SR 06-13-2023 7A
City Council
Report
City Council Meeting: June 13, 2023
Agenda Item: 7.A
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To: Mayor and City Council
From: David Martin, Director, Administration
Subject: Adult-Use Cannabis Study Session
Recommended Action
Staff recommends that the City Council:
1. Receive the presentation on key policy considerations for allowing adult -use
cannabis businesses and other non-retail cannabis business types within the City
of Santa Monica;
2. Discuss options for allowing adult-use cannabis sales and associated regulatory
restrictions as may be appropriate; and
3. Provide direction to staff on whether to bring back changes to the Municipal Code
to allow for adult-use cannabis retail businesses and non-retail cannabis
business types within the City.
Executive Summary
On May 10, 2022, the City Council requested that the City Manager schedule a stud y
session regarding whether to allow for the sale of non-medicinal (hereinafter referred to
as “adult-use”) cannabis in the City of Santa Monica. Subsequent to that, in the
November 2022 election, the voters approved Measure HMP, which enables the City to
levy a business tax on every licensed cannabis business. The study session seeks
Council direction on the following key policy topics:
1) Should consumer access to legal adult-use cannabis in Santa Monica be
permitted, or should the City maintain the restriction of medicinal-only cannabis?
2) What types of cannabis uses should be allowed?
3) Should the City set a limit to the number of retailers and other uses?
4) Should only the two medicinal cannabis retailers be allowed to expand into the
adult-use market, or should the City allow new cannabis retailers?
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5) Where in the City should cannabis uses be allowed to operate?
6) Which land uses, if any, should be recognized as sensitive uses requiring a
distance buffer from cannabis uses above and beyond state requirements?
Background
Cannabis regulations in the State of California have been evolving ever since the
passage of Proposition 215, the Compassionate Use Act of 1996 (CUA), which de -
criminalized the use, possession, and cultivation of cannabis for qualifying patients an d
their primary caregivers when recommended by a physician. The CUA did not create a
state regulatory program, nor did it provide any guidelines for local jurisdictions to
establish their own regulations.
The City of Santa Monica first adopted regulations for medical marijuana (medicinal
cannabis) in June of 2015 as a part of the City’s comprehensive Zoning Ordinance
update (Article 9 of the Santa Monica Municipal Code) which enabled up to two
medicinal cannabis retailers within the City subject to a regulatory permit and selection
process. All other cannabis-related uses were prohibited. The dispensaries were
allowed only along limited sections of Wilshire Boulevard and Santa Monica Boulevard
within the Mixed-Use Boulevard Low (MUBL), Mixed-Use Boulevard (MUB) or General
Commercial (GC) zones subject to a Conditional Use Permit.
In October of 2015 the State of California passed the Medical Cannabis Regulation and
Safety Act (MCRSA) which created a State licensing program for commercial medical
cannabis activities while allowing counties and cities to maintain local regulatory
authority. MCRSA required that the State would not issue a license without first
receiving authorization by the applicable local jurisdiction.
On November 8, 2016, the voters of the State of California approved Proposition 64, the
Adult Use of Marijuana Act (AUMA), which allows adults 21 years of age or older to
legally grow, possess, and use marijuana for personal, non-medical “adult-use”
purposes, with certain restrictions. AUMA also established state taxes on the cultivation
and sale of cannabis and specifically allowed local jurisdictions to impose their own
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taxes. Proposition 64 was approved by 57% of California voters and by 60% of the
voters in Los Angeles County. In Santa Monica support was even higher at 75%.
On March 7, 2017, the City Council directed staff to prohibit adult -use commercial
cannabis activities within the City, to draft an ordinance creating a regulatory permit and
selection process for medicinal cannabis retailers, to amend the City’s Municipal Code
to address changes in State law, and to consider options for allowing non-volatile
medicinal cannabis light manufacturing uses.
On June 27, 2017, the Legislature enacted SB 94, which repealed MCRSA and
incorporated certain provisions of MCRSA into the licensing provisions of AUMA. These
consolidated provisions are now known as the Medicinal and Adult-Use Cannabis
Regulation and Safety Act (MAUCRSA). MAUCRSA allows that a commercial cannabis
business can operate in both the medicinal and adult-use markets from a single location
though this allowance is still subject to local land use authority.
On October 24, 2017, the City Council adopted an Interim Zoning Ordinance (the IZO)
adding Section 6.200 to the Santa Monica Municipal Code, which established general
regulations and definitions for commercial cannabis activities, including a regulatory
permit process for medicinal cannabis retailers and light (non-volatile) manufacturing,
and making other changes as needed to conform with State law. The ordinance
prohibited all adult-use commercial cannabis activities including retail, cultivation,
testing, distribution, and manufacturing. The IZO has subsequently expired. After a
prolonged selection process, two medicinal cannabis retailers were selected. One of the
retailers began operations recently at 925 Wilshire Boulevard. The second retailer
located at 1416 Wilshire Boulevard is still in the permitting process.
On May 10, 2022, the City Council requested that the City Manager schedule a study
session regarding whether to allow for the sale of adult-use cannabis in the City of
Santa Monica. It was requested that the study session include suggested changes to
the City’s Municipal Code, as well as options for City Council direction on potential
locations, permitting process, social equity provisions, maximum number of allowable
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businesses, cannabis special events, and other regulatory restrictions as may be
appropriate. The Council further directed staff to prepare a can nabis business tax
ordinance to be placed on the November 8, 2022 ballot. Implementation of certain
aspects of the cannabis tax would be contingent on future actions to be taken by the
Council pursuant to the requested study session.
On July 26, 2022, the City Council voted to place a cannabis business license tax
measure (Measure HMP) on the November 2022 ballot. The measure would impose a
tax on all commercial cannabis activities at initial rates of 3% of gross receipts for adult-
use cannabis retailers, 2% for medicinal cannabis retailers and 1% on other cannabis
business types. These rates could be increased up to 10% of gross receipts at the
discretion of the City Council.
Measure HMP was approved by the voters on November 8, 2022, by a margin of 66%
to 34%. Pursuant to that approval and the Council’s previous direction, staff is now
bringing forward this study session to explore whether to allow for the sale of adult-use
cannabis in the City of Santa Monica as well as other non -retail cannabis business
types. This study session shall include a presentation by staff and HdL Companies, a
firm that has worked extensively on regulation, compliance, policy development,
taxation, fiscal analysis, and audit issues for local governments, and shall provide the
opportunity for Council to give direction to staff on potential locations, permitting
processes, social equity provisions, maximum number of allowable businesses,
cannabis special events, and other regulatory restrictions as may be appropriate.
Discussion
The City of Santa Monica currently allows medicinal cannabis businesses, which allows
sales to individuals over the age of 18 who have a recommendation from a medical
professional for the use of cannabis, but does not allow adult -use businesses, which
would allow sales to anyone over the age of 21. One of the medicinal cannabis retailers
recently began operations while the other is currently in the permitting process. Light
(non-volatile) cannabis manufacturing was allowed by the IZO adopted in 2023 with the
City receiving one application for a cannabis light manufacturer. That business has
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since closed, and cannabis light manufacturing is no longer permitted as the IZO has
expired. Medicinal cannabis retailers represent a small subset of the commercial
cannabis business types allowed by the State of California which also include
cultivation, distribution, laboratory testing, and other types of manufacturing currently
not permitted within the City.
To address Council’s request to better understand the decisions needed to enable adult-
use business, staff has engaged the services of consultant HdL Companies, who are
subject matter experts on the regulation of commercial cannabis businesses by counties
and cities in California.
If the Council desires to move forward with revisions to the City’s current commercial
cannabis program, staff will require direction on a number of key policy areas. Additional
issues for future consideration have also been identified. These additional issues do not
require direction from the Council at this time, but they may be informative to the
Council’s overall discussion.
Initial Key Policy Discussions
Confirming Adult-Use Cannabis as a Permitted Land Use
1) Should consumer access to legal adult-use cannabis in Santa Monica be permitted,
or should the City maintain the restriction of medicinal-only cannabis?
California’s cannabis regulations allow that cannabis can be sold commercially for either
medicinal or recreational adult-use purposes. Medicinal cannabis is available only to
persons 18 years or older who have a valid recommendation from a physician.
Medicinal cannabis patients also have the option of obtaining a State-issued Medical
Cannabis Identification Card (MMIC), but this is not required. Both the physician’s
recommendation and the identification card are required to be renewed every year. Only
3,199 such cards were issued in all of California in 2022. Adult -use cannabis can be
sold to anyone age 21 years or older without a physician’s recommendation.
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The State of California’s Department of Cannabis Control (DCC) may issue business
licenses for either medicinal (M) or adult-use (A), or for both medicinal and adult-use
(M/A) though the M/A designation is not available for cultivation. Initially, California’s
cannabis program required that all cannabis and cannabis products had to be
designated for either the medicinal or adult-use market through all stages of the supply
chain, but later revisions have changed this so that product grown or manufactured for
either market can be shifted to the other up until the point of sale. This makes the
medicinal or adult-use designation largely meaningless for wholesale cannabis
businesses as it does not predetermine how the product will eventually be sold.
Of over 11,000 cannabis business licenses1 in California, only 1,360 are for medicinal
cannabis only (12%). The rest are for either adult-use or for both medicinal and adult-
use. Among the state’s 1,891 retailers (including retailing microbusinesses), only 31 are
licensed for just medicinal cannabis sales.
Medicinal cannabis is estimated to make up only around 9% of cannabis retail sales in
California. The primary advantage for consumers to purchase cannabis through the
medicinal market is an exemption from regular sales tax only for those qualifying
patients who present a Medical Marijuana Identification Card at the time of purchase (a
savings of 7.25% to 10.25%, depending on the jurisdiction). The small number of
patients with valid MMIC cards makes their impact on tax revenues statistically
insignificant. Cannabis products labeled for medicinal use only may be packaged in
quantities that exceed the 100 milligrams per-package THC limit imposed on adult-use
products (1,000 milligrams per package for topical products). Qualified patients may
also purchase a greater quantity of cannabis or cannabis products per day, beyond
what is permitted for adult-use customers and up to the maximum amount stated on the
physician’s recommendation.
Retail and Non-Retail Uses
1 The number of licenses does not reflect the number of individual businesses as a single business may hold
multiple licenses.
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2) What types of cannabis uses should be allowed?
The City’s Interim Zoning Ordinance allowed for both medicinal cannabis retailers and
light-industrial (non-volatile) cannabis manufacturing. The City approved one
manufacturer under the IZO, but that business has since closed. The C ity no longer
permits cannabis light manufacturing. The City allows for two medicinal cannabis
retailers with only one recently commencing operation. These and other cannabis
business types are discussed below.
• Cannabis Retailers: Cannabis retailers may be licensed to sell medicinal
cannabis, adult-use cannabis, or both. Retailers can operate as a storefront
serving walk-in customers, as a non-storefront delivery service, or as part of a
microbusiness which includes at least three licensed cannabis activities such as
cultivation (of up to 10,000 square feet), manufacturing, or distribution. Storefront
retailers are allowed to also conduct sales by delivery, though not all do.
Currently there are 1,891 licensed cannabis retailers and retailing
microbusinesses in California. Of these, 1,142 are storefront retailers, 490 are
non-storefront delivery services, and 259 are microbusinesses. Virtually all
cannabis retailers in California are licensed for adult-use sales. There are only 31
retailers in all of California that are only licensed for medicinal sales.
Storefront retailers tend to generate significantly higher gross receipts than non -
storefront retailers. Analysis of a sample set of businesses shows that storefront
retailers average around $5 million per year in total sales while non-storefront
delivery services average less than $1.5 million. As a result, storefront retailers
typically generate more cannabis tax revenue for their host city.
The DCC shows 454 licensed cannabis retailers in Los Angeles County, including
storefronts, delivery services, and retailing microbusinesses. We estimate that
there are 30 retailers in the immediate vicinity of Santa Monica and another 100
or so within a 30-minute radius of the City. These retailers are shown in Figure 1
below. The high density or retailers in close proximity suggests that cannabis
consumers in Santa Monica have options for purchasing either medicinal or
adult-use cannabis within a short drive of the City or for having it delivered to
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their door. Any cannabis tax revenue being generated by sales to City residents
is currently going to the jurisdiction where the retailer is located, primarily the
City of Los Angeles.
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Figure 1:Medicinal and Adult Use Cannabis Retailers in the Santa Monica Vicinity
Based on the City’s population of roughly 91,000 people, it is estimated that the
City of Santa Monica could support four (4) to ten (10) cannabis retailers. This
assumes a very general benchmark of one retailer for every 10,000 to 20,000
people for considering an area as being ‘served’. Individual cities may have a far-
greater or far-lower retail density. The number of employees and visitors to Santa
Monica could also affect the demand for additional retailers.
• Cannabis Manufacturing
Cannabis manufacturers produce an ever-increasing variety of products,
including concentrates, edibles, tinctures, topicals, and infused (non-alcoholic)
drinks. Manufacturers may produce their own raw extract on site, or they may
buy extract from other licensees. Much like any other industry, cannabis
manufacturers often depend upon other businesses to supply them with the
various materials or components that go into their final product.
Cannabis manufacturing is a broad category that can include a wide range of
different activities. Manufacturers may use a variety of methods to extract THC
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and/or CBD, the primary compounds found in cannabis, from the raw product.
These methods may include volatile solvents such as butane, hexane, or
propane (Type 7), non-volatile solvents such as carbon dioxide, ethanol, cooking
oils or butter, or mechanical extraction using heat, cold, or pressure (Type 6). The
extract may be processed and sold as raw concentrate such as oil, wax, shatter,
or rosin, or it may be infused into edibles, topicals, tinctures, or other products.
Cannabis oil may also be loaded into vape cartridges. Both Type 6 and Type 7
licenses also allow for infusion, packaging, and labeling of cannabis products.
Many manufacturers do not make their own extract and instead buy extract from
other suppliers. The Type N license allows for making infused products using
extract purchased from other licensed manufacturers, as well as packaging and
labeling. The Type P license allows for packaging and labeling of “white label”
products, where a product purchased from another supplier is rebranded under a
new name. Lastly, the Type S license allows for manufacturers to operate in a
shared-use facility using non-volatile extraction and infusion, along with
packaging and labeling.
Some manufacturers may handle all steps from extraction to packaging the end
product in the form of vape pens or other such devices. Others may handle only
discrete steps, such as making the raw cannabis concentrate, which is then sold
either directly to retailers or to a Type N manufacturer who will package it into
vapor cartridges or other end consumer products.
Light-industrial (non-volatile) cannabis manufacturing was initially allowed under
the Interim Zoning Ordinance, but the only manufacturer to open its doors has
since closed. The City no longer permits this business type as the IZO has since
expired.
• Cannabis Cultivation
Cannabis cultivation can be conducted outdoors, in mixed-light greenhouses, or
in fully-enclosed indoor warehouse facilities. Cultivation activities can also
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include cannabis nurseries and processing facilities. Cultivation in urban areas is
almost always limited to indoor facilities due to available properties and other
land use considerations.
Indoor cannabis cultivation must be conducted using entirely artificial light.
Facilities must be designed so that no cannabis or cultivation lighting is visible
from outside. Cultivation facilities are also required to install odor control
equipment so that cannabis odors cannot be detected from outside the building.
Indoor cultivation facilities tend to be discreet with little or no signage to draw
attention to them.
As of January 2023, data from the DCC shows 7,651 active cultivation licenses
statewide, held by 3,359 distinct businesses. These licenses cover over 1,800
acres of canopy and are capable of producing over 16 million pounds of cannabis
per year. The 20 largest cultivation companies hold 2,232 licenses between
them, totaling 515 acres and capable of producing over 2.6 million pound s of
flower per year, or enough to supply the entire statewide market.
The cannabis cultivation market in California has far exceeded its saturation
point, which greatly limits new entrants into the market. More than any other part
of the cannabis industry, entry into the highly competitive cultivation sector can
be filled with risk and requires ample capitalization and a clear strategy to win
shelf space. It is not uncommon for cannabis producers and manufacturers to
have to pay for retail shelf space just to get their product in front of consumers.
• Cannabis Distribution
The DCC provides two separate license types for cannabis distributors. Type 11
distributors can move cannabis products and branded merchandise between
other wholesale cannabis businesses, provide warehousing and storage, arrange
for laboratory testing, provide packaging and labeling of products, and can
distribute finished cannabis goods to retailers. Type 13 transport-only distributors
can move product between other wholesale businesse s but are not allowed to
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distribute to retailers. The DCC also allows a reduced fee for cannabis cultivators
or manufacturers that only wish to transport their own product.
Perhaps more than any other part of the cannabis supply chain, distributors are
greatly dependent upon the number and variety of other cannabis business types
within their service area. Essentially, distributors need a certain “critical mass” of
other cannabis businesses for them to serve. As a very general figure, the
number of cannabis distributors statewide is roughly 25% of the number of all
cannabis businesses, combined, or 1 distributor for every 3 other cannabis
businesses. In addition, almost all (391 out of 392) licensed microbusinesses in
California include distribution as one of their licensed activities. It is common for
other cannabis businesses (cultivators, manufacturers, or retailers) to also hold a
distribution license as an ancillary activity.
The business model for distributors is commonly based on a percentage markup
on the price paid to their suppliers. This markup commonly averages 20% to
30%, though this can vary greatly depending upon the actual services being
provided. A distributor that is only buying and reselling cannabis at wholesale
may make as little as 10% or less on a transaction, while a distributor that is
purchasing raw flower and packaging it as pre-rolls for retail sale may make 50%
or more on such a value-added transaction.
Distributors may have annual revenues ranging from less than $1 million to over
$70 million. The vast majority of distributors would fall at the lower end of that
range, with those at the high end qualifying as outliers. While there is not yet an
abundance of data to determine the average gross receipts for distributors, HdL
has reviewed a number of pro-formas for distributors seeking licenses in other
jurisdictions. These indicate anticipated gross receipts commonly in the range of
$2 million to $3 million per year, with an average of $2.5 million. Though, again,
this is an average based upon a very wide range.
• Cannabis Testing Laboratories
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Testing is a semi-regulatory function mandated by the State to protect consumer
health and safety. State law requires that all dried cannabis flower or leaf must be
tested for tetrahydrocannabinol (THC) and cannabidiol (CBD) content,
contaminants, impurities and other factors before it can be sold to a
manufacturer, distributor, dispensary or end user.
State law requires that testing laboratories be completely independent from any
other cannabis business, and prevents them from benefitting from, or having any
interest in, the results of the test or the value of the product. A person who holds
an ownership interest in a cannabis testing business is not allowed to hold any
financial interest in any other cannabis business types.
The DCC has so far only issued 45 licenses for cannabis testing laboratories in
California. These laboratories tend to be located in areas with a large amount of
commercial cannabis activity.
• Cannabis Events
Cannabis events allow an opportunity for cannabis consumers to meet and
engage with a variety of cannabis retailers, cultivators, and manufacturers all in
one place, similar to a farmers’ market, craft fair, or trade show. These events
may or may not also allow for on-site consumption of cannabis under permitted
conditions similar to a homebrew festival or wine tasting event. While growers
and manufacturers can be on hand to display their products and talk with
attendees, cannabis and cannabis products can only be sold at the event by
licensed cannabis retailers.
The application for a temporary cannabis event must include the location where
the event will be held, the dates and hours that cannabis will be sold or
displayed, a list of all licensed vendors who will be participating, and a diagram
showing the specific locations assigned to each cannabis vendor and all areas
where participants will be allowed to purchase or consume cannabis. All
cannabis events require approval by the local jurisdiction, and local law
enforcement has the authority to stop the event if it is necessary to protect public
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health and safety.
If on-site consumption of cannabis is to be allowed, the consumption must not be
visible from any public place or non-age-restricted area. No alcohol or tobacco
shall be allowed on the premises and smoking of cannabis shall not be allowed in
any areas where smoking is otherwise prohibited by law. The local jurisdiction
can choose whether or not to allow on-site consumption (or to allow cannabis
events at all) and can impose additional requirements as it sees fit.
A temporary cannabis event license may only be issued for a location expressly
approved for such purposes by the local jurisdiction and shall not be issued for a
premises that is licensed for the sale of alcohol or tobacco. A cannabis event may
not last longer than 4 days. No person under the age of 21 shall be allowed in
any area designated for cannabis sales or consumption, regardless of whether
that person is a qualified medical marijuana patient.
• Consumption Lounges
A small but growing number of cities have chosen to allow for on-site
consumption of cannabis products at retailers or associated businesses. Such
facilities are generally referred to as “consumption lounges,” though the mode l for
their operations can vary dramatically. DCC regulations do not directly address
consumption lounges as either a use or a permit type, leaving the authority and
responsibility for permitting and regulating on-site consumption up to the local
jurisdiction.
The DCC’s regulations for on-site consumption at organized cannabis events
indicate some areas of concern that are generally applicable for local regulations.
These regulations prohibit access to persons 21 years of age or younger, require
that cannabis consumption not be visible from any public place or non-age-
restricted area, prohibit sale or consumption of alcohol or tobacco on the licensed
premises, and prohibit the smoking of cannabis goods in any areas where
smoking is otherwise prohibited by law. California’s smoke-free workplace law
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prohibits the smoking of tobacco products in any enclosed space at a place of
employment which prevents smoking in restaurants and conversely prevents
preparing or serving food in a consumption lounge.
There is no defined model for consumption lounges, nor is there a clear business
model for generating income or related cannabis tax revenue. Some such
businesses only offer a place for retail customers to sample what they’ve
purchased. These lounges appear to generate revenue only from the retail side
of the operation, which in most cases is a separate space from the lounge area.
Some other consumption lounges operate as clubs where customers must pay a
cover charge to get in.
Number of Retailers
3) Should the City set a limit to the number of retailers and other uses?
It is common for cities and counties to apply a cap to the number of cannabis retailers
within their jurisdiction. This can have the effect of limiting the concentration of such
businesses within any one area while simultaneously creating significant competition to
secure the limited number of available permits. Setting a cap requires that the City
adopt a competitive selection process to determine which applicants can move forward
for permits. Applicants who are not selected through this process may challenge the
results by appeal and/or lawsuit, creating significant risk to the local licensing agency
and delays in the permitting process.
A low cap on the number of retailers may have the effect of increasing the size and
neighborhood presence of each store. If a single store serves a large market, that store
may be bigger and may have a higher profile within the area, drawing more customers
and traffic. Conversely, a higher cap (or no cap) may have the effect of reducing the
impact of any one store as the same volume of customer traffic is distributed over more
stores in more locations. A higher cap may also spread the economic benefits of
owning and/or working within a cannabis facility more broadly within the local
community.
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Caps are somewhat less common for wholesale businesses, as the statewide market is
oversaturated. Allowing a higher number of wholesale businesses does not necessarily
mean the City is likely to attract more (or any) of those businesses.
Existing Businesses
4) Should only the two medicinal cannabis retailers be allowed to expand into the adult -
use market, or should the City allow new cannabis retailers?
The City currently allows for two medicinal cannabis retailers. Were the City to allow
adult-use sales, it should be assumed that these existing retailers would want to be
allowed an opportunity to modify their permits to conduct both medicinal and adult-use
sales.
Allowing for additional retailers would presumably mean allowing for ad ditional (and
potentially more preferable) locations that may not have been allowed previously.
Existing retailers may also want an opportunity to move their operations to these
alternate locations.
The City may also hear concerns from nearby businesses and residents who were
perhaps accepting of medicinal cannabis retailers but object to now allowing adult-use
cannabis sales at the same locations. While all security and operational requirements
are the same for both medicinal and adult-use retailers, it is reasonable to assume that
allowing adult-use sales could increase the amount of customers and foot traffic.
Allowable Locations
5) Where in the City should cannabis uses be allowed to operate?
Cities and counties have taken a variety of approaches in determining allowable
locations for cannabis businesses. Many apply standard zoning requirements with each
of the various cannabis business types being allowed within certain land use
designations where other, similar activities are allowed. This approach assumes that
cannabis retailers are consistent with other retail uses, that cannabis manufacturers are
consistent with other light manufacturing uses, and so on.
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Generally, storefront retailers are allowed in commercial zones while manufacturers,
distributors, testing, and non-storefront delivery services are allowed in industrial zones.
Cannabis cultivation is commonly allowed in either industrial or agricultural zones,
depending upon whether it is indoor, mixed-light, or outdoor. The various cannabis
business types may be either principally permitted within these zones or allowed with a
conditional use permit. Zoning for cannabis microbusinesses may be more problematic
as retail uses are typically not allowed in industrial zones, and cultivation or
manufacturing uses are typically not allowed in commercial/retail zones.
Some jurisdictions take a more prescriptive approach where cannabis activities are
allowed only within a defined overlay zone created for that specific purpose. The City
has specified that medicinal cannabis retailers are currently allowed subject to a
Conditional Use Permit in a subset of the MUB (Mixed-Use Boulevard), MUBL (Mixed-
Use Boulevard Low), or GC (General Commercial) zones as described below:
• Mixed-Use Boulevard District along Wilshire Boulevard between Lincoln
Boulevard and Centinela Avenue;
• General Commercial District along Santa Monica Boulevard between Lincoln
Boulevard and 20th Street; and
• Mixed-Use Boulevard Low District along Santa Monica Boulevard between
23rd Street and Centinela Avenue.
Light (non-volatile) manufacturing was previously allowed under the Interim Zoning
Ordinance within the Industrial Conservation (IC) zone, or with an approved Conditional
Use Permit (CUP) within the Office Campus (OC) zone, consistent with other similar
activities such as canners, roasters, breweries, wholesale bakeries, and frozen food
manufacturers. One such manufacturer opened but has since closed, and the City no
longer permits cannabis light manufacturing uses as the IZO has expired
Buffer Requirements
6) Which land uses, if any, should be recognized as sensitive uses requiring a distance
buffer from cannabis uses above and beyond state requirements?
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The State of California prohibits locating any cannabis businesses within 600 feet of any
K-12 schools, daycare facilities, or youth centers. These sensitive-use buffers are
provided as a default, but local jurisdictions are allowed to increase or decrease the
minimum distance. Additionally, local jurisdictions have the authority to recognize
additional types of buffers, such as parks, libraries, drug rehabilitation centers, and
playgrounds.
Some jurisdictions have chosen to increase the buffer distance to as much as 1,000 feet
in some instances or to reduce them to as low as zero. Other local jurisdictions have
chosen to vary the buffer distances for different sensitive uses or for different cannabis
use types or apply targeted buffers for specific locations such as a particular plaza or
downtown area.
Setting overly restrictive sensitive use buffers can greatly limit the allowable locations for
a cannabis business and can result in a de-facto ban or, conversely, in a high
concentration of cannabis businesses in a handful of areas. Restricting the allowable
locations can also have the effect of increasing the perceived value of those parcels to
where property owners demand an unrealistic premium for leasing or buying the
property.
Zoning and sensitive use buffers are not the only tools available to the City for resolving
neighborhood concerns with cannabis businesses. The City may also impose
requirements relating to signage, lighting, hours of operation, façade design, on -site
security, parking, or other physical or operational details.
Future Policy Considerations
Social Equity
Social equity in cannabis seeks to recognize the long-term negative impact that the
criminalization of cannabis has had on minority communities resulting from the
enforcement of federal and state laws related to cannabis use and possession.
Research from communities across the United States has consistently demonstrated
the disproportionate impact of cannabis enforcement on minority groups despite similar
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cannabis usage rates. In particular, African Americans have been negatively affected by
higher rates of arrest and incarceration for cannabis-related activities.
The consequences of a criminal conviction and incarceration include the permanent
loss of property, disqualification from employment opportunities, reduced earnings
potential, exclusion from public benefits such as housing assistance or student financial
aid, and other life-altering impacts. The goal of cannabis social equity is to help ensure
that the communities most impacted by federal and state cannabis enforcement policies
are provided an opportunity to benefit from the newly legalized industry.
Many cities and counties have sought to develop cannabis social equity programs as a
means for reducing barriers to entry into the commercial cannabis industry for
communities and individuals most impacted by the war on drugs. For social equity
programs to be meaningful, however, they must be based upon data to identify those
communities within each jurisdiction that have historically been most adversely
impacted.
For this reason, it is common for development of a social equity program to be preceded
by a detailed study or report that analyze factors such as disproportionate contact by
law enforcement, incarceration rates, or other metrics. Cannabis equity studies are
commonly conducted by local community foundations, universities, or other research
organizations, with significant outreach to local community members. The State of
California through the Governor’s Office of Business and Economic Development (GO -
Biz) has historically provided annual funding to local jurisdictions to assist with
development of cannabis equity studies.
Once the local jurisdiction has identified affected communities, there are numerous
policy options for promoting equity. Policy options may include application criteria
specific to equity applicants, fee waivers, business development assistance, workforce
training, assistance with accessing startup capital, business mentorship, assistance with
expunging cannabis-related criminal records, and utilizing cannabis tax revenues to
fund community reinvestment. Regardless of what benefits the City offers, it is important
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to recognize the challenges that other cities have faced in implementing local cannabis
equity programs. These challenges can include manipulative behavior by non -qualifying
individuals taking advantage of the program, sunk costs for applicants who are
ultimately unable to obtain a license, and limited staff resources to develop and
implement a comprehensive program.
In addition, there are unique barriers to entry into the cannabis market that make the
push for equity in the industry particularly challenging relative to other business types.
These barriers include startup costs that can approach or exceed one million dollars,
intense competition for a finite number of licenses, and limited availability of real estate
within eligible zones of the city. Although significant, these challenges should not act as
a deterrent to creating a cannabis equity program. They simply point to the need for
policymakers to carefully think through the parameters of an equity program which
starts with development of a cannabis equity study.
Selection Process
Cities have taken a variety of approaches to the selection and permitting process for
cannabis businesses should the community cap the num ber of outlets in the jurisdiction.
Application processes may be tailored to provide merit-based ranking or a lottery where
appropriate for awarding a specified number of permits, or to provide a quality
assurance standard for those business types where there is no such limit. The process
may include specific evaluation criteria to ensure that applicants have addressed all
requirements before being allowed to move forward to the permitting process. The
application process can be designed to accommodate a va riety of selection methods:
• Merit based: Applicants are ranked according to their score. Top-ranked applicants
are selected to move forward to the permitting process, consistent with the number
of permits available.
• Equity: Priority is given to individuals who qualify for the cannabis equity program, as
defined by the equity study.
• Lottery: All applications scoring above a minimum baseline are entered into a
drawing from which applications will be selected at random, consistent with the
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number of permits available. Those applications selected will be allowed to move
forward to the permitting process.
• First come / first served: Applications are reviewed and scored in the order they are
received. All applications scoring above a minimum baseline will be allowed to move
forward to the permitting process, until the maximum number of permits available
has been reached.
Determining the most appropriate process depends upon the number of permits
available and the anticipated demand for those permits. Development of the application
process is commonly done administratively and is subsequent to development of the
regulatory ordinance.
Affected City Departments
Administering and regulating cannabis businesses involves a variety of common local
government functions. In Santa Monica it is likely that the business licensing and
payment of any cannabis business taxes may be assigned to the Finance Department.
Location-specific criteria, permitting, land use entitlements, and tenant improvements
would be addressed by Planning and Building and Safety. The Fire Department and
Code Enforcement may conduct occasional inspections. Some jurisdictions choose to
place certain regulatory roles within law enforcement, which may include POST certified
officers; this can greatly increase the cost for these regulatory services.
Cities and counties have a variety of options for how they administer cannabis
regulatory programs. Some jurisdictions assign each aspect of regulatory oversight to
the appropriate department as described above. Others place primary oversight with a
single department or division. Still others choose to develop a dedicated Cannabis
Division that has responsibility for all aspects of oversight.
The decision of how to administer the cannabis program could depend on the number of
cannabis businesses and the desired level of regulatory oversight. Creation of a
dedicated Cannabis Division would depend on the number of businesses and whether it
would justify the number of staff positions and resources required.
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Other agencies may also have a regulatory role. Additional inspections may be
conducted by Los Angeles County Department of Public Health or County Agricultural
Commissioner.
In developing a cannabis regulatory program, the City should anticipate the impacts to
staff time and other departmental costs associated with the permitting, regulation and
enforcement of those businesses. Cities commonly develop cost recovery fees
adequate to cover all direct costs, which may include any or all of the following:
• Costs associated with the development of a commercial cannabis regulatory
program.
• Costs associated with the review and permitting of individual cannabis
businesses.
• Costs associated with inspections, audits, monitoring, and permit renewals.
• Costs associated with mitigating external impacts to the community or the
environment.
• Costs associated with enforcement and appeals.
Summary of Key Policy Questions
1) Should consumer access to legal adult-use cannabis in Santa Monica be
permitted, or should the City maintain the restriction of medicinal-only cannabis?
2) What types of cannabis uses should be allowed?
3) Should the City set a limit to the number of retailers and other uses?
4) Should only the two medicinal cannabis retailers be allowed to expand into the
adult-use market, or should the City allow new cannabis retailers?
5) Where in the City should cannabis uses be allowed to operate?
6) Which land uses, if any, should be recognized as sensitive uses requiring a
distance buffer from cannabis uses above and beyond state requirement s?
Past Council Actions
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Meeting Date Description
6/23/15 Ordinance Repealing the Existing Zoning Ordinance,
Chapter 9.04 of Article 9 of the Santa Monica Municipal
Code, and Adding a New Zoning Ordinance, Chapter 9.01
Through Chapter 9.52, to Article 9 of the Santa Monica
Municipal Code to Adopt a Comprehensive Zoning
Ordinance; Repealing Chapters 9.08 Through 9.72 of Article
9 of the Santa Monica Municipal Code and Adding New
Chapters 9.53 Through 9.68 to Article 9 of the Santa Monica
Municipal Code to Establish Land Use and Zoning Related
Provisions; and Implementing the New Zoning Ordinance By
Repealing the Existing Official Districting Map and Adopting
a New Final Official Districting Map.
3/7/17 Study Session on Cannabis Regulations.
10/24/17 Second Reading and Adoption of Interim Ordinance
Replacing the Term "Medical Marijuana Dispensary" with
"Medicinal Cannabis Retailer" Throughout the City's Zoning
Ordinance, Chapter 9.01 Through Chapter 9.52 of Article 9
of the Santa Monica Municipal Code; Creating a Definition
for "Medicinal Cannabis Retailer" to Replace the Definition
for "Medical Marijuana Dispensary" to Conform With State
Law; Removing Certain Requirements for Medicinal
Cannabis Retailers for Consistency with State Law and to
Allow for Separate Regulation and Rulemaking; and
Modifying the Definition of "Industry, Limited" to Allow for
Medicinal Cannabis Light Manufacturing.
5/10/22 Request of Councilmembers Negrete, de la Torre, and Brock
that the City Manager schedule a study session as soon as
practicable regarding whether to allow for the sale of
nonmedicinal cannabis in the City of Santa Monica, as the
City currently allows for the sale of medicinal cannabis. The
study session shall include suggested Municipal Code
changes, as well as options for City Council direction on
potential locations, permitting process, social equity
provisions to make legal cannabis business ownership and
employment opportunities more accessible to low-income
individuals and communities most impacted by the
criminalization of cannabis, and any other regulatory
restrictions as may be appropriate, including the maximum
number of medicinal and nonmedicinal cannabis
establishments in the City that are recommended. Finally,
the study session shall also include municipal code changes
that are necessary to allow for Cannabis-themed special
events in specified locations in the City.
7/26/22 Ballot measure for business license tax on the sale,
distribution, delivery, and consumption of cannabis.
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Environmental Review
No environmental review under CEQA is required at this time because this study
session will not result in direct or indirect physical changes in the environment.
Financial Impacts and Budget Actions
There is no immediate financial impact or budget request as a result of the
recommended action today. Staff has not included tax revenue projections associated
with Measure HMP in the FY 2023-25 Biennial Budget or five-year forecasting and has
not included projected fee revenue or resource needs associated with the
implementation of a cannabis retail presence. A review of activity in other jurisdictions
suggests that gross receipts may be in the range of $2 million to $3 million per year,
with an average of $2.5 million, resulting in new tax revenues of $75,000-$250,000 a
year per licensee. Staff will return to Council if specific budget actions are required in
the future.
Prepared By: Tony Kim, Principal Planner
Approved
Forwarded to Council
Attachments:
A. June 23, 2015 Council Meeting Zoning Update Adoption Council Report (Web
Link)
B. March 7, 2017 Council Meeting Study Session on Cannabis Regulations (Web
Link)
C. October 24, 2017 Council Meeting Medical Cannabis Retailer Interim Ordinance
(Web Link)
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D. May 10, 2022 Council Meeting Councilmember Request for Study Session (Web
Link)
E. July 26, 2022 Council Meeting Ballot Measure for Business License Tax on the
Sale, Distribution, Delivery, and Consumption of Cannabis (Web Link)
F. Written Comments
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Mental health: Studies link marijuana use to depression, anxiety, suicide planning, and
psychotic episodes. It is not known, however, if marijuana use is the cause of these conditions.
Athletic Performance: Research shows that marijuana affects timing, movement, and
coordination, which can harm athletic performance.
Driving: People who drive under the influence of marijuana can experience dangerous effects:
slower reactions, lane weaving, decreased coordination, and difficulty reacting to signals and
sounds on the road.
Baby’s health and development: Marijuana use during pregnancy may cause fetal growth
restriction, premature birth, stillbirth, and problems with brain development, resulting in
hyperactivity and poor cognitive function. Tetrahydrocannabinol (THC) and other chemicals from
marijuana can also be passed from a mother to her baby through breast milk, further impacting a
child’s healthy development.
Daily life: Using marijuana can affect performance and how well people do in life. Research
shows that people who use marijuana are more likely to have relationship problems, worse
educational outcomes, lower career achievement, and reduced life satisfaction.”
From:Peter Borresen
To:councilmtgitems
Subject:Public comment. June 13th meeting. Item 7a.
Date:Monday, June 12, 2023 10:28:34 AM
EXTERNAL
Dear City Council,
Our city should demand large and assertive health warnings regarding the risks caused by marijuana, at
the point of sale, on storefronts, and on all retail packaging.
And the city should ban the sale of marijuana products that encourage under-age use, such as flavored
products, and candy-style packaging – just as California has banned flavored tobacco products.
The National Institutes of Health has stated:
“…early, frequent cannabis use is associated with an increased risk of
developing schizophrenia…”
It is surely more than coincidental that the legalization of marijuana has coincided with
the seeming increase in mental illness and homelessness on our streets.
For every dollar our city will take from marijuana taxes, far more may be lost from
lessened tourism due to the homeless crisis in our city, and far more may have to be
spent on homelessness, crime and mental health services.
Furthermore, peer-reviewed studies have shown other serious and very real harms
from marijuana use. The US Department of Health and Human Services says:
“Brain health: Marijuana can cause permanent IQ loss of as much as 8 points
when people start using it at a young age. These IQ points do not come back,
even after quitting marijuana.
We require health warnings for tobacco, but not marijuana, which is absurd.
Our city should demand LARGE and ASSERTIVE health warnings regarding all the above harms, both at
the point of sale, on storefronts, and on all retail packaging. And the city should ban the sale of flavored
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products, and candy-style packaging.
To not do so is to commit a grievous harm on our children and society.
(And a recent National Academy of Sciences study finds that claims that marijuana
use reduces opioid deaths are "spurious".)
Peter Borresen,
Santa Monica.
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Packet Pg. 415 Attachment: Written Comments (5674 : Adult-Use Cannabis Study Session)
From:Joshua Canter
To:councilmtgitems
Subject:Cannabis License
Date:Monday, June 12, 2023 12:46:56 PM
EXTERNAL
Hello,
As a homeowner and voter in Santa Monica, I strongly recommend you vote to allow adult-use cannabis business
licenses within the city of Santa Monica.
While I support the freedom of choice within adults, I do ask that you severely limited the number of licenses,
following in the same guidance as medicinal cannabis.
We have clearly seen the economic benefit to other cities, with none of the negative impact some people have
associated with
Again, please support adult-use cannabis business licenses.
Thank you,
Joshua Canter
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Packet Pg. 416 Attachment: Written Comments (5674 : Adult-Use Cannabis Study Session)
From:Howard Keum
To:councilmtgitems
Cc:Tony Kim; Phil Brock; Christine Parra; Jesse Zwick; Caroline Torosis; Oscar de la Torre; Erin Carachilo;
paulysong@gmail.com
Subject:Study Session Letter Staff Report 5674 (Agenda 7A) to Councilmembers from Santa Monica’s Cannabis
Dispensary Operator CPC Compassion, Inc.
Date:Monday, June 12, 2023 2:05:05 PM
Attachments:image001.png
EXTERNAL
Dear City Councilmembers,
I am writing to you as one of the managers and owners of CPC Compassion, Inc., a minority-owned and woman-
run medical cannabis dispensary located at 925 Wilshire Blvd. I aim to present hard data to eliminate any
speculation and provide valuable insights to help the city make informed decisions.
Regarding the six items outlined in Staff Report 5674, Agenda 7A for Tuesday’s June 13, 2023, meeting (Adult
Use Cannabis Study), we have data that can greatly assist Santa Monica City in making the best-educated
decision on this matter. I will address key topics below:
1. Should consumer access to legal adult-use cannabis in Santa Monica be permitted, or should the City
maintain the restriction of medicinal-only cannabis?
We face the risk of going out of business if we are not allowed to convert to Adult-Use. Our store faces a
significant disadvantage compared to nearby adult-use options, such as 30 adult-use delivery services and Adult-
Use stores in Venice Beach, Brentwood, and West LA that already serve Santa Monica. No other store within 30
minutes has the same restrictions of Medical-Only that we do. We are the only store who is not Adult-Use in
the entire Los Angeles area. Due to the burdensome process and associated costs of obtaining a medical
recommendation card, our store at 925 Wilshire has witnessed 80-90% of potential customers walking out when
they discover it is not Adult-Use. Even with substantial coupon codes (up to 50% off), customers opt for adult-
use alternatives in Venice & Brentwood/West LA instead versus coming to our store. The current Santa Monica
Medical-Only ordinance, established in 2015-2016 when the entire state of CA was medical only, fails to account
for the current landscape where adult-use is prevalent. Presently, approximately 30 different adult-use delivery
services cater to Santa Monica residents, while our store is limited to addressing only 5-10% of the customer
base. In the last full week, our store averaged only about 10 customers per day. We are losing all Santa Monica
cannabis revenues to outside adult-use delivery services and neighboring adult-use retailers in Venice Beach and
Brentwood/West LA. Santa Monica locals are simply sending their business away to businesses right outside of
Santa Monica.
2. What types of cannabis uses should be allowed?
A) Converting the two medical-only stores to Adult-Use is crucial for the survival of our businesses. Our store
location on 925 Wilshire, has already invested 6 years and over $1,000,000 in dead rent, operations, and build-
out, only to attract about 10 customers per day under the highly restrictive Medical Only setup. Forcing the two
stores to remain Medical-Only will cause over $1,000,000 losses per year and eventual failure.
B) Allowing the current two retail operators to obtain a Type-11 Distributor License is important. Presently, we
are unnecessarily compelled to pay and use third-party distributors at considerable costs (typically charge 15-
20% of gross value) since we cannot directly receive products from cultivators and other manufacturers of
finished products. Retail operators could save costs by directly purchasing products from cultivation and
manufacturing companies instead of relying on outside distributors. This is an unnecessary cost placed on our
stores.
3. Should the City set a limit to the number of retailers and other uses?
Please let the hard data make this decision, not guesswork. There is currently no justification for having more
stores in Santa Monica. As the sole operator in Santa Monica, in our last full operating week, we only had on
average about 10 customers per day. That is approximately only 1 Customer for every hour of operation. It
would be prudent to wait and assess if the demand for Adult-Use cannabis in Santa Monica exceeds the capacity
of the two existing store operators to handle it. Understanding the actual demand makes more sense than
guessing and subjecting Santa Monica to a time-consuming application and appeals process that took over 8
years from the creation of the ordinance to our opening this year. Having additional stores will not increase the
Santa Monica market demand. We are already seeing very low demand due to the unfair advantages that
neighboring Adult-Use stores and the approximately 30 Adult-Use delivery businesses already servicing the Santa
Monica residents are currently using. It would make no sense to believe that increasing the store count in Santa
Monica would increase the market.
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4. Should only the two medicinal cannabis retailers be allowed to expand into the adult-use market, or
should the City allow new cannabis retailers?
The City needs to permit the two medical-only retailers to convert to Adult Use. If we are forced to remain
medical-only, our business will inevitably shut down. The Medical-Only retail model was established in 2015-
2016 when the entire state of CA was medical-only. Since then, the entire state and neighboring cities have
transitioned to Adult-Use. Every single retail store in the Los Angeles area has an Adult-Use permit. If we are
not allowed to convert to the state-wide industry standard, we will fail.
5. In which areas of the City should cannabis uses be allowed to operate?
We have gone through significant financial hardships, paying above-market rents and spending a substantial
amount of money (over $1,000,000) to reach this point. This was necessary because we were required to find a
location that is not within 600 feet of sensitive areas such as medical treatment centers, parks, or schools, and
it had to be on Wilshire or Santa Monica Blvd. We went through a painstaking process to secure a suitable
location and were forced to accept significantly higher rental rates. Therefore, it would be appropriate to
maintain the current designated areas for cannabis operations.
6. Which land uses, if any, should be recognized as sensitive uses requiring a distance buffer from
cannabis uses beyond state requirements?
The state of California's Department of Cannabis Regulations has already established well-thought-out
guidelines for sensitive areas. Considering that the two store operators have already secured their locations, it
is unclear why the city should invest time and effort in reevaluating this matter unless we specifically request
it. We are already committed to our chosen locations and adhering to the state's requirements.
--
I thought it would be important for CPC Compassion Inc (Local – Santa Monica) give the City Councilmembers
and Staff hard facts as to what is really going on in Santa Monica versus the opinion or hearsay of others. If you
have any additional questions, please feel free to call me directly at 917-657-6011 or email at
howard.keum@calyxpeak.com.
Cc: Tony Kim (Principal Planner Santa Monica), Phil Brock, Christine Parra, Jesse Zwick, Caroline Torosis, Oscar
de la Torre
Many thanks,
Howard Keum
Howard Keum
Co-Founder
Mobile: +1.917.657.6011
Email: howard.keum@calyxpeak.com
www.calyxpeak.com
www.localcannabiscompany.com
DISCLAIMER:
CONFIDENTIAL: This e-mail, including its contents and attachments, if any, are confidential. If you are not the named recipient please
notify the sender and immediately delete it. You may not disseminate, distribute, or forward this e-mail message or disclose its contents
to anybody else.
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Packet Pg. 418 Attachment: Written Comments (5674 : Adult-Use Cannabis Study Session)
From:Paul Song
To:councilmtgitems
Cc:Phil Brock; Christine Parra; Jesse Zwick; Caroline Torosis; Oscar de la Torre; Tony Kim
Subject:Regarding Staff Report 564
Date:Monday, June 12, 2023 9:25:37 PM
EXTERNAL
Dear City Councilmembers,
I am writing to you as the President of CPC Compassion Inc, also known as
Local Cannabis, located at 925 Wilshire Blvd. Today, I would like to provide
essential insights into the operations of Santa Monica's first functional
dispensary. My comments are in reference to Staff Report 5674 (Adult Use
Cannabis Study) for Agenda item 7A of the upcoming June 23, 2023
meeting.
Despite being awarded one of two licenses (based on the overall merit and
quality of our application) many years ago, our opening was significantly
delayed due to unsuccessful appeals by disgruntled applicants and a very
difficult overall permitting/inspection process. As a result, we have invested
over $1,200,000 in operational costs and rent over the past six years while
adhering to the ordinances established during that time.
As a Medical-Only store, our establishment is experiencing a significant
disadvantage compared to over 100 nearby Adult-Use delivery and
storefronts in neighboring districts. These businesses are not bound by the
same restrictions that compel our customers to obtain a medical
recommendation card. This requirement is not only costly and time-
consuming but also out of sync with current cannabis regulations in
California. However, under the Medical-Only platform, our business is on
the brink of failure. In the past week, we have averaged just 10 customers
per day, which is clearly unsustainable.
A concerning trend we have observed is that approximately 80-90% of
customers who walk into our store leave upon discovering that we are
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Medical-Only. This means that a significant portion of Santa Monica's local
sales revenue is now flowing to businesses located outside of our city. We
are witnessing the redirection of revenues and tax dollars to neighborhoods
that have no connection to Santa Monica, depriving our community of
much-needed economic support.
Additionally, I would like to address the potential consideration of allowing
additional cannabis stores in Santa Monica. I strongly advise against
speculation or assumptions about the market and instead encourage the use
of factual evidence. As previously mentioned, our store currently serves an
average of 10 customers per day. Based on this data, there is no justifiable
reason to approve more stores in Santa Monica until concrete facts indicate
otherwise.
I implore the City of Santa Monica to base its decisions on objective facts
and data. It is crucial to ensure fairness and equal treatment for all cannabis
businesses operating within our jurisdiction. By doing so, we can foster an
environment that supports evidence-based decision making, promoting the
success and sustainability of local businesses while maximizing revenue and
tax benefits for our community.
Thank you for your attention to this matter. I trust that you will consider the
issues raised and take the necessary actions to rectify the disparities faced by
Medical-Only establishments like ours. Your commitment to informed
decision making will undoubtedly contribute to the progress and prosperity
of Santa Monica.
Thank you,
Paul Y. Song
Santa Monica Resident
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Packet Pg. 420 Attachment: Written Comments (5674 : Adult-Use Cannabis Study Session)
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Packet Pg. 421 Attachment: Written Comments (5674 : Adult-Use Cannabis Study Session)
From:Paul Greaney
To:councilmtgitems
Subject:Cannabis Dispensaries
Date:Tuesday, June 13, 2023 6:42:22 AM
EXTERNAL
Dar City Councilmembers,
As a concerned resident of Santa Monica, I would like to share my thoughts regarding Agenda Item
7A (Adult Use Cannabis Study) scheduled for the June 13th, 2023 meeting.
Firstly, I believe it is crucial for Santa Monica to catch up with the times. There seems to be no valid
reason why the two existing stores should not be allowed to convert to Adult-Use. By enabling this
conversion, we can align our city's cannabis regulations with the modern standards upheld by other
nearby jurisdictions.
Furthermore, I would like to draw attention to the potential consequences of adding more stores at
this stage. I have personally observed the sluggish business activity at the store located at 925
Wilshire Blvd (Local Cannabis), where the customer flow appears to be minimal. In light of this
observation, I urge caution in contemplating the approval of new dispensaries. It is essential that we
first gauge the success and demand generated by the current Adult-Use conversion before making
any decisions about further expansion.
I strongly advocate for Santa Monica to transition to Adult-Use cannabis sales. Only by doing so can
we accurately assess the market demand and gauge the level of activity it will generate. It is
imperative that we base our decisions on factual data rather than speculation when considering the
addition of more dispensaries.
Thank you for your attention to this matter, and I urge you to take my comments into serious
consideration. Let us ensure that Santa Monica remains competitive and responsive to the needs of
our community.
Paul Greaney
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