, client-individual demand, and compliance in a regulated industry. Other important functions related to Marianna’s ongoing hand in Emerald Bay Reserve’s daily operations will include working closely with each department head or program coordinator to ensure all employees are properly trained. (See Employee Training)

SECTION 2: BUSINESS PLAN

Sub-section 2A: OPERATIONS – SOPs | Finances | Employee Training


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Pages 16-47 Redacted



Community Rapport Community outreach and relations efforts are critical components of a successful and socially-equitable cannabis business. Effective community relations planning is a continuous process that involves ongoing revisions and improvements. It is essential for new cannabis businesses to form and sustain healthy relationships with members of their communities to further the re-education of public perceptions of cannabis use and to maintain a respectable operational status. We believe cannabis businesses are obligated to aid individual health, wellness and substantially improve the welfare of communities in which they operate. It is the principal goal of the company to develop a reputable establishment and maintain operations as an upstanding corporate citizen and firmly rooted community leader. EBR is committed to reforming public perception of cannabis use and will provide all necessary measures to respect the comfort and dignity of the individuals and community we operate and serve. To ensure the effectiveness of our projected community relations plan, additional measures will be developed for increased range of involvement in outreach and improvement efforts detailed below. EBR has initiated preliminary integration efforts by identifying gaps in localized resources and engaging in progressive relationship-building conversations with municipal authorities and residents. In addition to our commitments to the betterment of the community at large, we are equally committed to establishing and sustaining dedicated ties between local and national wellness-centric cannabis community leaders.

Program Development

EBR will engage in productive community relationship-building efforts throughout the initial

business development process and proceed to strengthen its network of agents, individuals,

vendors, neighbors and local business associations as a continuous business practice.

Community relations measures, in addition to those detailed below, will be developed as new

opportunities or amendable community service deficiencies in the community are identified.

Implementation To facilitate the implementation of a Community Relations Plan, EBR will develop a strategic

timeline containing a projected schedule of service events and available information concerning

the initiation of those measures with potential for immediate application. At a minimum, initial

efforts to expedite the actionable community services, events, networking and charitable

contributions detailed in this section will be launched within the first year of operation of the

company.

Expansion

As EBR evolves to become an integral community member valued by individuals and

businesses throughout the community, the company will take measures to ensure the sustained

success of the community relations program. In addition to those standard policies and

procedures detailed below, the company will continue to conceptualize new services, events,


SUB-SECTION 2B: COMMUNITY BENEFITS – Serving Pasadena and its community.




charitable contributions and additional offerings of value to the community. Company's

Community Relations Plan will frequently be revised to include detailed policies and procedures

for other contributions and services added to our program offerings.

Philanthropy It is the goal of the company to help support organizations that are tax-exempt under Section 501 (c)(3) of the U.S. Internal Revenue Code working to strengthen the community. The company will direct its contributions to areas that the Board of Directors believe are important to the future of community development, education, and human services. The company’s first priority is to support programs and organizations whose chief purpose is health and community education. The company will support organizations and programs that support education, specifically programs that:

1. Work to eliminate pre-K – 12th grade achievement gap in public education through curriculum-based or school-sponsored programs;

2. Support post-secondary education; 3. Support booster programs for drug abuse prevention, awareness, and treatment; 4. The company will support organizations and programs that support health, specifically

programs that: a. Support research into cures and treatments for qualifying conditions, such as

cancer; b. Support further research into effective marijuana treatments of qualifying

conditions; and c. Support programs that will improve the health of the community.

5. work to enhance a community’s quality of life through projects involving civic engagement through:

a. Public policy; b. Community beautification; c. Civic leadership; d. Citizen education; e. Cultural diversity;

6. The company will consider sponsorship requests from social and human service organizations that:

a. Enable and sustain independence for individuals and families; and b. Ensure access to health education programs and quality health care.

The implementation of any sponsorship program will be at the discretion of the Board of Directors. The facility’s employees will receive any requests for sponsorship and forward them to the board for their evaluation and consideration.

Fundraising Events EBR recognizes the value of a strong business network when engaged in fundraising efforts for local charitable organizations designated to receive regular donations. Establishing a reputation for hosting regular, successful fundraising events for community organizations will also increase the ability of the company to compel corporate sponsorships and donations for future events.




Veteran Work Program We understand that Veterans have been disproportionately affected by cannabis criminalization in America and in California. This is due to the federal government’s stance on cannabis and its classification, regardless of legal standing within individual states. The Department of Veterans Affairs has a history of banning physicians from recommending state-legal medical marijuana to veteran individuals. The VA does have the discretion, in states where it is legal, to grant benefits to veterans who are also medical marijuana individuals. But, this is carried out largely as a “don’t ask, don’t tell” policy and VAs in states where medical marijuana is legal but not widely accepted, have denied benefits to veterans who are found to be using medical marijuana The VA estimates that as many as 20 percent of soldiers who have served in the Iraq and Afghanistan wars have post-traumatic stress disorder, according to The Associated Press. Scientists have speculated that marijuana could help veterans suffering from PTSD symptoms, which can include anxiety, flashbacks and depression. In California, cannabis is seen as a remedy for PTSD and the many symptoms that are associated with it. For these reasons and many more, EBR recognizes the contributions of military Veterans and aspires to provide those service members living in our community with ample opportunities for employment. Additionally, the company’s commitment to employing Veterans will provide these individuals with safe access to affordable cannabis and compassionate treatment programs utilizing cannabis that are currently unavailable through traditional, federally-funded Veterans’ services. The company also intends to establish a Veteran Work Program with the goal of employing a staff that is comprised 30% of Veterans at minimum. In addition, we will be providing cannabis education resources to local veterans through Veterans for Medical Cannabis Access (“VMMA”).

Local Non-Profits EBR has established communications and preliminary partnership ideas with the following non-profits for community engagement, activism, advocacy, youth development, community development, and for disseminating education to Pasadena and its communities.

Leadership Pasadena is committed to supporting the advancement of veterans by re-missioning their military wisdom to lead and serve the community through mutual empowerment.

Empowering women to increase their physical wellness and emotional stability while coping with the taxing effects of cancer and chemotherapy

Local Business Partnerships It is core to EBR’s mission to hire, collaborate, and partner with local businesses inside and outside of the cannabis industry to stimulate local market growth through employment, contracting work, advocacy, marketing, education, and procurement of goods and services. This




includes associating with locally licensed cannabis businesses in Pasadena once permitted. Below is a shortlist of local businesses in Pasadena who we plan to give priority to for procurement of goods and services related to the development of EBR’s licensed operations in Pasadena:

Floor Plans 24/7 Pasadena Plumbing G.L. Throop Company

Pasadena Lumber

Horizon Landscaping M & R Masonry DPR Construction Ultimate Staffing

Gs1 Group Inc Bark Security Southwest Patrol Echo-Factory PADV Pasadena Advtsn.

Zehana Interiors Rozalynn Woods Pasadena Star News

Leadership Pasadena Living Beauty Hedrick Fire Prevention

C.A.R.E Collection Cntr.

See Addendum (F) for Example Menu Concept in development.


Sub-Section 2C: PRODUCT OFFERINGS – Variety of strains and products.


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As an organization we realize that, if permitted, we will be responsible for the image of the cannabis industry at large as local operators and representatives in the city of Pasadena. As such, we believe it is our duty to act ethically and responsibly in a manner that is socially-equitable and advantageous to the city and its surrounding communities. We are developing community outreach programs, including those mentioned herein, which will constitute the enrichment of local constituents in Pasadena. Such programs include food and clothing drives for local food banks, churches, and other needing organizations or individuals and percentages of daily or monthly gross profits to local program development or other worthy causes.

Good Neighbor Policy It is our policy to implement and execute a Good Neighbor Plan and respond to any reasonable complaint immediately to the complainant with a proposed solution and within 10 days or as required by the City of Pasadena and the State of California. All neighbor communications must be maintained as part of the company record. The intent is one of mutual respect between neighbors; to avoid adversarial positions, to treat others as one would like to be treated; to keep an open mind; and be willing to cooperate with neighbors with a goal of creating a safe and healthy neighborhood environment. EBR has worked hard to take preliminary steps building positive relationships with the community and will continue to build relationships with the community through:

1. Introduction meetings with all surrounding businesses, building owners, and residents; 2. Educational information sessions to discuss the benefits of cannabis and the company’s

overall mission and goals; 3. Open feedback channels so any new concerns can be immediately addressed through

our website, telephone, or mail; 4. Complete compliance with all state and local ordinances; 5. Non-obtrusive business practices that ensure our business is discreet and operates like

any other business; 6. No blatant signage with offensive symbols or verbiage; and 7. Unmarked discreet transportation vehicles.

SECTION 3: NEIGHBORHOOD COMPATIBILITY & ENHANCEMENT


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Integration with Security Measures To align with the city’s goals, we have enlisted the aid of security consultants, advisors, architects, and design experts to ensure the future business premises aligns with the city’s goals for proper integration in terms of security and design concept. Our design goal is to draw less attention to the fact that we are cannabis operators and more attention to the aesthetic value of our premises to call attention to building enhancements that uplift and renovate local grounds and communities. All our designs will be approved by the city through their normal process and at their discretion. Our core design values are professionalism, quality, and ability to provide an extraordinary customer service experience to our clients. We can accomplish this goal and still maintain a smooth transition and blend with the local architecture and the community’s historic aesthetic. In terms of security, discreet dome surveillance will be installed to capture all angles of sight around our facility, which are minimalist in design and can be incorporated such that they are not easily noticed by the public. Additionally, the exterior of our facility will have no signage that would indicate the presence of a cannabis-related business. The Pasadena Municipal Code requires design review of new construction and alterations throughout the City. Depending on the size of the project, design review may be conducted by city staff or at a public hearing before the Design Commission, a group of nine citizens appointed by the Mayor & City Council. At minimum, we are prepared to undergo the three phases of the city’s standard design review process as follows:

1. Preliminary Consultation - Applications for design review that involve new construction or major alterations to existing buildings are required to go through a preliminary consultation process to obtain comments on the proposed design concept prior to preparing detailed drawings for the formal decision-making

2. Concept Design Review - Concept Design Review is the primary step in the Design Review process. Applications for Concept Design Review normally address the basic design of a project, including compatibility with surroundings, massing, proportion, siting, void-to-void relationships, and compliance with applicable design guidelines. A project must first go through Preliminary Consultation before applying for Concept Design Review.

3. Final Design Review - Final Design Review is the final phase of the Design Review process. It normally focuses on construction details, finishes, materials, landscaping, and on consistency of the project with the design approved during Concept Design Review (as well as compliance with the conditions of the approved Concept Design Review).

The company is prepared to meet and exceed the expectations of the city for all neighborhood compatibility and enhancement in terms of design, public welfare, or otherwise.

Signage All employees/contractors involved in the design and construction of the facility must become familiar with our documents and instruction concerning state regulations for signage for the facility. It is the responsibility of anyone working with the general contractor or subcontractors in the design of the facility to review the floor plan and signage plan to ensure the proper regulations are followed with regards to font size, lighting for the sign, proper warnings, etc.




Signs on the premises shall not obstruct the entrance or the video surveillance systems. The size, location, and design of any signage must conform to the sign provisions in the Pasadena Municipal Code. In addition, Business identification signage shall comply with the appropriate sign requirements with the applicable zoning district. Throughout the licensed premises, management will display the following identification signs with lettering no less than one inch in height:

1. License. We will display the Dispensary License in a conspicuous location, one that is easily viewable by any visiting regulatory employee.

2. “These premises are under constant video surveillance.” 3. “It is unlawful to consume cannabis on the licensed premises” 4. “Do not enter. Limited Access Area. Access Limited to Licensed Personnel and escorted

visitors” 5. “Danger Pesticides, Do Not Enter” signage. After each application of a pesticide, the

facility will display the required sign at the perimeter of the applied area. EBR, per state law, shall not post any signage visible from the exterior other than a single sign no greater than one thousand six hundred square inches that bears only the business or trade name in text without any pictures or illustrations; provided that if any applicable law or ordinance restricting outdoor signage is more restrictive, that law or ordinance shall govern. The company will post signs in conspicuous locations inside the Property advising:

1. It is a violation of State Law to engage in the sale of marijuana or the diversion of marijuana for non-medical purposes;

2. The use of marijuana may impair a person’s ability to drive a motor vehicle or operate heavy machinery;

3. Loitering at the location of a Marijuana Business for an illegal purpose is prohibited by Penal Code §647(h);

4. This cannabis business is licensed in accordance with the laws of the City of Pasadena;

5. We reserve the right to ban any client from purchasing our products if they engage in the illegal sale or diversion of Marijuana.

Aside from the above, EBR is not proposing any additional signage, other than the following notices:

1. The sale, dispensing, or consumption of alcoholic beverages on or about the medical cannabis facility or in the parking area for the facility is prohibited.

2. The loitering by persons outside the facility, either on the premises or within one hundred feet of the premises, is prohibited.

3. The loitering by persons outside the facility, either on the premise or within 100 feet of the premise is prohibited.

At such time that a sign is proposed, EBR will comply with all City requirements and obtain all necessary approvals.




Air Quality/Odor Control Our business premises shall have an air treatment system that ensures offsite odors shall not result from its operations. This requirement at a minimum means that the dispensary shall be designed to provide sufficient odor absorbing ventilation and exhaust systems so that any odor generated inside the location of the medical cannabis dispensary is not detected outside the building, on adjacent properties or public rights-of-way, or within any other unit located within the same building as the medical cannabis business, if the use only occupies a portion of a building.

Air Filtration Protocols Being a good neighbor and aware that marijuana products can create undesirable noxious odor, EBR intends on mitigating to prevent any nuisance to the surrounding community. EBR has selected odor control equipment and ventilation systems that will ensure that all cannabis inside the facility has no detectable odor from the exterior of the building. Two independent air-filtration technologies and one type of air purification device will be utilized to destroy air-borne pathogens and eliminate cannabis odor inside and outside of the facility.

HEPA Filters High-Efficiency Particulate Air (HEPA) filters provide a very high level of filtration efficiency for small and large particulate contaminants and are widely applied in air filtration and air purification applications to control airborne particulate levels. A filter must capture a minimum of 99.97% of contaminants at 0.3 microns in size in order to meet U.S. standards for HEPA classification. HEPA filters are even more efficient in removing particles that are smaller than 0.3 microns and larger than 0.3 microns. All mechanical air-handling units in the facility will be outfitted with commercial HEPA filters. These filters will serve all spaces and will be used not just for odor control, but to assist in mitigating environmental contaminants by catching airborne particulates, infectious agents, and pests, if present. HEPA filters will be added on the return side of all air-handling units serving the facility. In addition, ultraviolet light emitters will be installed ahead of these HEPA filters in the return duct, which will aid in the destruction of additional microorganisms in the room air. Filters will be replaced in accordance with manufacturer’s recommendations.

Active Carbon Filters Carbon filtration is a type of filtration in which activated carbon (i.e., charcoal) is used to remove contaminants, impurities, and odors through the process of chemical adsorption. As odor-producing gases come in contact with the activated carbon in the filter, they are adsorbed, trapped and held in 179 million microscopic carbon pores. Impurities and odors will be greatly reduced, as all exhaust air will pass through the active carbon filters prior to discharge from the building and into the atmosphere. EBR will install active carbon filters at all air exhaust points from the facility, ensuring that cannabis odor particles in the air leaving the facility will be trapped. Active carbon filters were selected because of their improved ability over particulate filters, such as HEPA, to remove extremely small particulates (<.01 microns) like vapors and gases and because they are well-known to be useful for




safely removing odors. Active carbon filters stop working as soon as all of the potential bonding sites are filled, so periodic replacement of the filters will be critical. A dispensary agent will be responsible for replacing the carbon filters as directed by the manufacturer.

Ozone Generator Ozone generators produce ozone (O3), which attaches to odors, mold, mildew, bacteria, microorganisms, and other pollutants in a space, if present, and oxidizes them. This process purifies the air and leaves the space odor and contaminant free. If all ozone molecules are not used in oxidation, they then convert back to normal oxygen (O2) after about an hour. Ozone generators are effective at eliminating strong odors and contaminants such as mold spores in contained non-occupied spaces, but are not approved for use in occupied spaces due to potential health hazards in very high concentrations. Though high concentrations of ozone will not be generated, commercial ozone generators will be installed and used only in non-occupied spaces in the facility in order to comply with federal regulations of ozone and promote agent safety. EBR plans to install commercial stationary ozone generator units in non-accessible and non-occupied open spaces. These generators are designed specifically for use in unoccupied spaces. Non-accessible open spaces may be built in above the ceilings in the facility storage and other such areas areas to accommodate ozone generators. Ozone generators will be set between 0.03 ppm and 0.10 ppm to ensure safe levels of ozone are maintained at all times and will be maintained in accordance with manufacturer’s recommendations.

SECTION 4: SECURITY PLAN


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ADDENDUM (D)

BCC’s State Testing Requirements Breakdown.




ADDENDUM (E)

Example education material.




ADDENDUM (I)

Proof of funding/capitalization.


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