Cathedral City City Council
September 24, 2025

INTRODUCTION
With the majority of United States and the District of Columbia having legalized recreational and/or medicinal cannabis, a significant problem has emerged in several regions related to the mitigation, regulation, and assessment of the odor generated by cannabis cultivation and processing activities.

This issue is complicated as odors are subjective, and the nature and composition of cannabis odor is highly variable. In addition, different societies have inherently different levels of acceptance for odors in their communities. Regulators at the state, regional, and local levels are attempting to deal with these complex issues through a combination of permitting, land use, and nuisance rules. The cannabis odor situation in Cathedral City is no different, and currently, the municipality is working to find a balance between responsible cannabis cultivation and impacted citizens.

It is estimated that 70% to 80% of the complaints issued to regulatory agencies concerning air pollution involve an odor component (Leonardos, 1996; Nicell, 2009; Shusterman, 1992). Odor is not regulated as a pollutant by the Clean Air Act; however, may be regulated at the state or local level through various types of “odor law,” whether it is called an ordinance, rule, regulation, or policy. “Odor laws” address community odor issues in several ways and methods that utilize various criteria:
1) Annoyance (subjective categories),
2) Complaint criteria (numbers of complaints),
3) Ambient odor concentration/detection threshold (various methods), 4) Ambient odor intensity (analytical testing),
5) Ambient odorant criteria (i.e. chemical surrogate),
6) Episode duration-frequency criteria (“odor-hours”).
7) Source emission criteria (chemical surrogate at source), and 8) Best available control technology criteria (i.e. industry standard).

In the absence of "odor laws," citizens and communities often find remedies and relief in basic common-law nuisance lawsuits. Due to this regulatory approach, sources of odors may face complex permitting scenarios when addressing potential offsite odors/impacts.

SCS Engineers (SCS) has drafted this document for the City of Cathedral City (City) for the purposes of the development and implementation of effective cannabis odor control strategies. This report intends to provide guidance to City regulators regarding the current state of understanding relative to cannabis odor emissions, methods for assessing cannabis odors, and to provide guidance for regulators in establishing odor rules and permitting guidance relative to cannabis cultivation operations.

Cathedral City – Regulatory Review - Cannabis Odor Control

REGULATORY REVIEW AND BEST PRACTICES ASSESSMENT
Regulatory Review Summary
Background
Cathedral City (City) is the home to a growing cannabis industry totaling over 100 active licenses. The City’s current code outlines a general expectation that odors not be detectable beyond the cannabis business, but it fails to include the permitting, review, and enforcement standards necessary to uphold and verify compliance with City expectations. There are no required odor abatement plans, third-party reviews, regular inspections, or performance testing, making it difficult for the City to hold operators accountable when odors persist. In response, the City conducted an internal review of the current cannabis processes and regulations that revealed the need for a formal odor abatement plan, defined performance standards, and objective enforcement tools. These findings led to the initiation of a cannabis moratorium.

Research Process
On February 26, 2025, the City Council extended the cannabis moratorium by 10 months and 15 days. City staff initiated a review of 84 California cities and counties permitting cannabis cultivation that was later narrowed down to 15 cities and 3 counties that provided insight into one or more of the focus areas included zoning, odor control, licensing, and enforcement.

The research focused on how different cities handled issues like permitting, zoning and separational requirements, operational limits, odor definitions, mitigation requirements, enforcement, and response to complaints. The City also initiated a records request with the Department of Cannabis Control (DCC) to assess how many large-scale indoor cannabis cultivation facilities existed statewide.

DCC research identified six licensed large-scale indoor cultivation facilities (≥ 22,000 SF canopy), which are smaller than Cathedral City’s 200,000+ square foot C4 Industry facility.

Findings
The City’s research focused on Palm Springs, Desert Hot Springs, Coachella, and local communities within the Coachella Valley for better understanding of how each jurisdiction manages cannabisrelated odor issues to support the development of a clear, enforceable cannabis odor control permitting process for the City that aligns with the best practices across California. Findings can be summarized into the following categories:

Zoning Requirements
Most jurisdictions permit cultivation, manufacturing, and testing only in industrial zones and have allowed dispensaries in both industrial and retail areas. The common zoning practices among these cities minimize cannabis-odor impacts by maintaining a zoning buffer requirement between cannabis operations and residential or sensitive land use areas such schools and daycares. Research confirmed that the City is an outlier by allowing cultivation and manufacturing in commercial zones, increasing the potential for odor complaints and conflict with neighboring zones.

Cathedral City – Regulatory Review - Cannabis Odor Control

Separation Requirements
Standard separation buffers vary across jurisdictions. For example, State law mandates 600 feet from schools/daycares/youth centers but local jurisdictions, such as Palm Springs (1,000 ft from residential), Palm Desert (1,500 ft between retailers), Long Beach (1,000 ft between dispensaries), and Grover Beach (100 ft from residential) implement stricter standards. The City does not enforce specific buffer distances between cannabis businesses and residential properties or between cannabis businesses themselves, beyond what is required by state law. The lack of the City’s separation standards enables cannabis businesses to operate closer to homes and sensitive land use areas as well as potentially create cumulative impact odor events.

Odor Control Standards
The City Code requires cannabis businesses to prevent odors from being detectable outside, but there is no requirement to submit odor abatement plans, no standard equipment guidelines, and no formal review of systems before or after installation. Most cities require cannabis businesses to install odor mitigation systems such as air filtration or negative pressure systems. Palm Springs, Coachella, and Desert Hot Springs require businesses to submit odor abatement plans, typically prepared by licensed professional engineers or certified industrial hygienists. Adopting an odor abatement standard like other cities would allow the City to have systems that are well-designed and effective.

Odor Definition
The City relies on a general nuisance definition, with odors considered a violation after three verified complaints or if observed by City staff. There are no objective tools or thresholds for measuring odor within the City ordinance. Cannabis odor is not defined precisely in most cities, but Palm Springs and Coachella use threshold-based standards involving olfactometers. Coachella also defines “odor threshold concentration” using standards from the American Society for Testing and Materials (ASTM). The Nasal Ranger is used in El Dorado and Santa Barbara County.

Enforcement & Compliance
The City can respond to complaints but does not require businesses to modify or upgrade systems following a violation. There’s currently no link between confirmed violations and CUP compliance or enforcement actions. Palm Springs uses an escalating fine structure and can revoke permits after repeated noncompliance. Desert Hot Springs authorizes daily fines for violations, while some cities require businesses to respond to complaints within specific timeframes (7–30 days).

Permitting
The City currently does not require odor abatement plans and lacks an inspection process for odor systems. Palm Springs integrates odor plan review into its CUP process with expert validation. Grover Beach requires an annual certification of odor control systems.

SCS recommends an odor abatement plan requirement for all cannabis business licensure, certified by either a Certified Industrial Hygienist or Professional Engineer. Recommendations for the framework of an OAP is outlined in Section 2.2.1.

Cathedral City – Regulatory Review - Cannabis Odor Control

Case Studies & Relevance to the City of Cathedral City
Some cities have odor control expectations written into their codes, but only a few have detailed processes for plan review, inspection, and ongoing compliance. Cities like Palm Springs and Coachella offer structured odor mitigation plan requirements but lack objective enforcement metrics.

Santa Barbara County’s recent code revisions use olfactometers but nevertheless rely on subjective assessments and complaints to drive responsive action.

Cathedral City would benefit from a structured odor mitigation plan and objective enforcement measures given the City is unique in how it permits cannabis in commercial zones and lacks measurable odor standards to highlight regulatory gaps.

Using a performance based standard places the onus on the cannabis operator/business and evaluates the system efficacy with empirical data.

Regulatory Review Summary Conclusion
When City staff compared local cannabis regulations across 15 cities and 3 counties, it was discovered that some jurisdictions have established odor control permitting processes and enforcement models, yet none had adopted objective standards for measuring cannabis odor.

Most cities rely on complaint-driven or subjective assessments, limiting consistency and effectiveness. Other jurisdictions require detailed odor abatement plans as part of the permitting process, along with engineering input and equipment specifications. These gaps highlight why the City needs expert support to create enforceable, measurable standards, outlines for what must be included in odor abatement plans, and develop checklists and procedures for inspection and enforcement.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor Control Plan Development
Odor abatement plans (OAP) contain procedures to reduce odors and include methods for managing odor complaints. The following subsections describe typical OAP contents.

Cannabis Facility Type, Odor Generating Potential & OAP Requirement
The following is a description of the various types of cannabis-related facilities, their potential for nuisance odor generation and whether having an OAP is recommended.

Cultivation Facility: Licensed premises where cannabis is cloned, propagated, grown, harvested, dried, cured, and trimmed. May include nursery (juvenile) and mature plants, or a mix of both.

Cultivation may occur indoors, outdoors, or in mixed-light environments such as greenhouses. This land use encompasses both mature plant production and nursery operations for immature plants or clones, and may involve the use of artificial lighting, environmental controls, and irrigation systems.

This facility type has a high odor generating potential and requires a robust OAP for mitigating odors generated by facility operations with an OAP checklist found in the Appendix E.

Manufacturing Facility: Licensed premises where cannabis is transformed or processed into cannabis products through chemical extraction, infusion, compounding, blending, packaging, or other preparation processes. Products may include pre-rolling, concentrates, edibles, topicals, tinctures, capsules, beverages, or other items intended for commercial sale and consumption. This facility type has a wide range of odor generating potential dependent on the nature of their operations. This type of facility requires a robust OAP for mitigating odors generated by facility operations with an OAP checklist found in the Appendix E.

Consumption Lounge: Licensed commercial establishment where adults may legally purchase and consume cannabis products on the premises in a designated, controlled environment. These lounges may be co-located with a licensed cannabis retailer or operate as standalone businesses, subject to Cathedral City authorization and compliance with state law. This facility type has a high odor generating potential and requires a robust OAP for mitigating odors generated by facility operations with an OAP checklist found in the Appendix E.

Dispensary (Retail Storefront): Licensed commercial establishment where cannabis and cannabis products are sold or delivered directly to adult-use consumers or medical patients. Retail operations may be conducted through a storefront (walk-in sales) and/or non-storefront delivery services, depending on license type and local authorization. Odor potential for this facility type is low-tomoderate, depending on product packaging, quantity and facility operations. An OAP for this facility type is recommended, with an OAP checklist found in the Appendix E.

Testing Laboratory: Licensed, independent facility authorized to receive and analyze cannabis and cannabis products for regulatory compliance. Testing includes, but is not limited to, analysis for potency, residual solvents, pesticides, heavy metals, microbial contaminants, moisture content, and terpene profiles, in accordance with state-mandated laboratory protocols. Odor potential for this facility type is low, and SCS does not recommend the City require an OAP for testing laboratories.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor Abatement Plan Outline
The following is an example outline of an effective and comprehensive odor abatement plan for a cultivation or processing facility. Appendix E includes an Odor Abatement Plan template checklists for five facility types: cultivation/processing, dispensaries (Retail Storefronts), and consumption lounges.
1) Introduction and Source Identification
 Facility Name
 Facility Address / Assessor’s Parcel Number(s) (APN)
 Vicinity & Zoning Map
 Site Map
 Process Flow Diagram
 Description of Operations and Layout
2) Description of Odor Emitting Activities or Processes  Identification of Odor Emitting Activities and Processes  Identification of Odorants
 Material Storage/Waste Generation
 Processes
 Operational Schedules
 Fugitive Sources
3) Description of Methods used for Odor Control
 Administrative Controls
 Engineering Controls
 Process Parameters for Proper Operation
 Maintenance Requirements
 Staff Training
 OAP plan certification by Certified Industrial Hygienist (CIH) or Professional Engineer (PE) 4) Complaint Management Procedures
 Facility Contact Information
 Complaint Management System
 Procedures for Response
 Community Outreach, if applicable
5) Corrective Action Plan, if required
Facility Description and Location
A site-specific odor abatement plan includes a description of the facility and surrounding area. The facility information includes a summary of the property size, location within the regional zoning, descriptions of the surrounding properties and land uses, dimensioned proximity to sensitive receptors, such as residential areas, schools, hospitals, daycares, and other public facilities, descriptions of type of activities taking place onsite, and a general summary of onsite structures. The presence of other potential odor-generating sites in the vicinity of the facility should also be noted.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor-Emitting Sources
The odor abatement plan includes a list of odor generating processes. The following information, where available, for the identified processes is recommended for inclusion. • Description of odor characteristics
• Odor release method (vent, building fugitives, etc.)
• Odor Controls, if any, related to the source
• Location of odor release point/proximity to sensitive neighbors • Operating schedule (continuous, intermittent, seasonal, how many weeks per each stage) Odor Control Strategies and Best Management Practices (BMPs) The odor abatement plan describes the technologies used to mitigate odors from odor generating sources or explains why odor control is not warranted. The Plan includes a description of the odor control technology, a summary of operating and maintenance requirements for proper operation of the odor control system components, and best management practices (BMPs) the facility implements to reduce potential for offsite odor impacts. The submitted OAP shall conform in design with the City’s requested criteria and reflect a design that echoes the regulatory framework requirements.

Complaint Management System
The odor abatement plan includes procedures for responding to odor complaints. This includes identification of site-specific personnel responsible for managing complaints, and a tiered approach for responding to and mitigating complaints. An example of sections that may be included in the complaint management system is provided below.
• Method for Submittal of Complaints
o Phone, Email, Web application
• Roles and Responsibilities of Facility Staff
• Compliance Response Process
o Level 1 Response – Initial Assessment and Corrective Actions o Level 2 Response – Diagnostic Assessment and Corrective Actions o Level 3 Response -- Analytical Assessment and Corrective Actions o Level 4 Response -- Comprehensive Controls Analysis and Corrective Actions • Maintain complaint records for a minimum of five (5) years for historic analysis and data trending.

Cathedral City – Regulatory Review - Cannabis Odor Control

Section 2.0 Summary and Recommendations
• We recommend all cannabis operations submit an Odor Abatement Plan (OAP) as part of the licensing process.
o The OAP should be prepared and certified by a Certified Industrial Hygienist (CIH), Professional Engineer (PE), or otherwise qualified expert. • We recommend the City integrate odor control requirements into the Conditional Use Permit (CUP) process.
o We recommend pre-occupancy inspections and annual re-certification of odor control systems.
• We recommend the City establish clear zoning and separation standards to reduce odor conflicts.
o New cultivation and manufacturing operations should be prohibited in commercial and residential zones.
o Existing facilities in commercial zones should be subject to enhanced odor mitigation requirements to meet no detectable and offensive odor at property line standards by a reasonable person of normal sensitivity. o We recommend implementing separation buffers (e.g., 1,000 feet from residential areas) and 500 ft between licensed businesses. • We recommend adopting objective odor definitions and measurement tools to support enforcement.
o We recommend defining “odor threshold concentration” using ASTM or similar recognized standards.
o We recommend inspectors be trained to detect and differentiate cannabis related odors from other local odor sources for field-based odor assessments by staff. • We recommend cannabis businesses maintain a structured, tiered complaint response process.
o We recommend operators document all complaints and resolutions and provide records to the City upon request.
• We recommend strengthening enforcement mechanisms to maintain compliance. o Fines should escalate with repeated violations or failure to meet OAP requirements.
o We recommend linking OAP compliance to license renewals and CUP conditions.

Cathedral City – Regulatory Review - Cannabis Odor Control

ODOR CONTROL TECHNOLOGY EVALUATION
There are various odor control technologies currently on the market and many others are being vetted for use in odor mitigation from cannabis operations. From enclosed spaces, the technology of choice continues to be scrubbing the effluent point through the use of carbon adsorption technologies and/or oxidation within effluent conveyance prior to release to atmosphere.

Vapor Phase odor neutralizers have been used with some success in cultivation facilities, but this technology has limitations and is generally not received favorably by the public. We recommend that the City prohibit the use of vapor phase systems as an odor control technology for cannabis operations, as these systems have increasingly become a source of community complaints and public opposition.

Carbon adsorption systems with various pretreatment options such as Photo Catalytic Oxidation (PCO) have also been shown to be capable of significantly reducing odor emissions from cultivation and manufacturing. Air scrubbing technologies come with some drawbacks such as a high capital expense to achieve adequate coverage/treatment depending on the method of use, as well as necessitating significant power consumption.

To be effective, odor reduction should be designed specifically to the type of source, facility structure, as well as the chemical composition of the odors. The first step to controlling odor typically requires capturing and transporting the odorous compounds from the source to the chosen odor reduction device. These methods vary based on source and business type.

Capturing odors from cannabis operations will vary depending on facility type. The transportation physics of odors from outdoor cultivation are different from those produced within an enclosed or semi-enclosed space. Similarly, odors and odor generating potential from a cannabis processing facility, where there may be a lot of movement between rooms and the building envelope via doors and HVAC systems, will vary from a retail storefront with sealed and packaged goods.

Odor Control Technologies
To achieve odor control, the chemical nature of the odor compounds can be changed to make them less odorous, the odorous compounds can be removed, or other compounds can be added to neutralize the odor perception character. A brief description of odor control technologies is provided below and additional details, including pros and cons of each, are provided in Table 1.

Change Chemical Structure
Changing the chemical structure of the odorant to a less odorous compound typically requires energy input (heat), an oxidizer, or biological activity to break the bonds between the elements of the odorous compound(s). Below is a list of some common technologies that change the chemical structure of odor compounds.
• Incineration such as combustion in flares or thermal oxidizers convert odorous compounds into carbon dioxide, nitrogen and water.
• Ozone is a powerful oxidant that can break apart odorous molecules through oxidation resulting in less odorous compounds.
• Non-Thermal Plasma uses electrically charged particles (plasma) that interact with odorous compounds and break them apart into less odorous compounds.

Cathedral City – Regulatory Review - Cannabis Odor Control

• Biological Filters use microorganisms that feed off odor-causing compounds to remove the odorant from the stream. The microorganisms biologically metabolize the compound releasing less odorous compounds.
• Photocatalytic Oxidation Photocatalytic oxidation (PCO) is a process that uses light energy to activate a catalyst to break down organic pollutants, bacteria, and viruses into harmless substances. This technology is widely used in air purification, water treatment, and selfcleaning surfaces.

Remove or Filter Odor
Removing or filtering the odor from the stream to be treated reduces the outlet or effluent concentration of odorous compounds. Below is a list of some common technologies that reduce odors through filtration.
• Adsorption captures odorous molecules in the pore space of adsorbent materials, such as activated carbon or zeolite, thus reducing the odors in the process stream. • Chemical/Wet Scrubbers use highly reactive chemicals such as acids, caustics, and surfactants to react with the odorous compounds and remove them from the process stream.

Neutralize or Mask Odor
Neutralizing and masking agents do not reduce or remove odorous compounds but rather alter how the odorous compound is perceived or not perceived by a person. Below is a list of some common technologies that reduce odors through vapor phase or misting systems. • Odor Neutralizers include compounds that adhere to odor molecules and change how the olfactory system recognizes the molecule, thus changing a person’s perception of odor to that stream.
• Masking Agents are similar to perfume in that they contain synthetic fragrance that are intended to “hide” odors. In some situations, the masking agents may bind to olfactory receptors thereby inhibiting the receptor’s ability to bind to odorous molecules.

Dispersion and Dilution
Primary factors that impact the transport of odor from a stationary source include the method of release of the odors, meteorological conditions, and the local topography/location of the facility.

Odors generated in the cannabis industry are emitted through various types of release points including stacks, vessel hatches/vents, and openings in buildings or enclosures, such as doorways and ventilation points. The following characteristics can impact the transport of odor from a release point.
• Odor Emission Rate (Odor Strength): The odor emission rate is a function of the concentration of the odorous stream and the volumetric flow rate of the release. In general, the higher the odor flux, the higher the ground-level odor concentration at a downwind location.
• Release Velocity: The velocity of a release impacts both the distance the odorous molecules travel and the potential for mixing/dilution with ambient air. The faster the release, the further the odors may travel, however, there is more potential for dilution/mixing with ambient air, which can decrease perceived ground-level impacts. In general, the higher the Cathedral City – Regulatory Review - Cannabis Odor Control

exit velocity, the lower the ground-level concentration may be at a downwind location; however, the distance odor can travel may be farther.
• Orientation of Release: The direction/orientation of an odor release impacts the transport of odor from the source. A vertical release provides the greatest potential for mixing and dilution. A horizontal release, such as a ventilation fan on the side of a building, will have limited vertical movement and reduced potential for mixing and dilution. Rain caps and hoods/enclosures around release points can also reduce the vertical movement and mixing of odor releases.
• Release Height: The height of the release will impact the amount of mixing/dilution with ambient air. A higher release point will generally lead to more mixing/dilution of an odorous source, which can decrease perceived ground-level odors. As will be discussed in Section

5.2.1, the release height can also be modified to avoid downwash from buildings, structures, and/or topography.
• Release Temperature: Although not as significant as release height or velocity, the temperature of an odorous source can impact the transport of odor. In general, the hotter the release temperature, the more buoyant the stream will be, which will increase the potential for mixing/dilution with ambient air.

The local meteorology impacts how odors are transported and mixed in the ambient air. Factors such as wind speed and direction and atmospheric stability will impact how odors are transported from a source.
• Wind Speed: Higher wind speed creates more mixing/dilution in the atmosphere and can reduce the potential for downwind odor impacts. Low wind speeds are more likely to create conditions for offsite odors.
• Wind Direction: The direction the wind blows directly impacts where the odorous release will travel. A turbulent condition, with frequent change in wind direction, can promote mixing/dilution of odors.
• Atmospheric Stability: The stability of the atmosphere influences the vertical movement of an emitted stream, which impacts the ability of the stream to mix/dilute with ambient air. In general, stable atmospheric conditions inhibit the vertical mixing of an emitted stream trapping odors close to the ground level and unstable conditions improve mixing and odor dilution.

The following figure depicts how weather affects the shape of an odor plume and the potential for mixing and dilution.

Cathedral City – Regulatory Review - Cannabis Odor Control

Figure 1: Behavior of Odor Plume as Function of Climatic Conditions (Douglas Hamilton, 2019) Stable atmospheric conditions commonly occur in the early morning hours, before sunrise, which is associated with an increase in potential for offsite odors during these periods.

Topography and larger facility structures, such as buildings and process/storage vessels, can alter the movement of wind/air around the facility and create additional surface roughness which can increase turbulence and impact the transport of odor from a source. • Topography: The topography surrounding a stationary source affects local wind patterns and surface roughness which impacts the direction odors are transported and the potential for mixing and dilution. As stated by Hamilton (Douglas Hamilton, 2019) obstacles to wind flow such as hills, trees and buildings increase the roughness of the terrain and, accordingly, the dispersion in the odor plume. Mixing is increased if winds carry the odor upslope or up-valley.

Downslope or down-valley winds lead to less dispersion and tend to concentrate odors in lower lying areas.
• Facility Structures: Similar to topographic features, facility structures alter the flow of wind around a source. As wind blows over/around a building/structure, a low-pressure area develops on the downwind side of the structure which pulls air toward the ground. Odor releases on the downwind side of this building/structure, will be affected and pulled toward the ground causing an increase in ground level odors. Increasing the release height of a source in the vicinity of a building is one method to counteract the effects of building downwash.

Use of Vegetative Buffers:

The use of vegetative buffers can provide several benefits related to the perception of odors downwind from cannabis operations. Vegetative Buffers are plantings of grasses, trees and/or shrubs that are strategically located around an odor source. Vegetative Buffers filter and trap dust, odor, particulate matter, and other molecules from the odor plume.

When used for their Vegetative Bio-Filtering and Windbreak capacities, Vegetative Buffers serve as a means of disruption of the odor plume. This allows heavier odorous molecules and odor-carrying material to settle out in areas of decreased air velocity and ‘dead spots’. Lighter molecules may lift Cathedral City – Regulatory Review - Cannabis Odor Control

up and away. Turbulence allows fresh air from above to mix with odorous air, diluting the concentration of odorous molecules toward or below odor detection thresholds.

Vegetative Filtering Concept – Vegetative Buffers, when used for their Vegetative Bio-Filtering and Windbreak capacities, are plantings of multiple rows of grasses, trees and/or shrubs that are strategically located around cannabis facilities. This active filtering helps to reduce the odor transport and increase dilution.

Visual Screening Concept – Vegetative Buffers, when used for their Visual Screening capacity, are plantings of single or multiple rows of grasses, trees and/or shrubs. Attractive trees and shrubs visually screen cultivation activities and can serve as landscape plants to beautify the facility.

Research concludes that sources judged as “attractive” have fewer odor complaints.

The following tables include an Odor Control Technology Summary in Table 1, explaining how various odor control technologies work, along with the pros and cons of the specific technology.

Table 2 details Odor Control Options Relative to Source Type, including source type, control method, footprint, known vendors, and capital expense.

Section 3.0 Summary and Recommendations
• SCS recommends the City maintain a technology-agnostic, performance-based approach to odor control (consistent with Section 4.1) to encourage innovation, site-specific flexibility, and alignment with evolving industry best practices. • We recommend facilities prioritize design features that enhance natural dispersion and dilution to reduce odor impacts, including:
o Vertical release configurations over horizontal or obstructed vents. o Optimized release height and velocity to promote ambient mixing. o Consideration of local terrain and building downwash effects when siting odor release points.
• SCS recommends operators evaluate the use of vegetative buffers as a supplemental mitigation strategy where feasible.
• We recommend that the City prohibit the use of vapor phase systems as an odor control technology for cannabis operations, as these systems have increasingly become a source of community complaints and public opposition.

Cathedral City – Regulatory Review - Cannabis Odor Control

Table 1 Odor Control Technologies Summary Table
Odor Control
Technology How It Works Pros Cons
Vapor Phase and
Misting Systems
(e.g., Ecosorb)
• Odor neutralizer chemical processes
involved are adsorption, absorption,
gas solubility and reaction:
o Contact: Proprietary chemical
usually consisting of essential
oils is delivered into an area
affected by odors and attracts to
odor molecules.
o Adsorption: Released material
attaches to odor molecules.
o Absorption: Neutralizer
surrounds odor molecules,
potentially neutralizing their
smell.
• Most vendors advertise natural ingredients –
no hazardous materials.
• Variety of application methods (vapor phase,
atomization, additive).
• Technology has been utilized by multiple odor
generating industries.
• On-going costs of the odor
neutralizer.
• Need to select the odor
neutralizer that best reduces
odors.
• If dispersing, need the odor
neutralizer plume to intersect
the odor plume.
• Difficult to quantify odor control
benefits.
• An additional emission source of
VOCs.
• The public may be opposed to
this type of control.

Masking Agents Chemicals are sprayed into the air, using synthetic fragrances to "hide" odors.
• Masking agents can come in many scents and
cover a broad range of odors
• They can be used outside facilities so they do
not impact finished goods and can come in
non-hazardous formulas
• Technology has been utilized by multiple odor
generating industries.
• Give an immediate cover to
odors, but the odors eventually
return as the fragrance and odor
molecules separate
• Many use hazardous chemicals
and are delivered by harmful
aerosols
• The relative effectiveness of this
type of technology is
questionable.

Chemical
Scrubbers /
Packed Tower
Wet Scrubber
Odors are combined with highly reactive
chemicals — acids, caustics, oxidizers,
and surfactants within a stack or tower.

The odorous compounds chemically
react with the solution, removing odors.
• Mechanics can be monitored and carefully
controlled.
• Systems are popular: known technology with
standard, “textbook” designs.
• System efficiency not dependent on nozzle
performance.
• Effective removal performance at high odor
concentrations.
• Expensive to build; must be
operated by trained personnel
and serviced in protective gear.
• Must be designed for a specific
application, with careful
considerations for dangerous
exhaust gas.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor Control
Technology How It Works Pros Cons
• Economically treats large volumes of air
• Relatively small footprint.
• Chemicals used are considered
reactive, hazardous, and must
be neutralized before disposal.
• Requires periodic cleanings.
• Relatively tall which may create
aesthetic issues.
• Requires efficient collection of
fugitive odors to be effective.

Adsorption
(Carbon Filters)
Gas particles from the air penetrate the
pores of an adsorbent material –
activated carbon, zeolite, or silica gel –
and removes odors from the air as it
passes through.
• Carbon is porous and has a large surface area,
which allows it to absorb odors in the air.
• Activated Carbon is a common adsorbent for
organic odor removal.
• Activated Carbon is used to remove sulfur
bearing compounds, aldehydes, and ketones.
• No chemical storage or recirculation pumps
• Simple operation and maintenance.
• Can remove a wider range of compounds than
wet scrubbers.
• Removes VOCs.
• Reversible in nature, which
allows odors to return if heated.
• Spent media disposal can be
messy and expensive, especially
when it contains hazardous
compounds.
• Adsorbents are consumable and
must be re-activated or
replaced.
• As influent odor increases,
carbon bed life expectancy
decreases.
• Systems can lose effectiveness
in highly humid environments.

Ozone
Generators create ozone molecules,
which are highly reactive to organic
material.
• Ozone is a powerful oxidant and anti-microbial.
• Ozone is fairly inexpensive to generate.
• Systems do not require filters.
• Can cause side effects if used
around people; treated areas
must be evacuated while in use
and hours afterward.
• Extremely caustic and could
damage cannabis products or
react to other chemicals in
treatment areas.
• Not effective on inorganic odors.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor Control
Technology How It Works Pros Cons
• Must be utilized within a duct or
stack to protect workers and
plants.

Biological Filters
Contaminated air passes through soil,
compost, wood chips, or other organic
material. As the odorous air flows
through the material, pollutants
(including odor molecules) transfer into a
thin biofilm on its surface.

Microorganisms in the biofilm eliminate
odors.
• Bacteria used are naturally occurring and can
metabolize many organic odor-causing
compounds.
• Works on odors that are biodegradable and
water-soluble.
• Easy to maintain and do not require chemical
addition.
• Can also remove VOCs.
• Large units with massive
footprints are needed to treat
airflow.
• Microbes must interact with the
odorous compounds over long
periods.
• Material must be replaced,
causing odors to go untreated
during downtime. Typical rebuild
is every 3-5 years.
• Installation costs can be
significant
Biological
Oxidation
(Scrubber)
Air is forced upward through an
adsorption column filled with synthetic
material. Water containing
microorganisms circulates through the
system, feeding off odor-causing
compounds and releasing cleaner air.
• These units work well to reduce odors caused
by ketones, alcohols, and ethers.
• Requires lower detention times (8 to 15
seconds for H2S) than bio filters.
• Media can be stacked higher.
• Inert media have a long bed life.
• Reduces potential footprint and requirements
for media replacement.
• Equipment needed to
recirculate water in
bioscrubbers makes for
expensive up-front and
operating costs.
• Requires selection of labdeveloped bacterial strain
specific to odor causing
chemicals.

Thermal &
Catalytic
Converters
The system burns odorous gases, The
gas is passed over (or through) catalytic
materials, converting residual gases into
compounds like carbon dioxide, nitrogen,
and water.
• There has been widespread development for
different catalytic mediums, mainly for
“reduction” and “oxidation” catalysts.
• Can potentially introduce toxins
and noxious substances into the
air.
• Even for well-designed and
operated systems, there is a
need for catalyst saturation and
sterilization.

Cathedral City – Regulatory Review - Cannabis Odor Control

Odor Control
Technology How It Works Pros Cons
Incineration
(Catalytic,
recuperative,
regenerative)
Odor-causing waste and gas are burned
at high temperatures supposedly
destroying process odors.
• Incinerators are one of the most positive and
proven methods for destroying VOCs with
efficiencies up to 99.9999%.
• Recuperative incinerators are usually more
economical than straight thermal incinerators
because they recover about 70% of the waste
heat.
• The incineration process is effective against
organic odors.
• Can also use modified incineration method to
produce Biochar with cannabis waste to reuse
as soil additive.
• High initial cost.
• Supplemental fuel requirement.
• Dangerously high temperatures
— usually around 1472°F
(800°C)— are needed to destroy
odors.
• Potentially introduces toxins and
additional odors into the
atmosphere.
• Additional air is sometimes
required and can cause volatile
gases to be released from the
waste gas.
• Not well suited to streams with
highly variable flow because of
reduced residence time and
poor mixing during increased
flow conditions.
• May not be suited for sulfur
containing compounds due to
formation of highly corrosive
acid gases.

Fabric Filter
(Mechanical
Shaker, PulseJet, Reverse-Air)
Gas is passed through a tightly woven
fabric, causing particulate matter (PM) in
the flue gas to be collected on the fabric
by sieving and other mechanisms.
• High collection efficiencies (95%+) of
particulates.
• Corrosion and rusting are not typical problems.
• Operation is relatively simple.
• Typically, does not require high voltage.
• Available in a large number of configurations.
• Useful for collecting particles with resistivities
either too low or too high for collection with
electrostatic precipitators.
• Potential for flammable dust.
• High temperatures require
special refractory mineral or
metallic fabrics which can be
expensive.
• Relatively high maintenance
requirements (e.g., periodic bag
replacement).
• Fabric life may be shortened at
elevated temperatures and in
the presence of acid or alkaline
particulate or gas constituents.

Cathedral City – Regulatory Review - Cannabis Odor Control

Table 2 Odor Control Options Relative to Source Type
Source Type Control Method Footprint Vendors Effectiveness (%)*Capital Expense High Low Controlled
Stacks (Indoor
Cultivation and
Processing
Facilities, Nonvented
Greenhouses)
Non-Thermal Plasma
Oxidation
Small - Placed on
Stacks IONOX 90% 65% Medium
Regenerative
Catalytic Oxidizers
(RCO)
Anguil 95% 80% High
Bio Filters

Large Footprint

Evoqua 95% 70% Medium
Envirogen 95% 70% Medium
Bio-Scrubber/Bio
Trickling Filter

Vertical Design

Evoqua 95% 70% Medium
Envirogen 95% 70% Medium
Chemical Scrubber
Horizontal or
Vertical Design,
Compact
Valkyrie System by
Streamline 95% 75% Medium
Molecular Filtration -
Carbon

Horizontal or
Vertical Design,

Carbon Bulk 95% 80% Medium
General Carbon 95% 80% Medium
Camfil 95% 80% Medium
Byers Scientific 95% 80% Medium
Multi Technology
Scrubber Systems
that include TiOx
Horizontal or
vertical Design Envinity Systems 98% 80% Medium
Vapor Phase
Neutralizer or Mask

Small footprint
OMI Not
Available
Not
Available Low
FogCo Not
Available
Not
Available Low
Cathedral City – Regulatory Review - Cannabis Odor Control

Source Type Control Method Footprint Vendors Effectiveness (%)*Capital Expense High Low Byers Scientific Not
Available
Not
Available Low
Vents
(Vented
greenhouses,
indoor
cultivation)
Internal Treatment -
Scrubber Towers Envinity, Camfil 95% 80% Medium
Misters Essential Oils Byers Scientific Not
Available
Not
Available High
Vapor Phase
Essential Oils OMI Not
Available
Not
Available Low
Iodine Based
Solution Fog Co Not Available
Not
Available Low
Fugitive
(All Source
Types)
Misters Small - 6'X6 Multiple Not
Available
Not
Available Low
Vapor Phase
OMI Not
Available
Not
Available Low
Fog Co Not
Available
Not
Available Low
Product
Storage/Waste
Treatment
Additive To Treated Chemical Tanks,
pumps
OMI Not
Available
Not
Available Low
Ph Control Chemical Tanks,
pumps
Various Not
Available
Not
Available Low
Talon Sulfide
Elimination System
Chemical Tanks,
pumps
Streamline Not
Available
Not
Available Low
* Values presented are from manufacturer literature and general research. SCS has not validated all of the listed specifications and ranges presented within cannabis operations.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

ODOR CONTROL PERMITTING PROCESS
Based on our comparative review of odor control permitting programs in peer jurisdictions and our direct experience developing odor abatement plans across the cannabis and broader industrial sectors, SCS recommends that the City adopt a permitting structure that clearly assigns the responsibility for demonstrating effective odor control to the cannabis operator. This approach promotes innovation, introduces accountability, and provides the regulatory flexibility needed to accommodate site-specific conditions. To support this structure, we recommend the following foundational components.

4.0.1 Conditional Use Permit Requirements for Nearby Jurisdictions Below is a concise comparison of Conditional Use Permit (CUP) frameworks across selected Coachella Valley agencies as well as other relevant jurisdictions.

City CUP Requirement Odor Control Specifics Enforcement Palm Springs Mandatory Operating plans, filtration,
inspections Permit suspension/inspection
Desert Hot
Springs Mandatory Detailed odor equipment in CUP, annual renewal Permits revoked if non-compliant Coachella Mandatory Time/place/manner review,
odor part of hearings Local discretion
Palm Desert CUP + regulatory
permit required Filtration implicitly required Standard CUP enforcement Grover Beach Mandatory
Uses County CUP standards,
detailed odor equipment with
annual recertification
Permit/business license suspension
Santa
Barbara Co. Mandatory
Detailed OAP with carbon
scrubber use requirements,
vapor phase / misting ban
Nasal ranger enforcement, penalties,
operational compliance required,
legal precedent for lawsuits
Performance-Based Standards
Rather than mandating specific odor control technologies, SCS recommends a technology and manufacturer agnostic approach where the City adopts a performance-based standard for odor control. This approach allows operators to select and propose systems best suited to their facility design and odor sources. The performance-based standard also provides flexibility for technological innovation as the odor control technology industry continues to evolve rapidly and new systems are tested for efficacy, introduced into the marketplace and system costs vary widely depending on the size and scope of the facility operations. This method also simplifies regulatory enforcement by focusing on measurable outcomes (e.g., verified odor complaints, odor sample testing following system introduction and improvements). Adopted standards should conform with considerations outlined in Section 5.2.

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Standardized Submittal Elements
A standardized submittal checklist has been provided in the appendix to assist in streamlining the permit review process and maintain consistency across applicants. The checklist includes substantial considerations for submittal review for any cannabis facility type. Key insights from OAP reviews include:
• Details on the facility and the supporting operations. • Vicinity and facility maps with proximal sensitive receptors and accurate distances and dimensions.
• Detailed specifications for all odor mitigation equipment, including manufacture make/model, quantity, flow capacities, media types, system configurations and control points.
• A narrative description of the site-specific odor mitigation strategy, explaining how the selected controls address potential odor sources under typical and worst-case conditions. • Maintenance schedules and media replacement intervals, with justification tied to manufacturer recommendations, specs or operational history. • Testing and sampling procedures, if applicable, ensuring system efficacy. • Engineering drawings or system schematics that depict the physical layout of odor control infrastructure within the facility, where odor controls are installed and how they integrate with ventilation systems.

Submittal Requirements
Ensuring technical credibility of the submitted odor abatement plans, the City should establish minimum qualifications for third-party consultants or engineers preparing the plans. This standard improves the quality and defensibility of submitted plans, reducing staff burden and ensuring fair expectations for applicants. Qualifications should include:
• Documented experience in designing or evaluating odor mitigation systems. • Certified Industrial Hygienist (CIH) or Professional Engineer (PE) licensure. • References demonstrating successful implementation or review of odor control system in cannabis or similar industries.

Review & Verification Protocols
SCS recommends the City adopt a formal review and verification process that includes an initial technical review to assess the completeness and adequacy of each OAP submission, including conformance with the checklist requirements and adherence to performance expectations. This process can be documented in internal review guidelines or codified as part of the permit ordinance or conditions of approval.

We also recommend field inspections and/or odor monitoring as needed to verify implementation and effectiveness. Having triggers for plan updates is also important as operational changes, technology upgrades, and/or documented odor complaints suggest underperformance, should also be in place. We recommend technical OAP update and review following any substantive improvements or changes to the facility including:
• Following odor control system modifications or changes in quantity, type, or operational adjustments to system.

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• Following facility improvements, adding or removing processes, site renovations, tenant improvements, or any other activity that alters the odor control system or odor generation at the facility.
• OAPs should be updated and resubmitted reflecting the system/facility changes and indicate that the system functionality continues to address on-site odor control.

Section 4.0 Summary and Recommendations
• We recommend the City adopt a permitting structure that places responsibility for demonstrating effective odor control directly on cannabis operators. • We recommend Conditional Use Permits (CUP) require formal Odor Abatement Plans (OAP) for all cannabis facilities, consistent with regional best practices. • We recommend the City adopt a performance-based odor control standard, rather than mandating specific technologies.
o Operators would be responsible for selecting and implementing odor control systems that meet measurable performance outcomes (e.g., verified odor reduction, complaint thresholds).
o This technology-agnostic approach provides flexibility for innovation and scalability across facility types and sizes.
• We recommend implementing standardized submittal requirements to promote consistency, efficiency, and defensibility in plan reviews. • We recommend the City establish minimum qualifications for third-party consultants preparing OAPs to maintain the integrity of technical evaluation. o We recommend requiring CIH or PE licensure and documented experience with odor mitigation in cannabis or similar industries.
• We recommend the City adopt a formal review and verification process for submitted OAPs.
o Initial technical reviews should assess plan completeness, adequacy, and conformance with City standards.
o We recommend incorporating field inspections and/or odor monitoring to verify proper system installation and initial baseline performance. This can be performed by a third party.
• We recommend establishing clear triggers for OAP updates to reflect operational or facility changes, including:
o Modifications to odor control systems (equipment quantity, type, or settings). o Facility expansions, process changes, tenant improvements, or activities that alter odor generation.
o Updated OAPs should demonstrate continued system effectiveness and alignment with performance-based standards.

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INSPECTION AND VERIFICATION PROTOCOLS
While there is no single molecule that represents “odor” and can be easily targeted or measured in real time, there are a range of identification and measurement tools to objectively identify odors.

Cannabis odor inspections in Cathedral City shall be governed by scientifically grounded procedures that include qualitative odor assessment, quantitative odor measurement, and source identification, using sample collection and dispersion modeling as necessary. These inspections serve as the basis for determining compliance with City regulations, issuing violations, and enforcing corrective actions.

All inspections shall be carried out by City personnel trained in odor verification techniques or qualified third-party assessors approved by the City.

Protocols and Continued Compliance
Inspection Protocols
Section 5.2 below expands on a host of options for monitoring and assessment methods related to odor. General audits and inspections should be done annually, or at a frequency determined by the City, at each facility to align all businesses to the same consistent performance standards, confirm all systems are operating properly, respond to changing conditions, and provide a paper trail of ongoing compliance. In short, compliance checks are used to confirm that operators and their employees are knowledgeable about the odor mitigation strategies they are employing. Appendix B contains an example Audit Form for items necessary to review during site visits. Items pertinent to audits, regardless of business type, include but are not limited to:
• Noting any observations of odors at the facilities property line or at adjacent properties; • Reviewing facility diagrams for completeness:
o Are odor control systems, exhaust points, negative pressure systems, etc labeled on the map/facility diagram?
o Is the map accurate?
• Inspecting each systems performance and identifying opportunities for maintenance such as clearing dust from intakes, replacing loaded filters based on manufacturer’s recommendations, or tightening fittings;
• Checking for leaks in the building envelope.

Demonstration of Compliance
While Audits verify that the systems in place are in operation, performance testing or third-party verifications assess operational effectiveness. Requirements for these depend on cases such as:
• Documentation of inconsistencies or repeat violations in multiple audits; • When discrepancies arise between visual inspections of system conditions and planned controls during an audit;
• After equipment modifications and upgrades, or facility layout changes; • Prior to or immediately after the commission of new equipment or systems.

The frequency of and requirements for internal audits and compliance checks should fall under the management of the facility. We recommend quarterly internal verifications for odor control and air filtration system performance, including required documentation of routine maintenance checklists and filter replacements. The schedule and methods for internal verifications should be included in the facilities OAP. Routine odor monitoring provides facilities with defensible documentation of performance and enables them to demonstrate a proactive approach to odor management and regulatory compliance.

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Enforcement Triggers and Subsequent Process
Regulations should not rely solely on complaints or triggers to elicit action, and odor audits or verifications should occur on a frequency defined by the City; however, verified complaints can drive action, and an example complaint verification, investigative, and corrective action process would look like this:

Stage 1 – Log Complaint Data (and build a Predictive Odor Window) • At a frequency defined by the City, complaint data will be reviewed to gather time-of-day and day-of-week patterns from odor complaints. These will be overlayed with historical wind patterns and weather conditions. This creates a Predictive Odor Window (POW). • With the POW defined, the City will conduct inspections in the POW. This allows the City to conduct targeted inspections as opposed to reactive enforcement, and provides objective verification.
• If staff observations match ongoing complaints during the POW, continue to Stage 2. o Residents and stakeholders generally expect a quick response, so public communications from the City regarding the non-reactive timeframe and benefits of this Predictive Program will be important.

Stage 2 – City Response
• City personnel or a City appointed representative will conduct in-field investigation(s) of odor surrounding the Facility in question using an Odor Assessment method listed in Table 3.

Observations must be documented in a standardized form noting the inspector’s name, location of observation, weather conditions, and time of observation. This method must be consistently utilized once chosen and written into the cannabis ordinance. The window of time during which the in-field investigation takes place must align with the POW’s specified timeframe.
o Based on the June 17, 2025 call with the City, direct olfactory observation is the preferred method of identifying odor and determining compliance with the “No Odor at the facility property line” requirement.
• In the field, investigations will be made downwind of the facility at the property line or 100ft downwind of the building edge, dependent on accessibility. o The detected odor must be characteristic to its distinctive operation. o If odor is NOT detected, the process of investigation for the facility in question, initiated by the complaints that created this specific POW is complete. o If odor IS detected, continue to Stage 3.

Stage 3 – Corrective Action
• The facility in question will be issued a Corrective Action Notice (CAN) by the City within three (3) business days of a failed inspection. The Operator shall submit a Plan of Action within seven (7) calendar days, detailing the problems identified, Corrective Actions to be taken, and establish a timeline for implementation. Corrective actions shall be implemented within three (3) weeks of the original CAN, unless otherwise approved by the City. o Should these deadlines not be met, a fine, as determined by the City, shall be imposed.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

o An example Plan of Action is included in Appendix B.
• Once the mitigation deadline is met, in-field investigations as listed in Stage 2 will be repeated.
o If odor is NOT detected, the process of investigation for the facility in question, initiated by the complaints that created this specific POW is complete. o If odor IS detected, repercussions as determined by the City will be implemented.

Continue to Stage 4.

Stage 4 – Third Party Mitigation
• The Facility in question will consult with, and retain as necessary, a third-party odor consultant at the operator’s expense, to mitigate the nuisance odors by a deadline implemented by the City. This could include, but is not limited to, implementing or revising an Odor Abatement Plan, installing approved Odor Control Technologies as listed in Table 2, conducting odor source identification to directly target and address the source, etc. Chemical surrogates used to measure odor in real time, as listed in Table 4, could also be implemented by the Facility in this Stage as a preventative measure or as a measure of defensibility.
o Qualifications for the third party must meet minimum levels of competence. In addition to understanding odor dynamics, examples of competencies may include, but are not limited to:
 Completion of an Odor School program
 Certification as an Industrial Hygienist (CIH)
 Licensure as a Professional Engineer (PE)
o Defensible methods in addressing odor source and receptor perception are listed in Section 5.2.1.
• Once the deadline is met, in-field investigations as listed in Stage 2 will be repeated. o If odor is NOT detected, the process of investigation for the facility in question is complete.
o If odor IS detected, harsher repercussions, as determined by the City, will be implemented. Stage 4 shall be repeated until odor is no longer detected, or until continued noncompliance results in revocation of the license.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Section 5.1 Summary and Recommendations
• Recommended frequency for site Audits are annual
o Audit notes: As a reference point, carbon filters are typically replaced every 3 to 6 months in high load environments but can extend to roughly a year based on specific use. Prefilters are typically replaced monthly. We recommend spot checking scrubbers and referencing maintenance logs to verify. • Building a Predictive Odor Window (POW) and inspecting a facility in that window is recommended in addressing complaints. This is a targeted approach as opposed to reactive and will prevent the City from being first responders. • Screening complaints:
o The City will screen complaints, or contract a third-party complaint management firm, to track and analyze:
 Complainant name and contact
 Exact date and time of odor event
 Location
 Odor character
 Duration
 Strength (faint, moderate, strong)
 Meteorological data (if available)
• We recommend the inspector take precise notes. Observations should occur downwind of the Facility in question. If observed odors are upwind, odor could be attributed to other operations. The precise location is vital in collecting complaint information; the address alone is not sufficient.
• We recommend the inspector to have a handheld anemometer to detail wind conditions during inspections.
• We recommend inspectors come equipped with a filtered mask, to avoid “nose fatigue” or “nose blindness”. They should wear the mask in between observations and take necessary breaks.
• In areas with a dense concentration of cannabis operations where odor is detected at the property line, the burden should shift to the operator to demonstrate compliance (e.g. maintenance records, odor control data). We recommend operators have wind sensors onsite to provide supplementary data.
• We recommend incremental increases in fines should proper documentation not be submitted to the City or deadlines are not met.
• We recommend the enforcement language be changed to be more flexible, e.g. “No operator shall cause or allow the release of cannabis-related odors beyond the property line of their facility that are detectable and offensive to a reasonable person of normal sensitivity, as determined by the City.”
• We recommend the City schedule the follow-up inspection within 30 days after the Corrective Actions have been implemented.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Odor Identification and Monitoring
The below sections are listed for informative purposes for the City, while responsibility to carry these out should fall under the facility and their chosen third-party consultants.

Odor Source Identification
To confirm the source of detected odors, SCS recommends that all facilities engaged in cultivation, manufacturing, or processing install and maintain an onsite Meteorological (MET) system capable of recording wind direction and wind speed. Retail and distribution facilities should be exempt from this requirement due to their significantly lower odor mitigation needs; however, if an inspection is failed, operators may be required to install and maintain an onsite MET system at the City’s discretion. MET sensors must be calibrated at least annually, and all collected data shall be archived and accessible for a minimum of two years.

Real-time and historical MET data in conjunction with operational logs and complaint timing will be used to assess source attribution. In areas with multiple cannabis operators, facility-specific odor logs and equipment performance records may be used to differentiate responsibility.

Below is a list of typical information compiled for identified odor sources:
• Location
o Coordinates
o Proximity to buildings/structures
• Release height
• Release dimensions
o Surface area/diameter
o Velocity or flowrate
o Temperature and pressure
o Release configuration details (rain cap, horizontal release, partial enclosure…) • Operating schedule (by hour)
o Continuous, hourly fluctuations, seasonal fluctuations, etc.

Sample Collection and Analysis
When field inspections do not produce conclusive results or are subject to dispute, the City may require air sample collection. Tedlar bags are typically recommended for collection due to their effectiveness in preserving volatile organic compounds and sulfur compounds associated with cannabis odor. Samples shall be analyzed using ASTM E679 and ASTM E544 by an accredited laboratory, or by using the European Standard EN 13725. For analysis via all methods, samples should be analyzed within 36-hours of collection for sample integrity.

Air samples shall be collected at the facility boundary and, where applicable, from ridge vent or effluent locations during periods of anticipated maximum odor generation. Sampling should be scheduled based on production cycles, meteorological forecasts, and historical complaint data to capture peak emission periods. All samples must be collected while the facility is operating under normal conditions and in accordance with standard operating procedures to present representative results.

During onsite sample collection, additional data that may be collected that can assist in the odor assessment are below:

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• Meteorological conditions during sample collection: wind direction, speed, atmospheric condition, precipitation
• Operating conditions during sample collection: what equipment is operating, operating throughputs, equipment condition (obvious issues)
• Ambient upwind and downwind samples for odor analysis • Measurements/analysis of potential odor surrogates, such as Total Reduced Sulfurs.

Odor Emission Rate
In cases of repeated violations or where corrective action plans are incomplete or disputed, the City may mandate source testing of odor emission rates.

The odor emission rate, source strength, is calculated for the identified odor sources by multiplying the odor concentration by the volumetric flow rate (in units of m3/s) of the release point. Volumetric flow rate for a point source (e.g., stack or vent) is:
• Calculated by the product of the air velocity in the stack/vent/duct and the cross-sectional area; or
• Obtained from equipment specifications, source testing reports, permit applications, or other documentation.

Volumetric flow rate for a non-point source (e.g., fugitive emissions) is estimated using engineering calculations, air velocity meters, and/or advanced measurement techniques such as a sampling hood (flux chamber).

Odor Dispersion Modeling
An atmospheric dispersion model is used to estimate off-site odor concentrations resulting from the source(s) identified from facility operations. The American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) is an often-used model by regulators, environmental consultants, and professionals for this type of modeling. Required input data for AERMOD includes:
• Odor source parameters (i.e., emission rate, dimensions, flowrate, temperature, pressure) • Odor source operating parameters (continuous, daily limits, seasonal limits, annual limits) • Building downwash parameters (building dimensions and heights) • Meteorological data (upper air and ground level – sources from National Weather Stations) • Terrain data (i.e., National Elevation Dataset terrain data files) • Receptors (locations the model will calculate odor concentration at – user specified) • Model options (specifics on dispersion options selected by user)

5.2.1.3.1 Model Results
AERMOD estimates the maximum odor concentration (D/T value) for the receptors (locations) included in the model. The model can be configured to output combined impacts from a facility as well as the odor impacts from individual onsite sources. The peak offsite odor concentration can be identified and then compared to an appropriate nuisance odor threshold for the region. For example, odors may be classified as a nuisance at or above 7 D/T. In addition, the modeling results can be processed into odor concentration contours that are overlaid onto aerial maps of the study region.

These contours help identify any offsite areas where estimated impacts exceeded the applicable nuisance odor threshold. If the predicted off-site impacts exceed the nuisance odor threshold selected, then additional modeling runs can be performed to identify the sources driving the results Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

as well as the amount of mitigation (i.e., reduction in odor emission rates) for predicted impacts to be below the nuisance odor threshold.

5.2.1.3.2 Model Limitations
A limitation and challenge when using air dispersion models to estimate odor impacts is the time and space resolution the model is based on (Nicola Pettarin, 2015). The smallest increment of time typical air dispersion models calculate results on is one hour, while it takes a few seconds for a person to inhale and perceive an odor. This is a large discrepancy between what the model will estimate and what a person may perceive. Furthermore, a modeled hourly average will not mimic a short-term increase in odors from a source, such as unloading a mature cannabis flower delivery over a 10-minute period. During the 10 minutes of unloading, there can be an increase in odors from the activity that will not be seen in the model results.

Odor Monitoring Options
Odors are a perception experienced when chemicals come into contact with odor receptors on olfactory nerves. This perception is quantified using an odor detection threshold defined as the theoretical minimum concentration that incites an olfactory response or sensation (defining 1 odor unit, or 1 OU), and varies by population based on the below factors. Whether an odor is perceived as a nuisance depends on those factors, and sets the framework for criteria that can be used to assess odor impacts in the field and supports consistent decision-making in enforcement • Odor quality: odor results stemming from a pure compound tend to have a higher threshold (less offensive) than a mixture of compounds.
• Odor frequency, timing, and duration: when and how an odor is perceived within a community affects the annoyance and offensiveness of the odor. • Population Sensitivity: individuals have a range of sensitivity to odors. This is affected by past experiences and previous exposures, as well as individual association with the odor. Some of the population may find certain odors pleasant, while other members of the population may find them offensive. This factor appears to be especially true relative to cannabis odor. • Background Level: background odors can affect the degree to which a specific source contributes to a cumulative impact.
• Public Expectation: the relative level of community tolerance to an odor. For example, farming communities may consider a background level of odor to not be offensive even at high concentrations while residents of other communities find the same odors offensive even at low concentrations.
• Source Characteristic: how the odors are emitted is an important factor. Controlling odors from a point source is significantly easier to control than odors from an area or diffusive source.

It’s important to note that the odor detection threshold (DT) is lower than the recognition threshold (RT). The recognition threshold is the point at which the panelist(s) recognize the character of the odor. In addition, the annoyance threshold is higher than the recognition threshold.

Odor perception varies among individuals and direct assessment of odor perception relies on human olfactometry for determination of odor impacts. Increasing the number of humans and observations helps to normalize variations in individual odor perceptions. Known methods of quantifying and measuring odor are limited; and each method is associated with a series of pros and cons related to use case, quantification, and cost. Methods of assessing odors vary between those that utilize human perception or chemical surrogates. This section will go into depth on each. Brief summary tables for each category are provided below.

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Qualitative Assessment
Qualitative odor assessments involve evaluation by trained personnel in response to public complaints or as part of scheduled inspections. These inspections rely on the perception of cannabis odor character at a facility property line or adjacent building/facility. An inspection may be triggered by verified odor complaints from separate individuals within a set period.

Complaints will be cross-referenced with meteorological (MET) data to verify alignment with wind direction and facility operations at the time of the reported incident. Inspections initiated from complaints will only proceed when the complaint’s timing and location are consistent with MET data and there are enough complaints to meet critical volume to develop a POW.

Inspectors must identify if cannabis odor is perceptible at the facility property line, provide a value on a scale from 1-5 on the odor intensity, describe the odor character using consistent terminology, record wind and atmospheric conditions, and confirm that the facility was operational at the time of the incident. Observations must be documented in writing and supplemented with photographs and site sketches where applicable.

Quantitative Assessment
Quantitative assessments may use calibrated field olfactometers or odor panels to measure odor concentration. This determination must be supported by sensory descriptors and MET data alignment with facility operations. Measurements must be taken under stable wind conditions of at least 1.5 miles per hour. All data, including odor character, D/T values, GPS locations, and meteorological readings, must be recorded.

Odor Assessment via Human Perception
A summary of the methods odor can be perceived/measured is provided in the table below with further details in the following sections.

Table 3 Summary of Odor Perception Methods Via Humans
Odor Perception
Method:

Measurement
Units:

Benefits: Limitations:

Direct
Observation
None, Scale of
odor
Perception (i.e.
1-5)
Inexpensive, Observations
can be made anywhere a
human can be present.

Objective, qualitative only,
significant potential for bias.

Field
Olfactometer
Dilutions to
Threshold
Ratio
Relatively inexpensive, field
deployable, somewhat
quantitative.

Limited quantitate value,
requires trained personnel,
subject to bias, olfactory
conditioning probable, does
not determine source of odor.

Odor Panel
(ASTM Method)
Dilutions to
Threshold
Ratio,
Intensity,
Character
Highly quantitative,
panelists are unbiased,
panelists do not know
source type or location,
Vetted American Society of
Testing and Measurements
Method (ASTM).

Repeatable and proven.

Logistically constraining as
odor panel needs to be
reserved in advance of
measurements, samples
should be analyzed soon
(within 30 hours) after
sampling. Observations are
conservative (higher) than
that of general population.

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Can be expensive if large # of
sampling points and/or times
are necessary.

Direct Observation
No methods currently are available that appropriately simulate or quantify complex odors. Thus, it is difficult to predict human responses to exposures of chemical mixtures. The human nose is, to this day, the most suitable ‘sensor’. There is currently no substitute for assessing odor perception of complex sources than direct human perception. Direct Observation, however, is highly subjective. An individual is subject to biases such as background odor, familiar odors, or simply being an individual with either a heightened or decreased sensitivity to smell, among other biases. Additionally, these observations are only qualitative and do not provide a quantitative measurement that is repeatable.

Field Olfactometers
Olfactometers, invented over a century ago, operate on the principle of diluting odors. The amount of dilution required to reduce an odor sample below detection represents the strength of an odor.

The Nasal Ranger® and Scentometer are specific types of olfactometers commonly used by regulators for field assessments. They are portable odor measuring device that combines odor detection with odor quantification. Odor quantification is determined by the Dilutions-to-Threshold ratio, or D/T. This ratio is a measure of the volume of carbon-filtered air needed to make a volume of odorous ambient air non-detectable. Users must breathe through the device at a flow rate of 16 – 20 liters per minute (LPM) when using the device. Users of the Field Olfactometers must be trained and certified via a specific training course provided by their respective manufacturers.

Field use examples include:

1. On-site monitoring—for monitoring of various on-site procedures and operations,

2. Random monitoring—for monitoring correlating with meteorological information and on-site activities,

3. Intensive odor surveying—for determining sources and operations that cause odor,

4. Citizen monitoring,

5. Complaint response

6. Permit compliance, and

7. Plume profiling.

While field olfactometers are portable and offer multiple field use examples, there are some biases inherent to this method that are not present in olfactometry performed through the use of an odor panel. Because field olfactometers are deployed and used in the field, the operator is subject to field conditions and has already biased himself, his nose, and olfactory senses with the ambient air on location. In many cases, the human nose can become accustomed to an odor after a period of exposure and become “nose-blind” to the odor(s) under evaluation. Thus, using the Nasal Ranger® or field Scentometer to determine in-field D/T can have a low bias on the results.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Figure 2: Examples of Field Olfactometers (Nasal Ranger, Facial Mask, Box Scentometer) Odor Panel
Using an odor panel on the other hand, removes the field environment bias seen with usage of the Nasal Ranger®. This method uses a stationary olfactometer that operates on the same principle as the Nasal Ranger®. Olfactometers generally have four (4) to six (6) stations for human panelists.

Each station is equipped with two (2) to three (3) sniff ports. One (1) random sniff port produces a stream of diluted odorous sample air, while the other port(s) produce a stream of pure air. Ideally, stationary olfactometers are located in an odor-free room, where panelists are asked to determine which port contains the odorous air. The dilution at which at least half the panel correctly and confidently identifies the correct port determines the D/T measurement of that sample of air. This is an objective method developed to establish odor concentration using human assessors.

The major constraint to this method is logistics. Generally, panels need to be booked in advance, and they can only handle a certain quantity of odor samples due to both time and panelist fatigue.

Additionally, odor samples have a holding time of 36 hours, so samples must be shipped to the odor lab via overnight courier, which can be costly.

Odor Assessment via Chemical surrogate
A summary of methods to assess odor through chemical surrogates is provided in the table below with further details in the following sections.

Table 4 Summary of Odor Assessment Via Chemical Surrogate Analytical
Measurement
Measurement
Units:

Benefits: Limitations:

Time Averaged
Samples with
follow-up Analysis
via Analytical
Laboratory
Dependent on
Method
Many compounds can be
detected to ppb level
accuracy.

Costs are per sample and can
be expensive. The sample only
represents the time and
location the sample was
collected. Field labor
dependent and requires
sampling expertise. No single
analytical method will cover all
odor causing emissions.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Analytical
Measurement
Measurement
Units:

Benefits: Limitations:

Total VOC
Detection w/
Photoionization
Detectors (PID)
Parts per billion Inexpensive analyzer
measures for total VOCs.

Fast response time and is
capable of real-time
measurements
Does not differentiate between
VOCs, Calibrated based on
single VOC that may be very
different from compounds of
interest. Responds to VOCs that
can exist in high background
concentrations. Many VOCs are
not significant contributors to
odors.

Field Deployable
GC w/ Various
Detectors
Parts per billion Accurately identifies and
quantifies concentrations of
multiple target compounds.

Can collect and measure
samples every 10 minutes
depending on the specific
compounds of interest. Can
be adapted to measure at
multiple sampling locations.

Limited detection to
compounds of similar retention
times under current
configuration. Calibration
standards are field-generated
or need to be created by
certified labs relative to the
compounds of interest. GC
system set up for terpene
analysis currently do not detect
any organosulfur compounds of
interest. The concentration of
measured VOCs relative to odor
concentration is not always
suitably correlated.

Electronic Noses
(electrochemical
sensors)
10-100 Parts
per billion
Measures multiple chemical
constituents that are known
to be odiferous
May not be able to detect all
the compounds emitted by
source known to be part of the
odor profile. Limited to specific
parameters and sensor types.

Total Reduced
Sulfurs (TRS)
Parts per billion Proven real-time surrogate
for odor concentration
Only works in high odor load
areas. Capability is severely
diminished outdoors.

Analytical Lab Analysis
There are a limited number of accepted standardized analytical methods performed by accredited laboratories for some compounds that are known to be odiferous. These methods include sample collection procedures, sample handling, as well as analytical methods specific to compounds or classes of compounds. Sulfonated compounds using ASTM D-5524 and certain Volatile Organic Compounds (VOCs) using EPA T0-15 are examples. With these methods, each sample can be tested for multiple compounds and down to a relatively low detection limit. This is important as many odiferous compounds have very low odor detection thresholds. It’s important that the sample collection and analytical method are compatible with the odor detection threshold of the target compound(s). However, each sample is only representative of a snapshot in time, and doesn’t show real-time or immediate results. Conducting the field sampling requires training, and each individual sample has an associated cost.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Photoionization Detectors (PID)
PIDs are field measurement tools that detect VOCs. They produce real-time readings and are generally used during first responses for many use cases, such as detecting a potential leak in the system or qualitative assessment of the presence of VOCs. However, while they are fast responding and can detect multiple VOCs, they cannot speciate and differentiate the compounds detected from each other. This may be ineffective in cases where there are multiple background compounds present.

Portable Gas Chromatograph (GC)
Portable Gas Chromatographs (GC) can be deployed in the field to speciate VOCs. However, while this method can identify and quantify individual VOCs, there are limitations to this method. GCs can only quantify predetermined, thermally stable compounds. Compounds with similar retention times can also be measured which leads to co-elution and potential interferents. Additionally, the VOCs identified may or may not be contributors to the odor profile. This method may not be real-time, but readings can be generated in field, and samples can be collected and analyzed roughly every 10 minutes. This method provides a middle ground between real-time sampling and discrete grab samples.

Electronic Nose
The Electronic Nose (e-Nose), is a type of electrochemical device that uses sensors that generate signal patterns to characterize odors. These sensors detect and react to different molecules which create response patterns due to changes in electrical properties that are then interpreted and analyzed. Most e-Noses use chemical sensor arrays that react to volatile compounds on contact, and the adsorption of these compounds causes a physical change of the sensor, which is then translated by the electronic interface into a digital value. E-Noses have been used in evaluation of odors related to the food, health, drug, safety, crime, and the environmental and agricultural sectors. However, it should be noted that they do not measure odors directly and that this technology uses chemical surrogates to calculate an odor index. The value an e-Nose can provide is limited to the array of sensors installed and may not correlate well with cannabis emission sources.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

Section 5.2 Summary and Recommendations
• We recommend responsibility for odor source identification and monitoring fall to cannabis operators and their qualified third-party consultants, subject to City oversight. • We recommend facilities engaged in cultivation, manufacturing, or processing install and maintain onsite MET sensors to record wind direction and speed. • We recommend facilities maintain detailed records for identified odor sources. • We recommend the City reserve authority to require air sampling, emissions rate monitoring, or dispersion modeling where field inspections are inconclusive or disputed. • We recommend a tiered response system for verified odor events, with escalating actions based on severity, complaint volume, and facility history, aligned with Section 5.0 recommendations.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com

BIBLIOGRAPHY
A. B. Malnic et al, Cell, 1999, 96, 713
American Industrial Hygiene Association, 2013. Odor Thresholds for Chemicals with Established Health Standards, Second Edition, Falls Church, Virginia: s.n.

Autelitano, F. a. G. F., 2018. Anatical assessment of asphalt odor patterns in hot mix asphalt production. Jornal of Cleaner Production, Volume 172, pp. 1212-1223.

Freemantle, M., 1999. Chemical & Engineering News. [En ligne] Available at: cen.acs.org
Grahn, K. G. P. A. T. L. A. H. T. S. J. a. P. W., 2021. Occupational exposure to particles and increased risk of developing chrominc obstructive pulmonary disease (COPD). A population-based cohort study in Stockholm, Sweden. Environmental Research 200: , p. Article 111739.

Hansen, E., 1991. Mortality of mastic asphalt workers. Scandinavian Journal of Work and Environmental Health 17, pp. 20-24.

IARC, 2013. Bitumens and Bitumen Emissions, and Some N- and S- Heterocyclic Polycyclic Aromatic Hydrocarbons. Volume 103. Lyon, France: s.n.

Jue Li, Y. Q. X. B. S. a. C. L., 2024. Emission Characeristics, Environmental Impacts and Health Rsisks of Volatile Organic Compounds from Asphalt Materials: A State-of-the-Art Review. Energy & Fuels .

Kargar-Shouroki, F. M. M. S. M. S. S. F. M., 2021. Genotoxic effect of exposure to polycyclinc aromatic hydrocarbons (PAHs) in asphalt workers. EXCLI Journal 20, pp. 686-697.

Lange, C. a. M. S.-G., 2005. Quantification of Potentially Odorous Volatile Organic Compounds from Asphalt Binders Using Head-Space Gas Chromatography. ASTM Journal of Testing and Evaluation, March, 33(2), pp. 101-109.

M. Edwards, J. H. R. H., 2020. Odour Management Guidance for Refineries, Brussels: CONCAWE.

NIOSH, 2024. NIOSH Pocket Guide to Chemical Hazards.. [En ligne].

OSHA, 2024. OSHA Occupational Chemical Database. [En ligne] Available at: https://www.osha.gov/chemicaldata/710
Petronaft, 2024. htttps:www.petronaftco.com/oxidized-bitumen. [En ligne].

Wikipedia, 2024. Heterocyclic Compound. [En ligne].

World Health Organization, 2004. Concise International Chemical Assessment Document 59. Aspahlt (Bitumen), Geneva: s.n.

Z. Zhou and L. B. Buck, Science, 2006, 311, 1477
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page A
Appendix A
What is Odor?
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-1
What is Odor?
Odor is a perception and is dependent not only on the relative chemistry and structure of odor molecules, but also on receptor factors such as sex, age, culture, social context, and personal experience. Odor perception is complex as responses to odors are inherently subjective and the nature and composition of odorants can vary greatly. In addition, different societies have varying levels of acceptance for odors in their communities.

Olfactory System
People can discriminate more than 10,000 odors, even though there are only about 400 odor receptors in the nose (Coker, 2013). An odor can generally be perceived if several criteria are met (Govind, 2023).
• There is an odor generating source present,
• The odorant molecule(s) is a volatile compound (VC),
• The odorant’s molecular weight is less than 300 Daltons, • The odorant’s vapor pressure is greater than 0.01 kilopascals (kPA) at 20 °C, and • The odor molecule has moderate-to-high hydrophobicity.

During the respiratory process, when odorous molecules enter the nasal canal, they reach the olfactory epithelium, near the top of each nostril. At this point, the molecules dissolve in the mucus layer covering the epithelium and contact olfactory sensory neurons (millions) which express the odor receptor(s) (~400) (Alila Medical Media, 2021). The combination of activated neurons and odor receptors send signals to the olfactory bulb, where the signal is deciphered and subsequently perceived by the brain as an odor perception. When you have a cold, your sense of smell is diminished because molecules have a harder time reaching the odor receptors. See Figure 1.

Studies on the interactions between
individual odor receptors and multiple
chemical odorants found that:
• An odor receptor can recognize many
odorant molecules, and
• An odorant molecule can bind to and
be detected by multiple odor
receptors.

Through the use of approximately 400
odor receptors in humans, the brain can
differentiate between a large number of
odorants simultaneously. Thus, although
there are only a few hundred active odor
receptors, humans can recognize over
10,000 different odors. This method is
referred to as the “Receptor Code”. The
receptor code is essentially the unique
pattern of activated receptors for a
specific odorant, and this pattern can shift
depending on concentration, leading to different odor perceptions.

Figure -1: Human Olfactometry System (Coker, 2013)
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-2
Chemical Concentration and Mixture Effects
Researchers have found that changes in odorant concentration alter its receptor code in the olfactory system. This explains why, for some chemicals, a substance smells different at different concentrations. As the concentration of an odorant increases, the set of olfactory receptors activated also changes, leading to a different perception of the smell, even for the same odorant molecule.

Additionally, research has shown that some neurons in the olfactory cortex only respond when two odorants are present and not when each component is present on its own, explaining why mixtures can have smells that are not simply the sum of the component molecules (Z. Zhou and L. B.

Buck, Science, 2006, 311, 1477).

Odor Assessment
The relative detectability of odor is a sensory property that refers to the theoretical minimum concentration that incites an olfactory response or sensation. This point is called the odor detection threshold, often referred to through the dilution to threshold ratio (D/T) and defines one odor unit (1 OU). Based on the available literature, the level at which odors are perceived to be a nuisance can range from 2 OU to 10 OU depending on the following variables or factors:
• Odor Quality: odor results stemming from a pure compound tend to have a higher threshold (less offensive) than a mixture of compounds.
• Odor Frequency, Timing, and Duration: when and how an odor is perceived within a community affects the annoyance and offensiveness of the odor. • Population Sensitivity: individuals have a range of sensitivity to odors. This is affected by past experiences and previous exposures as well as individual association with the odor. Some of the population may find certain odors pleasant, which can be found offensive to other members of the population. This factor appears to be especially true relative to cannabis odor.
• Background Level: background odors can affect the degree to which a specific source contributes to a cumulative impact. Due to the saturation density of cannabis cultivation in certain instances this is an important consideration.
• Public Expectation: the relative level of community tolerance to an odor. For example, farming communities may consider a background level of odor to not be offensive even at high concentrations while residents of other communities find the same odors offensive even at low concentrations.
• Source Characteristic: how the odors are emitted is an important factor. Controlling odors from a point source is significantly easier to control than odors from an area or diffusive source.

Odor Detection Threshold
The odor detection threshold (ODT) is the lowest concentration of an odorant that can be detected by a person. The concentration is established through testing conducted on human subjects in a laboratory setting and is commonly listed as the lowest concentration at which at least 50% of test subjects perceive an odor. The lower the detection threshold, the more potent the odor is. For example, hydrogen sulfide (characterized by a rotten egg odor) can be detected at a concentration as low as 0.0005 part per million by volume (ppmv) while carbon dioxide (vegetable, sulfide, medicinal odor) is not detected until a concentration over 39,000 ppmv.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-3
Because sensitivity to odor is subjective and varies from person to person, detection thresholds established for compounds vary and for this reason are frequently listed as a range of concentrations.

Due to the logistical constraints of using certified odor panels, it is not feasible to use odor panel analysis for complaint response. This is because odor panels need to be reserved ahead of time.

Any ordinance that specifies an ambient odor threshold (D/T, DT, RT, "Odor Units", etc.) should also specify the method of measurement as the different measurement methods produce different results. In addition, the effect of background odor concentrations on these measurements needs to be considered, as do the meteorological conditions during an odor event.

Due to the factors above SCS recommends that a Nasal Ranger or similar device be used for compliance monitoring relative to odors. In addition, the following factors should be considered:
1) Assessments of a source’s contribution to downwind odors should include measurements of background and or upwind odor and the differential in the two measurements should be considered as the net increase in odor.
2) SCS recommends a 7 D/T increase as a benchmark for downwind odor impacts if using detection threshold (DT).
3) SCS recommends a 4 D/T increase as a benchmark for downwind odor impacts if using recognition threshold (RT).

Finally, the ordinance should specify the number of observations that need to be made by the inspector and the period from which the observations need to be made. SCS recommends the average of 3 observations collected 5 minutes apart. This will confirm persistent conditions while not implicating sources if only a fleeting odor is detected.

Odor Characterization
Concentration alone does not describe the entire human response to an odor. Various qualitative and quantitative parameters are used to illustrate human perception to odors. A summary of parameters that can be used to further describe odor is provided in Table 1.

Table A-1: Technical parameter definitions used for describing odors Parameter Description
Concentration Odor concentration is quantified by determining the amount of dilution required to bring the odorous air sample to a detection threshold.

Intensity Odor intensity refers to the perceived strength of the odor. A quantitative measurement of intensity requires comparison of the odor to a “standard,” typically n-butanol in odor-free air. The intensity is expressed in terms of micrograms per cubic meter of n-butanol and is related to concentration through a power function.

A qualitative scale can also be used to describe intensity with zero being not perceptible to 6 being extremely strong.

Character Odor character describes what the substance smells like.

Examples of odor character include fishy, hay, nutty, oily, creosote, turpentine, rancid, sewer, sweet, ammonia, skunky, pine, wet grass, burnt hair, etc.

Hedonic Tone
(Offensiveness)
Hedonic tone is a subjective judgment on the relative pleasantness or unpleasantness of an odor.

Hedonic tone can be assessed on a graded scale from -4 (extremely unpleasant) to +4 (extremely pleasant) and 0 being neutral (neither pleasant or unpleasant) Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-4
Cannabis Specific Odor Drivers and Variables
The understanding of the primary cause of the odor, particularly the disagreeable "skunky" odor emitted from cannabis cultivation, and the methods to mitigate it, are rapidly evolving. Just a few years ago, it was a common perception that the main culprit relative to odors from cannabis operations were terpenes. We now know that although terpenes are part of the odor profile, they are not the cause of the unpleasant “skunky” odor character often experienced downwind from cannabis operations. Terpenes are not the main driver of odor concentration downwind from cannabis facilities.

There is interest by several entities to establish an odor detection threshold relative to cannabis odor emission. The idea is to have a molecule or class of molecules, operate as a surrogate for expected odor concentration and thus be used to determine a threshold for which objectionable odors are likely to be perceived by humans. Several factors complicate this consideration:
1) Cannabis, like most plants, has the potential to emit hundreds of different chemicals. Each at various rates, at widely divergent odor detection thresholds, and dependent on several external variables;
2) Emission rates are not constant throughout the cannabis plant life cycle or within the plant’s diurnal cycle;
3) Emission rates are influenced by temperature, exposure to light radiation, degree of agitation, and plant stresses, among other external factors. 4) The ratios of compounds emitted by cannabis are not constant through the plant’s life cycle and the times of highest emission of certain compounds can be decoupled from the emission of other types of compounds.
5) Relative strains of cannabis have different chemical ratios and thus varying odor profiles.

Identifications of Odorous Compounds Emitted by Cannabis When SCS began working with cannabis growers, we were already well-versed in odor investigations relative to landfills, recycling centers, compost facilities, and water treatment plants. SCS was familiar with identifying a facility’s “odor footprint” through the use of ASTM-defined olfactory assessment using odor panels in combination with flux measurements from the sources at these facilities. In addition, the main culprit for objectionable offsite odors is almost always Hydrogen Sulfide (H2S) for these types of facilities and sources. The nature and understanding of these sources have been studied for decades. There is ample understanding of how odor emissions are generated and presently there are significantly researched methods to mitigate odor from these types of sources and facilities, which are more straightforward than for cannabis cultivation.

Initial Tests of Cannabis Emissions
Most analytical labs in the United States are set up to perform standardized test methods for known criteria pollutants or hazardous air pollutants (HAPs). In addition, the common public understanding was that the main source of odors was associated with the terpenoid class of compounds. There was also interest in determining whether cannabis emissions result in concentrations of HAPs that could be a potential health concern. Therefore, initially, SCS focused on Volatile Organic Compounds (VOCs) and terpenoids using standardized methods.

SCS utilized EPA Method TO-15 to assess the concentrations of VOCs that are also considered Hazardous Air Pollutants. SCS also requested tentative identification of a large list of other compounds for which the laboratory doesn’t carry standards but can be identified through chromatography and detection. SCS used non-standardized methods developed by the Desert Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-5
Research Institute (DRI) to identify and quantify concentrations of a large library of terpenoids. Tests were performed in all aspects of cannabis operations including greenhouses, processing areas, drying rooms, and nurseries.

All of the tests showed that concentrations of VOCs and terpenoids were either not detectable or significantly below published health standards regardless of the location of the samples. In addition, the tests identified three terpenes that were present in almost every sample collected relative to a cannabis source. These terpenes were identified as Myrcene, Pinene, and Limonene. Caryophylene and Linalool were also detected in most samples. Tests indicated that emissions from the drying and curing phases of cannabis production were significantly higher than during the cultivation stage.

However, there were significant limitations to these tests:

1. The tests provided data that represented only the period and location from which the samples were collected.

2. The odor character of the measured terpenes does not represent the objectionable “skunky” character attributed to odor issues.

3. The tests were limited to Volatile Organic Carbons and terpenes. Other classes of compounds were not measured.

Identification of Volatile Sulfonated Compound (VSC) Emissions In SCS’s early investigations of cannabis emissions, we speculated that a sulfonated compound or a class of sulfonated compounds was the likely cause of the “skunky” character observed in the vicinity of cannabis operations. To test this theory, SCS performed an experiment.

The experiment entailed the collection of a ½ ounce of wet mature flower from 8 different strains of cannabis collected from multiple farms. SCS fabricated a blender/food processor with a bulkhead fitting at the top for the collection of a headspace sample. SCS then chopped/mixed each flower in the blender individually for 30 seconds. Immediately following the blending, SCS collected a headspace sample from above the blended cannabis. Immediately following sample collection, SCS delivered the samples to Atmospheric Analysis & Consulting, Inc. for analysis via ASTM-D5504. This method analyzes 21 different sulfonated compounds as well as Total Reduced Sulfurs (TRS). The difference between the sum of the detected sulfonated compounds and the TRS indicates the presence of an unidentified sulfur compound. The results of this test confirmed the hypothesis that VSCs were present for multiple strains. Three specific VSCs were identified, Carbonyl Sulfide, Dimethyl Sulfide, and Methyl Mercaptan. In addition, total reduced sulfur was detected in 6 of the 8 strains. The strains that were identified with the largest concentrations of total reduced sulfur were also confirmed to be the “skunkiest” strains based on the observations of cultivators.

Since this time, studies from other cannabis researchers have confirmed the presence of additional VSCs as potential sources of malodors from cannabis. To date, the following VSCs have been identified along with their relative scent character:

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page A-6
VSC Odor Character
• Dimethyl Sulfide: Sulfurous, cabbage
• Carbonyl Sulfide: Sulfurous, cabbage
• Methyl Mercaptan: Rotten cabbage
• 3-Methylthiophene: Fatty, wine-like
• 3-Methyl-2-butene-1-thiol: Intense, sulfurous, skunk-like • 3-methyl-1-(methylthio)-2-butene: Intense, sulfurous, savory • 3-methyl-2-butenyl acetothioate: Intense, sulfurous, skunk-like • bis(3-methyl-2-butenyl) sulfide: Mild, Onion and/or Garlic • bis(3-methyl-2-butenyl) disulfide: Mild, Onion and/or Garlic Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page B
Appendix B
Example Forms
Facility Name & Location
Primary Odor Contact at Facility
Date / Time Complaint Receieved
Complaintant Information
Name
Contact Number
Email
Location of Odor Detected
Odor Type
Strength of Odor (1-10 Scale | 1 = no smell, 10 = overwhelming odor) Odor Direction (What direction was the odor observed to be coming from) Was weather unusual during odor detection event?
Odor character description
Site Conditions & Specifics Related to Odor Complaint
Wind Direction at time (Use MET Data)
Barometric Pressure
Action Taken
Action Taken (Consult Tiered Response)
NOTES:

Person Conducting the Inspection:

Date of Inspection:

Time of Observation :

Wind Direction (at the surveyor's location): N; NE; E; SE; S; SW; W; NW Barometric Pressure:

Measured in HG as recorded at the onsite weather station Intesity:
(S
‐
Strong; M
‐
Medium; Sl
‐
Slight)
Odor Complaint Response Form
Online Odor Complaint Form
Submitting Your Complaint
COMPANY provides several ways of submitting an odor complaint in the community. Feel free to use any of the listed complaint system methods to provide us your submission.

Thank you and we look forward to hearing from you.
 Web Form: complete and submit the interactive form on this page  Call:
 Text:
 Email:

Disclaimer: Information given through our complaint management system will be used solely by COMPANY. Your name and address is secured and no information will be given or sold to any third party.

Title
User Information
First Name
Last Name
Contact
Home Phone
Address
Cell Phone
Apt/Suite #
City
State
Zipcode
Remember my details on this computer for next time
(Not recommended if on a public or shared device)
Contact Preferences
I would like to speak with someone as soon as possible
I am happy to discuss this complaint should there be questions I would like a copy of this complaint sent to my email
Please do not contact me regarding this complaint
Save and Enter Odor Details 
Odor Details
We kindly ask that you provide as much information as possible. Details will help us review and process your submission.

Date
Time
Odor Detection Location
Where did you notice the odor?
Please identity the approximate location where you noticed the odor. (NOT where you think it is coming from)
Click on the map to drop a pin.

This will populate the LAT and LON automatically.

Online Odor Complaint Form
Use my address from the previous user information section Save and Enter Odor Details 
Odor Intensity
Very Faint
Faint
Distinct
Strong
Very Strong
Addition Comment
Please add any additional comments pertaining to your concerns. (Ex. Smells like a sunk or sewage. Smell lasted for several hours.) Odor Description
Ammonia
Burn/Smoke
Sewer/Sewage-like
Chemical/Solvent
Earthy/Moldy/Musty
Fishy
Manure
Decaying Grass
Rotten Egg
Turpentine
Woody
Other – See Notes
(enter notes)
(enter notes)
Save and Submit Odor Complaint 
Online Odor Complaint Form
Cultivation Facility Audit Checklist

INSPECTION ITEM Y N NA NOTES

1. Direct Observation
a. At Property Line ☐ ☐ Intensity:
b. Adjacent to facility structure ☐ ☐ ☐ Intensity:

2. State and local cultivation license
valid ☐ ☐

3. Odor Management Plan (OMP)
a. OMP date:
b. Located onsite ☐ ☐ ☐
c. Up to date ☐ ☐ ☐
d. Employee training record for
odor mitigation procedures
reviewed
☐ ☐ ☐

4. Facility diagram reviewed ☐ ☐ ☐
a. Odor control system located
on map
☐ ☐ ☐
b. Exhaust points located on
map
☐ ☐ ☐
c. Negative pressure system
labeled on map ☐ ☐ ☐
d. ___________ located on map ☐ ☐ ☐

5. Approved odor control system ☐ ☐ ☐ Make/Model:
a. Installed and operational ☐ ☐ ☐
b. Routine inspection
documented (+ take photos) ☐ ☐ ☐ Inspection frequency:
c. Filters clean ☐ ☐ ☐ Replacement frequency:

6. Air filtration units
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:
d. Filters clean ☐ ☐ ☐ Replacement frequency:

7. Ventilation system
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Visible signs of buildup in
ducts or on vents ☐ ☐ ☐
d. Integrated with odor control
system ☐ ☐ ☐
e. Diagrams reviewed ☐ ☐ ☐
f. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:

8. Negative pressure system ☐ ☐ ☐
a. Operational ☐ ☐ ☐

INSPECTION ITEM Y N NA NOTES
b. Documented on facility
diagram ☐ ☐ ☐

9. Cultivation areas ☐ ☐ ☐
a. Enclosed ☐ ☐ ☐
b. Properly sealed ☐ ☐ ☐
c. Floor is clean; product is not
tracked everywhere ☐ ☐ ☐

10. Waste areas ☐ ☐ ☐
a. Enclosed ☐ ☐ ☐
b. Properly sealed ☐ ☐ ☐
c. Cannabis odors observed ☐ ☐ ☐

11. Facility operated odor complaint
management system
a. Available and operational ☐ ☐ ☐
b. Documented responses
accessible ☐ ☐ ☐ Review frequency:

12. Building envelope
a. Doors close automatically ☐ ☐ ☐
b. Operable windows in odorprone areas closed ☐ ☐ ☐
c. Air leaks and sources visible ☐ ☐ ☐
d. Loading/Unloading areas
enclosed ☐ ☐ ☐
Inspection Notes:
6d – clean filters are not loaded with a layer of dust or other materials. Dust or other materials may be on the filter but the filter itself is visible through the loading. Filters should be spot checked at easily accessible locations. Inquire about the process of how operators change filters.

Distribution Facility Audit Checklist

INSPECTION ITEM Y N NA NOTES

1. Direct Observation
a. At Property Line or adjacent
to facility ☐ ☐ Intensity:
b. Office space – Odors observed ☐ ☐ ☐ Intensity:

2. State and local cultivation license
valid ☐ ☐

3. Odor Management Plan (OMP)
a. OMP date:
b. Located onsite ☐ ☐ ☐
c. Up to date ☐ ☐ ☐
d. Employee training record for
odor mitigation procedures
reviewed
☐ ☐ ☐

4. Facility diagram reviewed ☐ ☐ ☐
a. Odor control system located
on map
☐ ☐ ☐
b. Exhaust points located on
map
☐ ☐ ☐
c. Negative pressure system
labeled on map ☐ ☐ ☐
d. Click or tap here to enter
text. located on map ☐ ☐ ☐

5. Approved odor control system ☐ ☐ ☐ Make/Model:
a. Installed and operational ☐ ☐ ☐
b. Routine inspection
documented (+ take photos) ☐ ☐ ☐ Inspection frequency:
c. Filters clean ☐ ☐ ☐ Replacement frequency:

6. Waste areas ☐ ☐ ☐
a. Enclosed ☐ ☐ ☐
b. Properly sealed ☐ ☐ ☐
c. Cannabis odors observed ☐ ☐ ☐

7. Facility operated odor complaint
management system
a. Available and operational ☐ ☐ ☐
b. Documented responses
accessible ☐ ☐ ☐ Review frequency:

8. Building envelope
a. Doors close automatically ☐ ☐ ☐
b. Operable windows in odorprone areas closed ☐ ☐ ☐
c. Air leaks and sources visible ☐ ☐ ☐
d. Loading/Unloading areas
enclosed ☐ ☐ ☐
Manufacturing Facility Audit Checklist

INSPECTION ITEM Y N NA NOTES

1. Direct Observation
a. At Property Line or adjacent
to facility ☐ ☐ Intensity:
b. Office space – Odors observed ☐ ☐ ☐ Intensity:

2. State and local cultivation license
valid ☐ ☐

3. Odor Management Plan (OMP)
a. OMP date:
b. Located onsite ☐ ☐ ☐
c. Up to date ☐ ☐ ☐
d. Employee training record for
odor mitigation procedures
reviewed
☐ ☐ ☐

4. Facility diagram reviewed ☐ ☐ ☐
a. Odor control system located
on map
☐ ☐ ☐
b. Exhaust points located on
map
☐ ☐ ☐
c. Negative pressure system
labeled on map ☐ ☐ ☐
d. ___________ located on map ☐ ☐ ☐

5. Cannabis Processing Onsite ☐ ☐ ☐
a. Flower Cannabis Processing ☐ ☐ ☐
b. Extract processing ☐ ☐ ☐

6. Approved odor control system ☐ ☐ ☐ Make/Model:
a. Installed and operational ☐ ☐ ☐
b. Routine inspection
documented (+ take photos) ☐ ☐ ☐ Inspection frequency:
c. Filters clean ☐ ☐ ☐ Replacement frequency:

7. Air filtration units
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:
d. Filters clean ☐ ☐ ☐ Replacement frequency:

8. Waste areas ☐ ☐ ☐
a. Enclosed ☐ ☐ ☐
b. Properly sealed ☐ ☐ ☐
c. Cannabis odors observed ☐ ☐ ☐

9. Facility operated odor complaint
management system
a. Available and operational ☐ ☐ ☐

INSPECTION ITEM Y N NA NOTES
b. Documented responses
accessible ☐ ☐ ☐ Review frequency:

10. Building envelope
a. Doors close automatically ☐ ☐ ☐
b. Operable windows in odorprone areas closed ☐ ☐ ☐
c. Air leaks and sources visible ☐ ☐ ☐
d. Loading/Unloading areas
enclosed ☐ ☐ ☐

11. Storage area ☐ ☐ ☐
a. Product is stored in odor-proof
packaging ☐ ☐ ☐
b. Packages ready to ship – Odors
observed ☐ ☐ ☐
Consumption Lounge Audit Checklist

INSPECTION ITEM Y N NA NOTES

1. Direct Observation
a. At Property Line or adjacent
to facility ☐ ☐ Intensity:
b. Office space – Odors observed ☐ ☐ ☐ Intensity:

2. State & local cultivation license
valid ☐ ☐

3. Odor Management Plan (OMP)
a. OMP date:
b. Located onsite ☐ ☐ ☐
c. Up to date ☐ ☐ ☐
d. Employee training record for
odor mitigation procedures
reviewed
☐ ☐ ☐

4. Facility diagram reviewed ☐ ☐ ☐
a. Odor control system located
on map
☐ ☐ ☐
b. Exhaust points located on
map
☐ ☐ ☐
c. Negative pressure system
labeled on map ☐ ☐ ☐
d. ___________ located on map ☐ ☐ ☐

5. Approved odor control system ☐ ☐ ☐ Make/Model:
a. Installed and operational ☐ ☐ ☐
b. Routine inspection
documented (+ take photos) ☐ ☐ ☐ Inspection frequency:
c. Filters clean ☐ ☐ ☐ Replacement frequency:

6. Air filtration units
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:
d. Filters clean ☐ ☐ ☐ Replacement frequency:

7. Ventilation system
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Visible signs of buildup in
ducts or on vents ☐ ☐ ☐
d. Integrated with odor control
system ☐ ☐ ☐
e. Diagrams reviewed ☐ ☐ ☐
f. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:

8. Negative pressure system ☐ ☐ ☐
a. Operational ☒
☐ ☐

INSPECTION ITEM Y N NA NOTES
b. Documented on facility
diagram/plans ☐ ☐ ☐

9. Waste areas ☐ ☐ ☐
a. Enclosed ☐ ☐ ☐
b. Properly sealed ☐ ☐ ☐
c. Cannabis odors observed ☐ ☐ ☐

10. Facility operated odor complaint
management system
a. Available and operational ☐ ☐ ☐
b. Documented responses
accessible ☐ ☐ ☐ Review frequency:

11. Building envelope
a. Doors close automatically ☐ ☐ ☐
b. Operable windows in odorprone areas closed ☐ ☐ ☐
c. Air leaks and sources visible ☐ ☐ ☐
d. Loading/Unloading areas
enclosed ☐ ☐ ☐

12. Storage area ☐ ☐ ☐
a. Product is stored in odor-proof
packaging ☐ ☐ ☐
b. Receiving area –Odors
observed ☐ ☐ ☐
Retail Facility Audit Checklist

INSPECTION ITEM Y N NA NOTES

1. Direct Observation
a. At Property Line or adjacent
to facility ☐ ☐ Intensity:
b. Indoor – Odors observed ☐ ☐ Intensity:
c. Office space – Odors observed

2. State and local cultivation license
valid ☐ ☐

3. Odor Management Plan (OMP)
a. OMP date:
b. Located onsite ☐ ☐ ☐
c. Up to date ☐ ☐ ☐
d. Employee training record for
odor mitigation procedures
reviewed
☐ ☐ ☐

4. Facility diagram reviewed ☐ ☐ ☐
a. Odor control system located
on map
☐ ☐ ☐
b. Exhaust points located on
map
☐ ☐ ☐
c. Negative pressure system
labeled on map ☐ ☐ ☐
d. ___________ located on map ☐ ☐ ☐

5. Air filtration units
a. Operational ☐ ☐ ☐
b. Labeled on facility diagram ☐ ☐ ☐
c. Maintenance log reviewed ☐ ☐ ☐ Last maintenance date:
d. Filters clean ☐ ☐ ☐ Replacement frequency:

6. Storage area ☐ ☐ ☐
a. Receiving area –Odors
observed ☐ ☐ ☐
b. Displays are filtered and
vented ☐ ☐ ☐

CITY OF CATHEDRAL CITY

RESPONSE TO CORRECTIVE ACTION NOTICE

PLAN OF ACTION
Company Contact
Address Cell

CORRECTIVE ACTION NOTIFICATION INFORMATION
Date of Inspection
Date of CAN By Whom
Plan of Action Due Date By Whom
Mitigation Due Date By Whom
Equipment and
Parameters
Breakdown
Description
Breakdown
Cause
Corrective
measures taken
to avoid future
occurrences.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page C
Appendix C
Communication and Public Outreach
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page C-1
Communication and Public Outreach
It is important to realize that a community relations program will not solve your odor issues. But be assured that you will not resolve them successfully without a community outreach program. Having good lines of communication with your neighbors will greatly enhance your success to isolate any causes of odor impacts and guide the design to ultimately control impacts. Community outreach serves not only to educate the public about your facility, but it must establish a partnership between the facility operators and members of the public to work together to resolve issues. An antagonistic relationship will not help find reasonable and effective solutions.

The facility relationship with the community may not be limited to just odors issues. It may require expansion to collectively address a broad spectrum of potential environmental related neighbor concerns such as, but not limited to, traffic, noise, dust, and other environmental topics. When such a community relations program is enacted, the public will sense that they are involved with the entire operation and will help to foster public participation in the solution of any issues.

Understanding Community Concerns
When a person encounters an odor, particularly an offensive odor, their initial and primary concern is that the exposure to whatever is causing the odor will make them sick. This perception is evident not only for short term exposure (on the scale of minutes) but also for longer term exposures (days and months). In addition to health issues, people believe that when odor impacts occur, their property values will suffer. These concerns can drive community outrage and as outrage grows the sphere of influence of the odor impacts expand. Good communication with the public can reduce and even quell the outrage and enable the facility to reasonably deal with facts and not rumor or speculation.

When the public senses an offensive odor, they need to be able to voice their concern and have their questions resolved as quickly and honestly as possible. When people feel they have no recourse or means to resolve an issue, outrage and irrational thinking takes hold. It can be very difficult to gain the trust of the community when sentiments rise to this level or they have been misinformed. A good public relations program will provide easy pathways for the facility to respond to community issues as they occur. The bottom-line is that people need to be heard and taken seriously.

It is not uncommon for people to blame a facility for odors when that facility is not causing the odors.

People respond to impacts with what they see and sense and often do not rely on facts (for example is the wind blowing in a direction that would connect your facility with the person complaining?).

Alternatively, if real-time accurate information is conveyed from the community to the facility about detected odors, then effective and meaningful solutions can be tailored to mitigate impacts. Finally, the public wants to know that their welfare is being considered and prioritized in the operation of the facility.

Key Elements of Community Action Plan
Goal of your Community Outreach
The goal of a community outreach program is to establish a partnership with neighbors to the extent that you will work together to resolve problems. This involves building trust between the cannabis operator and the community. If this trust is lost, the facility is vulnerable to unreasonable and expensive mitigation imposed by regulatory authorities that are leveraged by a community that is not with the cannabis operator.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page C-2
Community outreach must entail the conveyance of regulatory compliance, open dialog of measured data and observations, meaningful and open discussion of problems, and review of tailored solutions of which the community feels that they were a significant contributor. A public relations program needs to make the community feel that they are nothing less than a valued partner in facility operation and compliance.

Engaging with Community
Connecting with the community needs to take on a comprehensive outreach effort that can reach all levels of the community. There is no common or primary way that people communicate and gain information, so it is encumbered upon the facility to reach out in a variety of ways. This includes, but not limited to, the following:
• Having a designated odor complaint point-of-contact at each cannabis facility, who is trained on understanding and observing odor events, able to receive and log complaints, as well as be knowledgeable on the facility’s odor control system, how it’s maintained, ensuring operationality conforming to the manufacturers recommendations, where system improvements are logged, and routinely evaluated. Maintenance logs should be stored onsite for at least 5 years and readily available for trend analysis and historical inquiry. • In person Town hall meetings and presentations – the more personal interaction the better the chances of building a relationship.
• Zoom or Teams meetings that people can attend via computer link • Focus group meetings with small numbers of people – perhaps people from individual block neighborhoods or logical segments or subsets of the overall community. • General Information and Policy meetings.
• Educational Seminars – each on specific topics concerning odors – teach people on how to evaluate odors.
• Summary status letters and flyers sent to the community backed up on social media. • Light social events within the community sponsored by the facility – get people together.

Conveyance of Regulatory Compliance
Compliance with regulatory conditions is very important. The facility operators need to convey to the community a vision of compliance. This needs to be done as simply as possible so the public understands what compliance means, including what information is used to assess compliance. It is important to share this data with the public in a way that is understandable and visual. If possible, illustrate how the community has helped in attaining compliance with regulatory issues.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page D
Appendix D
Cathedral City Council Staff Report: Cannabis Moratorium Update
Staff Report
City Council
Item No. 1.A
Meeting Date: April 23, 2025
From: Andrew Firestine, AICP, Director of Community and Economic Development
Title: Cannabis Moratorium Update
RECOMMENDATION:

This item is for discussion purposes to serve as an update on the cannabis moratorium. No action is requested.

BACKGROUND:

On February 26, 2025, the City Council extended the cannabis moratorium by 10 months and 15 days. Through the discussion, the City Council requested routine updates as staff conducts additional research and initiates updates to the City’s cannabis regulations and processes. The prior report focused on an evaluation of the City’s zoning, locational requirements, definitions, standards, and enforcement provisions, fines, and penalties while building out an odor control plan to implement the required conditions of approval. This report provides a synopsis of cannabis research conducted in other cities and counties and efforts to engage consultant support to set standards and to support the development of an odor control permitting process. It also provides updates on consultant support to the city specifically on C4 Industry and an odor control reporting and monitoring pilot program.

DISCUSSION:

Staff has commenced research in these areas, first by identifying all the California cities and counties that allow for cannabis cultivation in some manner, a list of 84 cities and counties, and conducted an initial review of the cannabis zoning regulations, licensing, and enforcement provisions for each of these cities and counties. This initial review was narrowed down to a smaller list of 15 cities and 3 counties that potentially offer insight into one or more of the areas of focus. A review of these city and county regulations, with an emphasis on zoning and enforcement, is summarized in the sections below with additional text contained in the attachments
Staff also initiated a records request through the Department of Cannabis Control (DCC) for the purpose of understanding how many large indoor cannabis cultivation facilities are licensed in the State of California. The DCC defines large indoor cannabis cultivation as those with more than 22,000 square feet of total canopy. For comparison, C4 Industry, the existing large cannabis cultivation facility near Date Palm Drive and Ramon Road has a gross floor area of 326,000 square feet and each of its 9 bays has a canopy area of 21,504 square feet together with an 8,760 square foot mother room, totaling over 200,000 square feet of total canopy area. While the DCC began accepting applications for large indoor cultivation licenses in 2020, there are only 6 other large indoor cultivation facilities licensed by the DCC, all of which are located in Richmond and Oakland. None of these are a good comparison to C4 Industry – most are substantially smaller in size and are older warehouses in industrial areas converted to cannabis cultivation.

The initial research of other city and county regulations, together with the additional information from the DCC, reveals that while there are some models for odor control permit processes and stronger enforcement, no city or county is at the forefront of cannabis regulation. No city or county has adopted objective cannabis odor standards and most rely on reactive and subjective odor measurements for enforcement. These preliminary findings raise the importance of the city’s existing condition of approval on cannabis conditional use permits requiring odor mitigation.

As was identified in previous staff reports, there is no separate plan or document and there are no standards or minimum requirements to demonstrate how the City’s odor mitigation requirements are to be met. Other cities and counties have established odor mitigation requirements through an odor control plan and permitting process, which is captured in the summary below. To ensure the City is setting the right standards, including the evaluation of technologies and the establishment of odor control requirements, the development of content and submittal requirements for an odor control plan, and the preparation of inspection checklists, consultant support is needed. To date, staff has met and engaged with five companies with significant experience in cannabis odor control and monitoring and has prepared a scope of work specific to the City’s needs. This scope of work was issued for informal bid on April 14 with bids requested by April 28. A summary of the expected scope of work is provided below.

Through the process of identifying prospective consultants to engage with on an update of the City’s cannabis regulations, staff identified a nationally recognized expert on soil vapor sampling, soil vapor analysis, and vapor intrusion for environmental and exploration applications who has extended his work into the cannabis industry through the monitoring of cannabis odor causing compounds by similar analysis. Dr. Blayne Hartman, with Hartman Environmental Geoscience, has analyzed cannabis odor control systems and offers the ability to provide the City a qualified opinion on the effectiveness of both the current and any additionally proposed odor mitigation at C4 Industry. The business remains responsible for designing, implementing, and maintaining their odor control solutions. Dr. Hartman’s work is to validate their effectiveness through an objective analysis and to make specific recommendations to the City. Dr. Hartman does not represent any equipment manufacturer and does not design cannabis odor control systems – he has no conflict of interest with C4 Industry or any other cannabis business operating in Cathedral City. Staff has negotiated a contract and scope of work with Dr. Hartman to evaluate the performance of the odor control systems at C4 Industry, both existing and proposed.

Finally, staff has also met with Envirosuite on several occasions. Envirosuite is a leader in environmental intelligence and offers a technology driven, real-time reporting and monitoring service that provides benefits to the City and to cannabis operators. C4 Industry has contracted with Envirosuite to implement a pilot program at their facility, a program that can potentially be expanded citywide. Under the pilot program, cannabis odor reports in the vicinity of C4 Industry would be reported through the Envirosuite platform embedded on the City’s website, collecting information on the location and strength and intensity of the odor.

Envirosuite’s monitors would also collect data on weather, volatile organic compounds (VOCs), and other compounds. All of this data would be made available to the City and the operator in real-time, which is intended to better correlate odor complaints with objective data, informing both City actions and operational changes at C4 Industry. Additional details on this pilot program and partnership are outlined below.

Cannabis Regulations
In its review of cannabis regulations from 15 cities and 3 counties, City staff evaluated seven zoning questions, including questions directed to odor mitigation and odor mitigation plans.

Staff further assessed four questions related to enforcement of odor violations. The complete data collected from this research is attached to the staff report. The zoning and enforcement research is summarized for Coachella, Palm Desert, Palm Springs, Desert Hot Springs, Oakland, and Richmond for each question below.

Zoning

1. What zoning districts are cannabis cultivation, manufacturing, and lab uses permitted?
Upon reviewing neighboring cities in the Coachella Valley such as Coachella, Palm Desert, Palm Springs, and Desert Hot Springs, as well as Oakland and Richmond, it is evident that cannabis uses such as cultivation, manufacturing, distribution, and testing labs uses are typically restricted to industrial zone districts, while dispensaries are permitted in both industrial and retail zones. Cultivation, manufacturing, distribution, and testing labs uses are generally not permitted within commercial or residential zones, reflecting a common zoning practice aimed at minimizing potential impacts on retail areas and neighborhoods.

2. What separation requirements existing between cannabis uses and either residential zones or uses and other sensitive uses? Identify both the use and the separation requirement.

The separation requirements from residential uses vary significantly. Under the California Business and Professions Code (BPC) Section 26054(b), cannabis businesses shall not be located within a 600-foot radius of a school providing K-12 instruction, a daycare center, or a youth center. Cities and counties, at a minimum, must implement this standard, although they may adopt more stringent standards, including other separation requirements.

As an illustration, Palm Springs established a 1,000-foot separation requirement between cannabis cultivation and manufacturing and a residential zoning district.

Coachella, Lancaster, and Pasadena each have a 600-foot separation requirement from commercial cannabis uses and residentially zoned property. Grover Beach requires a 100-foot setback between retailers and residential zones.

The other cities studied as part of this evaluation do not have an explicit separation from cannabis uses and residential zones or uses. Cathedral City is the only city evaluated that allows cultivation, manufacturing, and distribution in a commercial zoning district. The other cities limit those uses to industrial zones, which are generally separated from residential zones.

3. Are there separation requirements between cannabis uses? Palm Desert requires that cannabis retailers be 1,500 feet apart and similarly requires cannabis businesses within their service industrial zoning district to be separated by 1,500 feet. With some exceptions, Palm Springs requires cannabis businesses be separated by 500 feet. Among the other cities studied, Long Beach has a 1,000 foot separation requirement between dispensaries.

4. Are there limits on either the number or size of cannabis uses? A review of other city regulations shows that other cities place limits on the number of cannabis dispensaries allowed, often setting the cap between three and 10. In contrast, most do not impose limits on other types of cannabis operations, including cultivation, manufacturing, distribution, and testing laboratories. This reflects a regulatory trend aimed at controlling the retail presence of cannabis while allowing more flexibility for non-retail sectors of the industry. Santa Cruz and Moreno Valley are two cities that have additional requirements for cultivation facilities. Santa Cruz restricts indoor cultivation to a maximum of 10,000 square feet. Moreno Valley restricts the total area of the premises designated/used for the cultivation canopy to no more than 22,000 square feet, effectively prohibiting large indoor cultivation facilities, as defined by the DCC. Pasadena limits cultivation to four licensed facilities.

5. What is the definition of a nuisance cannabis odor?
Nuisance cannabis odor is not consistently defined across all city zoning codes.

However, some cities have established specific standards to address this issue. For example, the City of Palm Springs defines “Odor Detection Threshold” as the threshold for the detection of odorous contaminants when one volume of the odorous air has been diluted with seven or more volumes of odor free air as measured by any instrument, device, or any other method designated by the City.

Similarly, the City of Coachella defines "Odor Threshold Concentration" as the lowest concentration of Odorous matter that produces an olfactory response in normal human beings. Odor thresholds shall be determined in accordance with the American Society for Testing and Materials Test Method D1391-57 (reconfirmed to 1967) or in an equivalent manner acceptable to the zoning administrator.

These definitions require measurement through an olfactometer, such as the St.

Croix Sensory Nasal Ranger Field Olfactometer. The specialized device uses a combination of human nose and an instrument to detect and measure odors. While the definition has been adopted by some cities and counties, including Santa Barbara County most recently, it remains a subjective measurement and is not widely accepted as an effective way of detecting cannabis odor.

6. What are the odor mitigation requirements, either through a CUP or cannabis license? Are there specific requirements or standards for cultivation and manufacturing uses? Odor mitigation requirements are standard among the cities researched and are consistent with Cathedral City’s requirements that a business install odor absorbing ventilation and exhaust system so that odor generated inside the cannabis business are not detected outside. The systems include an exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or an air system that creates negative air pressure between the interior and exterior so that the odors generated inside the cannabis business are not detectable outside.

7. Does the city or county require an odor mitigation plan or permit? If so, who is authorized to prepare and submit it? What are the submission requirements? Does it need to be renewed annually as part of the license? Who approves it? A common requirement found in the cities researched is the requirement to develop and implement a ventilation or odor control plan. These plans are required to include detailed information about the proposed ventilation system, including technical specifications indicating that the system can prevent the release of cannabis odors into the atmosphere from the cultivation or manufacturing operation. Coachella, Desert Hot Springs, and Palm Springs all require odor control plans. These are most often prepared by a licensed mechanical engineer. While Palm Springs requires an odor control plan to be prepared as part of a conditional use permit, other cities require it as a post-entitlement permit reviewed administratively and concurrent with a building permit. Some cities, including Palm Springs, use a third-party contractor to review odor control plans. Among the other cities, Grover Beach requires odor control systems to be certified annually.

Code Enforcement

8. What constitutes an odor violation? Are there thresholds or measurements for cannabis odor, either for the concentration of odor or the time period over which it is detected?
National City, La Mesa, and Desert Hot Springs require that odor not be detectable at the property line. El Dorado County uses the St. Croix Sensory Nasal Ranger Field Olfactometer, and Santa Barbara County established a nuisance threshold relying on an olfactometer as part of its recent cannabis code updates. Desert Hot Springs reported that it discontinued its use of the Nasal Ranger.

9. When there is an odor complaint, how is it investigated? Does the cannabis business have a period of time to correct a violation before a citation or further action is taken? If so, how long?
Several cities and counties require cannabis businesses to respond to cannabis odor complaints, including Santa Barbara County, Long Beach, and Desert Hot Springs.

Palm Springs allows cannabis businesses with a compliant odor control plan seven days to correct an odor issue.

10.What are the fines for a violation of the cannabis ordinance? Are there penalties beyond fines? If so, what?
Palm Springs has an escalating enforcement process. For odor violations related to a cannabis business with a compliant odor control plan, a cannabis business is first issued a written warning and given seven days to modify their odor control plan to mitigate odor issues. If the odor cannot be mitigated within seven days, the use must cease until effective odor control measures are in place. For odor violations with a non-compliant odor control plan, the business can be subject to a $10,000 administrative violation and have 30 days to remedy the odor issue and comply with their odor control plan before they’re issued another administrative citation of $10,000.

After three administrative citations, the permit shall automatically be revoked.

Desert Hot Springs code allows fines up to $1,000 per day, although their staff indicates that they have never needed to issue this fine.

11.Are there any unique provisions, such as a hearing officer, that warrant further evaluation?
Stanislaus County established a hearing officer process to conduct administrative hearings to determine whether the conditions described in the notice of violation, administrative citation and order to abate, and notice of hearing constitute a nuisance.

The hearing officer also considers the suspension, revocation, or non-renewal of cannabis permits.

Desert Hot Springs contracts with a third-party for all cannabis ordinance enforcement. Palm Springs contracts for the review of odor control plans.

Cannabis Consultant Support
On April 14, a scope of work for consultant support related to cannabis odor control was issued to four companies. This scope of work builds on the city and county research performed by City staff and seeks specific subject matter expertise on cannabis odor control.

It divides the work into six areas:

1. Regulatory review and best practices assessment

2. Odor control technology evaluation

3. Odor control permitting process

4. Inspection and verification protocols

5. Stakeholder engagement and presentations

6. Training
The full scope of work is attached for reference. It also included a timeline prepared by City staff leading to the presentation of an ordinance to the Cannabis Task Force and Planning Commission in August 2025 and the City Council in September 2025. Staff would be responsible for preparing the ordinance, but with input from the consultant to ensure the City is setting clear and appropriate standards and that the ordinance is accompanied by checklists and supporting documentation for any new processes.

In addition to this scope of work, a contract has been executed with Hartman Environmental Geoscience, the fifth consultant staff met with, specifically for the review of the odor control systems at C4 Industry, both existing and proposed. This contract allows up to 50 hours of consultant time and accounts for two site visits. Through the scope of work, they are tasked with providing the City a qualified opinion on the effectiveness of both the current and proposed odor mitigation plans and make specific recommendations to improve the effectiveness of the existing and any additionally proposed odor mitigation. This contract is not to support C4 Industry but rather to support the City in its review and assessment of the odor problem at C4 Industry using objective analysis and data.

Envirosuite
The City’s current process to report cannabis odors is inefficient and relies upon a platform that was not designed or intended for odor reporting. While it has been used to aggregate complaints, the information reported through the platform is not shared with a cannabis business in real-time. The auto-generated responses to a reporting party when a complaint is made are the same as any other code compliance case, which sets an expectation with the reporting party that the City will respond to their complaint individually. The volume of cannabis odor complaints has precluded staff from investigating and responding to each individual complaint. When the complaints are closed out by City staff, residents feel they are being ignored as the underlying issue has not been addressed. To address this, staff created an email distribution group that it has been sending weekly updates to both in response to cannabis odor complaints at C4 Industry and with respect to the cannabis moratorium.

Through the pilot program with Envirosuite, the City has an opportunity to substantially improve cannabis odor reporting for the area around C4 Industry. This could potentially be expanded to other areas of the City, but beginning in May 2025 an online form will be made available on the City’s website similar to what has been deployed in Des Moines, IA:
https://www.dsm.city/departments/neighborhood_services/odor.php.

The form will document the time and date of the complaint, location, description, and optional contact information for follow-up. Once submitted, City code compliance staff would be notified of a new complaint. Envirosuite would validate the plausibility of the complaint based on atmospheric conditions, including wind direction and speed, and the location of the complaint. Envirosuite also collects time-aligned sensor data and meteorological data. The sensors will be monitoring VOC, H2S and NH3 and can be programmed to monitor two additional compounds as may be directed by the City and its consultants.

Validated complaints are assigned to the business operator, in this case C4 Industry, for investigation and response. While the City does not presently have a response timeline for cannabis businesses to address odor complaints, the pilot program establishes an initial response time of 30 minutes during business hours and 90 minutes after hours, which would include an acknowledgement of the complaint, time of receipt, and immediate investigative steps. Under the pilot program, C4 Industry would be required to post a detailed investigation summary within 24 hours, including on-site observations, source identification (if any), and mitigation actions. Code compliance staff would be responsible for reviewing the investigation conducted by the business in response to a complaint, including its resolution.

The City’s role in the pilot program would be to support its implementation through the City website and to maintain oversight of it for the purpose of regulatory compliance, the tracking of complaints, and community engagement. The pilot program is proposed for a period of six-months, through which Envirosuite, C4 Industry, and the City will evaluate its effectiveness. The pilot program can be extended for an additional six-months upon mutual agreement.

Beyond its application in the area around C4 Industry, City staff are exploring the potential deployment of additional Envirosuite sensors and weather stations elsewhere in the City to permit cannabis odor reporting and monitoring through the Envirosuite platform. There is no estimated cost for these additional services at this point. They will be assessed and evaluated under the cannabis moratorium.

Next Steps
Staff anticipates that it will award a professional services contract to a cannabis consultant in the beginning of May and that staff and the consultant will immediately begin to identify those best practices the City should model in its updated cannabis regulations, including any new odor control requirements. The consultant is expected to produce an odor control permitting process for the City, including submittal and inspection checklists. While a substantial amount of work remains, staff has developed a timeline that would result in the presentation of an ordinance to the Cannabis Task Force and Planning Commission in August 2025 and City Council in September 2025.

FISCAL IMPACT:

The contract with Hartman Environmental Geoscience is not to exceed $12,500 and will be accommodated within the existing budget. The scope of work for the other consultant support was issued on April 14, 2025, for an informal bid with the expectation that it will be within the city manager’s signature authority. This contract is expected to be split between two fiscal years and will be accommodated within the existing and proposed budget.

FIVE-YEAR STRATEGIC PLAN:

F-17 – Review and update, as needed, our ordinances, policies, and practices regarding cannabis.

ATTACHMENTS:

1. City and County Cannabis Analysis

2. Cannabis Consultant Support Scope of Work
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page E
Appendix E
Odor Abatement Plan Template Checklists for Various Cannabis Facility Types
Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page E-1
Cannabis Cultivation & Manufacturing (Processing)
Odor Abatement Plan (OAP) Checklist Template
1) Introduction and Source Identification
□ Operator Name
□ OAP Certifier/Author Details
□ Facility Name
□ Facility Address
□ APN(s)
□ Vicinity map with adjacent landuse / zoning with spatial distances between cannabis facility and proximal sensitive receptors
□ Facility floorplans with accurately dimensioned operational facility layout, and room use designations (e.g.: trimming room, cure room, greenhouses, nursery areas, cloning rooms, etc.)
□ Description of operations, any phased construction, details on existing operations and proposed operations, if differs
2) Description of Odor Emitting Activities or Processes □ Identification of odor emitting activities and processes □ Identification of odorants
□ Material Storage/Waste Generation
□ Operational/Production Schedules
□ Fugitive Sources
3) Description of Methods used for Odor Control
□ Active Odor Control System Design
• Odor control facility plan with odor control system callouts, including odor control system type, location of odor control devices, device quantity • Detailed description of proposed odor control devices, including location, quantity and system integration
□ Administrative Controls
• Daily site and system inspections
• Odor control system maintenance log
• Filter replacement schedule and log
• Housekeeping controls: keeping facility doors closed, use of air curtains at egresses, strip curtains at man doors and loading bays
□ Engineering Controls
• Odor control system design: e.g.: carbon filtration, multi-stage filtration, vapor phase, vegetative buffering and any other odor control systems to be implemented
• Ensuring proper air exchanges 3-4 per hour with odor control system/HVAC • Use of negative pressure to help facilitate odor control in sealed buildings • Description of all equipment and methods to be used for reducing odors • Inclusion of technical specifications and O&M materials provided by the odor control system manufacturer
• Example odor inspection logs, inspection checklists and example odor complaint response forms
□ Required Site Preparation
• Repairing paneling, installing vapor barriers, walls and ensuring building envelope is sealed, if retrofitting/tenant improvement an existing structure Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page E-2
there’s acknowledgement of repairing broken panels or closing gaps to ensure a tight sealed building envelope.
• Ensure existing/proposed electrical system can accommodate the proposed odor control system, some carbon scrubbers require substantial electrical loads. • Details on improvements to HVAC system to accommodate odor control systems • Cannabis processing areas are isolated from administrative areas • Entry areas with secondary door containment, and air filtering systems • Cannabis processing areas equipped with cooler panel walls and ceilings • Roll-up and slide doors equipped with good seals
□ Process Parameters for Proper Operation
• System testing and odor sampling to ensure system efficacy □ Maintenance Requirements
• Filter replacement schedule (quarterly recommended)
• Daily system checks and facility walks
□ Staff Training
4) Complaint Management Procedures
□ Facility Odor Complaint Point-of-Contact Information
□ Complaint Management System description
□ Procedures for Response
□ Community Outreach, if applicable
□ Acknowledgement of departmental access
5) Corrective Action Plan, if required. See Section 5.1.3 for more detail.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page E-3
Cannabis Dispensaries (Retail Storefronts)
Odor Abatement Plan (OAP) Checklist Template
1) Introduction and Source Identification
□ Facility Name
□ Facility Address / Assessor’s Parcel Number(s) (APN)
□ Vicinity & Zoning Map
□ Site Map including entrances/exits, ventilation points □ Description of Facility Operations and Layout (e.g., retail floor, storage areas, security checkpoints)
2) Description of Odor Emitting Activities or Processes □ Identification of Odor Emitting Activities (e.g., display of cannabis products, product handling, packaging removal)
□ Identification of Potential Odorants (e.g., dried cannabis flower, concentrates, infused products)
□ Product Storage Details (including secured areas)
□ Waste Generation and Disposal Practices (e.g., expired product disposal, packaging waste)
□ Operational Schedules (hours of operation, delivery schedules) □ Potential Fugitive Odor Sources (e.g., entrance/exit air exchanges, storage room ventilation, product handling zones)
3) Description of Methods Used for Odor Control
□ Administrative Controls (e.g., odor-free product display protocols, customer handling guidelines)
□ Engineering Controls (e.g., carbon filtration systems, air curtains at entry points, HVAC filtration upgrades)
□ Process Parameters for Proper Operation (e.g., ventilation system performance per mechanical plan)
□ Maintenance Requirements (e.g., filter replacement schedules, ventilation system inspections)
□ Staff Training (odor management awareness, incident response procedures) □ OAP Certification by Certified Industrial Hygienist (CIH) or Professional Engineer (PE) 4) Complaint Management Procedures
□ Facility Contact Information (Odor complaint point-of-contact) □ Complaint Management System (e.g., log system, reporting protocols) □ Procedures for Investigation and Response
□ Community Outreach, if applicable (e.g., contact signage, neighborhood relations) 5) Corrective Action Plan, if Required
□ Steps to Investigate, Address, and Prevent Recurrence of Verified Odor Complaints.

See Section 5.1.3 for more detail.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Appendix Page E-4
Cannabis Consumption Lounges
Odor Abatement Plan (OAP) Checklist Template
1) Introduction and Source Identification
□ Facility Name
□ Facility Address / Assessor’s Parcel Number(s) (APN)
□ Vicinity & Zoning Map
□ Site Map including all consumption areas, ventilation points, and adjacent uses □ Description of Facility Operations and Layout (e.g., consumption lounge, retail area, private rooms, outdoor patios)
2) Description of Odor Emitting Activities or Processes □ Identification of Odor Emitting Activities (e.g., on-site smoking, vaping, edible consumption with residual odors)
□ Identification of Primary Odorants (e.g., cannabis smoke, vapor emissions, lingering odors)
□ Product Storage Details (if applicable)
□ Waste Generation and Disposal Practices (e.g., ash disposal, used vape cartridge management)
□ Operational Schedules (hours of operation, special events) □ Fugitive Odor Sources (e.g., door openings, patio areas, ventilation exhaust points) 3) Description of Methods Used for Odor Control
□ Administrative Controls (e.g., consumption area restrictions, designated smoking zones, door closure protocols)
□ Engineering Controls (e.g., high-efficiency carbon filtration, negative air pressure systems, enclosed smoking areas, exhaust stack placement) □ Process Parameters for Proper Operation (e.g., air exchange rates, airflow rates, filtration performance standards)
□ Maintenance Requirements (e.g., filter replacements, ventilation inspections, smoke evacuation systems)
□ Staff Training (odor management practices, incident handling, system operation) □ OAP Certification by Certified Industrial Hygienist (CIH) or Professional Engineer (PE) 4) Complaint Management Procedures
□ Facility Contact Information for Odor Concerns
□ Complaint Management System (e.g., community hotline, incident logs) □ Procedures for Response and Documentation
□ Community Outreach, if applicable (e.g., neighborhood meetings, communication channels)
5) Corrective Action Plan, if Required. See Section 5.1.3 for more detail. □ Steps to Investigate, Address, and Prevent Recurrence of Verified Odor Complaints.

See Section 5.1.3 for more detail.

Cathedral City – Regulatory Review - Cannabis Odor Control www.scsengineers.com Page F
Appendix F
City of Cathedral City Licensed Cannabis Business Type and Zoning Maps
Santa Maria, CA July 2025 ±
0 0.5 1 1.5
Miles
FIGURE #1 GENERAL VICINITY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Legend
Business Types
Cultivation
Dispensary
Distribution
Manufacturing
Microbusiness
Testing Laboratory
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Cultivation
Dispensary
Distribution
Manufacturing
Microbusiness
Testing Laboratory
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #2 ZOOM EXTENT

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Cultivation
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #3 CULTIVATION ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Dispensary
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #4 DISPENSARY ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Distribution
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #5 DISTRIBUTION ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Manufacturing
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #6 MANUFACTURING ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Microbusiness
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #7 MICROBUSINESS ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.25 0.5 0.75
Miles
Legend
Business Types
Testing Laboratory
City Limits
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #8 TESTING LABORATORY ONLY

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
Santa Maria, CA July 2025 ±
0 0.5 1 1.5
Miles
Legend
1000Ft Buffer
Business Type
Cultivation
Manufacturing
Microbusiness
City Limits
Zoning
Commercial
Industrial
Open Space
Residential
FIGURE #9 1000FT BUFFER

CATHEDRAL CITY

REGULATORY REVIEW
BUSINESS LICENSES | ZONING MAP

CITY OF CATHEDRAL CITY, CA
D e s e r t H o t
S p r i n g s
D e s e r t H o t
S p r i n g s
R a n c h o M i r a g e R a n c h o M i r a g e
P a l m
D e s e r t D e s e r t
P a l m S p r i n g s P a l m S p r i n g s
|ÿ111
Ramon Rd
Perez Rd
Date Palm Dr
Av
e
n
di a
M
a
r
a
vil al
Dinah Shore Dr
30th Ave
Date Palm Dr
Landau Blvd
Cathedral Canyon Dr
Gerald Ford Dr
Verona Rd
Vista Chino
D
a
Vall D
r
P
a
ml D
r
Varner Rd
Varner Rd
Edom Hill Rd
R1
R1-S
R1-8.5
R1
R1-12-LH
R1-15-LH
R1-LH
R2
R2
R3
R3
R3-B
RE
RE-HO
RM
RM
RR
RR
P a l m S p r i n g s P a l m S p r i n g s
|ÿ111
C
a
t
h
e
d
ral C
a
n
y
o
n
D
r
Date
P
alm
D
r
Perez Rd
E Palm Canyon Dr
R2
RR
Esri, NASA, NGA, USGS, FEMA, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community Z
Path: G:\Project Maps\_Planning\CannabisLocationalRequirements\CannabisLocationalRequirements.aprx | BUFFER ANALYSIS - 1000 Printed: 8/7/2025

CANNABIS CULTIVATION,

MANUFACTURING & DISTRIBUTION WITHIN
CITY OF CATHEDRAL CITY 1000FT OF RESIDENTIAL ZONING
The City of Cathedral City has made every
effort to ensure the accuracy of its data.

Use of this information is the sole
responsibility of the user, The City
Cathedral City assumes no liability
associated with the use or misuse of this
information.
0 1
Cannabis Business Location Mile
Cannabis Location Buffer
(R1) Single Family Residential
(R2) Multiple Family Residential
(R3) Multiple Family Residential
(RE) Residential Estate
(RM) Multiple Family Residential
(RR) Resort Residential
Cities
City Limits
COUNT
42 / 47
WITHIN 1000FT

OF ALL RESIDENTIAL
ZONING
R a n c h o M i r a g e R a n c h o M i r a g e
P a l m S p r i n g s P a l m S p r i n g s
|ÿ111
Ramon Rd
Landau Blvd
Perez Rd
Dinah Shore Dr Dinah Shore Dr
Ramon Rd
Date Palm Dr
D
a
t
e
P
alm
D
r
Gerald Ford Dr
Cathedral Canyon Dr
E Palm Canyon Dr
Ca
t
h
e
d
r
al C
a
n
y
o
n
D
r
PCC
PCC
PCC
PCC
PCC
18 11
26 28
56 Esri, NASA, NGA, USGS, FEMA, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community Z
Path: G:\Project Maps\_Planning\CannabisLocationalRequirements\CannabisLocationalRequirements.aprx | Cannabis Business in PCC Printed: 8/7/2025

CANNABIS CULTIVATION,

MANUFACTURING & DISTRIBUTION WITHIN

CITY OF CATHEDRAL CITY ZONING OF PCC
The City of Cathedral City has made every
effort to ensure the accuracy of its data.

Use of this information is the sole
responsibility of the user, The City
Cathedral City assumes no liability
associated with the use or misuse of this
information.
0 1,400
Feet Cannabis Business Location
Planned Community Commercial
Cities
City Limits
ID Business Name Site Address
11 CC Industry, LLC dba C4 USA 69375 Ramon Rd BLDG 1
18 Desert Oasis Group 68031 Ramon Rd STE 201-206
26 EMMI World Management, LLC, Dba Cannamsterdam 67625 East Palm Canyon Dr STE C1-C5 28 Green Dragon Collective #2 67772 East Palm Canyon Dr Bldg A 56 Tempter LLC 34212 Date Palm Dr
##
D e s e r t H o t
S p r i n g s
D e s e r t H o t
S p r i n g s
R a n c h o M i r a g e R a n c h o M i r a g e
P a l m
D e s e r t D e s e r t
P a l m S p r i n g s P a l m S p r i n g s
|ÿ111
Ramon Rd
30th Ave
Perez Rd
A
Date Palm Dr
v
e
n
di a
M
a
r
a
vil al
Dinah Shore Dr
Date Palm Dr
Landau Blvd
Gerald Ford Dr
Verona Rd
Vista Chino
D
a
Vall D
r
P
a
ml D
r
Cathedral Canyon Dr
Varner Rd
Varner Rd
Edom Hill Rd
RR
RR
P a l m
S p r i n g s S p r i n g s
RR
Esri, NASA, NGA, USGS, FEMA, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community Z
Path: G:\Project Maps\_Planning\CannabisLocationalRequirements\CannabisLocationalRequirements.aprx | BUFFER ANALYSIS - 300 Printed: 8/7/2025

CANNABIS CULTIVATION,

MANUFACTURING & DISTRIBUTION WITHIN
CITY OF CATHEDRAL CITY 300FT OF ZONING DESIGNATION RR
The City of Cathedral City has made every
effort to ensure the accuracy of its data.

Use of this information is the sole
responsibility of the user, The City
Cathedral City assumes no liability
associated with the use or misuse of this
information.
0 1
Cannabis Business Location Mile
Cannabis Business Buffer
(RR) Resort Residential
Cities
City Limits
COUNT
3 / 47
WITHIN 300FT

OF ZONING

RESORT RESIDENTIAL
City of Cathedral City
Public Hearing Notice
Notice of Availability for Public Review
and Environmental Determination
Notice is hereby given that the Cathedral City City
Council will hold a Public Hearing on the
following:

CASE(S)
Zoning Ordinance Amendment 25-0004

APPLICANT/REPRESENTATIVE
City of Cathedral City
Community and Economic Development Department

PROPOSAL
A proposal to amend the Cathedral City Municipal
Code, including the zoning ordinance, to amend the
licensing (chapter 5.88), permitting and zoning
(chapter 9.108 and section 9.30.030), and
enforcement (section 13.80.240) regulations related
to cannabis uses and to amend various sections of
the Municipal Code relating to administrative fines
contained in titles 1, 3, 5, 8, 9, 11 and 14).

Note that on August 20, 2025, the Planning
Commission conducted a public hearing on the
proposed zoning ordinance amendment and voted 4-
1 to recommend City Council adoption of an
ordinance adopting the proposed amendment.

LOCATION
City-Wide

ENVIRONMENTAL DETERMINATION
The project is exempt from the California
Environmental Quality Act (“CEQA”), pursuant to the
“common sense exemption” set forth in CEQA
Guidelines Section 15061(b)(3), which states that a
project is exempt from CEQA where it can be seen
with certainty that there is no possibility that the
activity in question may have a significant effect on
the environment.

All information regarding the proposed project is
available for public review at the City of Cathedral City Civic Center, Planning Department, 68-700 Avenida
Lalo Guerrero during regular business hours (Monday
through Friday, 8:00 AM - 4:30 PM)

DATE AND TIME OF HEARING
September 24, 2025, at 5:30 PM, or as soon
thereafter as the matter may be heard.

PLACE OF HEARING
Cathedral City Civic Center — Council Chambers
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234
Any person may appear at the hearing and be heard
in support of, or opposition to, or provide other
testimony on the proposed project or environmental
determination. In addition, persons may also submit
written testimony on the proposed project or
environmental determination, which must be
received by the Project Planner prior to the close of
the public hearing.

The City Council, at the public hearing or during
deliberations, may approve, deny, or propose
changes to the project or to the environmental
determination.

If you challenge any of these items in court, you may
be limited to raising only those issues you or
someone else raised at the public hearing described
in this notice or in written correspondence.

For further information, contact the Project Planner
at:

Andrew Firestine, Director
Community and Economic Development
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234 (760) 770-0380
NOTE: In compliance with the Americans with
Disability Act, if you need special assistance to
participate in this meeting, please contact the
Planning Department at (760) 770-0340. Notification
48 hours prior to the meeting will enable the city to
make reasonable accommodations to ensure
accessibility to this meeting. {28 CFR 35.104 ADA
TITLE II}
Outlook
Cannabis issues Perez Rd. neighbors. Please give to the task force, planning, and city council.

From John Murphy <[email protected]>
Date Sun 8/10/2025 7:21 AM
To Andrew Firestine <[email protected]>; Talen Weinman <[email protected]> Thank you all for listening to us down here by Perez Rd. And Date Palm. After buying this mobile home in Date Palm Country Club 1.5 years ago, we have suffered continuously with cannabis smells coming INTO the house from underneath through the vents and AC/furnace. It is difficult to be woken up every night with the 'skunk-like' smell. I feel like at times, my retirement has been ruined. Plus, with oxygen dependency due to emphysema, it only makes things worse if one is sensitive like myself. We explored every avenue with the existing AC and furnace to try and mitigate the smell but to no avail. It was being pulled in. We wound up spending $22K dollars for mini-spits which do not pull outside air in. Why should we be financially punished for something we did not create? Most of the cannabis owners know the rules yet seem to not care at all or are not capable of putting in enough machinery to achieve smell mitigation. Mr. Firestine has done an amazing job of setting up some guidelines and expectations of the cannabis growers. I would hope the city passes this and begins demanding action RE the smells.

Everyone down here along the corridor of Perez is being made to suffer. Remember there are many folks employed in the area (car dealers, bars, restaurants, city hall etc.) who have no escape when they go to work. Please do the right thing and make the cannabis growers/producers accountable. They appear to be, by the looks of the remodels, capable of spending the necessary funds to make our area livable. If they can't, shut them down. It's actually pretty simple. Thank you.

John Murphy
137 Via Estrada
CC
760-218-1836
8/11/25, 5:04 PM Cannabis issues Perez Rd. neighbors. Please give to the task force, planning, and city council. - Andrew Firestine - Outlook about:blank?windowId=SecondaryReadingPane1 1/1
Outlook
Cannabis odor regulation
From Kathy Fuller <[email protected]>
Date Tue 7/22/2025 12:28 PM
To Talen Weinman <[email protected]>
You don't often get email from [email protected]. Learn why this is important I read the draft ordinance for the cannabis odor control. I appreciate the City trying to do something about this problem as I am very sensitive to odors and cannabis smell makes me nauseous. Several areas of the city have made me ill with the smell, notably, around the senior citizen center area and Perez.  My question is what are the limits  or standards of the olfactometer reading? I did not see it in the ordinance. The setbacks are a good idea, but what if one can still smell the odor outside the building? I see that there are fines, but what determines if the odor is too strong? Kathryn Fuller, Cathedral City resident
8/11/25, 5:05 PM Cannabis odor regulation - Andrew Firestine - Outlook about:blank?windowId=SecondaryReadingPane1 1/1
Outlook
Draft Cannabis Ordinance Feedback
From Jeff & Erin Fitzpatrick-Bjorn <[email protected]> Date Sat 7/26/2025 1:21 PM
To Talen Weinman <[email protected]>
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
CCO Weinman,
We appreciate the opportunity to provide feedback about the proposed ordinance regarding the production, sale, and consumption of cannabis in Cathedral City.

As property owners at Outdoor Resort Palm Springs, we have experienced the cannabis odors released by the cannabis production facility adjacent to the resort along Ramon Road. Despite continued assurances from that business, those bothersome odors have persisted for years.

It seems that this ordinance provides businesses like that one with a clear path to continue operation and the City with a clear path to issue citations and, if needed, revoke licenses in the event of failure to comply.

While we are glad that the City is considering implementation of this ordinance, we remain a bit disappointed that it has taken this long and has the potential to take much longer: this neighboring business could continue to fail to comply for yet another season before losing their license.

Here’s hoping that the City takes prompt action on the ordinance and, if needed, future enforcement — and that businesses such as the one on Ramon Road promptly and consistently comply.

Sincerely,
Jeff & Erin Fitzpatrick-Bjorn
69411 Ramon Road #1198
Cathedral City
8/11/25, 5:07 PM Draft Cannabis Ordinance Feedback - Andrew Firestine - Outlook about:blank?windowId=SecondaryReadingPane1 1/1
Outlook
Re: Draft Cannabis Ordinance Released for Public Review From Rick Watts <[email protected]>
Date Sat 7/19/2025 3:56 PM
To Ernesto Gutierrez <[email protected]>; Mark Carnevale <[email protected]>; Nancy Ross <[email protected]>; Raymond Gregory <[email protected]>; Rita Lamb <[email protected]>; Ryan Hunt <[email protected]>; Talen Weinman <[email protected]>; Andrew Firestine <[email protected]> 1 attachment (54 KB)
Friday July 18, 2025 9-39 AM VOC 535.jpg;
I received the documents sent by Mr. Hunt. The following are my ongoing issues:
1) The glacial speed of which the city is moving on the Cannabis Ordinance update. It will be way over a year since the citizen uprising began. Instead of fast tracking the resolution, the city council continues to drag their feet. Enforce the ordinances already in place. Why isn't that happening? 2) Cathedral City is the only valley city with shockingly absurd low fines for ordinance violations.

Cathedral City has the lowest level of penalties for all cities in the Coachella Valley with cannabis permits. Why is that? Fines and penalties are used as deterrents. It's even mentioned in the attached report by the consulting firm. How many fines have been levied against the C4 complex for ANY violations? I'm guessing the answer is ZERO. Cathedral City should have the same level of fines and penalties as the other cities. Not less. Then again, the monthly revenue tax collected by the city lessens the desire to enforce the existing ordinances. 3) Finally........ the consultant mentioned Volatile Organic Compounds (VOC's) . The odorless, colorless gas that continues to be released into the air by the C4 complex. Attached is a screen shot of a recent VOC reading taken by a monitoring system at my residence on Friday June 18, 2025 at 9:39 AM. It measures an incredible 535. According to Mr. Firestein in an earlier email to me, VOC's are "harmless." Since Mr. Firestein is an expert, perhaps he will explain what chemicals compose the VOC's being released by the C4 complex. All of the residents who live around the C4 complex would be interested in knowing what is contained in the VOC's other than the stink of cannabis. I have seen the VOC level as high as 750.
4) What has happened to the Code Compliance drive by inspections I used to see in the Desert Sands Community? The last time I saw a Code Compliance vehicle was several weeks ago. I frequently see CCPD vehicles passing my residence, mostly in the very early morning hours. At least they have stopped turning on their "Alley Lights" and shining into the windows in my residence. The smell of cannabis has been less because the HVAC systems are running due to the summer heat.

Of course, the "stink number" has diminished as a result. This distorts your calculations contained in the reports. Cannabis reports appears less than it actually is. But I am sure the city council has figured that out.
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5) What happened to the landscaping trees which were included in the original plans at the C4 complex? Trees were supposed to line the masonry walls between the Desert Sands Community and the Outdoor Resort of Palm Springs. The trees were to shield the C4 building from the other communities. All I see is a huge metallic building facing my residence. The city approved plans called for landscaping to block the ugly building. What do we have? Nothing. Any idea(s) how the C4 ownership manages to evade non-compliance to the original approved plans? All of the "fix" work by a consulting firm should be paid for by the ownership of the C4 complex. Not by the Cathedral City taxpayers. How much are the taxpayers being asked to pay for the consultant and equipment? How much is the C4 ownership being asked to pay for these expenditures? I suspect the answer is ZERO. By the time the city finishes messing around with the E-Z to fix problem, the Canadian's (well most of them) will be back in the valley to find out nothing has changed since they left in April/May.

Here is my prediction: I will be writing emails to the city council on this same topic well into 2026. The talk will continue but little else will be accomplished. I welcome any communication from anyone at city government.

Regards,
Rick Watts
1322 Via Poco (400 yards directly south of the C4 complex) Desert Sands Community
Cathedral City, Ca. 92234
[email protected]
760-408-3578
From: Ryan Hunt <[email protected]>
Sent: Thursday, July 17, 2025 1:21 PM
To: Ryan Hunt <[email protected]>
Subject: Draft Cannabis Ordinance Released for Public Review Dear Valued Community Member,
Here is your latest update on the City's cannabis enforcement activities and a major milestone in our regulatory improvement process:

Draft Cannabis Ordinance Released for Public Review
The City has prepared a comprehensive draft ordinance to update our cannabis regulations and has made it available for public review and comment before formal consideration by the Planning Commission and City Council. This represents our commitment to transparency and community engagement throughout the regulatory development process.

The draft ordinance incorporates months of research, consultant analysis, and data collection to address cannabis odor concerns through:
8/11/25, 5:07 PM Re: Draft Cannabis Ordinance Released for Public Review - Andrew Firestine - Outlook about:blank?windowId=SecondaryReadingPane1 2/4
Mandatory odor control plans for all cannabis businesses with performance-based standards Enhanced enforcement provisions that provide clear corrective action processes Updated zoning requirements including new setback requirements from the Resort Residential zone
Public Comment Opportunity
The draft ordinance and supporting materials are also available for review at:
https://www.cathedralcity.gov/Home/Components/News/News/2378/ Community members are encouraged to review these documents and submit comments electronically to Code Compliance Officer Talen Weinman at [email protected].

Upcoming Public Hearings:

Planning Commission: August 20, 2025 (tentative)
City Council: September 24, 2025 (tentative)
Interested parties are encouraged to monitor the City's website for published meeting agendas and information on how to participate in public hearings.

Timeline Commitment
The City remains on track with the timeline presented to City Council in April 2025. The draft ordinance represents the culmination of extensive research into best practices from other California jurisdictions, professional consultation with SCS Engineers, and ongoing monitoring data from our Code Compliance Division.

This transparent approach ensures that our community has ample opportunity to review and provide input on proposed regulations before they are formally considered for adoption.

Please continue to report any cannabis-related concerns through our online reporting system at https://www.cathedralcity.gov/i-want-to/contact/report-an-issue or the free MyCathedralCity mobile app.

Best regards,
Ryan Hunt, CPC
Communications & Events Manager
City of Cathedral City, California
[email protected]
Cell: 540.664.8556|Monday-Thursday 7 a.m. – 6 p.m.
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8/11/25, 5:07 PM Re: Draft Cannabis Ordinance Released for Public Review - Andrew Firestine - Outlook about:blank?windowId=SecondaryReadingPane1 4/4
Scott McDonald
69411 Ramon Road
Cathedral city, CA
92234
2025 August 18
Mayor and City Council
City of Cathedral City
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234
Subject: Urgent Strengthening of Cannabis Odor & Emissions Ordinance Dear Mayor, Councilmembers, Commissioners, and Task Force Members:

I live directly adjacent to a cannabis cultivation facility. Since the opening of C4 Industries, my neighbors and I have endured intrusive odors and emissions that interfere with daily life, reduce property enjoyment, lower property values, and raise serious health concerns.

While I appreciate the City’s efforts to update the cannabis odor ordinance, the current draft contains major flaws that will delay relief, weaken enforcement, and fail to address key public health risks.

Key Concerns
● Compliance Delay – Existing operators have until December 31, 2026 to install odor control equipment, leaving residents exposed for two more years. ● Weak Enforcement – Verified violations result in warnings and grace periods instead of immediate citations. The city has not issued an odor violation since 2019. ● High Odor Threshold – The 7 DT standard still permits disruptive odors and is not protective of residents.
● Self-Certification – Annual operator self-certification is inadequate; independent third-party verification is essential.
● VOC & Chemical Risks – Emissions include VOCs (terpenes) and potentially hazardous pesticides, fertilizers, and odor-masking agents. Boilers and chillers may release additional chemicals. No monitoring or health risk assessment is required yet it is the release of these compounds that result in verified negative health consequences such as burning eyes, skin irritation, congestion, etc. ● Unjustified Buffer Zones – Distances appear based on zoning convenience, not peer-reviewed studies or air dispersion modeling.
● Lack of Transparency – Residents have no access to odor test results or meteorological sensor data.

Requested Fixes
● Require odor control plan approval within 90 days and equipment operational within 6 months.
● Impose immediate citations for verified violations.
● Adopt a lower, health-protective odor threshold.
● Mandate annual independent third-party verification.
● Require disclosure of all chemicals used in cultivation, processing, boilers, chillers, and odor systems.
● Conduct independent VOC monitoring and health risk assessments, with public reporting.
● Reevaluate buffer zones using independent science and modeling. ● Publish odor and air quality data for public access.

Accountability Questions
● Why delay compliance until 2026?
● Why use warnings instead of citations for verified violations? ● What scientific evidence supports a 7 DT standard as protective? ● Why rely on operator self-certification instead of independent verification? ● What safeguards protect schools, seniors, and vulnerable populations? ● What hazardous chemicals are used, and how are residents protected? ● Has the City conducted a health risk assessment of cannabis emissions? ● What data support current buffer zones?
● Will monitoring data be made publicly accessible in real time? ● Why is enforcement handled by the same department that promotes cannabis development, creating a conflict of interest?
● What protections exist for residents who report odors, so complaints are not dismissed?
● Will the City commit to contracting independent experts for monitoring and enforcement?
I urge the Council to strengthen this ordinance and require written responses to these questions in the public record. Residents deserve protection now, not years from now.

Sincerely,

CANNABIS TASK FORCE

MINUTES
Regular Meeting 4:00 PM
Monday, August 18, 2025
City Hall
Study Session Room
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234

CALL TO ORDER
City Manager Charles McClendon called the meeting to order at 4:00 p.m.

ROLL CALL
Members Present:

Kenneth Churchill, Member
Danny Lee, Member
James Lawrence, Member
John Ramistella, Member
Matthew Goodman, Member
Members Absent:

Armando Perez, Member
Staff Present:

Tracey Hermosillo, City Clerk
Charles McClendon, City Manager
Anne Ambrose, Assistant City Manager
Andrew Firestine, Community and Economic Development Director Justin Gardiner, Code Compliance Manager
Kevin Biersack, Financial Services Director
Kevin Reza-Ayala, Analyst II
Manuel Rocha, Assistant Planner
Talen Weinman, Code compliance Officer

1. APPROVAL OF MINUTES
A. Accept the February 24, 2025 Minutes.

A motion was made by Member Lee and seconded by Member Lawrence to accept the February 24, 2025 Cannabis Task Force Minutes.

RESULT: PASS
MOVER: Danny Lee, Member
SECONDER: James Lawrence, Member
AYES: Churchill, Lee, Lawrence, Ramistella, Goodman
ABSENT: Perez

2. AGENDA
A. Cannabis Ordinance Amendments
Recommendation: This item is presented for information, discussion and possible recommendation to City Council.

City Manager Charles McClendon introduced Andrew Firestine, Community and Economic Development Director, who provided an overview of the Cannabis Ordinance and proposed update. He noted that the following members of the team from SCS Engineers were also in attendance and available for questions:

Paul Schafer
Christopher Petro
Eva Luu
Armando Hurtado-Garcia
He covered the following points:
• A background of ordinances regulating the licensing of cannabis businesses
• The number of cannabis businesses and licenses
• Issues related to cannabis odor
• The responses to issues related to cannabis odor
• Ongoing challenges
• The enactment of a moratorium on the approval of new cannabis licenses and conditional use permits and the issuance of building permits for the build-out or expansion of new cannabis businesses • The extension of the moratorium
• Actions staff has taken since the moratorium was put in place • Review of cannabis regulations related to zoning
• Review of cannabis regulations related to separation requirements • Review of cannabis regulations – odor control
• Review of cannabis regulations – odor enforcement
• Cannabis research – what other cities and counties are doing o Zoning questions asked
o Enforcement questions asked
• Review of zoning questions
• Consultant support of SCS Engineers
• SCS Engineers Report
• Odor control technology
• Overview of the proposed Ordinance
o Zoning Regulations
o Odor Control Plans
o Enforcement
o Licensing
o Cannabis Tax
• Review of alternatives and other considerations
• Overview of public outreach and engagement
• Recommendation that will be made to the City Council
There was discussion among the members of the committee, concerns were expressed, and questions were raised. Staff responded to questions raised and provided clarification along with members of the SCS Engineers team.

A motion was made by Member Churchill and seconded by Member Ramistella to recommend that the proposed Ordinance presented by staff be presented to the City Council for consideration and approval.

RESULT: PASS
MOVER: Kenneth Churchill, Member
SECONDER: John Ramistella, Member
AYES: Churchill, Lee, Lawrence, Ramistella
NOES: Goodman
ABSENT: Perez

3. PUBLIC COMMENTS
There were no members of the public in attendance.

ADJOURNMENT
City Manager Charles McClendon adjourned the Cannabis Task Force Meeting at 5:30 p.m.

Chair, City of Cathedral City Secretary, City of Cathedral City

PLANNING COMMISSION

MINUTES
Regular Meeting 6:00 PM
Wednesday, August 20, 2025
City Council Chambers
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234
CHAIR
Danny Lee

PLANNING COMMISSION MEMBERS
Vice-Chair
Danielle Mead
Commissioner
Peter Bedard
Commissioner
Rich Malacoff
Commissioner
Roy MacPhail

CALL TO ORDER
Chair Danny Lee called the meeting to order at 6:00 p.m.

ROLL CALL
Members Present:

Danny Lee, Chair
Danielle Mead, Vice Chair
Rich Malacoff, Commissioner
Roy MacPhail, Commissioner
Peter Bedard, Commissioner
Members Absent:

None
Staff Present:

Andrew Firestine, Director of Community and Economic Development Sandra Molina, Deputy Director of Community and Economic Development Stephanie Gutierrez, Assistant City Attorney
Cynthia Schultz, Associate Planner

PLEDGE OF ALLEGIANCE
Chair Lee led the Pledge of Allegiance.

AGENDA FINALIZATION
There were no changes to the agenda.

1. PUBLIC COMMENTS
There were no members of the public that wished to speak.

2. PUBLIC HEARING ITEMS
A. Zoning Ordinance Amendment 25-0004
Recommendation: Adopt a resolution recommending that the City Council approve an ordinance amending the Cathedral City Municipal Code, including the zoning ordinance, to amend the cannabis tax (chapter 3.48), licensing (chapter 5.88), permitting and zoning (chapter 9.108 and section 9.30.030), and enforcement (section 13.80.240) regulations related to cannabis uses and to amend various sections of the Municipal Code relating to administrative fines contained in titles 1, 3, 5, 8, 9, 11 and 14).

Andrew Firestine, Director of Community and Economic Development, provided the presentation and responded to questions.

Consultant, Armando Hurtado, SCS Engineers, responded to comments raised by the Commission.

Chair Lee opened the Public Hearing to receive public comments.

Public Comments:

Scott McDonald, Cathedral City, submitted written comments for the record.

Chair Lee closed the Public Hearing and returned discussion to the Commission.

The Commission took a brief recess at 7:51 p.m.

The Commission reconvened at 7:57 p.m.

A motion was made by Chair Lee and seconded by Commissioner MacPhail to approve staff’s recommendation as presented.

Discussion ensued regarding the implementation of separation requirements between cannabis businesses, and between cannabis uses and sensitive uses, including the Cathedral City Community Amphitheater, residential areas, adult daycares, places of worship, social service agencies, and parks.

Additionally, the Commission discussed the potential inclusion of a 7-day correction or cease operations action for odor-related issues, limits on the maximum size of cannabis cultivation facilities and public engagement requirements for future large cultivation facilities.

Following discussion, the Commission supported the deletion of cannabis cultivation uses in the PCC zone district, elected not to take action on any of the items discussed, with the exception of cannabis cultivation facility size limitations. The Commission expressed support for aligning the maximum size of future cannabis cultivation facilities to a maximum canopy area of 22,000 square feet, consistent with size limitations of the State’s Department of Cannabis Control, for large indoor cultivation facilities.

A motion was made by Vice Chair Mead and seconded Commissioner Bedard to accept an amendment to the proposed motion to include limits on the maximum size of cannabis cultivation facilities to 22,000 square feet of canopy area, in alignment with the State’s Department of Cannabis Compliance size categories and definition of a large indoor cultivation facility.

RESULT: PASS
MOVER: Danielle Mead, Vice-Chair
SECONDER: Peter Bedard, Commissioner
AYES: Lee, MacPhail, Mead, Bedard
NOES: Malacoff
A motion was made by Chair Lee and seconded by Commissioner MacPhail to adopt a resolution recommending that the City Council approve an ordinance amending the Cathedral City Municipal Code, including the zoning ordinance, to amend the cannabis tax (chapter 3.48), licensing (chapter 5.88), permitting and zoning (chapter 9.108 and section 9.30.030), and enforcement (section 13.80.240) regulations related to cannabis uses and to amend various sections of the Municipal Code relating to administrative fines contained in titles 1, 3, 5, 8, 9, 11 and 14) with the inclusion of limits on the maximum size of cannabis facilities to align with the State’s Department of Cannabis size categories and definition of a large indoor cultivation facility.

RESULT: PASS
MOVER: Danny Lee, Chair
SECONDER: Roy MacPhail, Commissioner
AYES: Lee, MacPhail, Mead, Bedard
NOES: Malacoff

3. NON-PUBLIC HEARING ITEMS
A. Development Code Update
Recommendation: For discussion.

Cynthia Schultz, Associate Planner, provided the update.

This item was advisory with no formal action taken by the Commission.

4. COMMISSIONER'S COMMENTS
Commissioner Bedard inquired about certain medians in the City that are no longer landscaped.

Chair Lee recommended Commissioner Bedard speak with Public Works Manager Deanna Pressgrove for an update.

Commissioner Malacoff discussed the upcoming opportunity to tour the Kings School campus.

5. CITY ATTORNEY COMMENTS
There were no comments from the City Attorney.

6. STAFF COMMENTS
A. Work Plan and Future Agenda Items
There were no staff comments.

ADJOURNMENT
Chair Lee adjourned the meeting at 9:05 p.m.

Danny Lee, Chair Andrew Firestine, Secretary
City of Cathedral City City of Cathedral City
RESOLUTION NO. ______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CATHEDRAL

CITY, CALIFORNIA, AMENDING THE SCHEDULE OF USER AND

REGULATORY FEES FOR VARIOUS CITY SERVICES TO ADD A FEE

FOR THE REVIEW OF AN ODOR CONTROL PLAN AND THE ANNUAL

CERTIFICATION OF AN CONTROL PLAN
WHEREAS, user and regulatory fees are established by the City Council; and WHEREAS, the City recently completed a study to identify the cost of providing various user and regulatory fee-related services; and
WHEREAS, the City Council adopted a schedule of fees through Resolution No. 2025-04 after finding that the study provides adequate evidence to conclude that the fees do not exceed the cost to provide the services for which the fees are charged; and WHEREAS, the schedule of fees contains provisions such that the City Manager may update the various fees based on the percentage change, for 12-months ending March of the current fiscal year, in the All Urban Consumers Price Index (CPI-U) for Riverside-San Bernardino-Ontario, to become effective July 1 of the subsequent fiscal year; and
WHEREAS, in order to assist staff in implementing the requested annual adjustments, if any, Exhibit “A” includes a column identified as “CPI” that illustrates the recommended annual adjustment pattern for the fees set forth in Exhibit “A”; and WHEREAS, this Resolution is adopted based upon the evidence submitted during the April 23, 2025, City Council meeting including, without limitation, all documents presented to the City Council; and
WHEREAS, in adopting this Resolution, the City Council is taking action only on those fees for the services, programs or products set forth in Exhibit “A” which have been modified from prior resolutions of the City Council. The remaining fees that have not been modified from prior resolutions shall remain in full force and effect.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY, DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS:

SECTION 1. INCORPORATION OF RECITALS
The City Council hereby finds the recitals set forth above to be true and correct.

SECTION 2. AMENDMENT TO FEE SCHEDULE AND ESTABLISHMENT OF

REVISED CANNABIS LICENSING AND USER PERMIT FEES FOR THE

REVIEW OF AN ODOR CONTROL PLAN AND THE ANNUAL

CERTIFICATION OF AN ODOR CONTROL PLAN
The City Council hereby adopts an amendment to the fee schedule as set forth in attached Exhibit “A” and incorporated by reference.

SECTION 3. EFFECTIVE DATE
This Resolution shall take effect upon adoption.

SECTION 4. CERTIFICATION
The City Clerk shall attest to and certify the vote adopting this Resolution.

PASSED, APPROVED AND ADOPTED at a regular meeting of the City Council of the City of Cathedral City held on this 23rd day of September, 2025, by the following vote:

Ayes:

Noes:

Absent:

Abstain:

Nancy Ross, Mayor
ATTEST:

Tracey R. Hermosillo, City Clerk
APPROVED AS TO FORM:

Eric S. Vail, City Attorney
“Exhibit A”
City of Cathedral City
Master Fee Schedule – Cannabis Licensing and User Permit Fees Fee Description Fee Charge Basis Note CPI
2 Odor Control Plan and Amendments (Cultivation and
Manufacturing)
3 Odor Control Plan and Amendments (Consumption Lounge) 4 Odor Control Plan and Amendments (Dispensary, Distribution, and Testing Lab)
5 Odor Control Plan Annual Certification

$3980
$3980
$480
$480
Each
each
each
each
Y
Y
Y
Y
RESOLUTION NO. ______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CATHEDRAL

CITY, CALIFORNIA, ESTABLISHING A SCHEDULE OF FINES FOR

ISSUING ADMINISTRATIVE CITATIONS IN THE CITY OF CATHEDRAL

CITY AND ESTABLISHING A GREATER ADMINISTRATIVE FINE

AMOUNT FOR A PUBLIC NUISANCE VIOLATION OF CANNABIS ODOR WHEREAS, California Government Code Section 53069.4 authorizes cities to impose and collect administrative fines and penalties for violations of any of its codes and ordinances; and
WHEREAS, the City Council of the City of Cathedral City (“City Council”) adopted Ordinance No. 504, establishing a comprehensive code enforcement program and procedures for the imposition, enforcement, review and collection of administrative penalties for violations of the Cathedral City Municipal Code (“CCMC”), which is codified in Sections 13.58.010 through 13.58.160 of the CCMC; and WHEREAS, the City Council has adopted Ordinance No. _____, amending Section 13.58.020(A) to consolidate the administrative fine schedules within the CCMC into a single section and to authorize the imposition of a fine as set in the CCMC or such amount that the City Council may establish by resolution; and WHEREAS, the City Council has adopted Ordinance No. _____, amending Section 13.80.240(J) to modify the enforcement procedures for a public nuisance violation of cannabis odor; and
WHEREAS, the City Council now desires to adopt a resolution establishing an administrative fine schedule, incorporating the currently established administrative fines for all other violations of the CCMC that exceed the default fine established in Section

13.58.020 of the Cathedral City Municipal Code and establishing a fine greater than the default fine for a public nuisance violation of cannabis odor of up to: 1) $1,000 for each day a violation exists for those cannabis businesses with an approved odor control plan compliant with Sections 5.88 and 9.108 of the CCMC; or 2) $5,000 per month for those cannabis businesses required to obtain approval of an odor control plan pursuant to Chapter 5.88 of the CCMC that have failed to obtain approval of, comply with, or maintain an odor control plan.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY, DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS:

SECTION 1. INCORPORATION OF RECITALS
The City Council hereby finds the recitals set forth above to be true and correct.

SECTION 2. ESTABLISHMENT OF ADMINISTRATIVE FINE SCHEDULE The City Council hereby adopts an administrative fine schedule as set forth in attached Exhibit “A” and incorporated by reference.

SECTION 3. EFFECTIVE DATE
This Resolution shall take effect upon adoption.

SECTION 4. CERTIFICATION
The City Clerk shall attest to and certify the vote adopting this Resolution.

PASSED, APPROVED AND ADOPTED at a regular meeting of the City Council of the City of Cathedral City held on this 23rd day of September, 2025, by the following vote:

Ayes:

Noes:

Absent:

Abstain:

Nancy Ross, Mayor
ATTEST:

Tracey R. Hermosillo, City Clerk
APPROVED AS TO FORM:

Eric S. Vail, City Attorney
“Exhibit A”
CCMC
Provision
Chapter Name 1st Administrative
Citation
2nd Administrative
Citation
3rd Administrative
Citation

5.94.030 Plastic Beverage
Straws
1,000a- -

13.80.240(J) Cannabis 1,000/5,000b
a $1,000 per violation
b 1) $1,000 for each day a violation exists for those cannabis businesses with an approved odor control plan compliant with Sections 5.88 and 9.108 of the CCMC; or 2) $5,000 per month for those cannabis businesses required to obtain approval of an odor control plan pursuant to Chapter 5.88 of the CCMC that have failed to obtain approval of, comply with, or maintain an odor control plan
8/26/2025 1
ORDINANCE NO. ____

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY CALIFORNIA AMENDING CHAPTERS 3.48, 5.88, 9.108, AND 13.240 AND SECTION 9.30.030 OF THE CATHEDRAL CITY MUNICIPAL CODE TO

SUBSTANTIALLY UPDATE THE CANNABIS TAX, CANNABIS LICENSING

AND ZONING REGULATIONS, AND ENFORCEMENT PROVISIONS,

INCLUDING THE ADDITION OF AN ODOR CONTROL PLAN AS A

CONDITION OF APPROVAL FOR A CANNABIS CONDITIONAL USE

PERMIT AND APPLYING THIS REQUIREMENT RETROACTIVELY TO

EXISTING CANNABIS BUSINESSES THROUGH THE ANNUAL RENEWAL

OF A CANNABIS LICENSE, THE DELETION OF CANNABIS CULTIVATION

AS A CONDITIONAL USE WITHIN THE PLANNED COMMUNITY
COMMERCIAL ZONING DISTRICT, THE ADDITION OF A 300 FOOT

SETBACK FROM ANY CULTIVATION, MANUFACTURING AND

DISTRIBUTION SITE TO A PROPERTY ZONED RESORT RESIDENTIAL,

AND THE MODIFICATION OF THE PUBLIC NUISANCE REGULATIONS TO

ESTABLISH A PROCESS FOR THE ENFORCEMENT OF CANNABIS

ODORS TOGETHER WITH MODIFICATIONS TO THE CANNABIS TAX AND

CANNABIS LICENSING REGULATIONS TO PROMOTE THE EFFICIENT

ADMINISTRATION OF THE CODE, TO REQUIRE LOCAL CANNABIS

TAXES BE MADE CURRENT PRIOR TO THE RENEWAL OF A LOCAL

LICENSE, TO ADD AN OPERATIONAL REQUIREMENT PRIOR TO THE

RENEWAL OF A DISPENSARY LICENSE, AND TO ALLOW TAX PAYMENT AGREEMENTS; AMENDING SECTION 13.58.020 TO ESTABLISH A

DEFAULT FINE FOR ADMINISTRATIVE FINES AND TO AUTHORIZE THE CITY COUNCIL TO ESTABLISH DIFFERENT FINES BY RESOLUTION; AND AMENDING SECTIONS 5.82 AND 5.94 AND REPEALING AND
RESERVING SECTIONS 1.04.080, 3.24.190, 3.28.990, 5.03.075, 5.08.110,

5.12.350, 5.18.240, 5.19.160, 5.20.200, 5.24.100, 5.30.160, 5.32.360,

5.33.480, 5.34.070, 5.35.130, 5.36.050, 5.38.140, 5.40.100, 5.44.090,

5.48.220, 5.52.220, 5.56.190, 5.60.380, 5.68.110, 5.70.210, 5.72.080,

5.74.060, 5.82.040, 5.94.030, 8.24.090(D), 8.26.190, 8.50.135, 8.57.090,

9.62.130(E), 9.89.160, 11.08.020(E)(5), 11.52.040(E), 11.74.140, 11.80.230,

11.97.190, 11.98.180, AND 14.28.160 TO CONSOLIDATE ADMINISTRATIVE

FINES THROUGHOUT THE CATHEDRAL CITY MUNICIPAL CODE IN A SINGLE SECTION.

WHEREAS, the City of Cathedral City (“City”) is a municipal corporation and charter city, duly organized under the constitution and laws of the State of California; and WHEREAS, the City is authorized by California Constitution, Article XI, Section 7 to make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws; and
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WHEREAS, pursuant to California Constitution, Article XI, Section 5 and Cathedral City City Charter Section 100, the City, as a charter city, has plenary authority to make and enforce within its limits all ordinances and regulations in respect to municipal affairs; and WHEREAS, pursuant to Business and Professions Code Section 26200(a)(1)–(2), State cannabis laws do not supersede or limit the authority of a city to adopt and enforce local ordinances regulating commercial cannabis-related activities and cannabis-related businesses; and
WHEREAS, the City permits and regulates certain cannabis businesses pursuant to Chapters 5.88 and 9.108 of the Cathedral City Municipal Code and adopted administrative regulations (“Cannabis Regulations”); and
WHEREAS, the City declares persistent cannabis odors offensive to individuals of normal sensitivity and which adversely impact or unreasonably interfere with the use and enjoyment of property a public nuisance and enforces nuisance cannabis odors and other violations of Chapters 5.88 and 9.108 of the Cathedral City Municipal Code through Section

13.80.240 of the Cathedral City Municipal Code; and
WHEREAS, in April 2024, the City began experiencing a higher number of cannabis odor complaints. Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor reports. Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024. These complaints frequently cite the interference with the use and enjoyment of their property; and
WHEREAS, the above-mentioned complaints concerning cannabis odors were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road with the balance of complaints pertaining to businesses located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza; and WHEREAS, Government Code Section 65858 allows cities to protect the public health, safety and welfare by adopting interim emergency moratoria in order to allow time to study whether certain land uses should be allowed, prohibited, or regulated under the City’s municipal code; and
WHEREAS, on January 22, 2025, the City Council adopted Ordinance No. ______, which enacted a forty-five (45) day interim moratorium on the approval or issuance of new licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use to a cannabis business as more particularly described therein (“Ordinance No. ______”); and
WHEREAS, on February 26, 2025, the City Council extended the moratorium enacted by Ordinance No. ______ for an additional period of ten (10) months and fifteen (15) days pursuant to Government Code Section 65858; and WHEREAS, since the adoption of Ordinance No. _________, the City has evaluated amendments to the Cannabis Regulations, including those related to zoning, locational requirements, standards, and enforcement provisions, fines and penalties; and 8/26/2025 3
WHEREAS, pursuant to Chapter 2.32 of the Cathedral City Municipal Code, the Cannabis Task Force, as an advisory body to the City Council on cannabis issues, reviewed and discussed a draft ordinance amending the Cannabis Regulations on ___________; and
WHEREAS, the Planning Commission conducted a noticed public hearing on those amendments to Chapter 9.108 of the Cathedral City Municipal Code on __________; and WHEREAS, the City has complied with the notice and public hearing requirements of Government Code Sections 65858(a) and 65090; and
WHEREAS, the report required by Government Code Section 65858(d) has been prepared and made available to the public at the City Clerk’s Office. In addition, the agenda report accompanying this ordinance provides the information required under Government Code section 65858(d).

THEREFORE, THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY DOES ORDAIN AS FOLLOWS:

SECTION 1. AMENDMENTS TO SECTION 5.88.025 OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 5.88.025 of the Cathedral City Municipal Code is amended to update the list of definitions applicable to the City’s cannabis regulations. Specifically, this section is amended to: 1) add new definitions describing odor control equipment and odor control plans; 2) add other new cannabis-related definitions; and 3) modify existing definitions, necessary for clarity and the efficient administration of the Cannabis Regulations. All added and revised definitions shall be inserted into Section 5.88.025 in proper alphabetical order.

The added and stricken definitions are as follows:
“Commercial cannabis activity” means any activity, recreational or medicinal, including the cultivation, possession, manufacturing, distribution, processing, storing, laboratory testing, packaging, labeling, transportation, delivery, or sale of cannabis and/or cannabis products as provided in this chapter.
“Cultivation” means any activity involving the planting, growing, harvesting, drying, curing, grading, or trimming of cannabis.
“Delivery” means the commercial transfer of cannabis or cannabis products to a customer. "Distribution site" means a facility where cannabis and cannabis products are stored or inspected by a distributor for the purposes of distribution. “Distribution” means the procurement, wholesale, and transport of cannabis and cannabis products between licensees, and may include the storage of packaged goods, coordination of compliance testing, packaging, re-packaging, labeling, re-labeling, and preparation of pre-rolls using previously-processed plant material.
"Manufacturing site" means a premises where a manufacturer engages in the manufacture of cannabis products.
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“Manufacturing” means a cannabis operation that engages in extraction and/or infusion processes, including processing, preparing, holding, storing, packaging, or labeling of cannabis products. Manufacturing also includes any processing, preparing, holding, or storing of components and ingredients. Manufacturing operations may involve the use of chemical solvents, heating, mixing, or other processes. “Odor control equipment” means any equipment utilized to counteract the distinguishable odor of the cannabis plant.
“Odor control plan” means a written plan prepared by a licensed professional engineer or certified industrial hygienist that describes the odor emitting activities or processes specific to a cannabis business together with a description of the methods used for odor control to ensure that odors are not detected off-site.
"Owner" means any of the following:

1. A person with an aggregate ownership interest of twenty percent or more in the person applying for a license or a licensee, unless the interest is solely a security, lien, or encumbrance.

2. The chief executive officer of a nonprofit or other entity.

3. A member of the board of directors of a nonprofit.

4. An individual who will be participating in the direction, control, or management of a cannabis facility on behalf of the owner of the license the person applying for a license.
“Testing laboratory” means a facility, laboratory, entity, or site that (i) offers or performs tests of cannabis or cannabis products, (ii) offers no service other than such tests, (iii) sells no products, excepting only testing supplies and materials, (iv) is accredited by any necessary accrediting body that is independent from all other persons involved in the cannabis industry in the state, and (v) is registered with any necessary state agency required by law.

SECTION 2. AMENDMENTS TO SECTION 5.88.040(C)(2) OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 5.88.040(C)(2) of the Cathedral City Municipal Code is amended to strike an unnecessary reference to the community development director, as follows:

2. Authorization for the local licensing authority and community development director to seek verification of the information contained within the application and authorization for the chief of police to conduct background checks of the owner(s). 8/26/2025 5
SECTION 3. AMENDMENTS TO SECTION 5.88.050(A) OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 5.88.050(A) of the Cathedral City Municipal Code is amended to authorize the chief of police or designee to conduct a background check as part of a transfer or change to the ownership of a license, as follows:

A. Change of Ownership. Subsequent to the issuance of a local license, the licensee shall report any transfer of ownership in the cannabis business to the local licensing authority on forms prescribed by the local licensing authority and pay the processing fee established by resolution of the city council. A change of ownership that solely involves a previously approved owner no longer being an owner of the cannabis business shall be reported to the local licensing authority within thirty days of the change. A change in ownership that involves adding a new owner to the previously approved ownership must be approved by the local licensing authority in advance. All proposed new owners must submit to a background check conducted by the chief of police or designee. The local licensing authority shall approve the change in ownership unless there is good cause to deny the change.

SECTION 4. AMENDMENTS TO SECTION 5.88.055 OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 5.88.055 of the Cathedral City Municipal Code is amended to insert new subsections and to reorder the remaining sections to address the payment of local cannabis taxes and to incorporate an operational requirement for the renewal of a dispensary license and to require an odor control plan with the renewal of a local license beginning January 1, 2026, as follows:

A. A cannabis business that desires to renew its license shall apply for the renewal no less than thirty days prior to the local license's expiration date. If the cannabis business files a renewal application within thirty days prior to expiration, the cannabis business must provide a written explanation detailing the circumstances surrounding the late filing. The local licensing authority may accept or reject such late filing in its discretion. The local licensing authority may elect to administratively continue a local license past its expiration date, provided that the licensee has submitted a renewal application that is pending final action.

B. An application for renewal shall be submitted on forms provided by the local licensing authority, accompanied by the processing fee established by resolution of the city council. The following information shall be submitted as a part of the renewal application:

1. A current list of the employees, independent contractors, and volunteers working at the licensed premises.

2. Proof that no changes to the ownership of the licensee have occurred since last approved by the local licensing authority.
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3. Proof that the licensee is still entitled to the possession and use of the licensed premises.

4. For dispensaries, proof that commercial cannabis activity is occurring on the premises in accordance with the following:
a. For a first renewal application, proof that commercial cannabis activity permitted by the license has been occurring on the premises for the previous month. A tax return submitted pursuant to Section 3.48.080 of this code showing that taxable commercial cannabis activity occurred on the premises shall be sufficient proof.
b. For a second and subsequent renewal application, proof that commercial cannabis activity permitted by the license has been occurring on the premises for the previous twelve consecutive months. Tax returns submitted pursuant to Section
c. 3.48.080 of this code showing that taxable commercial cannabis activity occurred on the premises shall be sufficient proof.
d. The local licensing authority may renew a license not meeting the requirements of subparagraphs a or b above if the renewal application demonstrates unique or extraordinary circumstances that have impacted the ability of the cannabis business to conduct commercial cannabis activity on the premises, including, but not limited to, fire, flood or other act of God resulting in substantial damage to the premises, or a delay in the issuance of necessary licenses, permits or other approvals necessary to conduct the commercial cannabis activity at no fault of the applicant.

5. For licensees that have ten or more full-time equivalent non-supervisorial employees, proof that the licensee has entered into and abided by the terms of a labor peace agreement.

6. Proof that the cannabis business is not delinquent on the submission of any tax returns or the payment of any taxes due under Chapter 3.48 of this code.

7. Any other information that the local licensing authority deems necessary to determine whether to renew the local license.

C. All owners of the cannabis business must be fingerprinted each year at renewal if required in the discretion of the local licensing authority.

D. The local licensing authority shall renew a local license if the licensee has submitted a complete application and paid the application processing fee, unless the local licensing authority finds that good cause exists to deny the license renewal.

E. Local cannabis taxes must be current prior to renewing licensees’ local cannabis license. Should a licensee hold multiple licenses within Cathedral City, their taxes for all licenses must be current to renew any one of their licenses. 8/26/2025 7
F. Licensees must be able to prove they have been operational for at least one month prior to the first renewal for any dispensary license by providing a paid tax return and prove they have been operational for 12 months prior to a second and all subsequent renewals for any dispensary license.

G. Unless administratively continued pursuant to subsection A, a local license is immediately invalid upon expiration and the cannabis business shall cease operations.

If a local license expires, the local licensing authority may approve a renewal of the expired license at any time up to three months from the expiration date of the license.

After the license has been expired for three months, the license may not be renewed by the local licensing authority, and the holder of the expired license must apply for and obtain a new cannabis license to resume operations.

H. Licenses initially issued on or before January 22, 2025, shall obtain approval of an odor control plan conforming with the requirements of this Chapter and Chapter 9.108 of the Cathedral City Municipal Code as a requirement of local license renewal beginning on January 1, 2026. Any additionally required odor control equipment to meet the requirements of this Chapter shall be installed and operational within 6 months of the local license renewal application date and no later than December 31, 2026. Thereafter, the renewal of any local license shall annually certify the performance of its odor control plan to the requirements of this Chapter and Chapter 9.108 of the Cathedral City Municipal Code.

SECTION 5. AMENDMENTS TO SECTION 5.88.065 OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 5.88.065 of the Cathedral City Municipal Code is amended to strike reference to a cannabis industry worker identification card in subsection (E), to substitute local license authority for the community development director in subsection (O), and to add subsections (W) and (X) to require the submittal and approval of an odor control plan for all cannabis businesses and the installation and maintenance of any odor control systems required as part of an approved odor control plan and to require meteorological (MET) sensors, as follows:

E. Worker Register. Cannabis businesses must maintain a complete register of all persons that work at the licensed premises or have access to cannabis or cannabis products, whether as an employee, independent contractor, or volunteer. This register must include:

1. The individual's complete name, address, and last known telephone number;

2. The individual's hire date and, if applicable date of termination;

3. A copy of the individual's city-issued cannabis industry worker identification card.

The register and required records must be made available for inspection by any city officer or official for purposes of determining compliance with the requirements of this 8/26/2025 8
chapter during standard business hours of the licensed facility or at any other reasonable time.

O. Community Relations Designee. A cannabis business must provide the local license authority community development director with the name, phone number, facsimile number, and email address of an on-site community relations representative or staff member or other representative to whom the city can provide notice if there are operating problems associated with the cannabis business or refer members of the public who may have complaints or concerns regarding the cannabis business. The cannabis business shall also provide this contact information to all neighboring businesses located within one hundred feet of the cannabis business, as measured in a straight line without regard to intervening structures, between the front doors of each establishment.

W. Odor Control Plan. A cannabis business shall obtain approval of an odor control plan pursuant to the requirements of Section 5.88.125. All required odor control equipment shall be installed and operational prior to the commencement of operations and shall be maintained in good working order. The licensee shall certify the performance of an odor control plan to the requirements of this Chapter annually with the renewal of a cannabis license.

X. Meteorological Sensors. All cultivation and manufacturing cannabis businesses shall install and maintain an onsite meteorological (MET) system capable of recording wind direction and wind speed and with cloud based data logging made accessible to the City. The MET sensors shall be calibrated annually. All data collected by the MET system shall be maintained and accessible for two years.

SECTION 6. AMENDMENTS TO SECTION 5.88.070(J)(4) OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 5.88.070(J)(4) of the Cathedral City Municipal Code is amended to modify the odor control requirements for on-premises consumption on the licensed premises of a dispensary to be internally consistent with other sections of the Cathedral City Municipal Code, as follows:

4. The cannabis business shall specifically address odors caused by the consumption of cannabis in the odor control plan required in Section

5.88.125. The cannabis business must install and maintain in good working order an odor control system in accordance with Section 9.108.080(A)(1). Odors caused by the consumption of cannabis at the dispensary must not be detectable from any public place. The cannabis business shall submit and abide by a certified odor control plan approved by the local licensing authority as a part of the license application and approval process. The plan shall include the use of a Vapor Phase System utilizing an odor neutralizer, such as Cannabolish or a similarly effective technology.
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SECTION 7. AMENDMENTS TO SECTION 5.88.075(A) OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 5.88.075(A) of the Cathedral City Municipal Code is amended to include an additional operational requirement for the manufacturing of edible cannabis products, as follows:

5. All cannabis manufacturing facilities shall ensure that cannabis is obtained from permitted and licensed cultivation sources and shall implement best practices to ensure that all manufactured cannabis is properly stored, labeled, transported, and inspected prior to distribution at a legally permitted and licensed retailer.

SECTION 8. AMENDMENT TO CHAPTER 5.88 OF THE CATHEDRAL CITY MUNICIPAL CODE TO ADD A NEW SECTION 5.88.125
Chapter 5.88 of the Cathedral City Municipal Code is amended to add a new Section

5.88.125 to create an odor control plan review process. § 5.88.125. Odor Control Plan
A. Purpose and content. Odor control plans are intended to be prepared and designed as performance-based systems for each cannabis business such that cannabis odors are not detected off-site. The odor control plan must specifically identify any administrative controls, engineering controls, process parameters, maintenance requirements, and training necessary to control cannabis odor together with detailed information and specifications on odor control equipment incorporated within the plan.

B. Application. A cannabis business shall submit and obtain approval of an odor control plan in a form acceptable to the community development director.

C. Fee. A fee as determined by resolution of the city council to defray the costs and expenses of the city in processing the application shall be paid prior to accepting the application for filing, no part of which fee shall be refundable to applicant.

D. Decision process. Upon receipt of a completed application as determined by the community development director, an odor control plan shall be reviewed for its ability to effectively mitigate odors from odor generating sources or adequately explain why odor control is not warranted. The community development director may request revisions or modifications to an odor control plan prior to rendering a decision to approve an odor control plan or otherwise place conditions of approval on an application.

E. Appeals. Decisions of the community development director may be appealed by the applicant to the planning commission by filing a written request along with the established city fee within ten business days of the date of the staff determination. The planning commission shall consider the appeal as a public hearing item. The determination of the planning commission shall be effective ten calendar days after the date of decision unless appealed to the city council, by written appeal filed with the city clerk, whose decision shall be final.
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F. Annual certification. A cannabis business shall certify in a form acceptable to the community development director the performance of its odor control plan to the requirements of this Chapter at the time of its annual license renewal. This annual certification shall further confirm the maintenance of any required odor control equipment.

G. Amendments. Amendments to an odor control plan shall demonstrate continued system effectiveness and compliance with this Chapter and Chapter 9.108.

Amendments to an odor control plan may be required as a result of corrective action taken by a cannabis business in response to enforcement action as set forth in Chapter 13.80. Amendments to an odor control plan may also be required to reflect operational or facility changes, including:
a. Modifications to odor control equipment, including the addition or deletion of equipment and changes to the type of odor control equipment; and b. Facility expansions, process changes, tenant improvements, or other activities that alter the generation of cannabis odors.

H. Installation of odor control equipment. For cannabis businesses established after January 22, 2025, all required odor control equipment shall be installed and operational prior to the commencement of operations. Cannabis businesses established on or before January 22, 2025 shall follow the requirements of Section

5.88.085(H) for the installation of any additionally required odor control equipment.

I. Maintenance. All required odor control equipment shall maintained in good working order.

J. Enforcement. Should an odor control plan fail to adequately mitigate cannabis odors to the standards of this section, the cannabis business may be subject to enforcement action for public nuisance cannabis odors as set forth in Chapter 13.80. Failure to comply with, obtain approval of, or maintain an odor control plan as required by this Chapter may be subject to enforcement action.

K. Prohibition. Vapor phase and misting systems shall not be permitted odor control equipment.

SECTION 9. AMENDMENTS TO SECTION 9.30.030 OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Section 9.30.030 of the City of Cathedral City Municipal Code is amended to strike cannabis cultivation sites as a conditional use within the Planned Community Commercial (PCC) zoning district, as follows:
§ 9.30.030. Conditional uses.

The following uses may be permitted subject to the issuance of a conditional use permit pursuant to Chapter 9.72:
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Any use involving outdoor activity or storage except those permitted uses listed in Section 9.30.020, parking appurtenant to other permissible uses; Auctions;
Automobile repair shops;
Automobile service stations;
Carwashes, limited to self-serve and full-serve only;
Commercial recreation facilities;
Cannabis cultivation sites;
Cannabis dispensaries;
Cannabis distribution sites;
Cannabis testing laboratories;
Fast-food restaurants and drive-thrus;
Game arcades;
Private clubs and lodges;
Public service facilities and public utility structures; Retail store—used;
Tattooing establishments (as defined by Chapter 5.34 of this code); Vehicle rental establishments and used vehicle sales (except used vehicles sold in conjunction with the operation of a manufacturer licensed new vehicle sales dealership) subject to the provisions of Section 9.96.170 pertaining to special provisions applying to miscellaneous uses;
Vocational or trade schools;
Such other similar uses as are approved by the planning commission.

SECTION 10. AMENDMENTS TO SECTION 9.108.070 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 9.108.070 of the City of Cathedral City Municipal Code is amended to modify an existing locational requirement for dispensaries, to add an additional locational requirement for cultivation, manufacturing and distribution sites, and to define how the setback is measured from the Resort Residential zone, as follows:
8/26/2025 12
§ 9.108.070 Locational requirements.

A conditional use permit for a cannabis business shall not be approved unless the proposed cannabis business will be located in a zoning district in which cannabis businesses of the type proposed are conditionally permitted. In addition, a conditional use permit shall not be approved for a cannabis business unless all of the following locational requirements applicable to the type of cannabis business proposed are satisfied:

A. Dispensaries. No dispensary shall be located:
a. Within six hundred feet of a school, day-care center, or youth center; or b. Within two hundred fifty feet of a residential zone. c. Within two hundred fifty feet of the RR (Resort Residential) zone, if the dispensary includes an area for the outdoor consumption of cannabis and cannabis products pursuant to Section 5.88.070(J).

B. Cultivation, Manufacturing and Distribution Sites. No cultivation, manufacturing, or distribution site shall be located:
a. Within six hundred feet of a school, day-care center, or youth center; or b. Within three hundred feet of a residential zone; or
c. Within three hundred feet of the RR (Resort Residential) zone.

C. All distances specified in this section shall be measured in a straight line, without regard to intervening structures or topography, from the nearest point of the building or structure in which the cannabis business is, or will be located, to the following locations, or until the city limit is reached. If the cannabis business is, or will be located, in a multi-unit building, the distances shall be measured from the nearest point of the suite in which the cannabis business is or will be located. a. Setbacks from schools, day-care centers and youth centers, shall be measured to the nearest property line of the parcel where such use is located. b. Setbacks from residential zones shall be measured to:
i. The nearest point of any legally permitted structure located in a residential zone; or
ii. If there is land within a residential zone with no legally permitted structure, the measurement shall be to the nearest property line unless the nearest property line is within the public right-of-way, in which case the measurement shall be to the edge of the right-of-way furthest from the proposed cannabis business.
c. Setbacks from the Resort Residential zone shall be measured to the nearest property line of the parcel.
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SECTION 11. AMENDMENTS TO SECTION 9.108.080 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 9.108.080 of the City of Cathedral City Municipal Code is amended to modify the condition of approvals for all cannabis businesses to require an odor control plan and to eliminate redundant language, as follows:
§ 9.108.080. Conditions of approval.

A. All Cannabis Businesses. Every cannabis business conditional use permit shall include the following conditions of approval.

1. The cannabis business shall submit and obtain approval of an odor control plan meeting the requirements of Chapter 5.88 of the Cathedral City Municipal Code. When required by the odor control plan, the cannabis businesses must install and maintain an the following odor control equipment or any other equipment which local licensing authority determines has the same or better effectiveness:
a. An exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or
b. An air system that creates negative air pressure between the cannabis businesses' interior and exterior so that the odors generated inside the cannabis business are not detectable outside the cannabis business.

Should compliance with the odor control plan fail to properly control odor, the local licensing authority may impose additional or modified plan restrictions.

SECTION 12. AMENDMENTS TO SECTION 13.58.020 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 13.58.020 of the City of Cathedral City Municipal Code is amended to establish a default fine for administrative fines and to authorize the City Council to establish different fines by resolution. This revision consolidates various other sections of the Cathedral City Municipal Code that independently set administrative fine amounts while also referencing Chapter 13.58. The changes also set the default fine levels to equal those specified in Cal.

Gov. Code §36900.
§ 13.58.020. Administrative fines.

A. Any party to whom an administrative citation is issued, shall be responsible for payment of an administrative fine, the amount of which shall be set forth in the applicable chapter of the municipal code. Any person issued an administrative citation, under this chapter, for each separate violation shall be subject to: (1) an administrative fine in an amount not to exceed one hundred dollars for the first citation, or such amount as the city council may establish by resolution; (2) an administrative fine in an amount not to exceed two hundred dollars for a second 8/26/2025 14
citation issued for the same offense within a twelve-month period from the date of the first offense, or such amount as the city council may establish by resolution; and (3) an administrative fine in an amount not to exceed five hundred dollars for a third and any subsequent citation issued for the same offense within a twelve-month period from the date of the first offense, or such amount as the city council may establish by resolution.

B. If payment of an administrative fine is not paid by the applicable deadline as set forth in Section 13.58.150, the following late fees shall apply and shall be added to the total amount owed by the violator:

1. Zero to thirty days after deadline: no late fee.

2. Thirty-one to sixty days after deadline: late fee equal to fifty percent of the initial underlying administrative fine.

3. Over sixty days after deadline: late fee equal to one hundred percent of the initial underlying administrative fine.

C. Processing fees actually incurred by the city shall be added to the total amount due and payable on every administrative fine, in addition to the base amount of the fine.

SECTION 13. AMENDMENTS TO SECTIONS 1.04.080, 3.24.190, 3.28.990,

5.03.075, 5.08.110, 5.12.350, 5.18.240, 5.19.160, 5.20.200, 5.24.100,

5.30.160, 5.32.360, 5.33.480, 5.34.070, 5.35.130, 5.36.050, 5.38.140,

5.40.100, 5.44.090, 5.48.220, 5.52.220, 5.56.190, 5.60.380, 5.68.110,

5.70.210, 5.72.080, 5.74.060, 5.82.040, 5.94.030, 8.24.090(D), 8.26.190,

8.50.135, 8.57.090, 9.62.130(E), 9.89.160, 11.08.020(E)(5), 11.52.040(E),

11.74.140, 11.80.230, 11.97.190, 11.98.180, AND 14.28.160 OF THE CITY

OF CATHEDRAL CITY MUNICIPAL CODE
Sections 1.04.080, 3.24.190, 3.28.990, 5.03.075, 5.08.110, 5.12.350, 5.18.240, 5.19.160,

5.20.200, 5.24.100, 5.30.160, 5.32.360, 5.33.480, 5.34.070, 5.35.130, 5.36.050, 5.38.140,

5.40.100, 5.44.090, 5.48.220, 5.52.220, 5.56.190, 5.60.380, 5.68.110, 5.70.210, 5.72.080,

5.74.060, 8.24.090, 8.26.190, 8.50.135, 8.57.090, 9.62.130(E), 9.89.160, 11.08.020(E)(5),

11.52.040(E), 11.74.140, 11.80.230, 11.97.190, 11.98.180, and 14.28.160 of the Cathedral City Municipal Code are repealed and reserved for future use. Each of these sections stipulates administrative fines for administrative citations that are proposed to be consolidated in Section 13.58.020.

SECTION 14. AMENDMENTS TO SECTION 5.82.040 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 5.82.040 of the Cathedral City Municipal Code is amended to model the standard language used throughout the Code authorizing the issuance of an administrative citation pursuant to Chapter 13.58.

The city may issue an administrative citation, pursuant to Chapter 13.58, to any person responsible for committing, causing or maintaining a violation of Any person issued an 8/26/2025 15
administrative citation for violating Sections 5.82.010, 5.82.020 and/or 5.82.030 of this chapter. shall for each violation be subject to: (1) an administrative fine in an amount not to exceed one hundred dollars for the first citation; (2) an amount not to exceed two hundred fifty dollars for a second citation issued for the same offense within a twelve-month period of the date of the first offense; and (3) a fine in an amount not to exceed five hundred dollars for a third and any subsequent citations issued for the same offense within a twelvemonth period of the date of the first offense.

SECTION 15. AMENDMENTS TO SECTION 5.94.030 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 5.94.030 of the Cathedral City Municipal Code is amended is amended to model the standard language used throughout the Code authorizing the issuance of an administrative citation pursuant to Chapter 13.58
In addition to any other remedy provided for by this code, any violation of the provisions of this chapter by any beverage provider is subject to administrative citation pursuant to Chapter 13.58 of this code. The administrative fine for each violation shall be one thousand dollars or as is otherwise set by resolution of the city council.

SECTION 16. AMENDMENTS TO SECTION 13.80.240(J) OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 13.80.240(J) of the Cathedral City Municipal Code is amended to modify the definition of cannabis odors that constitute a public nuisance and to incorporate cannabis odor control plans into the response to a nuisance odor. For those cannabis businesses with an approved and compliant odor control plan, the response is a written warning and a requirement to make modifications to an odor control plan within 10 days. The modifications detail potential corrective actions, including the potential for a cannabis odor assessment at the property line. Upon reinspection, if cannabis odors persist, the City may issue an administrative citation and the business may be fined for each and every day a violation persists. The modifications also address businesses that are required to have an odor control plan and have not done so or have otherwise not complied with or maintained an odor control plan. The amendments also reference Chapter 5.88 of the Cathedral City Municipal Code and what constitutes good cause for denying a local license renewal or the suspension or revocation of a local license.

J. To cause or permit persistent cannabis odors that are offensive to individuals of normal sensitivity and which adversely impact or unreasonably interfere with the use and enjoyment of property, to:

1. Emanate across any property line.

2. Emanate across a common wall or otherwise be detectable within an adjacent or nearby unit in a multi-tenant building or in a multi-family residential building that is occupied by another.

For the purposes of this subsection J, cannabis odors shall be presumed to be persistent, offensive to individuals of normal sensitivity, and adversely impacting or 8/26/2025 16
unreasonably interfering with the use and enjoyment of property, if the city receives three or more verified complaints from individuals representing separate residences or places of business within the city of a persistent cannabis odor emanating from the subject property within a one- month time span. Nothing in this subsection shall be deemed to require three complaints before the city may initiate enforcement action. The city may determine that a public nuisance exists under this subsection J if less than three complaints are received or even if no complaints are received but city officials or employees notice odor conditions that violate this subsection J.

The City may initiate enforcement action either as a result of its direct observation of cannabis odors or in response to the receipt of three or more verified cannabis odor complaints within a one-month time span. Cannabis odor complaints may be verified by meteorological data, direct observation, or any other means that both: 1) establish the presence of nuisance cannabis odors in violation of this subsection; and 2) attribute the cannabis odors to a cannabis business or cannabis businesses. The city council shall establish fines, penalties, and other charges for violation of this subsection by resolution, which may be amended from time to time.

Notwithstanding any other provision of this Chapter, if a cannabis business with an approved odor control plan compliant with Sections 5.88 and 9.108 of the Cathedral City Municipal Code violates this subsection, the City may issue the business a written warning and the licensee shall take corrective action within ten days. The cannabis business shall submit a written statement at the end of the ten day period documenting the corrective actions taken. As part of the corrective action process, the cannabis business shall review and confirm the maintenance of its odor control equipment and shall review and confirm the measures contained within its approved odor control plan are being followed. As part of the corrective action process, the City may require a cannabis business to conduct a cannabis odor assessment using an odor assessment method acceptable to the City. The City may, at its discretion, grant a cannabis business additional time to implement additional corrective actions to mitigate nuisance cannabis odors, including the repair or replacement of cannabis odor control equipment or the installation of additional cannabis odor control equipment or other updates or modifications proposed through an amendment to a cannabis odor control plan. Upon reinspection, if a continued violation is observed, the City may issue the licensee an administrative citation for each day a violation continues.

If a cannabis business required to obtain approval of an odor control plan pursuant to Chapter 5.88 of the Cathedral City Municipal Code both violates this subsection J and fails to obtain approval of, comply with, or maintain an odor control plan, the City may issue an administrative citation. The cannabis business shall have 30 days to take corrective action to fully comply with all requirements of Chapters 5.88 and 9.108 of the Cathedral City Municipal Code.

The cannabis business shall be issued an administrative citation for each subsequent month the licensee fails to obtain approval of, comply with, or 8/26/2025 17
maintain an odor control plan. If a permittee receives three administrative citations under this paragraph within a 12-month period, those citations shall constitute good cause for denying a local license renewal or the suspension or revocation of a local license pursuant to Chapter 5.88 of the Cathedral City Municipal Code.

Prior to December 31, 2026, if a cannabis business violates this subsection and has not submitted or received approval of an odor control plan as required by Section 5.88.055(F), the cannabis business, regardless of its license renewal date, shall have 30 days to submit an odor control play complying with all requirements of Chapters 5.88 and 9.108 of the Cathedral City Municipal Code. The City may issue an administrative citation if a cannabis business in violation of this subsection fails to timely submit or obtain approval of an odor control plan. If a cannabis business violates this subsection based on engaging in cannabis activity that it is not licensed for, the City may issue an administrative citation and the citation shall constitute good cause for denying a local license renewal or the suspension or revocation of a local license pursuant to Section 5.88 of the Cathedral City Municipal Code.

Any person who violates any provision of this subsection is guilty of a misdemeanor.

SECTION 17. AMENDMENTS TO SECTION 3.48.020 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 3.48.020 of the Cathedral City Municipal Code is amended to update the list of definitions applicable to the City’s cannabis tax. All revised definitions shall be inserted into Section 3.48.020 in proper alphabetical order. The revised definitions are as follows:
"Cannabis" means all parts of the plant Cannabis sativa Linnaeus, Cannabis indica, or Cannabis ru-deralis, whether growing or not; the seeds thereof; the resin, whether crude or purified, extracted from any part of the plant; and every compound, manufacture, salt, derivative, mixture, or preparation of the plant, its seeds, or resin. "Cannabis" also means the separated resin, whether crude or purified, obtained from marijuana. "Cannabis" also means marijuana as defined by Section 11018 of the Health and Safety Code as enacted by Chapter 1407 of the Statutes of 1972. "Cannabis" does not include the mature stalks of the plant, fiber pro-duced from the stalks, oil or cake made from the seeds of the plant, any other compound, manufacture, salt, derivative, mixture, or preparation of the mature stalks (except the resin extracted therefrom), fiber, oil, or cake, or the sterilized seed of the plant which is incapable of germination, nor paraphernalia used to consume cannabis products. For the purpose of this chapter, "cannabis" does not mean "industrial hemp" as defined by Section 81000 of the Food and Agricultural Code or Section 11018.5 of the Health and Safety Code.
"Cannabis business" means any person engaged in commercial cannabis activity, including cultivation, possession, manufacture, processing, storing, laboratory testing, labeling, transporting, distribution, or sale of cannabis or a product containing cannabis. A cannabis 8/26/2025 18
business does not include any business whose activities are limited exclusively to the production or sale of cannabis accessories.
"Cannabis concentrate" means cannabis that has undergone a process to concentrate the cannabinoid active ingredient, thereby increasing the product's potency. Types of cannabis concentrate include, but are not limited to, hash, butane hash oil, CO2 oil, kief, dry sift, Rick Simpson oil, and rosin. A cannabis concentrate is not considered food, as defined by Section 109935 of the Health and Safety Code, or a drug, as defined by Section 109925 of the Health and Safety Code.
"Cannabis cultivation space" means the gross square footage of any building, facility or site, including any limited access area, where cannabis cultivation and related activities occur. Cannabis cultivation space includes, without limitation, areas used for growing, planting, seeding, germinating, lighting, warming, cooling, aerating, fertilizing, watering, irrigating, tipping, pinching, cropping, curing or drying cannabis, and areas used for storing products, supplies or equipment related to any such activities. Cannabis cultivation space does not include any part of a building, facility or site where cannabis cultivation and related activities occurs that is used for cannabis business activities that are separately taxed under this chapter.
"Dispensary" means a facility where cannabis, cannabis concentrate, cannabis extracts, and cannabisinfused products are sold, or devices for the use of cannabis, cannabis concentrate, cannabis extracts, and cannabisinfused products are offered, either individually or in any combination, for retail sale, and may also include the sale of devices for the use of cannabis, cannabis concentrate, cannabis extracts, and cannabis-infused products, including an establishment that delivers cannabis and cannabis products as part of a retail sale.
"Gross receipts" except as otherwise specifically provided, means the total amount actually received or receivable from all sales; membership dues; reimbursements; the total amount or compensation actually received or receivable for the performance of any act or service, of whatever nature it may be, for which a charge is made or credit allowed, whether or not such act or service is done as a part of or in connection with the sale of cannabis and cannabis products; the monetary value of in-kind contributions; discounts, rents, royalties, fees, commissions, dividends, and gains realized from trading in stocks or bonds, however designated. Included in "gross receipts" shall be all receipts, cash, credits and property of any kind or nature, without any deduction therefrom on account of the cost of the property sold, the cost of materials used, labor or service costs, interest paid or payable, or losses or other expenses whatsoever, except that the following shall be excluded therefrom: (1) cash discounts allowed and taken on sales; (2) credit allowed on property accepted as part of the purchase price and which property may later be sold, at which time the sales price shall be included as gross receipts; (3) any tax required by law to be included in or added to the purchase price and collected from the consumer or purchaser; (4) such part of the sale price of any property returned by purchasers to the seller as refunded by the seller by way of cash or credit allowances or return of refundable deposits previously included in gross receipts; (5) receipts from investments where the holder of the investment receives only interest and/or dividends, royalties, annuities and gains from the sale or exchange of 8/26/2025 19
stock or securities, provided such items are directly derived exclusively from the investment of capital and not from the sale of property other than financial instruments, or from the provision of services, to any person; (6) receipts derived from the occasional sale of used, obsolete or surplus trade fixtures, machinery or other equipment used by the cannabis business in the regular course of the cannabis business' business; (7) whenever there are included within the gross receipts amounts which reflect sales for which credit is extended and such amount proved uncollectible in a subsequent year, those amounts may be excluded from the gross receipts in the year they prove to be uncollectible; provided, however, if the whole or portion of such amounts excluded as uncollectible are subsequently collected, they shall be included in the amount of gross receipts for the period when they are recovered; (8) receipts of refundable deposits, except that such deposits when forfeited and taken into income of the business shall not be excluded when in excess of one dollar; (9) amounts collected for others where the business is acting as an agent or trustee and to the extent that such amounts are paid to those for whom collected; (10) credit and debit card processing fees, provided such fees are separately stated and not retained by the cannabis business. These agents or trustees must provide the finance department with the names and the addresses of the others and the amounts paid to them. This exclusion shall not apply to any fees, percentages, or other payments retained by the agent or trustees.

SECTION 18. AMENDMENTS TO SECTION 3.48.070 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 3.48.070(C) of the Cathedral City Municipal Code is amended to increase the frequency of the requirement to review and report the total amount of revenue raised from the cannabis tax, as follows:

C. The city manager or the city manager's designee shall review the cannabis taxes imposed by this chapter on a quarterly basis and convene a meeting and/or publish a report/minutes detailing the total amount of revenue raised from the cannabis tax. The city manager or the city manager's designee shall annually review the cannabis taxes imposed by this chapter and publish a report detailing the total amount of revenue raised from the cannabis tax.

SECTION 19. AMENDMENTS TO SECTION 3.48.080 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 3.48.080 of the Cathedral City Municipal Code is amended to make minor modifications to the returns and remittance requirements for the purpose of clarifying existing requirements and creating internal consistency, as follows:

The tax shall be due and payable as follows:

A. All cannabis businesses subject to this chapter shall, on or before the last day of the month following the close of each calendar month, or such different reporting period as may be established by the city manager or the city manager's designee, file a tax return with the city manager or the city manager's designee on forms provided by the 8/26/2025 20
city manager or the city manager's designee, of the amount of tax owed for the reporting period preceding calendar month.

B. The return shall be filed whether or not taxes are owed during the month.

C. Each such return shall contain a declaration under penalty of perjury, executed by the cannabis business or authorized agent, that to the best of the signatory's knowledge, the statements in the return are true, correct and complete.

D. At the time the return is filed, the full amount of the tax owed for the reporting period preceding calendar month shall be remitted to the city manager or the city manager's designee.

E. Returns and accrued tax payments are due immediately upon cessation of business for any reason.

F. Returns and taxes not received by the city manager or the city manager's designee on or before the due date as provided in this section are delinquent and subject to the penalties imposed under Section 3.48.090.

G. Returns filed and taxes remitted by mail shall be deemed timely filed only if the envelope or similar container enclosing the returns and taxes is addressed to the city manager or the city manager's designee, has sufficient postage, and bears a United States postmark or a postage meter imprint prior to midnight on the last day for reporting and remitting without penalty. If the envelope or other container bears a postage meter imprint as well as a United States Post Office cancellation mark, the latter shall govern in determining whether the filing and remittance are timely. If the city manager is provided with credible evidence that a return or payment was deposited in the United States mail on or before the required due date, the city manager may, at their discretion, consider the filing or remittance to have been made on time.

H. The city manager or the city manager's designee is not required to send a delinquency or other notice or bill to any person subject to the provisions of this chapter; and failure to send such notice or bill shall not affect the validity of any tax or penalty due under the provisions of this chapter.

SECTION 20. AMENDMENTS TO SECTION 3.48.090 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 3.48.090 of the Cathedral City Municipal Code is amended to make minor modifications for the purpose of clarifying existing requirements, as follows:

A. Any person who fails or refuses to pay any tax required to be paid pursuant to this chapter on or before the due date shall pay penalties and interest as follows:

1. A penalty equal to twenty-five percent of the amount of the tax in addition to the amount of the tax, plus interest calculated from the due date on the total unpaid balance, including tax and penalty. 8/26/2025 21

1. A penalty equal to twenty-five percent of the amount of the tax in addition to the amount of the tax, plus interest on the unpaid tax calculated from the due date of the tax at a rate established by resolution of the city council. ; and

2. An additional penalty equal to twenty-five percent of the amount of the tax if the tax remains unpaid for a period exceeding one calendar month beyond the due date, plus interest on the unpaid tax and interest on the unpaid penalties calculated at the rate established by resolution of the city council.

B. Whenever a check is submitted in payment of a tax and the check is subsequently returned unpaid by the bank upon which the check is drawn, and the check is not redeemed prior to the due date, the cannabis business will be liable for the tax amount due plus penalties and interest as provided for in this section plus any additional banking fees or charges any amount allowed under state law.

C. The tax due shall be that amount due and payable from January 1, 2014 or the first date on which the cannabis business first operated in the city, whichever date occurred last, together with applicable penalties and interest calculated in accordance with subsection A of this section.

D. The city manager may waive the first penalty and second penalties of twenty-five percent each imposed upon any person if:

1. The person provides evidence satisfactory to the city manager that failure to pay timely was due to circumstances beyond the control of the person and occurred notwithstanding the exercise of ordinary care and the absence of willful neglect, and the person paid the delinquent business tax and accrued interest owed the city prior to applying to the city manager for a waiver.

2. The waiver provisions specified in this subsection shall not apply to interest accrued on the delinquent tax and a waiver shall be granted only once to the same person or entity during any twenty-four-month period.

SECTION 21. AMENDMENTS TO SECTION 3.48.100(D) OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE
Section 3.48.100(D) of the Cathedral City Municipal Code is amended to strike reference to a form, as follows:

D. Whenever the amount of any tax, penalty, or interest has been overpaid, paid more than once, or has been erroneously or improperly collected or received by the city under this chapter, the overpayment may be refunded as provided in subsections (E) and (F), provided a claim in writing under penalty of perjury stating the specific grounds upon which the claim is founded is filed with the city manager or the city manager's designee within three years of the date of payment. The claim shall be on forms available from the city manager or the city manager's designee. 8/26/2025 22
SECTION 22. AMENDMENTS TO CHAPTER 3.48 OF THE CITY OF CATHEDRAL

CITY MUNICIPAL CODE
Chapter 3.48 of the Cathedral City Municipal Code is amended to add a new Section

3.48.140 for the purpose of regulating tax payment arrangement agreements, as follows:
§ 3.48.140 Tax Payment Arrangements.

The City finds that authorizing tax payment arrangement agreements (“agreements”) with individuals or entities delinquent in cannabis-related tax payments serves the best interests of the City. These agreements offer a practical means of enhancing tax recovery efforts while also affording taxpayers a pathway to financial recovery and future compliance.

A. The City Manager, or designee, may offer tax payment arrangements to individuals or businesses with outstanding cannabis-related tax obligations.

B. The City Manager, or designee, shall have the sole authority to negotiate, execute and bind the City into a tax payment arrangement agreements, and any amendments thereto, for the full amount of the taxes owed.

C. The tax payment arrangement agreement shall be prepared to the satisfaction of the City Manager, or designee. The City Attorney shall review and approve the agreement and any amendments as to form.

D. Entering into a payment agreement does not prevent the City from pursuing any other methods it deems necessary to recover unpaid taxes.

E. A single tax payment arrangement agreement may be authorized and maintained per ownership associated with a cannabis license. In the event of a change in ownership, any existing agreement may be deemed void at the sole discretion of the City Manager, or designee.

SECTION 23. AMENDMENTS TO SECTION 9.108.080 OF THE CITY OF

CATHEDRAL CITY MUNICIPAL CODE TO LIMIT CANNABIS CULTIVATION CANOPY AREA
Section 9.108.080 of the City of Cathedral City Municipal Code is amended to add a new condition of approval (5) to subsection (C) to restrict the total canopy area to a maximum of 22,000 square feet, as follows:

5. The total area of the premises designated/used for the cultivation canopy shall not be more than 22,000 square feet for every conditional use permit application approved.

SECTION 24. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) Adoption of this ordinance is exempt from the requirements of the CEQA and is not considered a project under Division 13 (commencing with Section 21000) of the California Public Resources Code.
8/26/2025 23
SECTION 25. SEVERABILITY
If any chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion of this ordinance, is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision will not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have adopted this ordinance, and each chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof be declared invalid or unconstitutional.

SECTION 26. POSTING
The City Clerk shall, within fifteen (15) days after passage of this Ordinance, cause it to be posted in at least three (3) designated public places; shall certify to the adoption and posting of this Ordinance; and shall cause this Ordinance and its certification, together with proof of posting, to be entered in the Book of Ordinances of this City.

SECTION 27. MORATORIUM
Urgency Ordinance No. ______________, imposing a temporary moratorium on the approval of licenses, permits, approvals, or other entitlements for use, including any modification thereof, for cannabis businesses, within the City of Cathedral City is hereby repealed as of the effective date of this Ordinance.

SECTION 28. CERTIFICATION
The foregoing Ordinance was approved and adopted at a meeting of the City Council held on the ____ day of _____________, 2025, by the following vote:

Ayes:

Noes:

Abstain:

Absent:
___________________________
Nancy Ross, Mayor
ATTEST:
____________________________
Tracey Hermosillo, City Clerk
8/26/2025 24
APPROVED AS TO FORM:
____________________________
Eric S. Vail, City Attorney
Staff Report
City Council
Item No. 5.A
Meeting Date: January 22, 2025
From: Andrew Firestine, AICP, Director of Community and Economic Development
Title: Urgency Ordinance Adopting A 45-Day Interim Moratorium on the Approval of New Cannabis Licenses and New Cannabis Conditional Use Permits and the Issuance of Building Permits for the Build-out or Expansion of New Cannabis Businesses
RECOMMENDATION:

Staff recommends approval of the urgency ordinance adopting a 45-day initial moratorium on the approval of new cannabis licenses and conditional use permits and the issuance of building permits for the build-out or expansion of new cannabis businesses.

BACKGROUND:

On October 25, 2017, the City Council adopted Ordinance Nos. 800 and 801 establishing a set of regulations allowing adult-use cannabis businesses to operate within the City. These regulations were created to provide the public with a clear understanding of the process for obtaining City approval to operate a cannabis business within the City. These regulations were codified within the Cathedral City Municipal Code in chapters 5.88 and 9.108 and have been amended since their adoption, with the last amendment in 2022.

Chapter 5.88 provides for the regulation and licensing of medical and adult-use cannabis business throughout the City in conformance with applicable state and local laws and regulation pertaining to medicinal and adult use cannabis.

Chapter 9.108, as currently codified is contained in Title 9 of (Zoning Ordinance) of the Municipal Code, regulates cannabis business land uses, including the zone districts where cannabis uses are permitted, as authorized by section 26200 of the California Business and Professions Code, in a manner designed to minimize negative impacts on the City and neighboring uses, and to promote the health, safety, morals, and general welfare of residents and businesses within the City.

The City currently has 64 cannabis businesses with 105 licenses comprised of 46 operating businesses with 67 licenses and 16 non-operational businesses with 38 licenses.

DISCUSSION:

In April 2024, Cathedral City began experiencing a higher number of cannabis odor complaints. Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor reports. Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024. These complaints frequently cite the interference with the use and enjoyment of their property.

The complaints concerning cannabis odors were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road with the balance of complaints pertaining to businesses located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza.

Despite staff efforts to manage the complaints through additional inspections of cannabis businesses, increased proactive patrols, and specific actions by cannabis businesses to mitigate odors, the City has seen an increase in the number of cannabis odor complaints.

While there are likely multiple reasons for this, not all of which have been identified at this point, there are two explanatory factors that stand out: 1) a 325,000 square foot cannabis cultivation use started operations in 2024 in the vicinity of Date Palm Drive and Ramon Road; and 2) the City has a large concentration of cannabis businesses located off of located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza.

The large cannabis cultivation use was conditioned to provide an odor absorbing ventilation and exhaust system that prevents internal odor from being emitted externally. They have been required by the City to install additional odor mitigation, including a fogging system, which was installed on November 29, 2024. The City has continued to receive cannabis odor complaints related to this business since the installation of the fogging system.

The concentration of cannabis businesses off Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza has presented challenges with respect to identifying the source of a complaint. Collectively, the cumulative volume of complaints citing the interference with the use and enjoyment of property and the limited effect actions to date have had in mitigating these complaints necessitate a review of the City’s cannabis regulations, with particular emphasis on zoning, odor control, and enforcement.

California Government Code section 65858 provides statutory authority for interim ordinances prohibiting uses that may conflict with a contemplated general plan, specific plan or zoning proposal that the city is studying or plans to study. An interim ordinance, commonly called a moratorium, imposes temporary land use controls based on a documented, current and immediate threat to public health, safety, and welfare. An interim ordinance protects and promotes the planning process by prohibiting the introduction of potentially nonconforming land uses that could defeat or impair a later adopted general plan or zoning ordinance.

Procedurally, such an ordinance may be adopted initially without a public hearing following a 4/5 vote of the legislative body. The initial moratorium lasts for 45 days. After notice and a public hearing, the ordinance may be extended, again with a 4/5 vote, for an additional 10 months and 15 days.

Thereafter, the ordinance may be extended for one additional year, again with a 4/5 vote.

No more than two extensions may be adopted. The City Council cannot adopt or extend any interim ordinance unless the ordinance contains a finding that there is a current and immediate threat to the public health, safety or welfare, and that the approval of applicable land use entitlements would result in that threat to public health, safety or welfare. Ten (10) days prior to the expiration of such an ordinance or any extension, a written report is to be issued describing the measures taken to alleviate the condition that led to the adoption of the ordinance.

The adoption of the urgency ordinance would allow the City to begin an assessment of its cannabis regulations, including those on zoning, odor control, and enforcement. It is not expected that this full evaluation will occur within the initial moratorium period but rather the period will be used to develop a comprehensive strategy, including future public outreach and engagement with the cannabis industry and engagement with the Cannabis Task Force and the Planning Commission. This strategy will be presented at the February 26, 2025, City Council meeting together with an extension of the moratorium.

The urgency ordinance is written to prohibit new cannabis licenses and conditional use permit applications for all cannabis business types while the moratorium is in effect together with the issuance of new building permits that would permit the build-out and development of an approved cannabis license and conditional use permit where no building permit had been previously issued. The urgency ordinance excludes the renewal or transfer of existing cannabis licenses, except where the transfer is to a new location without an approved conditional use permit or where the transfer proposes an amendment or modification to an approved conditional use permit, such as for an expansion or a change in use. It also excludes the issuance of building permits to existing cannabis businesses with an approved cannabis license and conditional use permit where the building permit does not involve the build-out or expansion of the use but rather pertains to the ordinary use and maintenance of the business.

FISCAL IMPACT:

N/A
FIVE-YEAR STRATEGIC PLAN:

F-11 – Implement a code compliance program that proactively identifies and responds to code compliance complaints
ATTACHMENTS:

1. Interim Urgency Ordinance
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ORDINANCE NO. _____

AN INTERIM URGENCY ORDINANCE OF THE CITY COUNCIL OF THE

CITY OF CATHEDRAL CITY, CALIFORNIA, ADOPTING AND

IMPOSING A TEMPORARY MORATORIUM ON THE APPROVAL OF

LICENSES, PERMITS, APPROVALS, OR OTHER ENTITLEMENTS FOR

USE, INCLUDING ANY MODIFICATION THEREOF, FOR CANNABIS

BUSINESSES
WHEREAS, the City of Cathedral City has consistently worked to encourage economic development and to maintain the economic vitality of the community by encouraging development that provides significant tax revenue to the City and that provides significant employment opportunities for City residents wherever possible; and WHEREAS, the City of Cathedral City has attempted to balance various land uses to accomplish these goals; and
WHEREAS, On October 25, 2017, the City Council adopted Ordinance Nos. 800 and 801 establishing a set of regulations allowing adult-use cannabis businesses to operate within the City, and, further, the City established administrative rules and regulations dated December 28, 2017, that implement such ordinances (“Cannabis Regulations”).

The Cannabis Regulations were created to provide the public with a clear understanding of the process for obtaining City approval to operate a Cannabis Business within the City, and were codified within the Cathedral City Municipal Code (“Code”) in Chapters 5.88 and 9.108 and have been amended since their adoption, with the last amendment in 2022; and
WHEREAS, Chapter 5.88 provides for the regulation and licensing of medical and adultuse cannabis business throughout the City in conformance with applicable state and local laws and regulation pertaining to medicinal and adult use cannabis; and WHEREAS, Chapter 9.108, as currently codified is contained in Title 9 of (Zoning Ordinance) of the Code, regulates cannabis business land uses, including the zone districts where cannabis uses are permitted, as authorized by section 26200 of the California Business and Professions Code, in a manner designed to minimize negative impacts on the City and neighboring uses, and to promote the health, safety, morals, and general welfare of residents and businesses within the City; and WHEREAS, the City currently has 64 cannabis businesses with 105 licenses comprised of 46 operating businesses with 67 licenses and 16 non-operational businesses with 38 licenses; and
WHEREAS, in April 2024, the City began experiencing a higher number of cannabis odor complaints. Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor reports. Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024. These complaints frequently cite the interference with the use and 2 4922-1190-7599 v5
enjoyment of their property; and
WHEREAS, the above-mentioned complaints concerning cannabis odors were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road with the balance of complaints pertaining to businesses located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza; and WHEREAS, despite City staff’s efforts to manage the complaints through additional inspections of cannabis businesses, increased proactive patrols, and specific actions by cannabis businesses to mitigate odors, the City has seen an increase in the number of cannabis odor complaints; and
WHEREAS, while there are likely multiple reasons for this, not all of which have been identified at this point, there are two explanatory factors that stand out: 1) a 325,000 square foot cannabis cultivation use started operations in 2024 in the vicinity of Date Palm Drive and Ramon Road; and 2) the City has a large concentration of cannabis businesses located off of located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza; and
WHEREAS, the large cannabis cultivation use was conditioned to provide an odor absorbing ventilation and exhaust system that prevents internal odor from being emitted externally. They have been required by the City to install additional odor mitigation, including a fogging system, which was installed on November 29, 2024. However, the City has continued to receive cannabis odor complaints related to this business since the installation of the fogging system; and
WHEREAS, the concentration of cannabis businesses off Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza has presented challenges with respect to identifying the source of complaints; and
WHEREAS, the City is therefore concerned about the efficacy of the Cannabis Regulations in preventing/minimizing cannabis odors emanating from the City’s cannabis businesses and is concerned about the impact of such odors upon sensitive receptors (e.g., residential properties, schools, community centers, places of worship) and the effect thereof upon the public health, safety and welfare; and WHEREAS, collectively, the cumulative volume of complaints citing the interference with the use and enjoyment of property and the limited effect actions to date have had in mitigating these complaints necessitate a review of the City’s cannabis regulations, with particular emphasis on zoning, odor control, and enforcement.; and WHEREAS, given the number of cannabis odor complaints, the City desires to review the Cannabis Regulations (including, without limitation, zoning designations, building construction standards, odor mitigation requirements, enforcement mechanisms, and other cannabis regulations) to ensure that odors from cannabis businesses are effectively mitigated and cannabis businesses located in the appropriate zones with appropriate buffers and distance requirements from sensitive receptors (e.g., residential 3 4922-1190-7599 v5
properties, schools, community centers, places of worship); and WHEREAS, therefore, the City desires to study and analyze the Cannabis Regulations to ensure that they are up to date and effectively regulate cannabis businesses in the City.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY DOES HEREBY ORDAINS AS FOLLOWS:

Section 1. FINDINGS
The City Council finds and determines the following:
(a) The recitals set forth above are hereby adopted as findings of the City Council.
(b) Based upon the findings set forth above and all oral and written testimony and reports presented by members of the public and City staff to the City Council on January 22, 2025, the continuous approval, establishment, and operation of cannabis businesses in the limited areas where they are permitted in the City poses an immediate threat to the public health, safety and welfare because it will potentially increase cannabis odors within the City such that it could create a public nuisance and negatively impact the City’s residents, such as their quality of life, and, in particular, negatively impact the City’s sensitive receptors (e.g., residential properties, schools, community centers, places of worship). Therefore, the immediate threat of the impact of cannabis odors upon the City’s residents and its sensitive receptors (e.g., residential properties, schools, community centers, places of worship) within the City justifies adoption of an interim urgency moratorium ordinance; and (c) In order to allow the City appropriate time to study the impacts of cannabis businesses and to adopt, if necessary, amendments to the Cannabis Regulations so as to ensure that the Cannabis Regulations are up to date and effectively regulate cannabis businesses, a temporary moratorium on the approval of new cannabis businesses must be enacted.

Section 2. MORATORIUM
Pursuant to the authority granted to the City Council by California Government Code Section 65858 to protect the health, safety and general welfare of the residents of the City of Cathedral City, and based upon the findings set forth above and all oral and written testimony and reports presented by members of the public and City staff to the City Council on January 22, 2025, the City Council hereby enacts as an interim urgency measure a moratorium to take effect immediately upon the adoption of this Ordinance as follows:
4 4922-1190-7599 v5
(a) Definitions. Except as otherwise provided herein, all terms used in this Ordinance shall have the same definitions as provided for in Chapters 5.88 and

9.108 of the Code.
(b) Moratorium. Beginning on the effective date of this Ordinance, no licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use shall be approved for or issued to a cannabis business, including, without limitation, local licenses pursuant to Chapter 5.88 of the Code; conditional use permits pursuant to Chapter 9.108 of the Code; any permits for cannabis business lounges; and any permits for temporary cannabis events pursuant to Section 5.88.035 and Chapter

9.68 of the Code (“Permit”). In addition, no modification to any existing Permit shall be approved, including, without limitation, the following:
(i) Modifications that will result in an increase, intensification or expansion in the cannabis-related use or operations, or the square-footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business (“Increase in Operations”). An increase in sales volume based on increased demand and not on an Increase in Operations is not considered to be an Increase in Operations. (ii) Modifications to change the location of a cannabis business. (c) Exemptions. The following shall be exempt from the moratorium provided in this Ordinance:
(i) Any modification to an existing Permit solely for the purposes of changing ownership of a cannabis business, provided that such modification shall not result in an Increase in Operations or a change in location of the cannabis-related operations of the cannabis business.
(ii) Any Permit or modification thereof that that does not result in the Increase in Operations of the cannabis-related operations of the cannabis business, such as expansions to administrative office space, minor tenant improvements, and repairs.
(iii) Any Permit modification that decreases the cannabis-related use or operations, or square-footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business.
(iv) Any renewal of a Permit.
(v) If both applications for a local license pursuant to Chapter

5.88 of the Code and conditional use permit pursuant to Chapter 9.108 of the Code were received by City staff by 4:30 p.m. on January 22, 2025, and such applications were fully completed and accompanied by all of the required supporting documents and application deposits as required by the Cannabis Regulations, then Permits related to 5 4922-1190-7599 v5
such applications may be approved and/or issued, as applicable.

Section 3. REPORT
Pursuant to Government Code § 65858(d), ten (10) days prior to the expiration or any extension of this Ordinance, the City Council will issue a written report describing the measures taken to alleviate the conditions which led to the adoption of this Ordinance.

Section 4. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
The City Council finds that this Ordinance is not subject to the California Environmental Quality Act (“CEQA”) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15061(b)(3) (there is no possibility the adoption of this Ordinance will have a significant effect on the environment) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly; rather it prevents changes in the environment pending the completion of the contemplated Municipal Code review.

Section 5. SEVERABILITY
If any chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion of this Ordinance, is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision will not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have adopted this Ordinance, and each chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof be declared invalid or unconstitutional.

Section 6. EFFECTIVE DATE; EXPIRATION; EXTENSION
Pursuant to Government Code § 65858(a), this Ordinance shall take effect immediately but shall be of no further force and effect forty-five (45) days from its date of adoption, unless the City Council, after notice and public hearing as provided under Government Code § 65858(a) and adoption of the findings required by Government Code § 65858(c), subsequently extends this Ordinance.

Section 7. POSTING
The City Clerk shall cause this Ordinance to be posted in the manner as required by law.

Section 8. CERTIFICATION
The foregoing Ordinance was approved and adopted at a meeting of the City Council held on the 22 day of January, 2025, by the following vote:
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Ayes:

Noes:

Abstain:

Absent:
___________________________
Nancy Ross, Mayor
ATTEST:
_____________________________
Tracey Hermosillo, City Clerk
APPROVED AS TO FORM:
_____________________________
Eric S. Vail, City Attorney
Cannabis Urgency
Ordinance
Andrew Firestine
Director of Community and Economic
Development
January 22, 2025
Background
• Ordinances regulating the licensing of medical and adult-use cannabis and establishing the zoning and land use requirements for cannabis business land uses were adopted in 2017 with the last amendment in 2022
• Cathedral City currently has 64 cannabis businesses with 105 licenses
• 47 operating businesses with 67 licenses
• 17 non-operating businesses with 38 licenses
Issues
• City has seen a large increase in the number of cannabis odor complaints
• Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor complaints
• Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024
• Complaints were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road
Response to Issues
• Engaged with cannabis enforcement staff in other Coachella Valley cities and with the Department of Cannabis Control
• Evaluated cannabis odor control regulations in other cities • Increased staff training and created cannabis enforcement guide • Initiated cannabis business inspections by code compliance staff • Developed patrol routes for cannabis odor detection
• Authorized overtime to permit evening patrols
• Partnered with Cathedral City Police Department to collect additional data
• Required additional cannabis odor mitigation
Ongoing Challenge
• Despite staff efforts to manage the complaints through additional inspections of cannabis businesses, increased proactive patrols, and specific actions by cannabis businesses to mitigate odors, the City has seen an increase in the number of cannabis odor complaints
Urgency Ordinance – Interim Moratorium
• Under California Government Code 65858(a), City Council may adopt a moratorium as an urgency measure where:
• It is supported by a 4/5 vote of Council;
• The ordinance contains legislative findings that there is a current and immediate threat to the public health, safety, or welfare; and
• The approval of additional entitlements and permits would result in that threat to public health, safety, or welfare.
• Initial moratorium lasts 45 days
• After notice and public hearing, the ordinance may be extended with a 4/5 vote for an additional 10 months and 15 days
• It may be extended for one additional year with a 4/5 vote Draft Urgency Ordinance – Interim
Moratorium
• As of the effective date of the ordinance, no licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use shall be approved for or issued to a cannabis business, including:
• Local licenses
• Conditional use permits
• Permits for cannabis lounges
• Permits for cannabis events
• No modifications that would result in an increase, intensification, or expansion in the cannabis-related use or operations, or the square- footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business
• No modifications to change the location of a cannabis business Draft Urgency Ordinance – Interim
Moratorium
• Exemptions include:
• Modifications for the purposes of changing ownership
• Permits or modifications that do not result in an increase in operations • Permits or modifications that decrease the cannabis-related use or operations or square-footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business
• Renewals
• Processing of existing applications for a local license or conditional use permit received by 4:30 p.m. on January 22, 2025, that were fully completed with all supporting documentation and fees, and permits related to those applications
Next Steps
• If adopted:
• Initial moratorium lasts 45 days
• Would be brought back to City Council on February 26, 2025 • For February 26, Council would see a more detailed strategy on an assessment of the City’s cannabis regulations, including those on zoning, odor control, and enforcement together with a plan for public engagement (e.g. residents and cannabis industry)
• City Council would need to take action on February 26 to extend the moratorium
• If extended beyond February 26, likely to include multiple meetings with the Cannabis Task Force, Planning Commission, and City Council Recommendation
• Staff recommends approval of the urgency ordinance adopting a 45-day initial moratorium on the approval of new cannabis licenses and conditional use permits and the issuance of building permits for the build-out or expansion of new cannabis businesses.

Staff Report
City Council
Item No. 5.A
Meeting Date: February 26, 2025
From: Andrew Firestine, AICP, Director of Community and Economic Development
Title: Extension of Cannabis Moratorium
RECOMMENDATION:

Staff recommends approval of the ordinance extending the cannabis moratorium on the approval of new cannabis licenses and conditional use permits and the issuance of building permits for the build-out or expansion of new cannabis businesses.

BACKGROUND:

On October 25, 2017, the City Council adopted Ordinance Nos. 800 and 801 establishing a set of regulations allowing adult-use cannabis businesses to operate within the City.

Ordinance No. 802 established enforcement provisions for cannabis. These regulations were created to provide the public with a clear understanding of the process for obtaining City approval to operate a Cannabis Business within the City. These regulations were codified within the Cathedral City Municipal Code in chapters 5.88 and 9.108, and Section 13.80.240, which have been amended since their adoption, with the last amendment in 2022.

Chapter 5.88 provides for the regulation and licensing of medical and adult-use cannabis business throughout the City in conformance with applicable state and local laws and regulation pertaining to medicinal and adult-use cannabis.

Chapter 9.108, as currently codified is contained in Title 9 of (Zoning Ordinance) of the Municipal Code, regulates cannabis business land uses, including the zone districts where cannabis uses are permitted, as authorized by section 26200 of the California Business and Professions Code, in a manner designed to minimize negative impacts on the City and neighboring uses, and to promote the health, safety, morals, and general welfare of residents and businesses within the City.

Section 13.80.240 defines a range of cannabis related public nuisances.

The City currently has 64 cannabis businesses with 105 licenses comprised of 47 operating businesses with 67 licenses and 17 non-operational businesses with 38 licenses.

On January 22, 2025, the City Council adopted an urgency ordinance enacting a 45-day interim moratorium on new licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use shall be approved for or issued to a cannabis business, including, without limitation, local licenses pursuant to Chapter 5.88 of the Code; conditional use permits pursuant to Chapter 9.108 of the Code; any permits for cannabis business lounges; and any permits for temporary cannabis events pursuant to Section 5.88.035 and Chapter 9.68 of the Code (“Permit”). In addition, no modification to any existing Permit shall be approved, including, without limitation: 1) modifications resulting in an increase, intensification or expansion in the cannabis-related use or operations, or the square-footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business (“Increase in Operations”); or 2) modifications changing the location of a cannabis business. The interim moratorium included several exemptions, including:

1. Any modification to an existing Permit solely for the purposes of changing ownership of a cannabis business, provided that such modification shall not result in an Increase in Operations or a change in location of the cannabis-related operations of the cannabis business.

2. Any Permit or modification thereof that does not result in the Increase in Operations of the cannabis-related operations of the cannabis business, such as expansions to administrative office space, minor tenant improvements, and repairs.

3. Any Permit modification that decreases the cannabis-related use or operations, or square-footage utilized for cannabis cultivation, manufacturing, processing, distribution, storage, sales, display, or similar cannabis-related activity, of a cannabis business.

4. Any renewal of a Permit.

5. If both applications for a local license pursuant to Chapter 5.88 of the Code and conditional use permit pursuant to Chapter 9.108 of the Code were received by City staff by 4:30 p.m. on January 22, 2025, and such applications were fully completed and accompanied by all of the required supporting documents and application deposits as required by the Cannabis Regulations, then Permits related to such applications may be approved and/or issued, as applicable.

The January 22, 2025 staff report to the City Council acknowledged that 10 days prior to the expiration of such an ordinance or any extension, a written report is to be issued describing the measures taken to alleviate the condition that led to the adoption of the ordinance. As well, the staff report also acknowledged that the moratorium may be extended twice, initially by a period of 10 months and 15 days and again by an additional year with the same findings as the interim moratorium that there is a current and immediate threat to the public health, safety or welfare, and that the approval of applicable land use entitlements would result in that threat to public health, safety or welfare and a 4/5 vote of City Council. This staff report constitutes both the written report required under California Government Code section 65858 as part of the interim ordinance imposing a 45-day moratorium and as support for an extension of the moratorium.

DISCUSSION:

Odor Complaints
As described in the January 22, 2025, staff report, the City has received an increasing number of odor complaints over the course of 2024, which supported the interim ordinance imposing a moratorium. The City continues to receive odor complaints. In response to the complaints, the City has increased its resources dedicated to cannabis odor detection. The Code Compliance Division created and distributed a cannabis odor reporting memorandum and implemented a proactive patrol system with a schedule for collecting data on cannabis odor within the community. These patrols have included overtime shifts through the Code Compliance Division and overnight patrols by the Cathedral City Police Department with an emphasis on the areas in proximity to the large cannabis cultivation facility near Date Palm Drive and Ramon Road.

Between December 1, 2024, and February 12, 2025, the City has conducted 59 patrols and collected 227 observation points, identifying odor 37 percent of the time. The frequency of the cannabis odor detections has declined since repairs were made to an exhaust fan at the large cannabis cultivation facility near Date Palm Drive and Ramon Road in mid-January and are now detected intermittently by City staff. The intensity of these observations has ranged from light to strong. The patrols and observations reveal there are still odors, although they are most appropriately classified as nuisance odors under section 13.80.240 of the Cathedral City Municipal Code.

Both the Riverside County Department of Environmental Health and the South Coast Air Quality Management District (AQMD) have inspected the business near Date Palm Drive and Ramon Road. The Riverside County Department of Environmental Health is responsible for administering the hazardous materials programs within Riverside County and has found the facility to be compliant with County and State requirements following their inspection.

AQMD required a permitting process for their boilers and chillers, which the business is in the process of completing. There are no public health concerns identified by either agency.

Cannabis Regulations
The City of Cathedral City cannabis regulations are codified within the Cathedral City Municipal Code in chapters 5.88 and 9.108. Enforcement provisions are adopted as chapter

13.80.240 of the Cathedral City Municipal Code. Together, these regulations were initially adopted through Ordinance Nos. 800, 801, and 802. While the regulations have been amended several times since their initial adoption, including through Ordinance Nos. 807, 817, 827, 841, 848, 863, and 870, as described in further detail in the table below, many of the regulations remain as they were adopted in 2017, particularly those in chapters 9.108 and 13.80.240.

Ordinance No. Date Subject
807 March 14, 2018 Amendment to Chapter 5.88 to permit on-site consumption at licensed dispensaries and to provide
a grace period for employee background checks
817 December 12,
2018
Amendment to Chapter 5.88 to require cannabis
businesses to enter into labor peace agreements as
a condition of licensure renewal
827 September 25,
2019
Amendment to Chapter 5.88 to establish a cannabis
industry employee identification card program
848 January 27,
2021
Amendment to Chapter 5.88 to repeal the Cathedral
City Task Force regulations contained in Section

5.88.125 and to replace those with new regulations
in Chapter 2.32, recognizing the Cannabis Task
Force in a consistent manner with other commissions
and committees
863 September 14,
2022
Amendment to Chapter 5.88 to update local
regulations to address new concerns and ensure
consistency with State requirements
870 June 28, 2023 Amendment to Chapter 5.88 to address cannabis business license expiration and renewals
Cannabis uses may be permitted as a conditional use in the Planned Community Commercial (PCC), Commercial Business Park (CBP-2), and Light Industrial (I-1) zoning districts subject to chapter 9.72 of the Cathedral City Municipal Code. The table below identifies the City’s commercial and industrial zoning districts and those districts that allow cannabis uses:

PCC CBP-2 I-1
Cannabis cultivation sites CUP CUP CUP
Cannabis dispensaries CUP CUP CUP
Cannabis distribution sites CUP CUP CUP
Cannabis testing
laboratories

CUP CUP CUP
The PCC zoning district is the most common commercial zoning district in the City and is typified by retail uses and shopping centers throughout the City. The CBP-2 and I-1 zoning districts are generally clustered around Perez Road.

Through the conditional use permit process, a cannabis use must demonstrate it meets the locational requirements set in section 9.108.070 of the Cathedral City Municipal Code, which are summarized in the following table:

Minimum Separation Requirement from Use
School, Day-Care
Center, or Youth
Center1
Residential Zone2 Resort Residential
Zone
Dispensaries 600-feet. 250-feet 250-feet, if the
dispensary allows for
outdoor consumption
Cultivation,
Manufacturing, and
Distribution Sites
600-feet 300-feet -
1 Setbacks from schools, day-care centers and youth centers, shall be measured to the nearest property line of the parcel where such use is located 2 Setbacks from residential zones shall be measured to: the nearest point of any legally permitted structure located in a residential zone; or if there is land within a residential zone with no legally permitted structure, the measurement shall be to the nearest property line unless the nearest property line is within the public right-of-way, in which case the measurement shall be to the edge of the right-of-way furthest from the proposed cannabis business.

The Resort Residential (RR) zoning district is separately identified in section 9.108.070 and the locational requirements only apply to dispensaries with outdoor consumption, not to other dispensaries or cultivation, manufacturing, and distribution sites.

Across the City, the RR zoning district includes Desert Princess, Outdoor Resort Palm Springs, Desert Shadows RV Resort, Cathedral Canyon Country Club, Canyon Shores, Date Palm Country Club, Cathedral Palms RV Resort, and the District. Any of the cannabis uses could propose a conditional use permit on a property zoned PCC, CBP-2, or I-1 adjacent to one of these properties and it would not be subject to any locational restriction from the RR zoning district, and there are examples of that, including on Kieley Road adjacent to the Cathedral Palms RV Resort and on Ramon Road adjacent to the Outdoor Resort Palm Springs. Most of the odor complaints received in 2024 were received from residents in Outdoor Resort Palm Springs concerning the adjacent cultivation site.

The City’s odor control regulations are contained primarily in chapter 9.108 of the Cathedral City Municipal Code. Section 9.108.080 requires as a condition of approval:

A. All Cannabis Businesses. Every cannabis business conditional use permit shall include the following conditions of approval.

1. The premises must be equipped with an odor absorbing ventilation and exhaust system so that odor generated inside the cannabis business that is distinctive to its operation is not detected outside the cannabis business, anywhere on adjacent property or public rights-of-way, on or about any exterior or interior common area walkways, hallways, breeze-ways, foyers, lobby areas, or any other areas available for common use by tenants or the visiting public, or within any other unit located within the same building as the cannabis business. As such, cannabis businesses must install and maintain the following equipment or any other equipment which local licensing authority determines has the same or better effectiveness:
a. An exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or
b. An air system that creates negative air pressure between the cannabis businesses' interior and exterior so that the odors generated inside the cannabis business are not detectable outside the cannabis business.

This has been applied consistently to cannabis conditional use permits as a condition of approval and sets a “no odor” standard. This is further addressed in section 13.80.240.J of the Cathedral City Municipal Code, which declares a public nuisance:

J. To cause or permit persistent cannabis odors that are offensive to individuals of normal sensitivity, and which adversely impact or unreasonably interfere with the use and enjoyment of property, to:

1. Emanate across any property line.

2. Emanate across a common wall or otherwise be detectable within an adjacent or nearby unit in a multi-tenant building or in a multi-family residential building that is occupied by another.

This section continues by establishing that “cannabis odors shall be presumed to be persistent, offensive to individuals of normal sensitivity, and adversely impacting or unreasonably interfering with the use and enjoyment of property, if the City receives three or more verified complaints from individuals representing separate residences or places of business within the City of a persistent cannabis odor emanating from the subject property within a one-month time span” while also qualifying that the City may determine that a public nuisance exists if less than complaints are received or even if no complaints are received but City detects odor conditions that violate this section of code.” The process of cannabis cultivation and manufacturing produces odor. The requirements of chapter 9.108 are intended to mitigate these odors but practical experience in the years since the code was adopted reveal that cannabis odor persists and that it doesn’t take much for cannabis odors to be released from a building, including through open doors or HVAC exhaust points. The presence of cannabis businesses is likely to produce cannabis odor.

While it declares it a public nuisance, the code lacks sufficient detail in section 13.80.240.J of the Cathedral City Municipal Code on how violations should be resolved. Section

13.80.240.J of the Cathedral City Municipal Code references chapter 13.90 for enforcement, subjecting cannabis violations to fines of $100 for a first violation, $200 for a second violation within a 12-month period, and $500 for a third and every subsequent violation within a 12- month period from the first violation.

The cannabis odor mitigation requirements in chapter 9.108 are applied as a condition of approval to cannabis conditional use permits. While this is the case for all cannabis conditional use permits, the means and methods of achieving compliance and how it is maintained once the entitlements are in place are not clear. Typically, these systems are incorporated into the mechanical heating, ventilation, and air conditioning (HVAC) plans submitted as part of a building permit application and consist of carbon filters, including activated carbon filters, that trap the odor causing compounds in the filter media. The filter media becomes less effective over time as it absorbs the odor causing compounds and requires maintenance to replace it with new filter media.

Currently, however, this is not a separate plan or document and there are no standards or minimum requirements for its contents or preparation. Questions such as what type of filtration should be installed, how much is required, and how often the filters should be changed out are not sufficiently addressed. While there are building code requirements for HVAC systems, they are not sufficient to address cannabis odor mitigation techniques, and the building permit plan check and inspection process is not calibrated to gauge the type and quantity of mitigation needed to adequately control cannabis odor.

Assessment
Other communities have required odor control plans as part of a permitting or licensing process, requiring the identification of specific odor control systems and detailed information on how a business is mitigating cannabis odor. The City of La Mesa, as an example, requires an odor control and air filtration concept plan as part of a conditional use permit and cannabis business license, defined as:

An odor control and air filtration concept plan designed by a California licensed engineer shall be submitted with the Conditional Use Permit application and/or the Adult Use Cannabis Business License application for cultivation and/or manufacturing. The air filtration concept plan shall include:
• An odor control and air filtration concept plan narrative, prepared by a California licensed mechanical engineer, an environmental engineer, or a similar professional discipline acceptable to the Building Division, that describes the approach and equipment to be utilized to contain, absorb, and neutralize all odors emanating from the property, and the field testing methodology to be utilized to determine the effectiveness of the odor containment, absorption, and/or neutralization design.
• An odor control and air filtration concept plan design that clearly shows the location of proposed equipment and appurtenances on site and floor plans. • Building section(s) and elevation(s) to clearly illustrate all equipment located on the exterior of the building, including all ducting and conduits, and the proposed method of achieving required screening.

This requirement is similar to what is required in the City of Palm Springs, which requires a written plan describing specific odor mitigation technologies and techniques incorporated to ensure that odors are not detected off-site. This odor control plan is required as part of a cannabis permit application and is also reinforced in their enforcement provisions which reference compliance with an approved odor control plan and direct enforcement staff to start with a written warning and directs a permittee to work with the City of Palm Springs to modify an approved odor control plan to mitigate odor issues within seven days. Following this period, if a permittee cannot mitigate the odor issues, the use must cease until effective odor control measures are in place. The City of Palm Springs code also contains fines of $10,000 for failure to comply with an approved odor control plan and $25,000 for odor violations related to an unpermitted activity.

The preceding examples are not exclusive of the range of potential solutions, although they provide important context for the gaps identified in the Cathedral City Municipal Code and what should continue to be studied as part of a potential code amendment, including an evaluation of:
• Definitions and standards in the cannabis regulations, including the thresholds for an odor violation;
• Requirements for a separate odor control plan to be submitted as part of a cannabis permit or license;
• Enforcement provisions, including the maintenance of an approved odor control plan and a well-articulated enforcement process for odor violations; and • Fines and penalties for non-compliance with an approved odor control plan.

Additionally, the allowances for cultivation, manufacturing, and distribution sites as a conditional use in the PCC zoning district should be assessed together with the locational requirements from the RR zoning district.

Next Steps
California Government Code section 65858 provides statutory authority for interim ordinances prohibiting uses that may conflict with a contemplated general plan, specific plan or zoning proposal that the City is studying or plans to study. An interim ordinance, commonly called a moratorium, imposes temporary land use controls based on a documented, current and immediate threat to public health, safety, and welfare. An interim ordinance protects and promotes the planning process by prohibiting the introduction of potentially nonconforming land uses that could defeat or impair a later adopted general plan or zoning ordinance.

Procedurally, such an ordinance may be adopted initially without a public hearing following a 4/5 vote of the legislative body, which describes the actions taken by the City Council on January 22, 2025. The initial moratorium lasts for 45 days. After notice and a public hearing, the ordinance may be extended, again with a 4/5 vote, for an additional 10 months and 15 days. The cannabis moratorium has been noticed as a public hearing for February 26, 2025 to allow the City Council to consider an extension of the moratorium for an additional 10 months and 15 days.

Thereafter, the ordinance can be extended twice: the first extension is for a period of 10 months and 15 days and the second extension is for a period of 1 year. Both extensions must be approved by the City Council with a 4/5 vote. No more than two extensions may be adopted.

The City Council cannot adopt or extend any interim ordinance unless the ordinance contains a finding that there is a current and immediate threat to the public health, safety or welfare, and that the approval of applicable land use entitlements would result in that threat to public health, safety or welfare.

The attached ordinance provides the necessary findings to support an extension of the cannabis moratorium and the staff report. The urgency ordinance is written to prohibit new cannabis licenses and conditional use permit applications for all cannabis business types while the moratorium is in effect together with the issuance of new building permits that would permit the build-out and development of an approved cannabis license and conditional use permit where no building permit had been previously issued. The urgency ordinance excludes the renewal or transfer of existing cannabis licenses, except where the transfer is to a new location without an approved conditional use permit or where the transfer proposes an amendment or modification to an approved conditional use permit, such as for an expansion or a change in use. It also excludes the issuance of building permits to existing cannabis businesses with an approved cannabis license and conditional use permit where the building permit does not involve the build-out or expansion of the use but rather pertains to the ordinary use and maintenance of the business.

Should the City Council extend the cannabis moratorium, it is staff’s recommendation that specific recommendations be presented to the Planning Commission and Cannabis Task Force to address the zoning, locational requirements, definitions, standards, and enforcement provisions, fines, and penalties identified in this staff report while building out an odor control plan to implement the required conditions of approval. Following recommendations from the Planning Commission and Cannabis Task Force, an ordinance proposing code amendments can be prepared and scheduled for public hearings within the moratorium period.

FISCAL IMPACT:

None at this time.

FIVE-YEAR STRATEGIC PLAN:

F-11 – Implement a code compliance program that proactively identifies and responds to code compliance complaints
ATTACHMENTS:

1. Cannabis Moratorium Extension Ordinance
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ORDINANCE NO. _____

AN INTERIM URGENCY ORDINANCE OF THE CITY COUNCIL OF THE

CITY OF CATHEDRAL CITY, CALIFORNIA, CONTINUING THE
PROVISIONS OF ORDINANCE NO. ____ ADOPTING AND IMPOSING

A TEMPORARY MORATORIUM ON THE APPROVAL OF LICENSES,

PERMITS, APPROVALS, OR OTHER ENTITLEMENTS FOR USE,

INCLUDING ANY MODIFICATION THEREOF, FOR CANNABIS

BUSINESSES, WITHIN THE CITY OF CATHEDRAL CITY FOR A
ADDITIONAL PERIOD OF TEN (10) MONTHS AND FIFTEEN (15) DAYS WHEREAS, the City of Cathedral City (“City”) permits and regulates certain cannabis businesses pursuant to Chapters 5.88 and 9.68 of the Cathedral City Municipal Code and adopted administrative regulations (“Cannabis Regulations”); and WHEREAS, in April 2024, the City began experiencing a higher number of cannabis odor complaints. Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor reports. Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024. These complaints frequently cite the interference with the use and enjoyment of their property; and
WHEREAS, the above-mentioned complaints concerning cannabis odors were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road with the balance of complaints pertaining to businesses located off of Perez Road, Kieley Road, Bankside Drive, and Sunair Plaza; and WHEREAS, Government Code Section 65858 allows cities to protect the public health, safety and welfare by adopting interim emergency moratoria in order to allow time to study whether certain land uses should be allowed, prohibited, or regulated under the City’s municipal code; and
WHEREAS, on January 22, 2025, the City Council adopted Ordinance No. 884, which enacted a forty five (45) day interim moratorium on the approval or issuance of new licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use to a cannabis business as more particularly described therein (“Ordinance No. 884”); and
WHEREAS, Government Code Section 65858 authorizes the City Council to extend the moratorium enacted by Ordinance No. 884 for an additional period of ten (10) months and fifteen (15) days; and
WHEREAS, since adoption of Ordinance No. 884 on January 22, 2025, the City continues to receive odor complaints and, in response to such complaints, the City has increased its resources dedicated to cannabis odor detection. The City’s Code Compliance Division created and distributed a cannabis odor reporting memorandum and implemented a proactive patrol system with a schedule for collecting data on 2 4904-6342-8124 v1
cannabis odor within the community. These patrols have included overtime shifts through the Code Compliance Division and overtime patrols by the Cathedral City Police Department with an emphasis on the areas in proximity to the large cannabis cultivation facility near Date Palm Drive and Ramon Road, which potentially qualify as nuisance odors under Section 13.80.240 of the Cathedral City Municipal Code; and WHEREAS, between December 1, 2024, and February 12, 2025, the City has conducted 59 patrols and collected 227 observation points, identifying odor approximately 37 percent of the time; and
WHEREAS, the City therefore continues to be concerned about the efficacy of the Cannabis Regulations in preventing/minimizing cannabis odors emanating from the City’s cannabis businesses and about the impact of such odors upon sensitive receptors (e.g., residential properties, schools, community centers, places of worship) and the effect thereof upon the public health, safety and welfare; and WHEREAS, since the adoption of Ordinance No. 884, the City requires additional time to study what legislative steps might be appropriate to amend the Cannabis Regulations within the City in order to protect the public health, safety, and welfare of the public; and WHEREAS, pursuant to Government Code Section 65858, the City may, after notice and a public hearing, extend the moratorium enacted by Ordinance No. 884 for up to ten (10) months and fifteen (15) days; and
WHEREAS, as described in this Ordinance, the City Council continues to find that there is a current and immediate threat to the public health, safety, and welfare based on the findings herein and the findings contained in Ordinance No. 884, and upon that basis has determined that an extension of the moratorium enacted in Ordinance No. 884 is warranted; and
WHEREAS, the City has complied with the notice and public hearing requirements of Government Code Sections 65858(a) and 65090; and
WHEREAS, the report required by Government Code Section 65858(d) has been prepared and made available to the public at the City Clerk’s Office. In addition, the agenda report accompanying this ordinance provides the information required under Government Code section 65858(d).

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CATHEDRAL CITY DOES HEREBY ORDAINS AS FOLLOWS:

Section 1. FINDINGS
The City Council finds and determines the following:
(a) The recitals set forth above are hereby adopted as findings of the City Council.
3 4904-6342-8124 v1
(b) The factual basis for extending the moratorium enacted by Ordinance No. 884 also includes the recitals and findings set forth in Ordinance No. 884, which are adopted and incorporated herein by this reference. (c) Pursuant to Government Code Section 65858(d), the City has issued the report relative to the steps taken to alleviate the conditions that necessitated the adoption of Ordinance No. 884.
(d) Based upon the above and all oral and written testimony and reports presented by members of the public and City staff to the City Council on February 26, 2025, there continues to be an immediate threat of harm to the public, health, safety, and welfare that may occur if licenses, permits, approvals, or other entitlements for grading, building, improvements, and/or use are approved for or issued to cannabis businesses pursuant to the current Cannabis Regulations. (e) In order to appropriately respond to this immediate threat of harm to public health, safety, and welfare, the City needs more time to do the following: (1) assess whether there is an over concentration of cannabis business within the City such that it would impact the public health, safety, and welfare of the City’s residents, or cause excessive or chronic nuisance conditions that may impact the health, safety, and welfare of the City’s residents; (2) study the impacts of cannabis businesses upon the City and its residents; (3) study potential new or amended regulatory requirements for cannabis businesses, including, without limitation, appropriate distancing requirements and maximum number and concentration of business within areas of the City and the City as a whole; and (4) assess any other impacts that cannabis businesses may have upon the City that jeopardize the public health, safety, and welfare. (f) Based upon the forgoing, the City desires to extend the moratorium described in Ordinance No. 884 by ten (10) months and fifteen (15) days.

Section 2. EXTENSION OF MORATORIUM
Pursuant to the authority granted to the City Council by California Government Code Section 65858 to protect the health, safety and general welfare of the residents of the City of Cathedral City, and based upon the findings set forth above and all oral and written testimony and reports presented by members of the public and City staff to the City Council on February 26, 2025, the City Council hereby extends the term of Ordinance No. 884 for a period of ten (10) months and fifteen (15) days from the expiration date of March 8, 2025, for a new expiration date of January 23, 2026.

Section 3. REPORT
Pursuant to Government Code Section 65858(d), ten (10) days prior to the expiration or any extension of this Ordinance, the City Council will issue a written report describing the measures taken to alleviate the conditions which led to the adoption of this Ordinance.
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Section 4. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
The City Council finds that this Ordinance is not subject to the California Environmental Quality Act (“CEQA”) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15061(b)(3) (there is no possibility the adoption of this Ordinance will have a significant effect on the environment) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly; rather it prevents changes in the environment pending the completion of the contemplated Municipal Code review.

Section 5. SEVERABILITY
If any chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion of this Ordinance, is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision will not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have adopted this Ordinance, and each chapter, sections, subsections, subdivisions, sentences, clauses, phrases, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof be declared invalid or unconstitutional.

Section 6. EFFECTIVE DATE
This Ordinance is declared to be an urgency ordinance by authority conferred on the City Council of the City of Cathedral City by Government Code Section 65858, and shall be in full force and effect immediately upon its adoption by a four-fifths vote of the City Council.

Section 7. POSTING
The City Clerk shall cause this Ordinance to be posted in the manner as required by law.

Section 8. CERTIFICATION
The foregoing Ordinance was approved and adopted at a meeting of the City Council held on the 26th day of February, 2025, by the following vote:

Ayes:

Noes:

Abstain:

Absent:
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___________________________
Nancy Ross, Mayor
ATTEST:
_____________________________
Tracey Hermosillo, City Clerk
APPROVED AS TO FORM:
_____________________________
Eric S. Vail, City Attorney
Cannabis Update
Andrew Firestine
Director of Community and Economic
Development
April 23, 2025
Background
• On February 26, 2025, the City Council extended the cannabis moratorium by 10 months and 15 days
• Council requested routine updates
• Prior report focused on an evaluation of the City’s zoning, locational requirements, definitions, standards, and enforcement provisions, fines, and penalties
Presentation Objectives
• Provide updates on:
• Cannabis research conducted in other cities and counties • Consultant support to set standards and to support the development of an odor control permitting process
• Consultant support to the City related to cannabis odors at C4 Industry • Cannabis odor control reporting and monitoring pilot program Review of Cannabis Regulations – Zoning
• Cannabis uses may be permitted as a conditional use in the Planned Community Commercial (PCC), Commercial Business Park (CBP-2), and Light Industrial (I-1) zoning districts • The PCC zoning district is the most common commercial zoning district in the City and is typified by retail uses and shopping centers throughout the City
• The CBP-2 and I-1 zoning districts are generally clustered around Perez Road
Review of Cannabis Regulations –
Separation Requirements
Minimum Separation Requirement from Use
School, Day-Care Center, or
Youth Center1
Residential Zone2 Resort Residential Zone
Dispensaries 600-feet 250-feet 250-feet, if the dispensary allows for outdoor
consumption
Cultivation, Manufacturing,
and Distribution Sites
600-feet 300-feet -
1 Setbacks from schools, day-care centers and youth centers, shall be measured to the nearest property line of the parcel where such use is located
2 Setbacks from residential zones shall be measured to: the nearest point of any legally permitted structure located in a residential zone; or if there is land within a residential zone with no legally permitted structure, the measurement shall be to the nearest property line unless the nearest property line is within the public right-of-way, in which case the measurement shall be to the edge of the right-of-way furthest from the proposed cannabis business.

Review of Cannabis Regulations – Odor
Control
• Section 9.108.080 requires as a condition of approval:

A. All Cannabis Businesses. Every cannabis business conditional use permit shall include the following conditions of approval.

1. The premises must be equipped with an odor absorbing ventilation and exhaust system so that odor generated inside the cannabis business that is distinctive to its operation is not detected outside the cannabis business, anywhere on adjacent property or public rights-ofway, on or about any exterior or interior common area walkways, hallways, breeze-ways, foyers, lobby areas, or any other areas available for common use by tenants or the visiting public, or within any other unit located within the same building as the cannabis business. As such, cannabis businesses must install and maintain the following equipment or any other equipment which local licensing authority determines has the same or better effectiveness:
a. An exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or
b. An air system that creates negative air pressure between the cannabis businesses' interior and exterior so that the odors generated inside the cannabis business are not detectable outside the cannabis business.

Review of Cannabis Regulations – Odor
Enforcement
• Section 13.80.240.J of the Cathedral City Municipal Code declares a public nuisance:

J. To cause or permit persistent cannabis odors that are offensive to individuals of normal sensitivity, and which adversely impact or unreasonably interfere with the use and enjoyment of property, to:

1. Emanate across any property line.

2. Emanate across a common wall or otherwise be detectable within an adjacent or nearby unit in a multi-tenant building or in a multi-family residential building that is occupied by another.

Cannabis Research – Other Cities and
Counties
• Department of Cannabis Control defines large indoor cultivation licenses as licenses that are 22,000 square feet in size or greater • There are 7 of these across the State, 5 in Oakland,1 in Richmond, and 1 in Cathedral City
• Only the location in Cathedral City was purpose built, all the others were conversions of industrial warehouses
• Except for the Tinnery in Oakland, none of the other licenses are comparable in size to C4 Industry and none are good comparisons
• 84 California cities and counties allow indoor cultivation • Staff conducted an initial review of the cannabis zoning regulations, licensing, and enforcement provisions for each of these cities and counties and identified 15 cities and 3 counties to research further Cannabis Research – Other Cities and
Counties
El Dorado County Hayward Long Beach Desert Hot
Springs
Palm Springs Grover Beach
Santa Barbara
County
Richmond Pasadena Moreno Valley La Mesa Santa Cruz
Stanislaus
County
Lancaster Coachella Palm Desert National City Oakland
Zoning Questions

1. What zoning districts are cannabis cultivation, manufacturing, and lab uses permitted?

2. What separation requirements existing between cannabis uses and either residential zones or uses and other sensitive uses? Identify both the use and the separation requirement.

3. Are there separation requirements between cannabis uses?

4. Are there limits on either the number or size of cannabis uses?

5. What is the definition of a nuisance cannabis odor?

6. What are the odor mitigation requirements, either through a CUP or cannabis license? Are there specific requirements or standards for cultivation and manufacturing uses?

7. Does the city or county require an odor mitigation plan or permit? If so, who is authorized to prepare and submit it? What are the submission requirements? Does it need to be renewed annually as part of the license? Who approves it?
Enforcement Questions

8. What constitutes an odor violation? Are there thresholds or measurements for cannabis odor, either for the concentration of odor or the time period over which it is detected?

9. When there is an odor complaint, how is it investigated? Does the cannabis business have a period of time to correct a violation before a citation or further action is taken? If so, how long?

10.What are the fines for a violation of the cannabis ordinance? Are there penalties beyond fines? If so, what?

11. Are there any unique provisions, such as a hearing officer, that warrant further evaluation? Zoning - Question #1
• What zoning districts are cannabis cultivation, manufacturing, and lab uses permitted?
• Cannabis uses such as cultivation, manufacturing, distribution, and testing labs uses are restricted to industrial zone districts • Dispensaries are permitted in both industrial and retail zones Zoning - Question #2
• What separation requirements existing between cannabis uses and either residential zones or uses and other sensitive uses? Identify both the use and the separation requirement.
• Under the California Business and Professions Code (BPC) Section 26054(b), cannabis businesses shall not be located within a 600-foot radius of a school providing K-12 instruction, a daycare center, or a youth center • Separation requirements from residential uses vary significantly • Palm Springs established a 1,000-foot separation requirement between cannabis cultivation and manufacturing and a residential zoning district • Coachella, Lancaster, and Pasadena each have a 600-foot separation requirement from commercial cannabis uses and residentially zoned property • Grover Beach requires a 100-foot setback between retailers and residential zones
Zoning - Question #3
• Are there separation requirements between cannabis uses? • Palm Desert requires that cannabis retailers be 1,500 feet apart and similarly requires cannabis businesses within their service industrial zoning district to be separated by 1,500 feet
• With some exceptions, Palm Springs requires cannabis businesses be separated by 500 feet
• Long Beach has a 1,000-foot separation requirement between dispensaries
Zoning - Question #4
• Are there limits on either the number or size of cannabis uses? • Other cities place limits on the number of cannabis dispensaries allowed, often setting the cap between three and 10
• Most do not impose limits on other types of cannabis operations, including cultivation, manufacturing, distribution, and testing laboratories • Santa Cruz and Moreno Valley are two cities that have additional requirements for cultivation facilities
• Santa Cruz restricts indoor cultivation to a maximum of 10,000 square feet • Moreno Valley restricts the total area of the premises designated/used for the cultivation canopy to no more than 22,000 square feet
• Pasadena limits cultivation to four licensed facilities Zoning - Question #5
• What is the definition of a
nuisance cannabis odor?
• Nuisance cannabis odor is
not consistently defined
across all city zoning codes
• No objective standard
• Palm Springs and Coachella
• Odor Detection Threshold /
Odor Threshold
Concentration
• Olfactometer
Zoning - Question #6
• What are the odor mitigation requirements, either through a CUP or cannabis license? Are there specific requirements or standards for cultivation and manufacturing uses?
• Consistent standard requiring odor absorbing ventilation and exhaust system
• Exhaust air filtration system with odor control
• Air system that creates negative air pressure between the interior and exterior Zoning - Question #7
• Does the city or county require an odor mitigation plan or permit? If so, who is authorized to prepare and submit it? What are the submission requirements? Does it need to be renewed annually as part of the license? Who approves it?
• Common requirement, including Coachella, Desert Hot Springs, and Palm Springs
• Includes detailed information about the proposed ventilation system, including technical specifications indicating that the system can prevent the release of cannabis odors into the atmosphere from the cultivation or manufacturing operation
• Prepared by a license mechanical engineer
• Post-entitlement submittal
• Annual certification through license renewal
Enforcement – Question #8
• What constitutes an odor violation? Are there thresholds or measurements for cannabis odor, either for the concentration of odor or the time period over which it is detected?
• National City, La Mesa, and Desert Hot Springs require that odor not be detectable at the property line
• El Dorado County uses the St. Croix Sensory Nasal Ranger Field Olfactometer and Santa Barbara County’s new regulations incorporate a nuisance threshold relying on an olfactometer
• Desert Hot Spring and Palm Springs report that they have discontinued use of the Nasal Ranger
Enforcement – Question #9
• When there is an odor complaint, how is it investigated? Does the cannabis business have a period of time to correct a violation before a citation or further action is taken? If so, how long? • Multiple cities and counties require cannabis businesses to respond to cannabis odor complaints, including Santa Barbara County, Long Beach, and Desert Hot Springs
• Palm Springs allows cannabis businesses with a compliant odor control plan seven days to correct an odor issue
Enforcement – Question #10
• What are the fines for a violation of the cannabis ordinance? Are there penalties beyond fines? If so, what?
• Palm Springs has an escalating enforcement process
• Compliant odor control plan
• Written warning
• 7 days to correct
• After 7 days, if the odor cannot be mitigated, the use must cease until effective odor control measures are in place
• Non-compliant odor control plan
• Subject to $10,000 administrative citation
• 30 days to remedy
• Additional $10,000 administrative citations every 30 days • After three administrative citations, the permit is automatically revoked • Desert Hot Springs code allows fines up to $1,000 per day Enforcement – Question #11
• Are there any unique provisions, such as a hearing officer, that warrant further evaluation?
• Stanislaus County established a hearing officer process • Desert Hot Springs contracts with a third-party for all cannabis ordinance and enforcement
• Palm Springs contracts for the review of odor control plans Consultant Support - General
• Scope of work issued on April 14 to four firms with a due date of April 28
• Builds on the city and county research performed by City staff and seeks specific subject matter expertise on cannabis odor control • Focus is on six areas:

1. Regulatory review and best practices assessment

2. Odor control technology evaluation

3. Odor control permitting process

4. Inspection and verification protocols

5. Stakeholder engagement and presentations

6. Training
Consultant Support – Odor Analysis
• Contract has been executed with Hartman Environmental Geoscience for the review of the odor control systems at C4 Industry, both existing and proposed
• They are tasked with providing the City a qualified opinion on the effectiveness of both the current and proposed odor mitigation plans and make specific recommendations to improve the
effectiveness of the existing and any additionally proposed odor mitigation
Envirosuite Pilot Program
• Envirosuite is a leader in environmental intelligence and offers a technology driven, real-time reporting and monitoring service • 6-month pilot program to be launched in May 2025 in the vicinity of C4 Industry
• Improved data collection and reporting
• Environmental monitoring
• Accountability and response timelines
Envirosuite Pilot Program
• Time and date
• Location
• Description
• Contact info
Complaint
Submitted
• Routed to
City
• “New –
Unvalidated”
Initial Routing
• Weather
info from
weather
station
• Sensor data
Environmental
Validation
• Complaint
assigned to
business for
response
• 30-minutes to
initial response
during business
hours (8-6)
• 90 minutes to
initial response
after-hours
Routing to
Business • Led by business
• Investigation
summary within 24-
hours
Investigation
• City reviews
the
investigation
City Oversight
Next Steps
• Training
October
• City Council
September
• Cannabis
Task Force
• Planning
Commission
August
• Review of
Draft
Ordinance
July
• Draft
Ordinance
• Develop
Odor Control
Permitting
Process and
Checklists
June
• Award
contract to
cannabis
consultant
• Assessment
and
Evaluation
May
Staff Report
City Council
Item No. 1.A
Meeting Date: April 23, 2025
From: Andrew Firestine, AICP, Director of Community and Economic Development
Title: Cannabis Moratorium Update
RECOMMENDATION:

This item is for discussion purposes to serve as an update on the cannabis moratorium. No action is requested.

BACKGROUND:

On February 26, 2025, the City Council extended the cannabis moratorium by 10 months and 15 days. Through the discussion, the City Council requested routine updates as staff conducts additional research and initiates updates to the City’s cannabis regulations and processes. The prior report focused on an evaluation of the City’s zoning, locational requirements, definitions, standards, and enforcement provisions, fines, and penalties while building out an odor control plan to implement the required conditions of approval. This report provides a synopsis of cannabis research conducted in other cities and counties and efforts to engage consultant support to set standards and to support the development of an odor control permitting process. It also provides updates on consultant support to the city specifically on C4 Industry and an odor control reporting and monitoring pilot program.

DISCUSSION:

Staff has commenced research in these areas, first by identifying all the California cities and counties that allow for cannabis cultivation in some manner, a list of 84 cities and counties, and conducted an initial review of the cannabis zoning regulations, licensing, and enforcement provisions for each of these cities and counties. This initial review was narrowed down to a smaller list of 15 cities and 3 counties that potentially offer insight into one or more of the areas of focus. A review of these city and county regulations, with an emphasis on zoning and enforcement, is summarized in the sections below with additional text contained in the attachments
Staff also initiated a records request through the Department of Cannabis Control (DCC) for the purpose of understanding how many large indoor cannabis cultivation facilities are licensed in the State of California. The DCC defines large indoor cannabis cultivation as those with more than 22,000 square feet of total canopy. For comparison, C4 Industry, the existing large cannabis cultivation facility near Date Palm Drive and Ramon Road has a gross floor area of 326,000 square feet and each of its 9 bays has a canopy area of 21,504 square feet together with an 8,760 square foot mother room, totaling over 200,000 square feet of total canopy area. While the DCC began accepting applications for large indoor cultivation licenses in 2020, there are only 6 other large indoor cultivation facilities licensed by the DCC, all of which are located in Richmond and Oakland. None of these are a good comparison to C4 Industry – most are substantially smaller in size and are older warehouses in industrial areas converted to cannabis cultivation.

The initial research of other city and county regulations, together with the additional information from the DCC, reveals that while there are some models for odor control permit processes and stronger enforcement, no city or county is at the forefront of cannabis regulation. No city or county has adopted objective cannabis odor standards and most rely on reactive and subjective odor measurements for enforcement. These preliminary findings raise the importance of the city’s existing condition of approval on cannabis conditional use permits requiring odor mitigation.

As was identified in previous staff reports, there is no separate plan or document and there are no standards or minimum requirements to demonstrate how the City’s odor mitigation requirements are to be met. Other cities and counties have established odor mitigation requirements through an odor control plan and permitting process, which is captured in the summary below. To ensure the City is setting the right standards, including the evaluation of technologies and the establishment of odor control requirements, the development of content and submittal requirements for an odor control plan, and the preparation of inspection checklists, consultant support is needed. To date, staff has met and engaged with five companies with significant experience in cannabis odor control and monitoring and has prepared a scope of work specific to the City’s needs. This scope of work was issued for informal bid on April 14 with bids requested by April 28. A summary of the expected scope of work is provided below.

Through the process of identifying prospective consultants to engage with on an update of the City’s cannabis regulations, staff identified a nationally recognized expert on soil vapor sampling, soil vapor analysis, and vapor intrusion for environmental and exploration applications who has extended his work into the cannabis industry through the monitoring of cannabis odor causing compounds by similar analysis. Dr. Blayne Hartman, with Hartman Environmental Geoscience, has analyzed cannabis odor control systems and offers the ability to provide the City a qualified opinion on the effectiveness of both the current and any additionally proposed odor mitigation at C4 Industry. The business remains responsible for designing, implementing, and maintaining their odor control solutions. Dr. Hartman’s work is to validate their effectiveness through an objective analysis and to make specific recommendations to the City. Dr. Hartman does not represent any equipment manufacturer and does not design cannabis odor control systems – he has no conflict of interest with C4 Industry or any other cannabis business operating in Cathedral City. Staff has negotiated a contract and scope of work with Dr. Hartman to evaluate the performance of the odor control systems at C4 Industry, both existing and proposed.

Finally, staff has also met with Envirosuite on several occasions. Envirosuite is a leader in environmental intelligence and offers a technology driven, real-time reporting and monitoring service that provides benefits to the City and to cannabis operators. C4 Industry has contracted with Envirosuite to implement a pilot program at their facility, a program that can potentially be expanded citywide. Under the pilot program, cannabis odor reports in the vicinity of C4 Industry would be reported through the Envirosuite platform embedded on the City’s website, collecting information on the location and strength and intensity of the odor.

Envirosuite’s monitors would also collect data on weather, volatile organic compounds (VOCs), and other compounds. All of this data would be made available to the City and the operator in real-time, which is intended to better correlate odor complaints with objective data, informing both City actions and operational changes at C4 Industry. Additional details on this pilot program and partnership are outlined below.

Cannabis Regulations
In its review of cannabis regulations from 15 cities and 3 counties, City staff evaluated seven zoning questions, including questions directed to odor mitigation and odor mitigation plans.

Staff further assessed four questions related to enforcement of odor violations. The complete data collected from this research is attached to the staff report. The zoning and enforcement research is summarized for Coachella, Palm Desert, Palm Springs, Desert Hot Springs, Oakland, and Richmond for each question below.

Zoning

1. What zoning districts are cannabis cultivation, manufacturing, and lab uses permitted?
Upon reviewing neighboring cities in the Coachella Valley such as Coachella, Palm Desert, Palm Springs, and Desert Hot Springs, as well as Oakland and Richmond, it is evident that cannabis uses such as cultivation, manufacturing, distribution, and testing labs uses are typically restricted to industrial zone districts, while dispensaries are permitted in both industrial and retail zones. Cultivation, manufacturing, distribution, and testing labs uses are generally not permitted within commercial or residential zones, reflecting a common zoning practice aimed at minimizing potential impacts on retail areas and neighborhoods.

2. What separation requirements existing between cannabis uses and either residential zones or uses and other sensitive uses? Identify both the use and the separation requirement.

The separation requirements from residential uses vary significantly. Under the California Business and Professions Code (BPC) Section 26054(b), cannabis businesses shall not be located within a 600-foot radius of a school providing K-12 instruction, a daycare center, or a youth center. Cities and counties, at a minimum, must implement this standard, although they may adopt more stringent standards, including other separation requirements.

As an illustration, Palm Springs established a 1,000-foot separation requirement between cannabis cultivation and manufacturing and a residential zoning district.

Coachella, Lancaster, and Pasadena each have a 600-foot separation requirement from commercial cannabis uses and residentially zoned property. Grover Beach requires a 100-foot setback between retailers and residential zones.

The other cities studied as part of this evaluation do not have an explicit separation from cannabis uses and residential zones or uses. Cathedral City is the only city evaluated that allows cultivation, manufacturing, and distribution in a commercial zoning district. The other cities limit those uses to industrial zones, which are generally separated from residential zones.

3. Are there separation requirements between cannabis uses? Palm Desert requires that cannabis retailers be 1,500 feet apart and similarly requires cannabis businesses within their service industrial zoning district to be separated by 1,500 feet. With some exceptions, Palm Springs requires cannabis businesses be separated by 500 feet. Among the other cities studied, Long Beach has a 1,000 foot separation requirement between dispensaries.

4. Are there limits on either the number or size of cannabis uses? A review of other city regulations shows that other cities place limits on the number of cannabis dispensaries allowed, often setting the cap between three and 10. In contrast, most do not impose limits on other types of cannabis operations, including cultivation, manufacturing, distribution, and testing laboratories. This reflects a regulatory trend aimed at controlling the retail presence of cannabis while allowing more flexibility for non-retail sectors of the industry. Santa Cruz and Moreno Valley are two cities that have additional requirements for cultivation facilities. Santa Cruz restricts indoor cultivation to a maximum of 10,000 square feet. Moreno Valley restricts the total area of the premises designated/used for the cultivation canopy to no more than 22,000 square feet, effectively prohibiting large indoor cultivation facilities, as defined by the DCC. Pasadena limits cultivation to four licensed facilities.

5. What is the definition of a nuisance cannabis odor?
Nuisance cannabis odor is not consistently defined across all city zoning codes.

However, some cities have established specific standards to address this issue. For example, the City of Palm Springs defines “Odor Detection Threshold” as the threshold for the detection of odorous contaminants when one volume of the odorous air has been diluted with seven or more volumes of odor free air as measured by any instrument, device, or any other method designated by the City.

Similarly, the City of Coachella defines "Odor Threshold Concentration" as the lowest concentration of Odorous matter that produces an olfactory response in normal human beings. Odor thresholds shall be determined in accordance with the American Society for Testing and Materials Test Method D1391-57 (reconfirmed to 1967) or in an equivalent manner acceptable to the zoning administrator.

These definitions require measurement through an olfactometer, such as the St.

Croix Sensory Nasal Ranger Field Olfactometer. The specialized device uses a combination of human nose and an instrument to detect and measure odors. While the definition has been adopted by some cities and counties, including Santa Barbara County most recently, it remains a subjective measurement and is not widely accepted as an effective way of detecting cannabis odor.

6. What are the odor mitigation requirements, either through a CUP or cannabis license? Are there specific requirements or standards for cultivation and manufacturing uses? Odor mitigation requirements are standard among the cities researched and are consistent with Cathedral City’s requirements that a business install odor absorbing ventilation and exhaust system so that odor generated inside the cannabis business are not detected outside. The systems include an exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or an air system that creates negative air pressure between the interior and exterior so that the odors generated inside the cannabis business are not detectable outside.

7. Does the city or county require an odor mitigation plan or permit? If so, who is authorized to prepare and submit it? What are the submission requirements? Does it need to be renewed annually as part of the license? Who approves it? A common requirement found in the cities researched is the requirement to develop and implement a ventilation or odor control plan. These plans are required to include detailed information about the proposed ventilation system, including technical specifications indicating that the system can prevent the release of cannabis odors into the atmosphere from the cultivation or manufacturing operation. Coachella, Desert Hot Springs, and Palm Springs all require odor control plans. These are most often prepared by a licensed mechanical engineer. While Palm Springs requires an odor control plan to be prepared as part of a conditional use permit, other cities require it as a post-entitlement permit reviewed administratively and concurrent with a building permit. Some cities, including Palm Springs, use a third-party contractor to review odor control plans. Among the other cities, Grover Beach requires odor control systems to be certified annually.

Code Enforcement

8. What constitutes an odor violation? Are there thresholds or measurements for cannabis odor, either for the concentration of odor or the time period over which it is detected?
National City, La Mesa, and Desert Hot Springs require that odor not be detectable at the property line. El Dorado County uses the St. Croix Sensory Nasal Ranger Field Olfactometer, and Santa Barbara County established a nuisance threshold relying on an olfactometer as part of its recent cannabis code updates. Desert Hot Springs reported that it discontinued its use of the Nasal Ranger.

9. When there is an odor complaint, how is it investigated? Does the cannabis business have a period of time to correct a violation before a citation or further action is taken? If so, how long?
Several cities and counties require cannabis businesses to respond to cannabis odor complaints, including Santa Barbara County, Long Beach, and Desert Hot Springs.

Palm Springs allows cannabis businesses with a compliant odor control plan seven days to correct an odor issue.

10.What are the fines for a violation of the cannabis ordinance? Are there penalties beyond fines? If so, what?
Palm Springs has an escalating enforcement process. For odor violations related to a cannabis business with a compliant odor control plan, a cannabis business is first issued a written warning and given seven days to modify their odor control plan to mitigate odor issues. If the odor cannot be mitigated within seven days, the use must cease until effective odor control measures are in place. For odor violations with a non-compliant odor control plan, the business can be subject to a $10,000 administrative violation and have 30 days to remedy the odor issue and comply with their odor control plan before they’re issued another administrative citation of $10,000.

After three administrative citations, the permit shall automatically be revoked.

Desert Hot Springs code allows fines up to $1,000 per day, although their staff indicates that they have never needed to issue this fine.

11.Are there any unique provisions, such as a hearing officer, that warrant further evaluation?
Stanislaus County established a hearing officer process to conduct administrative hearings to determine whether the conditions described in the notice of violation, administrative citation and order to abate, and notice of hearing constitute a nuisance.

The hearing officer also considers the suspension, revocation, or non-renewal of cannabis permits.

Desert Hot Springs contracts with a third-party for all cannabis ordinance enforcement. Palm Springs contracts for the review of odor control plans.

Cannabis Consultant Support
On April 14, a scope of work for consultant support related to cannabis odor control was issued to four companies. This scope of work builds on the city and county research performed by City staff and seeks specific subject matter expertise on cannabis odor control.

It divides the work into six areas:

1. Regulatory review and best practices assessment

2. Odor control technology evaluation

3. Odor control permitting process

4. Inspection and verification protocols

5. Stakeholder engagement and presentations

6. Training
The full scope of work is attached for reference. It also included a timeline prepared by City staff leading to the presentation of an ordinance to the Cannabis Task Force and Planning Commission in August 2025 and the City Council in September 2025. Staff would be responsible for preparing the ordinance, but with input from the consultant to ensure the City is setting clear and appropriate standards and that the ordinance is accompanied by checklists and supporting documentation for any new processes.

In addition to this scope of work, a contract has been executed with Hartman Environmental Geoscience, the fifth consultant staff met with, specifically for the review of the odor control systems at C4 Industry, both existing and proposed. This contract allows up to 50 hours of consultant time and accounts for two site visits. Through the scope of work, they are tasked with providing the City a qualified opinion on the effectiveness of both the current and proposed odor mitigation plans and make specific recommendations to improve the effectiveness of the existing and any additionally proposed odor mitigation. This contract is not to support C4 Industry but rather to support the City in its review and assessment of the odor problem at C4 Industry using objective analysis and data.

Envirosuite
The City’s current process to report cannabis odors is inefficient and relies upon a platform that was not designed or intended for odor reporting. While it has been used to aggregate complaints, the information reported through the platform is not shared with a cannabis business in real-time. The auto-generated responses to a reporting party when a complaint is made are the same as any other code compliance case, which sets an expectation with the reporting party that the City will respond to their complaint individually. The volume of cannabis odor complaints has precluded staff from investigating and responding to each individual complaint. When the complaints are closed out by City staff, residents feel they are being ignored as the underlying issue has not been addressed. To address this, staff created an email distribution group that it has been sending weekly updates to both in response to cannabis odor complaints at C4 Industry and with respect to the cannabis moratorium.

Through the pilot program with Envirosuite, the City has an opportunity to substantially improve cannabis odor reporting for the area around C4 Industry. This could potentially be expanded to other areas of the City, but beginning in May 2025 an online form will be made available on the City’s website similar to what has been deployed in Des Moines, IA:
https://www.dsm.city/departments/neighborhood_services/odor.php.

The form will document the time and date of the complaint, location, description, and optional contact information for follow-up. Once submitted, City code compliance staff would be notified of a new complaint. Envirosuite would validate the plausibility of the complaint based on atmospheric conditions, including wind direction and speed, and the location of the complaint. Envirosuite also collects time-aligned sensor data and meteorological data. The sensors will be monitoring VOC, H2S and NH3 and can be programmed to monitor two additional compounds as may be directed by the City and its consultants.

Validated complaints are assigned to the business operator, in this case C4 Industry, for investigation and response. While the City does not presently have a response timeline for cannabis businesses to address odor complaints, the pilot program establishes an initial response time of 30 minutes during business hours and 90 minutes after hours, which would include an acknowledgement of the complaint, time of receipt, and immediate investigative steps. Under the pilot program, C4 Industry would be required to post a detailed investigation summary within 24 hours, including on-site observations, source identification (if any), and mitigation actions. Code compliance staff would be responsible for reviewing the investigation conducted by the business in response to a complaint, including its resolution.

The City’s role in the pilot program would be to support its implementation through the City website and to maintain oversight of it for the purpose of regulatory compliance, the tracking of complaints, and community engagement. The pilot program is proposed for a period of six-months, through which Envirosuite, C4 Industry, and the City will evaluate its effectiveness. The pilot program can be extended for an additional six-months upon mutual agreement.

Beyond its application in the area around C4 Industry, City staff are exploring the potential deployment of additional Envirosuite sensors and weather stations elsewhere in the City to permit cannabis odor reporting and monitoring through the Envirosuite platform. There is no estimated cost for these additional services at this point. They will be assessed and evaluated under the cannabis moratorium.

Next Steps
Staff anticipates that it will award a professional services contract to a cannabis consultant in the beginning of May and that staff and the consultant will immediately begin to identify those best practices the City should model in its updated cannabis regulations, including any new odor control requirements. The consultant is expected to produce an odor control permitting process for the City, including submittal and inspection checklists. While a substantial amount of work remains, staff has developed a timeline that would result in the presentation of an ordinance to the Cannabis Task Force and Planning Commission in August 2025 and City Council in September 2025.

FISCAL IMPACT:

The contract with Hartman Environmental Geoscience is not to exceed $12,500 and will be accommodated within the existing budget. The scope of work for the other consultant support was issued on April 14, 2025, for an informal bid with the expectation that it will be within the city manager’s signature authority. This contract is expected to be split between two fiscal years and will be accommodated within the existing and proposed budget.

FIVE-YEAR STRATEGIC PLAN:

F-17 – Review and update, as needed, our ordinances, policies, and practices regarding cannabis.

ATTACHMENTS:

1. City and County Cannabis Analysis

2. Cannabis Consultant Support Scope of Work

Cannabis Urgency
Ordinance Extension
Andrew Firestine
Director of Community and Economic
Development
February 26, 2025
Background
• Ordinances regulating the licensing of medical and adult-use cannabis and establishing the zoning and land use requirements for cannabis business land uses were adopted in 2017 with the last amendment in 2022
• Cathedral City currently has 64 cannabis businesses with 105 licenses
• 47 operating businesses with 67 licenses
• 17 non-operating businesses with 38 licenses
Issues
• City has seen a large increase in the number of cannabis odor complaints
• Between January 1 and March 30, 2024, the City received a total of 38 cannabis odor complaints
• Between April 1 and December 31, 2024, the City received an additional 904 cannabis odor complaints, including 220 in November 2024 and 501 in December 2024
• Complaints were reported across the City with a large number of complaints occurring in the vicinity of Date Palm Drive and Ramon Road
Response to Issues
• Engaged with cannabis enforcement staff in other Coachella Valley cities and with the Department of Cannabis Control
• Evaluated cannabis odor control regulations in other cities • Increased staff training and creation of cannabis enforcement guide • Initiated cannabis business inspections by code compliance staff • Developed patrol routes for cannabis odor detection
• Authorized overtime to permit evening patrols
• Partnered with Cathedral City Police Department to collect additional data
• Required additional cannabis odor mitigation
Ongoing Challenge
• Despite staff efforts to manage the complaints through additional inspections of cannabis businesses, increased proactive patrols, and specific actions by cannabis businesses to mitigate odors, the City has seen an increase in the number of cannabis odor complaints
Initial Moratorium
• On January 22, 2025, Council adopted a 45-day initial moratorium on the approval of new cannabis licenses and conditional use permits and the issuance of building permits for the build-out or expansion of new cannabis businesses
Initial Moratorium
• Since the adoption of the initial moratorium, the City has continued to conduct proactive cannabis odor patrols
• The frequency of the cannabis odor detections by staff has declined since repairs were made to an exhaust fan at the large cannabis cultivation facility near Date Palm Drive and Ramon Road in mid-January
• Odor is detected intermittently by City staff, with an intensity ranging from light to strong
• There are no public health concerns identified by either the Riverside County Department of Environmental Health or the South Coast Air Quality Air Management District
• Odors are most appropriately classified as nuisance odors under section

13.80.240 of the Cathedral City Municipal Code
Review of Cannabis Regulations
• Cannabis regulations are codified within the Cathedral City Municipal Code in chapters 5.88 and 9.108
• Enforcement provisions are adopted as chapter 13.80.240 of the Cathedral City Municipal Code
• These regulations were initially adopted through Ordinance Nos. 800, 801, and 802
• Many of the regulations remain as they were adopted in 2017, particularly those in chapters 9.108 and 13.80.240
Review of Cannabis Regulations – Zoning
• Cannabis uses may be permitted as a conditional use in the Planned Community Commercial (PCC), Commercial Business Park (CBP-2), and Light Industrial (I-1) zoning districts • The PCC zoning district is the most common commercial zoning district in the City and is typified by retail uses and shopping centers throughout the City
• The CBP-2 and I-1 zoning districts are generally clustered around Perez Road
Review of Cannabis Regulations –
Separation Requirements
Minimum Separation Requirement from Use
School, Day-Care Center, or
Youth Center1
Residential Zone2 Resort Residential Zone
Dispensaries 600-feet 250-feet 250-feet, if the dispensary allows for outdoor
consumption
Cultivation, Manufacturing,
and Distribution Sites
600-feet 300-feet -
1 Setbacks from schools, day-care centers and youth centers, shall be measured to the nearest property line of the parcel where such use is located
2 Setbacks from residential zones shall be measured to: the nearest point of any legally permitted structure located in a residential zone; or if there is land within a residential zone with no legally permitted structure, the measurement shall be to the nearest property line unless the nearest property line is within the public right-of-way, in which case the measurement shall be to the edge of the right-of-way furthest from the proposed cannabis business.

Review of Cannabis Regulations – Odor
Control
• Section 9.108.080 requires as a condition of approval:

A. All Cannabis Businesses. Every cannabis business conditional use permit shall include the following conditions of approval.

1. The premises must be equipped with an odor absorbing ventilation and exhaust system so that odor generated inside the cannabis business that is distinctive to its operation is not detected outside the cannabis business, anywhere on adjacent property or public rights-ofway, on or about any exterior or interior common area walkways, hallways, breeze-ways, foyers, lobby areas, or any other areas available for common use by tenants or the visiting public, or within any other unit located within the same building as the cannabis business. As such, cannabis businesses must install and maintain the following equipment or any other equipment which local licensing authority determines has the same or better effectiveness:
a. An exhaust air filtration system with odor control that prevents internal odors from being emitted externally; or
b. An air system that creates negative air pressure between the cannabis businesses' interior and exterior so that the odors generated inside the cannabis business are not detectable outside the cannabis business.

Review of Cannabis Regulations – Odor
Enforcement
• Section 13.80.240.J of the Cathedral City Municipal Code declares a public nuisance:

J. To cause or permit persistent cannabis odors that are offensive to individuals of normal sensitivity, and which adversely impact or unreasonably interfere with the use and enjoyment of property, to:

1. Emanate across any property line.

2. Emanate across a common wall or otherwise be detectable within an adjacent or nearby unit in a multi-tenant building or in a multi-family residential building that is occupied by another.

Assessment of Cannabis Regulations
• Process of cannabis cultivation and manufacturing produces odor and the presence of cannabis businesses is likely to produce cannabis odor • No clear method to ensure conditions of approval are met or maintained • While the code requires filtration systems, it may not be current technology • Code lacks sufficient detail in section 13.80.240.J of the Cathedral City Municipal Code on how violations should be resolved
• Section 13.80.240.J of the Cathedral City Municipal Code references chapter 13.90 for enforcement subjecting cannabis violations to fines of $100 for a first violation, $200 for a second violation within a 12-month period, and $500 for a third and every subsequent violation within a 12-month period from the first violation
Potential Solutions
• Modify the zoning code to remove cultivation and manufacturing from the PCC zoning district and evaluate the separation requirements in other zones
• Develop an odor control plan to be required as part of a conditional use permit and cannabis license
• Review and update definitions and standards, including those setting the standard for odor thresholds and what constitutes a public nuisance
• Enhance code enforcement provisions for maintenance of an odor control plan and the resolution of odor violations, including fine schedule
Interim Moratorium
• Under California Government Code 65858(a), City Council may adopt a moratorium as an urgency measure where:
• It is supported by a 4/5 vote of Council;
• The ordinance contains legislative findings that there is a current and immediate threat to the public health, safety, or welfare; and
• The approval of additional entitlements and permits would result in that threat to public health, safety, or welfare.
• Initial moratorium lasts 45 days
• After notice and public hearing, the ordinance may be extended with a 4/5 vote for an additional 10 months and 15 days
• It may be extended for one additional year with a 4/5 vote Next Steps
• With an extension of the moratorium, staff would perform additional research to identify the current best practices for odor control and enforcement, focusing on communities with a large presence of indoor cannabis cultivation
• Staff would prepare a draft ordinance for presentation to the Cannabis Task Force and the Planning Commission (Title 9) • Ordinance would be presented at public hearings before the Planning Commission (Title 9) and the City Council
Recommendation
• Staff recommends approval of the moratorium extension.

Regulatory Review &
Cannabis Odor Management Tool
July 11th, 2025
1601 N. Imperial Ave.

El Centro, CA 92243
760-339-4969
Section Page
Cathedral City – Regulatory Review - Cannabis Odor Control Page i www.scsengineers.com
Table of Contents
Introduction...................................................................................................................................2 Regulatory Review and Best Practices Assessment.....................................................................3 Regulatory Review Summary....................................................................................3 Background...........................................................................................................3 Research Process .................................................................................................3 Findings.................................................................................................................3 Case Studies & Relevance to the City of Cathedral City .......................................5 Regulatory Review Summary Conclusion..............................................................5 Odor Control Plan Development...............................................................................6 Cannabis Facility Type, Odor Generating Potential & OAP Requirement..............6 Odor Abatement Plan Outline ...............................................................................7 Facility Description and Location..........................................................................7 Odor-Emitting Sources ..........................................................................................8 Odor Control Strategies and Best Management Practices (BMPs).......................8 Complaint Management System...........................................................................8 Section 2.0 Summary and Recommendations.............................................................................9 Odor Control Technology Evaluation.......................................................................................... 10 Odor Control Technologies .....................................................................................10 Change Chemical Structure................................................................................10 Remove or Filter Odor.........................................................................................11 Neutralize or Mask Odor.....................................................................................11 Dispersion and Dilution.......................................................................................11 Section 3.0 Summary and Recommendations...........................................................................14 Odor Control Permitting Process................................................................................................ 21

4.0.1 Conditional Use Permit Requirements for Nearby Jurisdictions ........................21 Performance-Based Standards ..............................................................................21 Standardized Submittal Elements..........................................................................22 Submittal Requirements ........................................................................................22 Review & Verification Protocols..............................................................................22 Section 4.0 Summary and Recommendations...........................................................................23 Inspection and Verification Protocols ........................................................................................ 24 Protocols and Continued Compliance....................................................................24 Section Page
Cathedral City – Regulatory Review - Cannabis Odor Control Page ii www.scsengineers.com
Table of Contents
Inspection Protocols............................................................................................24 Demonstration of Compliance ............................................................................24 Enforcement Triggers and Subsequent Process.................................................25 Section 5.1 Summary and Recommendations...........................................................................27 Odor Identification and Monitoring.........................................................................28 Odor Source Identification ..................................................................................28 Odor Monitoring Options.....................................................................................30 Section 5.2 Summary and Recommendations...........................................................................36 Bibliography ............................................................................................................................... 37 Figures
Figure 1: Behavior of Odor Plume as Function of Climatic Conditions (Douglas Hamilton, 2019) .... 13 Figure 2: Examples of Field Olfactometers (Nasal Ranger, Facial Mask, Box Scentometer)............. 33 Tables
Table 1: Odor Control Technologies Summary Table.......................................................................... 15 Table 2: Odor Control Options Relative to Source Type...................................................................... 19 Table 3: Summary of Odor Perception Methods Via Humans ............................................................ 31 Table 4: Summary of Odor Assessment Via Chemical Surrogate....................................................... 33 Appendices
Appendix A What is Odor?
Appendix B Example Forms
Appendix C Communication and Public Outreach
Appendix D Cathedral City Council Staff Report: Cannabis Moratorium Update Appendix E Odor Abatement Plan Template Checklists for Various Cannabis Facility Types Appendix F City of Cathedral City Licensed Cannabis Business Type and Zoning Maps Cathedral City – Regulatory Review - Cannabis Odor Control