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Council Information - Barlow Printing

Cotati City Council
July 25, 2023

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Council Information - Barlow Printing
Meeting
July 25, 2023
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Cotati City Council
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City of Cotati - Development Dept.
201 West Sierra Ave.

Cotati, California 94931
ATTN: Community Development Dept. & Office of the City Manager To whom it may concern:

Please accept the attached table of contents, application, and required documents for your consideration for a distribution license with the City of Cotati. Barlow Printing, LLC is an existing processing licensee at 481 Aaron Street, Cotati, CA 94931. As our industry changes and grows, we will be shifting the primary operations at the facility to distribution services under Barlow Printing, LLC.

We are thrilled at the opportunity to promote reliable, compliance-forward distribution throughout the state of California from this Cotati hub. Should you have any questions or need clarification as you review the application binder, please do not hesitate to contact our compliance department directly at [email protected].

We look forward to working with you to contribute to the community and economy of Cotati! Sincerely,
Jessica Hulser
808-829-0280
[email protected]
Compliance/Licensing Contact:

Alyssa Clemmer
323-926-1893
[email protected]
[email protected]

APN #144-010-043-000
481 AARON ST
COTATI, CA 94931
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COMMON AREA

ADMIN/BATRHOOMS

DISTRIBUTION FUNCTIONS &

DISTRIBUTION

FUNCTIONS

Barlow Printing, LLC
Distribution Applicant / Processing Licensee
Business Signage Plan
Business signage at 481 Aaron Street, Cotati, CA 94931 will not be altered or updated whendistribution activities transfer to the Barlow Printing, LLC entity. The exterior of the premises willremain as-is.

Business Operations Plan
Barlow Printing, LLC - 481 Aaron St, Cotati, CA 94931
a. Full description of the activities and products of the business and a detailed description of how operations will comply with local and state law. For retail facilities, please include a description of anticipated design aesthetic and user experience of public areas. i. Our proposed cannabis operations will add Type 11 distribution operations to the existing Processing operations under Barlow Printing, LLC. Distribution operations will include receipt and storage of retail-ready cannabis products provided by licensed and fully-vetted brands. The business will follow all regulations set forth by the City of Cotati and the California Department of Cannabis Control.
b. Procedure for storing and tracking inventory and a plan for implementation of safeguards to prevent product diversion.
i. Barlow Printing, LLC will utilize ERP software to support storage and tracking of inventory. At the time of application, the business primarily utilizes Distru to track skus in our distribution locations. This system tracks batch information, sku counts, and other relevant data that syncs with CA’s track-and-trace system (METRC). Inventory reconciliations are a top priority of our operations team, and cycle counts take place through both Distru and METRC at least every 30 days, per state requirements.
ii. Product is stored onsite at the distribution location with security onsite during business hours and continuous monitoring through camera surveillance. The facility is also equipped with a security alarm system. Manifests and inventory are cross-checked on a regular basis to prevent diversion.
c. Project supply chain; i.e., expected sources of products, locations where products have been manufactured, testing labs used, transporters, distributors, etc.). i. Product onsite at the distribution premises will be retail-ready and pass full regulatory compliance testing. Our brands utilize a number of testing labs and manufacturers, all in accordance with state requirements. d. Procedure for ensuring quality of products and identifying, managing and disposing of unusable products.
i. Products at the distribution facility will only be accepted in their retail-ready, tested form. Quality is ensured by COA review against the product packaging, along with internal audits confirming storage meets requirements for exposure to extreme temperatures and moisture. Before products are approved to be added to our distribution portfolio, full diligence of the producer/cultivator takes place, including packaging and sku review.
ii. Discovery of unusable products is rare, but are potentially discovered during the pick-and-pack process, through an internal inventory audit, or by a retailer at drop-off. Any unusable product will be returned to the distribution facility and rendered completely unusable by authorized staff, with packaging discarded and product destroyed or removed in accordance with state and local regulations. e. Personnel policies and procedures for hiring and ensuring thorough background information is reviewed prior to hire.
i. Personnel will be hired through a number of conventional methods, including posting to job boards, utilizing recruiters, and referrals from current team members. After a thorough interview process, employees are provided an offer letter and a ClearCheck background check is performed by the business’s HR department. Upon receipt of an offer letter, the prospective employee is also provided with the City of Cotati live scan form and asked to have a live scan completed, noting that an approval from Cotati PD is required before the employee can begin work and their offer of employment is contingent on Cotati PD approval.
f. If retail, include an approximate number of patients or customers the business anticipates serving.
i. N/A
g. Detailed record keeping procedures, including chain of custody controls. i. The chain of custody begins with the cultivator, who is responsible for tagging the plant with a UID and beginning the entries into the state’s track-and-track system, METRC. As the cannabis products move through the supply chain, they are updated within the METRC system.
ii. Upon receipt of the retail-ready, packaged goods, our inventory team will review packaging against METRC manifests, Certificates of Analysis, and a packaging checklist provided internally and “accept” the inventory in the METRC system. iii. Chain of custody is also managed through a seed-to-sale cannabis ERP software.

At this time, the business utilizes Distru. This software allows tracking down to the individual item and syncs information about retailers and other participants in the chain of custody to METRC, providing an additional layer of review and control.
iv. All Distru records are maintained digitally and retained for at least 7 years as required by the Department of Cannabis Control. All sales invoices and METRC manifests are maintained in both paper form and digitally, also retained in accordance with the DCC’s recordkeeping requirements.
h. Proof of application for and/or receipt for all required other agency permits and licenses (i.e., entitlement, building, health department, resource agencies, etc.). i. See attached.
i. Copy of government issued photo ID for each person engaged in the day-to-day operations or having ownership interest or decision making authority, or involved in any way with the business.
i. See attached
j. Copy of social security cards for all business owners. i. See attached
k. Proof of status as a qualified patient or primary caregiver if applicable. i. N/A
l. List of licenses and/or permits for similar business activities issued to and/or revoked from the business or any person who is an owner and/or has decision making capabilities, or involved in the day-to-day operations of the business. Include type of permit/license, issued by, issued to, current status, reason for denial. i. All owners are associated with the following licenses:

1. Entity: Cabo Connection
a. License Numbers:

CDPH-10003631 (Type 6 Manufacturing)
C11-0000488-LIC (Type 11 Distribution)
b. Licensing Agency: CA Dept. of Cannabis Control
c. Status: Active

2. Entity: Cabo Connection
a. Licensing Agency: Los Angeles Department of Cannabis Regulation
b. Status: Active

3. Entity: Heritage Holding of California, Inc.
a. License Number:

C11-0000983-LIC (Type 11 Distribution)
b. Licensing Agency: CA Dept. of Cannabis Control
c. Status: Active

4. Entity: Barlow Printing, LLC
a. License Number:

CCL19-0005020 (Cultivation - Processor)
b. Licensing Agency: CA Dept. of Cannabis Control
c. Status: Active
m. List all persons who are owners and/or have decision making capabilities, or involved in the day to day operations of the business and has been investigated and/or convicted of a felony and/or misdemeanor including but not limited to violent offenses, fraud, deceit, embezzlement, moral turpitude or illegal use, possession, transportation, and/or distribution of illegal substances and/or involved in a lawsuit or other litigation. i. N/A
Air Quality and Energy Management Plan
Barlow Printing, LLC
481 Aaron St, Cotati, CA 94931
a. A calculation of expected emissions, by type and a detailed description of devices and techniques necessary to comply with BAAQMD standards.
i. Barlow Printing, LLC will be participating in existing processing activities and with this application, seeks to add distribution activities. We will not be cultivating or participating in any activity that releases greenhouse gasses or harmful emissions. See the following pages for the CEQA exemption application for the CA Dept. of Cannabis Control. b. A calculation of anticipated greenhouse gas emissions for the operation of the business and demonstrated compliance with any applicable state, regional or local plan for greenhouse gas reduction.
i. The project is not anticipated to change or increase current greenhouse gas emissions relative to the area, please see the attached CEQA exemption application for the DCC. c. An odor control plan which details devices and techniques to prevent detectable odors outside the facility.
i. The facility is outfitted with basket fans using carbon filters throughout a number of interior rooms, ensuring proper air circulation and ventilation to control odor. Since the majority of products onsite will be retail-ready and in finished packaging, we do not anticipate significant odor control will be necessary. Should it become necessary in the future, additional measures will be added as-needed.
d. A detailed energy conservation plan which includes a description of devices which will enable the proposed facility and activities to operate at or below energy usage parameters of building’s occupancy classification.
i. We do not anticipate energy usage that exceeds the building’s occupancy classification, as the facility will not be participating in cultivation or other high-energy-use activities.

Should our energy use exceed usage parameters for the building’s occupancy classification, we will provide a detailed energy conservation plan as requested.

Fire Prevention, Hazardous Materials, & Waste Disposal Plan Barlow Printing, LLC
481 Aaron St, Cotati, CA 94931
a. Emergency vehicle access and turn-around at the facility site(s), vegetation management and fire break maintenance around all structures.
i. The facility is located in the general industrial zone of Cotati, allowing sufficient access for emergency vehicles and ample room for turn-around. There is no cultivation at the facility and all exterior vegetation will be handled with standard landscaping contracts, limiting fire risk. We do not believe fire break measures are necessary at this time. b. Procedure for handling of any hazardous materials (i.e., fertilizers, chemicals, etc.) will be stored, handled, used and disposed of. Plan shall comply with all federal, state and local requirements for management of the proposed substances. “Hazardous materials” includes any substance regulated by a federal, state or local law or regulation intended to protect human health or the environment from exposure to such substances.
i. There will be no hazardous materials used under the permit or stored on-site. c. Recycling, composting and waste disposal facilities and procedures. i. Conventional waste and recycling from office and general uses will be stored on-site in traditional waste receptacles/recycling bins.
ii. Cannabis waste will be rendered unusable in accordance with state regulations and disposed of through a certified third-party cannabis waste disposal company. iii. Cannabis waste will be stored in locking containers while awaiting pick-up. All cannabis waste will be measured and documented with a waste manifest and tracked accordingly in the state’s track-and-trace platform (METRC). The manifest requires multiple signatures from both on-site management and the third-party pick-up service, and we will receive confirmation of disposal from the vendor when the process is completed. d. Sonoma County’s Department of Emergency Services is the local CUPA tasked with implementing California’s hazardous materials standards in the City of Cotati. If your business will utilize hazardous materials, please contact them at (707) 565-1152 to understand their requirements prior to completing this Plan.
i. N/A
Water / Wastewater Management and Conservation Plan
Barlow Printing, LLC
481 Aaron St, Cotati, CA 94931
a. A calculation of planned water usage, water conservation measures and disposal of wastewater. i. There will be no cultivation or other high-water uses taking place at the facility. Water usage on-site will be limited to cleaning, sanitation, and other standard employee uses. ii. We do not anticipate participating in activities that produce wastewater that could have potential environmental impacts.
b. A detailed description of devices or processes which will enable proposed facility and activities to operate at or below water usage parameters of building’s occupancy classification. i. Since there will be no cultivation or other high-water uses taking place at the facility, water usage on-site will be limited to cleaning, sanitation, and other standard employee uses. We anticipate this to mean that we will not exceed water usage parameters for the building’s occupancy classification.
c. A calculation of anticipated waste water, excess irrigation and domestic waste water anticipated, pre-treatment method (when applicable), as well as disposal method. All waste water discharged to the City sewer system shall comply with the City’s Municipal Code. All cultivation operations shall comply with all state regulations, any regulations adopted by the City Council through resolution or ordinance and the discharger shall submit to the City verification of compliance with the Waste Discharge Requirements of the applicable Regional Water Quality Control Board and the City’s sewer ordinance, or waiver thereof if needed. i. N/A
d. The Plan shall also describe devices and procedures that will be in place to protect stormwater runoff quality for any outdoor wash down or equipment clean up. Note that all site operations shall comply with the City’s Stormwater Discharge Permit and limitations on outdoor activities generally.
i. N/A

BCC-LIC-025 (New 10/18)
California Department of Consumer Affairs
Bureau of Cannabis Control
State of California
Gavin Newsom, Governor
www.bcc.ca.gov
Bureau of Cannabis Control
Project-Specific Information Form
(To be completed by applicant – attach additional sheets as needed) If a previously certified or adopted environmental document is not available or does not exist, you must submit a completed Project-Specific Information Form. The Bureau of Cannabis Control (Bureau) will use this form to determine whether the project has the potential to generate significant adverse environmental impacts that might require preparation of a CEQA document or the need for additional information. (Cal. Code Regs., tit. 14, § 15060(a) [CEQA Guidelines].).

Please provide detailed responses to the items below. If more space is needed, additional pages may be added. Missing, incomplete, or inconsistent information may delay the processing of your application. Applicants must complete this form when the local jurisdiction from which they received authorization to conduct commercial cannabis activity did not certify a CEQA document.

Applicant Name: ______________________________________________ Application Number: ___________________________________________ Local jurisdiction (city/county): ___________________________________ SECTION A. PROJECT LOCATON AND SURROUNDING USES

1. Describe the project location including street address, city, county, Assessor’s Parcel Number, major cross streets, general plan designation, zoning designation, and any other physical description that clearly indicates the project site location.

2. Describe the surrounding land uses and zoning designations within one-half mile radius of the project and list the abutting land uses.

3. Provide a vicinity map and aerial image to show the project location.

BCC-LIC-025 Page 1 of 4 (New 10/18)

State of California BCC-LIC-025 (New 10/18) Gavin Newsom, Governor California Department of Consumer Affairs Bureau of Cannabis Control
www.bcc.ca.gov

4. Provide photographs, not larger than 8 ½ by 11 inches, of the of existing visual conditions as observed from the publicly accessible vantage point(s).

SECTION B: PROJECT DESCRIPTION

1. Describe the activities included in the project application and identify any other commercial cannabis activity or activities occurring at the proposed premises.

2. Quantify the project size (total floor area of the project) in square feet and the lot size on which the project is located, in square feet.

3. List and describe any other related public agency permits and approvals, including any entitlements required for this project (e.g., those required by a planning commission, city council, board of supervisors, local air district, or regional water board).

4. Identify whether the applicant is licensed by, or has applied for licensure from, the California Department of Food and Agriculture or the State Department of Public Health to engage in commercial cannabis activity at the proposed premises.

BCC-LIC-025 Page 2 of 4 (New 10/18)
State of California BCC-LIC-025 (New 10/18) Gavin Newsom, Governor California Department of Consumer Affairs Bureau of Cannabis Control
www.bcc.ca.gov

5. Explain whether any of the project activities will expand the existing footprint of the facility beyond the current structural or parcel boundaries, increase the amount of impervious surface, or reduce any natural habitat. If the project is part of a larger project, attach a separate sheet to briefly describe the larger project.

6. Discuss whether the project will increase the quantity and type of solid waste, as defined by Public Resources Code section 40191, or hazardous waste, as defined by Health and Safety Code section 25117, that is generated or stored onsite.

7. Identify the location, type, and quantity of hazardous materials, as defined by Health and Safety Code section 25260, that are stored, used, or disposed of at the project site and a copy of the Hazardous Material Business Plan (HMBP) prepared for the proposed premises, if any.

8. List the water source(s) and amount, in gallons, supplied for each indoor and outdoor commercial cannabis activity at the project site. Identify the wastewater treatment system (e.g., septic, aerobic or lagoons) used for the project site.

9. Estimate the number of anticipated employees onsite, occupancy during operating hours, frequency of deliveries or shipments originating to and from the project site, describe the anticipated transportation activity at the project site including the effects of the project related to public transit, bicycle, or pedestrian facilities.

BCC-LIC-025 Page 3 of 4 (New 10/18)
State of California BCC-LIC-025 (New 10/18) Gavin Newsom, Governor California Department of Consumer Affairs Bureau of Cannabis Control
www.bcc.ca.gov

10. Describe the project’s anticipated operational energy needs, identify the source of energy supplied for the project and the anticipated amount of energy per day, and explain whether the project will require an increase in energy demand and the need for additional energy resources.

SECTION C: OTHER RELEVANT CEQA INFORMATION
Submit any other relevant CEQA documentation or information that will assist the Bureau in determining CEQA compliance (e.g., any environmental impact analysis prepared by a consultant).

BCC-LIC-025 Page 4 of 4 (New 10/18)

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