Item 14 2023-01587 Update on the Cannabis Opportunity Reinvestment and Equity Program’s (CORE) Storefront Cannabis Dispensary Permitting Progres — Sacramento City Council, January 23, 2024 (part 1 of 2)

City of Sacramento
City Council - 5PM Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2023-01587 1/23/2024 Discussion Item 14.

Update on the Cannabis Opportunity Reinvestment and Equity Program’s (CORE) Storefront Cannabis Dispensary Permitting Progress
File ID: 2023-01587
Location: Citywide
Recommendation: 1) Receive a status report on the progress of the ten CORE participants awarded the opportunity to apply for a storefront cannabis dispensary business permit; and 2) provide direction to staff concerning: a) participants who are unable to become operational by the April 1, 2024 deadline, and b) whether additional storefront permit opportunities should be made available to CORE participants.

Contact: Davina Smith, Program Manager, (916) 808-4772, [email protected]; Fiona Mattson, Program Specialist, (916) 808-8925, [email protected], Office of Cannabis Management, Office of the City Manager
Presenter: Davina Smith, Program Manager, (916) 808-4772, [email protected], Office of Cannabis Management.

Attachments:
1-Description/Analysis
2-Resolution No. 2020-0338
3-Cannabis Equity Study
4-Sacramento Comprehensive Cannabis Study EPS
5-CORE Survey and Interview Analysis
6-Ordinance No. 2020-0035
Description/Analysis
Issue Detail: The City’s storefront cannabis dispensary (storefront) business permit is the only cannabis business permit (BOP) type that is capped. On October 13, 2020, the Council authorized 10 new storefront permits to be issued to Cannabis Opportunity Reinvestment and Equity Program's (CORE) participants increasing the number of permits from 30 to 40 (30 non-CORE majority-owned and 10 CORE-majority owned). Council resolved to offer the opportunity to apply for the new permits

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to the most business-ready participants, determined through a request for qualifications (RFQ) process. The 10 top-scoring participants were given 3 years to apply for and operate a storefront. If any of the top-scoring participants were not able to apply for and operate a storefront within that time, the opportunity to apply for the new permits would be given to the next top-scoring participants (Resolution No. 2020-0338) (Attachment 2).

As such, Council directed staff to report back once several of the new storefronts had opened so that the Council could further discuss whether additional storefront opportunities should be made available to CORE participants. That 3-year period expires on April 1, 2024, and 5 out of the 10 top- scoring participants have successfully applied for and been issued a storefront permit. The following includes staff’s report to Council:

Status of the CORE Storefront Permit Progress
As of December 29, 2023, the progress of the ten top-scoring participants is as follows:
· Permitted Participants
o 5 participants have been issued storefront BOPs.
· In-Process Participants - Prior to issuance of a storefront BOP, at a minimum, applicants must have secured a location, a conditional use permit (CUP), building permits, and certificate of occupancy (COO). The other 5 top-scoring participants are at various stages of the process (In-Process).
o BOP applications: 2 participants have applied for a BOP. o CUPs: 4 participants have secured locations with an existing CUP or have been issued a CUP for their location.
o Building Permits/COOs: 4 participants are in various stages of obtaining building permits and building out the premises to receive a COO from the City’s Building Division.
o Securing Location
:1 participant is in the process of securing a location and beginning the CUP process (previous location had a fire).

In-Process Participants & the April 1, 2024 Deadline
The Office of Cannabis Management (OCM) has significant concerns that most of the participants that are In-Process will not meet the April 1, 2024 deadline. Three or four of the participants have indicated that they need additional time to become operational. There are several factors that have challenged the business development climate for the participants since the RFQ process was approved in 2020 during the global pandemic. First, CORE participants, generally, do not have access to generational wealth and have had to overcome many barriers non-CORE businesses would not encounter as noted in the City’s Cannabis Equity Study (Attachment 3). Several of the participants have discussed the difficulty in finding partners/investors that are not predatory and that offer fair terms.

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Next, it is a significant challenge to maintain and pay for a lease on a premises able to house a cannabis storefront while applying and paying applicable fees for and obtaining land-use approvals.

Contractors must be obtained to configure the premises, along with permits for the building upgrades.

Participants must navigate and meet regulatory requirements for the City and the State, as well as facing supply chain disruptions due to the global pandemic and financial barriers non-cannabis businesses typically do not encounter (i.e. banking and conventional loan procurement).

Further, it is important to note that the top-scoring participants have invested significant time, money, and resources into the process of obtaining a storefront BOP over the last several years.

In acknowledgement of this investment, the challenges, and associated impacts on the ability to open the business within 3 years, staff feels it is prudent for Council to provide direction on whether additional time should be provided to the 5 participants that are In-Process. In doing so, Council could direct staff to return to Council with a resolution extending the deadline to April 1, 2025.

Alternatively, Council could direct that this extension be made available only to those who have hit a tangible benchmark (e.g. having applied for a Conditional Use Permit or building permits or obtained a Certificate of Occupancy) by April 1, 2024.

Consideration of Additional Storefront BOP Opportunities for other CORE Participants As indicated from the survey analysis below, storefront BOPs continue to be the most sought-after permit type among CORE participants. It is important to note that although there are currently more than 360 CORE participants, only about 100 applied for the storefront RFQ. Some participants weren’t in CORE at that time or weren’t at a place in their lives where they were ready to submit a Statement of Qualifications. Many of those participants have said that they would like to have those opportunities made available again through the addition of more storefront permits for CORE participants.

Opening additional CORE storefront permits would also be a significant step towards the goal in the CORE Program Guidelines of having half of all cannabis businesses be majority CORE-owned to increase equity and inclusion in the Sacramento cannabis industry. Currently, 16.4% of cannabis businesses in Sacramento are majority CORE-owned (41 CORE businesses and 250 non-CORE businesses). This number has been steadily, but slowly, rising since 2019, but there is still a long way to go before 50% is reached. Additional cannabis storefront opportunities exclusive to CORE participants would help in reaching this goal.

Although there were some concerns expressed by CORE participants in the survey results below around oversaturation leading to declining profits, oversaturation does not appear to be an issue at this time, as detailed in the Comprehensive Cannabis Study authored by EPS and presented to Council on May 31, 2022 (Attachment 4). Sacramento is a net exporter of cannabis to the region and the only place in Sacramento County where cannabis businesses are allowed (except for the City of Isleton). Many of the neighboring counties do not allow cannabis businesses at all, which leaves a

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vacuum for Sacramento businesses to fill. Once the 40 storefront dispensaries that are currently authorized by the Council all become operational, it will result in one storefront dispensary for every 39,311 residents in Sacramento County. Although data is sparse on the performance of the CORE storefront dispensaries because most have only been open a few months or less, the one CORE dispensary that has been open for a year shows that their gross proceeds and business operating tax remittances are in line with non-CORE storefronts.

A final consideration is that an ordinance for consumption lounges connected to storefront dispensaries has been requested by the Law & Legislation Committee. CORE members have asked that this opportunity be made exclusive to CORE participants and be made available to more than the original ten highest RFQ scorers. This would again help in attaining the goal of 50% of all cannabis businesses owned by CORE participants.

Consistent with prior Council request to revisit the question, staff are seeking direction on whether additional storefront dispensary opportunities should be made available for CORE participants apart from the ten already approved by Council.

If Council chooses not to provide further direction on either item of consideration, the number of storefront dispensary permits will remain at 40 and staff will remind the participants who are In- Process that they must obtain a storefront BOP by the close of business on April 1, 2024, otherwise their opportunity will be void. Staff will then attempt to contact the next highest scorer(s) on the request for qualifications (RFQ) from 2021 and offer them the opportunity to apply for a storefront dispensary permit with the requirement that they become operational within three years (2027).

CORE Survey and Meetings
OCM conducted two surveys and six interviews in October 2023 and December 2023, respectively (Attachment 5):
· One survey for the whole CORE community (CORE Storefront Dispensary Survey) · One survey of the 10 top scoring participants (Storefront Dispensary RFQ Survey) · Six interviews with Storefront Dispensary RFQ participants who had not obtained a BOP as of December 29, 2023
The objective of the surveys and interviews was to collect insights and information about whether additional time should be provided for the RFQ top scorers and if there was still an interest in future storefront opportunities if allowed by the Council.

Analysis for the CORE Storefront Dispensary Survey
The results of the CORE Storefront Dispensary Survey reveal a strong consensus among respondents, with 88% of respondents agreeing that Council should expand the opportunities for storefront dispensaries in Sacramento, particularly with the goal of having 50% of all storefronts majority-owned and operated by CORE participants. With 12% of CORE participants oppose opening more storefront opportunities, citing concerns about oversaturation leading to reduced profits for

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existing dispensary owners. Despite this opposition, the survey overwhelmingly supports a desire for more opportunities for storefront dispensaries.

While 58% of respondents reject the notion of OCM seeking an extension from Council for the top- scoring ten participants, citing that the allotted three-year timeline is sufficient, 42% believe an extension is needed due to the challenging nature of meeting requirements and securing investments for CORE participants.

If additional new storefront dispensary permit opportunities are to be awarded, respondents suggest three allocation methods: 1) RFQ process, 2) awarding to the next highest scorers from the previous 2021 RFQ, or 3) a lottery/random selection process for all interested CORE participants. Staff are not supportive of another RFQ process given the challenges faced with the initial process and would recommend a lottery/random selection process for those meeting specified criteria.

Lastly, it's essential to highlight some of the motivations of respondents who express a desire to open a storefront dispensary. A number of them operate existing cannabis businesses and seek vertical integration. Others have worked in dispensaries as a way to learn the business and want to open a storefront that reflects their vision. Most respondents’ aspirations extend beyond individual success to include serving the community, assisting those affected by the War on Drugs, and creating generational wealth for their families.

Analysis for the Storefront Dispensary RFQ Survey
At the time of analysis, only four out of the 10 RFQ participants had successfully opened their storefront dispensaries (one received their BOP in late December 2023, leaving five that have not opened), while the remaining face a deadline of April 1, 2024. The survey encompasses responses from six participants, including two who have successfully opened their storefront dispensaries and four who are still in the process. It is important to note that two of the five participants who have yet to open their storefront dispensaries did not partake in the survey. This introduces a challenge, as the survey analysis may not fully encapsulate the perspectives of all 10 participants.

Despite this challenge, the survey analysis reveals that three of the five participants who have not obtained a BOP yet anticipate requiring an extension, ranging from 6 to 12 months. Furthermore, the analysis indicates that at least three of the 10 participants are in favor of OCM approaching the Council to request an extension beyond the April 1, 2024, deadline.

Storefront Dispensary RFQ Interviews
OCM requested to meet and speak with the 6 CORE participants who had not obtained BOPs. Five of them agreed to meet. Interviews with the top scorers yet to open a storefront revealed that difficulties in finding non-exploitative partners/investors was a significant hurdle for most of the interviewees. Some even indicated that on-going issues with partners/investors around ownership and control of the un-opened storefronts led to several participants pivoting to new locations and a search for new partners, which also contributed to delays in opening. Some also cited delays due to

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extensive work required to get the buildings they’d leased permittable (one interviewee shared that they were required to install new water and sewer pipes), delays in obtaining contractors and supplies due to supply-chain disruptions, navigating the CUP, appeal and building permit processes, and the lack of capital.

Background: Storefront dispensaries that were open prior to the development of regulations and who registered with the City in 2009 and 2010 and then applied for and successfully completed a two -part application process between roughly 2011 and 2015 were issued storefront dispensary permits.

Changing state laws and federal directives, and the uncertainty created by these accounted for the length of time needed for this application process. The 30 who made it through that process became the only storefronts that were permitted.

In August 2018, the City of Sacramento created the CORE program to address the impacts of disparate enforcement of cannabis offenses in Sacramento by creating resources to reduce barriers to entry into the regulated cannabis industry for the impacted community members. The CORE Guidelines expressed a goal of having 50% of all cannabis businesses in Sacramento be majority- CORE owned.

On October 13, 2020, the Council adopted an ordinance (Ordinance No. 2020-0035) amending Title 5 to add 10 new storefront dispensary permits through a Request for Qualifications (RFQ) process (Attachment 6). The RFQ process is a competitive procedure wherein CORE participants were required to submit a Statement of Qualification (SOQ). A panel of non-staff scorers with expertise in business finance, cannabis equity, and operating an equity storefront assessed and scored the SOQs using a predefined scoring rubric.

The Council also adopted a resolution (Resolution No. 2020-0338) establishing the RFQ Process for issuing storefront cannabis dispensary permits, which required the 10 CORE storefront dispensary permit holders to have at least 51% of the ownership interest in the storefront cannabis dispensary and receive at least 51% of the storefront cannabis dispensary’s profits for a period of ten years from the issuance of the permit. Furthermore, the RFQ Process also established a timeline of 3 years from the date of the applicant’s award announcement to open a storefront dispensary, meaning the deadline for the 10 participants to open and operate is April 1, 2024. If a participant is unable to meet that deadline, the opportunity defaults to the next highest RFQ scorer.

Policy Considerations: Opening additional CORE storefront dispensary opportunities would aid in the achievement of the Council’s goal of having 50% of all cannabis businesses be majority-CORE owned.

Economic Impacts: None.

Environmental Considerations: Not applicable.

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Sustainability: Not applicable.

Commission/Committee Action: On October 13, 2020, Council adopted Ordinance No. 2020-0035 amending Title 5 to add 10 new storefront dispensary permits and adopted a resolution to establish a RFQ process to administer the ten new storefront dispensary permits. Staff were tasked with reporting back on the progress of the opening of these storefront dispensaries, at which time, the Council would decide whether to revisit the number of storefront dispensary permits available for CORE participants.

Rationale for Recommendation: No specific staff recommendation is being made. However, staff has identified the challenges encountered and the severe consequences that will be experienced by the remaining 5 RFQ top scorers if they are not able to obtain a BOP by the April 1, 2024, deadline.

Council can choose to direct staff to bring forward a resolution to extend that deadline by 12 months in light of this information. Conversely, Council can decide to provide no direction, which will result in the storefront opportunities becoming void for those that cannot obtain a BOP by the April 1, 2024 deadline and OCM providing those opportunities to the next highest scorers of the 2021 RFQ.

Similarly, staff has brought forward, as requested, an update on the status of the CORE storefront dispensaries for Council discussion on whether additional storefront opportunities should be made available to CORE participants. If directed by Council, staff can bring forward an agenda item to increase the number of storefront permit opportunities.

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RESOLUTION NO. 2020-0338
Adopted by the Sacramento City Council
October 13, 2020
Process to Issue Storefront Cannabis Dispensary Permits

BACKGROUND
A. The City of Sacramento may have no more t han 40 valid storefront cannabis dispensary (“storefront”) permits. (Sacramento City Code section 5.150.350) B. The City Manager may issue a storefront pe rmit through a process that is established by resolution of the City Council. (Sacramento City Code section 5.150.350) C. The process must comply with the City C ode and may evaluate an applicant’s ability to successfully apply for and operate a storefront and utilize criteria reasonably necessary to protect the public health, safety, and welfare. (Sacramento City Code section 5.150.350) D. The City’s Cannabis Oppor tunity Reinvestment and Equity (“CORE”) Program was established to reduce barriers of entry and participation to cannabis businesses for communities and individuals negatively impacted by the disproportionate enforcement of cannabis-related crimes. CORE Program participants are currently granted priority for any storefront permits. (Resolution 2018-0323.)
E. On January 14, 2020, the City Council determi ned that: i) all storefront permits should be issued to an individual or a group of individuals in classifications 1 or 2 of the City’s CORE Program; ii) at least 51% of the ownership interest in and profits from these new storefronts must be allocated to participants that meet classifications 1 or 2 of the CORE Program for a period of 10 years from issuance of the permit; and iii) CORE Program participants be given three years from selection to apply for and operate a storefront dispensary.

F. On September 1, 2020, the City Council determined that a storefront dispensary permit should be issued through a competitive process that weighs qualifications of CORE Program participants.

G. A fair and equitable way to allocate a st orefront permits, and ensure that the best qualified CORE Program participants are selected, is through a request for qualifications (“RFQ”) process that utilizes criteria that evaluate the ability for an individual or group of individuals in the CORE Program to successfully apply for and operate a storefront dispensary.

Resolution 2020-0338 October 13, 2020 Pa
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Attachment 1

BASED ON THE FACTS SET FORTH IN THE BACKGROUND, THE CITY COUNCIL RESOLVES AS FOLLOWS:

Section1. The RFQ Process for issuing st orefront cannabis dispensary permits to individuals or groups of individuals in classifications 1 or 2 of the CORE Program is hereby adopted. (Exhibit A).

Section 2. Exhibit A is a part of this Resolution.

Table of Contents:

Exhibit A - Request for Qualifications (“RFQ”) Process to Issue a Storefront Cannabis Dispensary Permit

Adopted by the City of Sacramento City Council on October 13, 2020, by the following vote:

Ayes: Members Ashby, Carr, Guerra, Hansen , Harris, Jennings, Schenirer, Warren and Mayor Steinberg

Noes: None

Abstain: None

Absent: None

Attest:
_____________________________________
Mindy Cuppy, City Clerk

The presence of an electronic signature certifies that the foregoing is a true and correct copy as approved by the Sacramento City Council.

Resolution 2020-0338 October 13, 2020 Pa ge 2 of 8
Mindy Cuppy
Digitally signed by Mindy Cuppy
Date: 2020.10.16 09:33:54 -07'00'

EXHIBIT A

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CITY OF SACRAMENTO
REQUEST FOR QUALIFICATIONS (“RFQ”) PROCESS TO ISSUE A

STOREFRONT CANNABIS DISPENSARY PERMIT
The following RFQ process is established pursuant to Sacramento City Code section 5.150.350, which provides that whenever the number of storefront cannabis dispensary permits falls below 40, the City may issue a permit to an applicant through a process that is consistent with the City Code and established by city council resolution. (Resolution No. _________) A. Definitions.

The following definitions apply to this process:

1. “Applicant” means an individual or group of individuals in classification 1 or 2 of the CORE Program who submits a statement of qualifications in response to the City’s RFQ for issuance of a permit.

2. “Cannabis dispensary, storefront ” has the same meaning as in City Code section 5.150.020.

3. “Classification 1” means classification 1 of the CORE Program as described in City Council resolution 2018-0323.

4. “Classification 2” means classification 2 of the CORE Program as described in City Council resolution 2018-0323.

5. “City Attorney” means the City Attorney or the City Attorney’sdesignee.

6. “City Manager” means the City Manager or the City Manager’s designee.

7. “CORE Program participant” has the same meaning as described in City Council resolution 2018-0323.

8. “CORE Program” means the City’s Cannabis Opportunity Reinvestment and Equity Program, adopted by City Council resolution 2018-0323.

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EXHIBIT A

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9. “Individual” means a sole, natural person.

10. “OCM” means the City’s Office of Cannabis Management.

11. “Ownership interest” has the same meaning as in City Code section

5.150.020.

12. “Permit” means a business operations permit issued by the City to operate a storefront cannabis dispensary.

13. “Permit application process” means the City’s process for an applicant to obtain a permit in accordance with applicable state law and City Code. It includes, at a minimum, obtaining a certificate of occupancy, conditional use permit, and a business operating permit.

14. “Request for Qualifications” or “RFQ” means a written request for the submission of qualifications to successfully apply for and operate a storefront cannabis dispensary.

15. “Statement of Qualifications ” or “SOQs” means the written document submitted in response to a RFQ.

B. Process.

1. Who May Apply? The RFQ is open to all individuals who are CORE Program participants in classification 1 or 2.

2. Advertising. When a permit becomes available, OCM will advertise the RFQ for 10 calendar days on the City’s website and through other industry appropriate means.

3. RFQ Requirements.
a. The RFQ will be used solely to identify CORE Program participants with the highest scoring SOQs to successfully apply for and operate Resolution 2020-0338 October 13, 2020 Pa ge 4 of 8

EXHIBIT A

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a storefront cannabis dispensary within three years of being awarded the opportunity to apply for the permit.
b. OCM will prepare the RFQ. The RFQ must be in the City’s standard RFQ format.

4. RFQ Evaluation Criteria.
a. The RFQ shall utilize criteria that comply with the City Code and all applicable City procurement policies and procedures; are reasonably necessary to protect the public health, safety, and welfare; and evaluate the experience and training of applicants to determine which applicants will be the most successful at applying for and operating a storefront cannabis dispensary including:
i. A description of classes, trainings, and workshops completed to prepare the applicant for operating a successful cannabis business in the city of Sacramento.
ii. A business plan that includes a detailed timeline, budget, and a plan to achieve success and sustainability.
b. In developing the RFQ criteria, OCM must consider input of CORE Program participants.
c. The criteria for the RFQ are subject to the approval of the City Manager and the City Attorney.

5. Statement of Qualifications.
a. To respond to the RFQ, CORE Program participants must submit a SOQ in writing to OCM by the due date indicated in the advertisement. b. A SOQ may be submitted by one CORE Program participant or by a group of participants. No individual may be identified in any capacity in more than one SOQ. Such a duplicate submission will result in the Resolution 2020-0338 October 13, 2020 Pa ge 5 of 8

EXHIBIT A

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subject SOQs being deemed nonresponsive and disqualified from review.

6. Required Certifications in SOQs.
a. Applicants must certify in their SOQ that for a period of 10 years from the issuance of the permit that:
i. At least 51% of the ownership interest in the storefront cannabis dispensary will be held by one or more CORE Program
participants in classifications 1 or 2, and
ii. Owner(s) of the dispensary who are CORE Program
participants will receive at least 51% of the storefront cannabis dispensary’s profits.
b. The certification of ownership and profits will be a condition on the permit.

7. SOQ Acceptance and Evaluation.
a. SOQs shall not be altered after opening.
b. No criteria may be used in evaluating a SOQ that are not specified in the RFQ or in applicable City Code or other applicable laws or regulations.
c. All responsive SOQs shall be reviewed and scored by an unbiased and neutral review panel who possess the relevant knowledge or experience to evaluate the SOQs. Members of the review panel may consist of individuals who:
i. Have some level of expertise in economic or business development;
ii. Have an active involvement in social equity matters; or iii. Are cannabis business regulators from another jurisdiction.

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EXHIBIT A

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d. Under no circumstances will a member of the review panel be an employee or a contractor of the City or affiliated in any way with the cannabis industry in the city of Sacramento.
e. No member of the review panel may discuss the SOQ with applicants for any purpose other than administrative clarification after the submission of SOQ, except during the presentation phase, if any. f. Once OCM has received and calculated all the reviewing panels ’ scores, the top scoring SOQs shall be awarded the opportunity to apply for a permit, until all available permits have been issued. g. OCM will notify all applicants of the status of their SOQs through award announcements and publish the scores for all SOQs on its website as soon as reasonably possible.

8. Late and Nonresponsive SOQs.
a. A SOQ is late if it is received at the location designated in the RFQ after the deadline specified in the RFQ. A late SOQ shall be rejected and not considered, regardless of the reason for the lateness, including circumstances beyond the control of the individual or group that submits the SOQ. A late SOQ may only be opened for identification purposes.
b. A SOQ is nonresponsive if it does not comply with requirements of the RFQ or if it is submitted in accordance with section 5(b). c. Late and nonresponsive SOQs will be returned.
d. OCM shall have the authority to reject SOQs that are late or nonresponsive.

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9. Public Disclosure. SOQs submitted in response to the RFQ will be made available in response to a request for public records in accordance with the California Public Records Act.

10. Timeframe for Opportunity to Apply for a Permit. It is imperative that permits are actually issued to businesses that will successfully operate within a reasonable period of time. Therefore, any opportunity to apply for a permit shall become void and of no effect if the awarded applicant surrenders the opportunity to apply in writing or the storefront cannabis dispensary is not operating after a period of three years from the date of the applicant’s award announcement.

11. Conditions on Permits. By responding to the RFQ, applicants understand and agree that in addition to all other applicable permit conditions, the City will place the following conditions on their permit for 10 years starting from its issuance: at least 51% of the ownership of the permitted storefront cannabis dispensary must be held by one or more CORE Program participants in classifications 1 or 2; and at least 51% of the profits of the dispensary must be allocated to the CORE Program participant owner(s).

12. Tied Scores. If there are tied top scoring SOQs and there are more tied scores than permits, then the City will use a process to randomly select an applicant from among those tied SOQs.

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1 City of Sacramento
Office of Cannabis Policy & Enforcement
Cannabis Equity Study
I. Purpos
e of the Study
II. Topline Results
III. History of Cannabis Enforcement
IV. City of Sacramento Demographics
V. Literature Review
VI. Methodology
VII. Analysis of Cannabis Enforcement in the City of Sacramento VIII. Conclusion
IX. Appendix
Special
Thanks to the City of Sacramento Police Department, Crime Analysis Unit for providing the data which made this report possible.

Repo
rt Produced by Daniel Sanchez, Special Project Manager, City Manager’s Office Comp
leted: May 2018
Attachment 3

2 I. Purpose of the Study:

The Cannabis Equity Study (the “Study”) is intended to determine if and which demographic groups have been arrested at a disproportionate rate to their population within the City of Sacramento. This is important as an arrest and a conviction often mean significantly reduced employment opportunities and life outcomes.1 According to federal government research, a criminal record in the United States makes finding employment much more difficult and people who have been incarcerated earn 10 to 40 percent less than similar people who do not have criminal records.2 Similarly, enforcement of cannabis criminal laws ( “cannabis enforcement” for our purposes) affects the life outcomes of family members of individuals arrested. 3 Groups with higher rates of poverty and experience with the criminal justice system are less likely to have the means to begin successful cannabis businesses. The City of San Francisco and Los Angeles describe various barriers to entry to begin a cannabis business, these barriers include: access to capital, access to real estate, regulatory fees, among others.4 This data is included in the City’s analysis for this Study. Based on this Study, the City of Sacramento intends to develop an equity program to support communities impacted by cannabis enforcement.5 I
I. Topline Results:
1) C
annabis related arrest rates in the City of Sacramento spiked in 2006 with 1,590 total arrest incidents where one charge was related to cannabis. Arrest rates for cannabis related charges precipitously dropped after 2010. In 2010 Governor Schwarzenegger signed Senate Bill 1449 which reduced the charge for possession of one ounce or less of cannabis to a misdemeanor (
from a misdemeanor). From 2010 to 2011, cannabis arrest rates fell nearly 45% in the city of Sacramento. From 2006 to 2016 the cannabis related arrest rates citywide dropped 65%. 2) Th
e racial group arrested more frequently, where the arrest included at least one cannabis charge, was Black/African American. White, Hispanic and Asian all had arrest rates for cannabis related lower than their citywide populations.
3) Males were significantly more likely to be arrested than females. 4) The communities with the highest arrest rates disproportionate to their population between 2004 and 2017, based on zip code were: Downtown (95811 and 95814), Land Park (95818), Oak 1 Labelling, life chances and adult crime: The direct and indirect effects of official intervention in adolescence on crime in early adulthood. Bernburg, Krohn. 2003.
2 Economic Perspectives on Incarceration and the Criminal Justice System. The White House. Office of the Press Secretary. 2016.
3 Cannabis Social Equity Analysis Report. Amec Foster Wheeler Environment and Infrastructure, Inc. 2017. 4 City and County of San Francisco. Cannabis Equity Report. Office of Cannabis, Human Rights Commission, Controller’s Office. 2017.
5 This report uses data on arrest incidents where the incident included at least one cannabis charg e. The report also analyzed data on arrests for cannabis charges only. The distribution of the data on arrests for cannabis only was nearly identical to the data on arrest incidents where the incident included at least once cannabis charge. The main difference between the two data sources was that cannabis only charges were roughly half of the volume of arrests where cannabis was one of the charges. Both data sources are included in the attachments. 3 Park (95817), Parkway Meadowview (95823), Del Paso Heights South (95815), Florin Perkins (95826), Fruitridge (95820), and Elder Creek (95824 and 95828). 5) It is unclear if the locations where people were arrested for cannabis activity are also the same lo
cations where the people who were arrested lived. It is also unclear why those arrests took place. The significant number of arrests-to-population Downtown suggests that the high number of arrests occurred because of people from outside the area (not living in the area) congregating in Downtown and a high police presence in that area due to its civic and entertainment amenities.

II
I. History of Cannabis Enforcement:

T
he following is a brief overview of recent US history on cannabis enforcement.

Until recently, US government action on cannabis moved towards greater restrictions and enforcement.

The Federal Food and Drug Act of 1906 regulated food and drugs for the first time in the United States and required that any over-the-counter remedies containing cannabis be labeled. In 1937, the Marijuana Tax Act effectively criminalized cannabis. The Act both restricted possession of cannabis and required paying a tax for its authorized use in industrial or medical uses.6 The US Justice Department’s Bureau of Narcotics and Dangerous Drugs was created in the late 1960s which coincided with significant increases in cannabis arrests in California, from 7,560 in 1964 to 50,327 in 1968. 7 Furthermore, the
Comprehensive Drug Abuse Prevention and Control Act of 1970 created five schedules for regulating drugs based on medical value and assumed danger of addiction. According to the law, cannabis was a Schedule 1 drug, which along with cocaine and heroin, had no medical use and a high risk of addiction.

The law also made it a federal crime to manufacture, distribute or possess cannabis. 8 The 1990 Crime Control Act, passed by Congress, provided funds for local law enforcement agencies in seizing private property associated with unlawful drug activities, including cannabis cultivation or distribution. From 1991 to 2008, there was a drastic increase of arrests for simple cannabis possession.

The number of people arrested for possession of small amounts of cannabis nationally increased by three times as much from 1991 to 2008.9 During the same time, cannabis use did increase but not at the same rate as the number of arrests. From 1991 to 2008, according to the National Household Survey on Drug Abuse, the rate of use over the last year increased from 6,520 in 1991 to 9,797 in 2008, per 100,000 people.

Public opinion shifted on cannabis in the late 1990s. In 1996, California passed Proposition 215, the Compassionate Use Act, which allowed patients and primary care providers to cultivate and possess cannabis for personal medical use. In 2010 Governor Schwarzenegger signed Senate Bill 1449 which reduced the charge for the possession of one ounce of cannabis. In addition, in 2010 the City of Sacramento began to legalize and permit medicinal cannabis dispensaries. This led to a precipitous drop in cannabis related arrests in the City of Sacramento in the subsequent years. The Control, Regulate and 6 PBS Frontline. Marijuana Timeline.
7 Institute of Medicine Committee for the Substance Abuse Coverage Study, 1992. 8 Cannabis use in the United States: Implications for policy. Harrison, Backenheimer, and Inciardi. 1995. 9 How Risky is Marijuana Possession? Considering the Role of Age, Race, and Gender. Nguyen and Reuter. 2012 4 Tax Adult Use of Marijuana Act in 2016 passed by California voters allowed cannabis to be used and cultivated legally under state law.

On January 1, 2018 the State of California began issuing licenses for cannabis businesses under the Medicinal Adult Use Cannabis Regulation Safety Act. In 2017 the City of Sacramento Council adopted policies to regulate cultivation, manufacturing and testing of cannabis in anticipation of state law. Later in 2017 the City Council took steps to develop the Cannabis Opportunity, Reinvestment and Equity (CORE) Program that seeks to reduce barriers to entry into the cannabis market by groups disproportionately impacted by cannabis enforcement.

I
V. City of Sacramento Demographics:

Th
e data below shows City of Sacramento demographics in 2010. The year 2010 was selected because it is derived from the decennial census where more accurate data is available for subpopulations. Dates between 2000 and 2009 and after 2010, have significant margins of error for subpopulations. A high margin of error makes data less reliable.

Figure 1: City of Sacramento Demographics by Race, 2010 Total population 466,488 Percent
Hispanic or Latino (of any race) 125,276 26.86%
White alone 210,006 45.02%
Black or African American alone 68,335 14.65%
American Indian and Alaska Native alone 5,291 1.13%
Asian alone 85,503 18.33%
Native Hawaiian and Other Pacific Islander alone 6,655 1.43% Source: US Census Bureau 2010
Figure 2: City of Sacramento Zip Code Population, 2010
Location Zip Code
Percent of City population
within Zip Code Population
Parkway Meadowview 95823 10.82% 50,451
Greenhaven 95831 8.81% 41,078
South Land Park/Hollywood Park 95822 8.05% 37,570
Natomas North 95835 7.72% 35,992
Natomas South 95833 7.51% 35,040
Del Paso South 95815 7.44% 34,693
Del Paso North 95838 7.05% 32,879
Fruitridge North 95820 6.92% 32,259
Elder Creek 95824 95828 4.20% 19,607
East Sacramento 95816 4.15% 19,341
5 Natomas Center 95834 5.22% 24,353
Meadowview West 95832 3.47% 16,174
Oak Park 95817 3.46% 16,154
Land Park 95818 3.35% 15,639
Sac State East Sacramento 95819 3.33% 15,516
Center City 95814 2.98% 13,882
Surrounding Center 95811 2.00% 9,347
Florin Perkins 95826 1.36% 6,329
University Howe Ave 95825 0.48% 2,224
Source: US Census Bureau 2010 and City of Sacramento Community Development Department V. Literature Review
Academic literature confirms that there are disparities in arrest rates for cannabis by geography, race, age and gender. The literature, however, does not have consensus on exactly why certain groups have higher cannabis related arrests rates. It could be that certain racial groups or geographic areas are arrested at a greater rate because those groups have another undetected characteristic (such as greater call volume in a particular area, or higher rates of blue collar occupations—blue collar men have higher chances of being arrested for cannabis than non-blue collar men).10 Some research suggests that Black/African American people are more likely to be arrested for cannabis use because they have less access to private spaces and therefore are more likely to carry out drug use and purchases in public.

Research also shows that Black/African American people are significantly more likely to buy drugs outdoors, from strangers, and further from home—this increases the likelihood that they will be visible to police and therefore more likely to be arrested.11 These differences in cannabis purchasing behavior, however do not seem to account for the differences in arrest rates between Whites and Blacks/African Americans. If it did, according to research, Whites should have significantly more drug arrests. The literature also shows that Blacks/African Americans and Whites do not have significantly different rates of cannabis use.12 This suggests that Blacks/African Americans are not arrested more for cannabis simply because they use more cannabis compared to Whites.

The characteristic of a community is also relevant in determining the arrest rates for Blacks/African Americans and Whites. Arrests for cannabis are more likely to occur in higher visibility areas such as downtowns. Higher police presence per capita is another factor, which the literature suggests, for why Black/African American people are arrested more often for cannabis than White people.13 Research in Seattle notes that race plays a major factor in drug arrest disparities between Whites and Black/African Americans, and that per capita concentrations of police presence or citizen complaints did not account for arrest disparities.14 Subsequent research in Seattle suggests that arrests are largely 10 Arrest Probabilities for Marijuana Users as Indicators of Selective Law Enforcement. Johnson, Petersen, Wells. 1977.
11 Racial differences in marijuana users’ risk of arrest in the United States. Ramchand, Pacula, Iguchi. 2006 12 How Risky is Marijuana Possession? Considering the Role of Age, Race and Gender. Nguyen and Reuter. 2012. 13 Predicting drug arrest rates: Conflict and social disorganization perspectives. Mosher. 2001. 14 Race, Drugs and Policing: Understanding Disparities in Drug Delivery Arrests. Beckett, Nyrop, Pfingst. 2006. 6 driven by deployment of police officers and resident’s calls for service.15 This suggests that a data driven method of deploying police resources will pick up more populations in communities that have higher crime incidents and calls for service.

L
imitations of the Analysis:

It is beyond the scope of this analysis to determine which, if any, factor led to higher cannabis arrest rates for Black/African American males in Sacramento, as described below. Similarly, this report cannot specify why certain geographic regions had higher cannabis arrests than their populations would suggest.

This report does not measure City of Sacramento Police Department deployment trends, nor does it measure individual cannabis use trends per racial category per year, or methods of purchasing cannabis.

The analysis also does not measure whether arrest rates differed because of differential involvement in criminal activity. Data sources for these variables, either were not available or do not exist for the City of Sacramento.

The analysis uses zip code arrest data, but zip codes do not perfectly align with Census tracts. This means that some geographic areas are included in the Census data but should not have because they are outside the city limits.

The analysis shows that Black/African American male residents living in certain zip codes were arrested more often than their population would suggest—but not why. The analysis cannot state the reason in different arrest rates, or whether other factors, such as higher calls for service, were significant.

VI. Methodology
The primary data source for this study was City of Sacramento Police Department Crime Analysis Unit data by zip code on the number of arrest incidents, where at least one charge was cannabis related, for each year from 2004—2017 by race and gender. This date range was used because the Police Department changed their records management system in 2004. Using data before 2004 would create problems with the accuracy of the data and mean that comparing data before 2004 and after would no longer be possible. This data was used to determine which groups were disproportionately impacted by cannabis enforcement. By “disproportionate enforcement” we mean at a greater rate than the ratio of their citywide or zip code population would suggest.

Census tract data is the most basic unit of measurement for the decennial census which is collected every 10 years and for the continuous American Community Survey. The boundaries of a census tract are developed so that each tract contains roughly 1,200 to 8,000 people. Census tracts roughly, though not exactly, match zip codes within the City of Sacramento. By matching multiple Census tracts together into their zip code, this report provides an estimate of the demographics of each zip code in the City of Sacramento.
15 Race, Place and Drug Enforcement. Engel, Smith, Cullen. 2012. 7 Census tract data does not exactly match zip codes, yet this is the closest method to find the demographics of each zip code. This was necessary because the Sacramento Police Department does not collect data by Census tract, nor does the Census Bureau collect demographic data by police beat or zip code. It was therefore necessary to match these two as approximate as possible.

Once a demographic profile of each zip code was developed, including population and the proportion of population by race, this demographic data was compared to corresponding arrest rates. As stated above, arrest data from 2010 forward was used because that is when the most accurate Census tract data was available. There were 10 zip codes out of 20 analyzed which had a higher proportion of arrests for a racial group, than its population would suggest.

V
II. Analysis of Cannabis Enforcement in the City of Sacramento:
1) C
annabis related arrests in the City of Sacramento spiked in 2006 at 1,590 and remained relatively stable until 2010. In 2010, Governor Arnold Schwarzenegger signed California State Senate Bill 1449, which reduced the offense for an ounce or less of cannabis possession.16 From 2010 to 2011, cannabis arrest rates fell roughly 45% in the city of Sacramento. From 2006 to 2016, the arrest rates citywide dropped by 65%. By 2017, there were less than two hundred cannabis related arrests in the city of Sacramento.

Fi
gure 3: City of Sacramento Number of Cannabis Arrests by Year 2004 – 2017 Year Number of Arrests
2004 913
2005 1282
2006 1590
2007 1562
2008 1498
2009 1500
2010 1360
2011* 742
2012 640
2013 711
2014 702
2015 600
2016 552
2017 195
Source: City of Sacramento Police Department
16 State of California. California Legislative Information. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200920100SB1449 8 Figure 4: City of Sacramento Number of Cannabis Arrests 2004 – 2017 S
ource: City of Sacramento Police Department
2) Blac
k/African American residents were arrested, where at least one charge was cannabis related, at a rate higher than their citywide population proportion. Black/African American residents make up only 14.65% of the city’s population but 47.87% of cannabis related arrests in 2010. White and Asian residents were arrested at a lower rate than their population. Hispanic residents were arrested at a comparable, and slightly lower rate to their population. These t
rends in arrest rates by race also hold for other years, where Black/African American residents are more likely to be arrested given their population while White, Hispanic and Asian residents are arrested at a lower rate to their population. This finding does not intend to suggest why Black/African American residents were arrested at a higher rate.

Fi
gure 5: Number and Percent of Cannabis Related Arrests by Race, 2010 Race
Number
Arrests
Percent
Population Percent Arrests
White 299 45.02% 21.99%
Black 651 14.65% 47.87%
Hispanic 318 26.86% 23.38%
Asian 69 18.33% 5.07%
Source: City of Sacramento Police Department and US Census 2010 3) M
ales in the City of Sacramento were overwhelmingly more likely than females to have an arrest where at least one charge was cannabis related. This figure is comparable to most of the 0 200
400
600
800
1000
1200
1400
1600
1800
2004 2005 2006 2007 2008 2009 2010 2011* 2012 2013 2014 2015 2016 2017 Number of Cannabis Arrests
City of Sacramento Cannabis Related Arrests 2004--2017
9 academic literature which shows that males are significantly more likely to have drug related arrests and convictions.

Fi
gure 6: Gender and Percent of Cannabis Related Arrests 2004--2017 Gender
Number of
Arrests
Percent of Arrests
2004--2017
Male 12211 88.19%
Female 1636 11.81%
Total 13847 100%
Source: City of Sacramento Police Department
4) Th
ere are 20 zip codes in the City of Sacramento. Elder Creek (95824 and 95828) has two zip codes which were combined due to their proximity. Each zip code roughly corresponds to a community within the City of Sacramento, such as Oak Park or East Sacramento. Matching each zip code to multiple Census tracts gives a demographic profile for each zip code. This demographic profile contains information on the zip code’s population, and race proportion.

Certain zip codes had a higher proportion of cannabis related arrests in 2010 than their p
opulation would suggest.

For example, Oak Park (95817) made up 5.51% of all cannabis related arrests in 2010, but only

3.46% of the city population. Greenhaven (95831), meanwhile, constituted 8.81% of the p
opulation in 2010, but only amounted to 3.01% of cannabis related arrests. The report t
herefore recommends Oak Park to be included in a cannabis equity program, but not Greenhaven. Of the 20 zip codes in the City of Sacramento, 10 had a higher cannabis related arrest rate than their population percent.

Fi
gure 7: Number and Percent of Cannabis Related Arrests by Most Frequent Zip Codes, 2010 Location Zip Code 2010 Arrests
Percent of
Population, 2010
% of Cannabis
related Citywide
Arrests, 2010
Surrounding City 95811 34 2.00% 2.50%
Center City 95814 154 2.98% 11.32%
Land Park 95818 100 3.35% 7.35%
Oak Park 95817 75 3.46% 5.51%
Florin Perkins 95826 28 1.36% 2.06%
Fruitridge North 95820 118 6.92% 8.68%
Elder Creek 95824 95828 85 4.20% 6.25%
10 Del Paso South17 95815 98 7.44% 7.21%
Parkway Meadowview 95823 174 10.82% 12.79%
Source: City of Sacramento Police Department
5) C
ertain groups (male and black) and certain geographic areas (95811, 95814, 95818, 95817, 95826, 95820, 95824, 95828, 95815, 95823) had cannabis related arrests at a higher rate than their population would suggest. Exactly why these regions and groups have higher cannabis related arrests is not clear. This data also does not tell whether people who were arrested in certain areas lived in those locations in which they were arrested.

Some data suggests that people were arrested in places removed from where they lived. In the City Center (95814) most of the cannabis related arrests are concentrated between 7th and 9th s
treet along L Street. This is the same location as the former 815 L Street Nightclub and the old Greyhound Bus Station. For this reason, the report recommends removing 95814 from the list of zip codes eligible to participate.

The cannabis related arrests for the zip code 95818 are concentrated around two public housing c
omplexes. Such may be the case for other areas. For this reason, the report also discusses the im
pact of disproportionate cannabis enforcement for low income households.18 Fur
ther considerations:

Convictions:

The City of Sacramento may wish to include a cannabis related conviction as an eligibility criterion. This is because a criminal conviction record can limit a person’s ability to gain employment, apply for public assistance, or obtain a loan. Individuals convicted of drug offenses are often subject to fines, court costs, incarceration and other disadvantages. The Government Accountability Office (GAO) identified 641 additional consequences from a nonviolent drug conviction. These consequences include limited ability to achieve education, employment and government benefits. According to the GAO, 78% of these consequences can last a lifetime.
19 Early research suggests that a criminal conviction stigmatizes individuals with a criminal conviction, and that employers are less likely to respond positively to prospective employees with past convictions. 20 Similarly, employers are more likely to hire welfare recipients or applicants with scant employment history rather than former felons, according to survey research in four metropolitan areas. 21 Research
also suggests that, since many jobs are found through personal connections that match potential 17 Del Paso South (95815) in 2010 had slightly less cannabis related arrests given its population. However, between 2004-2017, 95815 experienced a higher cannabis arrest rate than its population would suggest. The population of 95815 is roughly 7% of the city while it made up nearly 9% of cannabis related arrests (2005—2017) in the City of Sacramento. For this reason, Del Paso Heights South was included. 18 “Low income households” as defined by Sacramento City Code section 17.712.020. 19 Cannabis Social Equity Analysis Report. Amec Foster Wheeler Environment and Infrastruct ure, Inc. 2017. 20 Delinquency and Stigmatisation. Buikhuisen and Dijksterhuis. 1971. 21 What Employers Want: Job Prospects for Less Educated Workers. Holzer. 1996. 11 workers with employers, these connections are weakened during incarceration. Former felons are therefore more likely to struggle to find employment, in part because their social circles are less likely to provide employment leads.22 The evidence also suggests that incarceration lowers a person’s earnings, though not always the ability to find employment. The negative impacts on earnings is greater for older employees and white-collar workers.23
Poverty:

An arrest or conviction can have significant negative impacts on an individual’s lifetime outcomes. This increases a person’s likelihood to remain in poverty. Previous Equity Studies have, therefore, included income as an eligibility criterion; this report also recommends the inclusion of income as an eligibility criterion.
24 According to the US Census Bureau the Median Household Income for Sacramento was $57,509 in 2016.25 Meanwhile, 21.4% of the population of Sacramento was in poverty.

VIII. C
onclusion:

Th
e City of Sacramento seeks to create an equity program to support groups with disproportionately higher rates of cannabis related arrests than their population would suggest. As such, this report recommends extending the program to:

Ty
pe 1: A resident of the city of Sacramento who has lived in the following zip codes for five (5) consecutive years between 1990 and 2011, 26 and who resides in a Low-Income Household. 27 These zip codes are:
95811 95820
95823 95824
95818 95828
95817 95815
95826
Ty
pe 2: A resident of the city of Sacramento who resides in a Low-Income Household and was either a) arrested or convicted for a cannabis related crime in the city of Sacramento during the 22 The Labor Market Consequences of Incarceration. Western, Kling and Weiman. 2001. 23 The Labor Market Consequences of Incarceration. Western, Kling and Weiman. 2001. 24 Cannabis Social Equity Analysis Report. Amec Foster Wheeler Environment and Infrastructure, Inc. 2017. 25 United State Census Bureau. QuickFacts. Sacramento county, California. 26 The 2011 year has been selected because from 2011 forward, cannabis related arrests dropped significantly citywide.
27 City of Sacramento Title 17: Section 17.712.020 “Low income household” means a household whose income does not exceed 80% of median income applicable to Sacramento County, adjusted for family size as published and annually updated by the United States Department of Housing and Urban Development pursuant to section 8 of the United States Housing Act of 1937.

The County of Sacramento Median Household income in 2016 was: $57,509. 12 time specified in Type 1, or b) is an immediate family member of an individual described in subsection a of Type 2.28
For the purposes of this report an immediate family member is a child or a parent. Limiting the program to residents who lived in these zip codes prior to 2011 is because from 2011 forward, the number of cannabis related arrests dropped precipitously.
28 The City of San Francisco Equity Study has recommended to make the following serious criminal convictions not eligible: offenses that include violent felony conviction(s); serious felony conviction(s); felony conviction(s) with drug trafficking enhancements; felony conviction(s) for hire; employing or using a minor to transport, ca rry, sell, give away, prepare for sale, or peddle any controlled substance to a minor; or sell, offer to sell, furnish, offer to furnish, administer, or give away a controlled substance to a minor.

13 IX. Appendix:

Barriers to Entry:

Previous Cannabis Equity Studies in Oakland, San Francisco, and Los Angeles have described significant barriers to entry for individuals and communities impacted by cannabis enforcement. Some of the significant barriers to entry are due to the nature of the new industry including an evolving regulatory framework, uncertain federal prohibitions, limits on banking due to federal regulations, real estate, utilities and capital requirements to starting the business. These are significant challenges for any entrepreneurs, but they are even more pronounced for individuals who are low income and have history with the criminal justice system.

Below is a Description of Barriers to Entry and Potential Tools to Overcome the Barriers.

Location: The availability of real estate appropriate for a cannabis business is a barrier to entry. This is due to travel distances, and the cost of purchasing or leasing in appropriately zoned locations.

Disadvantaged groups may not have access to a reliable method of transportation, while the cost of purchasing or leasing space for a cannabis business may include deposits and insurance costs which eligible individual equity applicants may not have.

Financial: Banks are regulated by the federal government and depend upon federal deposit insurance.

Banks are subject to significant penalties if they knowingly do business with a customer suspected of criminal activity. A cannabis business, under existing federal laws is not lawful. Currently, few banks and credit unions offer traditional financial services to cannabis businesses. 29 As a result, cannabis
business often must rely on cash to conduct business. Property owners and real estate professionals often do not accept cash and may be cautious to engage with an all cash business. All cash cannabis businesses may also be exposed to a greater amount of criminal activity which may increase the costs to insure the business. Furthermore, City of Sacramento conditional use permit fees and Business Operation Permit fees can increase the costs to beginning a business to tens of thousands of additional dollars.

Start Up Costs: According to the City of Los Angeles Equity Study, the start-up costs for cultivating cannabis outdoors in California range from $5,000 to $10,000. Meanwhile the start up costs for mixed light cultivators is between $18,000 to $200,000 for greenhouses. Electricity costs can hover around $5,000 annually. According to the California Department of Food and Agriculture, indoor cultivation start-up costs may exceed $400,000 for creating indoor grow rooms. 30 Without traditional methods of
raising capital, entrepreneurs may need to rely on personal wealth, which eligible individual equity applicants are less likely to have.

Business Skills and Knowledge: Eligible individual equity applicants are less likely to have significant business expertise as they are likely not employed or working in industries that expose them to the necessities of starting a business, likely reside in neighborhoods with similar disadvantaged individuals, and have limited access to capital to fund such educational pursuits. Beginning a business requires knowledge of creating a business plan, relationship with industry vendors, knowledge of regulatory and 29 Cannabis Social Equity Analysis Report. Amec Foster Wheeler Environment and Infrastructure, Inc. 2017. 30 California Department of Food and Agriculture. 2017. Economic Impact Analysis of Medical Cannabis Program Regulation: Standardized Regulatory Impact Assessment.
14 legal requirements. Beginning a cannabis business, meanwhile requires specialized agriculture, chemicals or manufacturing knowledge.31
Lack of Regulatory and Government Knowledge: Groups with little experience, or negative experience with city government or government in general may be more likely to struggle to navigate through the complex regulatory and permitting process of developing a legal cannabis business. Eligible individual equity applicants may also have less awareness of local government policies nor be able to afford professional services to help them navigate such as attorneys or professional consultants.

Below is a Description of Potential Tools to Overcome Barriers:

Financial Assistance: The City of Los Angeles Equity Study describes a municipal bank which could provide business loans and other financial products to cannabis businesses. The City could also provide low interest or no interest loans to cannabis businesses. Other financial support could include credit repair, financial planning needs, fee waivers, and assistance securing alternative financing.

Real Estate: An Equity Program could provide real estate support to entrepreneurs through an existing industry partner or an incubator program. An incubator could provide eligible businesses real estate and other business support services. Similarly, an existing cannabis business could provide real estate to disadvantaged entrepreneurs in return for certain incentives.

Business Support Services: In addition to direct financial assistance and real estate support, the city could provide business mentorship, and technical assistance. This could include consulting services on financial management, business accounting, hydroponics, manufacturing, obtaining licenses or fertilizers. Eligible individual equity applicants are less likely to be familiar with legal requirements of establishing a business, particularly a cannabis business. Connections to legal services could also assist such applicants with beginning a cannabis business.

Permit and Business Operation Permit Fees: Previous cannabis equity studies have considered the option of waiving or reducing licensing, permitting and inspection fees to reduce the financial barriers for eligible individual equity applicant entrepreneurs.

Expungement of Past Cannabis Criminal Convictions: According to the Los Angeles Equity Study, expungement of cannabis related convictions would lift certain employment barriers and the stigma that individuals carry from having a criminal record. Expungement would mean that previous cannabis related charges would change from “guilty” to “dismissed.” While having “dismissed” on a criminal record is preferable than “guilty,” individuals would, however, continue to have a criminal record and therefore may retain some stigma.32
31 City and County of San Francisco. Cannabis Equity Report. Office of Cannabis, Human Rights Commission, Controller’s Office. 2017.
32 Cannabis Social Equity Analysis Report. Amec Foster Wheeler Environment and Infrastructure, Inc. 2017.

Appendix 2:

Th
e Council of the City of Sacramento adopted the Cannabis Equity Study (the “Equity Study”) on August 9, 2018. (Resolution No. 2018-0323) In it, the City Council directed the City to continue to evaluate the Equity Study with the purpose of “[addressing] any disparate, negative impacts of cannabis-related regulation and enforcement in the city of Sacramento.” As directed, the City has conducted further research into the impacts of cannabis-related regulation and enforcement. This research and analysis is included here as an Appendix to the Equity Study.

The City continued its examination of the Equity Study by reviewing other municipalities equity reports and Census demographic data to better understand the impacts of cannabis enforcement on individuals and communities. In particular, the City and County of San Francisco’s Equity Report, which is incorporated into the research of this Equity Study, found that there are significant connections between an individual’s contact (e.g., charges, arrests, convictions, and other similar contact) with the criminal justice system and lower economic opportunity, or more directly, the development of poverty. 1 (See the City and County of San Francisco Cannabis Equity Report.) The report notes that a person with a criminal record has more difficulty in finding employment and that those that do find jobs experience lower wages on average.2
Similarly, the report notes that rates of criminal incarceration are 2 to 7 times more likely for Black and Hispanic parents. Children with incarcerated parents are more likely to experience adverse outcomes such as poor mental health, dropping out of school, and being unemployed. Furthermore, the report indicates that job application experiments found that applicants with criminal records were 50 percent less likely to receive an interview request or job offer compared to the same applicant with no criminal record. Such impacts on neighborhood poverty may increase the attraction towards the perceived immediate benefits of illicit activities. If a young person, often black and poor, does not have access to, whether practical, social, or environmental, legal economic opportunities, the cost of being involved in crime goes down.
3 Given that poverty is significantly connected to cannabis enforcement, the report recommends that the city of Sacramento’s highest poverty zip codes be included in the cannabis equity program.

In researching Sacramento zip codes, the City used Census 2010 data to organize Census tracts into zip codes. A Census tract is an area that is roughly equivalent to a neighborhood as estimated by the U.S.

Bureau of Census. The tracts generally include about 1,200 to 8,000 people in an effort to provide a stable set of geographic units for statistical data. By roughly adding Census tracts to match zip code boundaries, the percentage of families living in poverty in each zip code citywide can be estimated.

Those zip codes where the percentage of families living in poverty was 20% or more are the most impoverished areas in the city and are recommended to be included as part of the Cannabis Equity Program.
1 City and County of San Francisco. Cannabis Equity Report. Office of Cannabis, Human Rights Commission, Controller’s Office. 2017.
2 The White House. Economic Perspective on Incarceration and the Criminal Justice System. April 2016. 3 Urban Poverty and Juvenile Crime: Evidence from a Randomized Housing -Mobility Experiment. Ludwig, Duncan, Hirschfield. 2001.

Those communities are: Del Paso Heights South (95815), Del Paso Heights North (95838), Elder Creek (95824, 95828), and Meadowview West (95832). Since Elder Creek and Del Paso Heights South are already included in the report, this Appendix recommends adding only Del Paso Heights North and Meadowview West as eligible zip codes in the CORE Program.

Final Report
Sacramento Comprehensive
Cannabis Study
Prepared f
or:

City of Sacramento, Office of Cannabis Management
Prepared by:

Economic & Planning Systems, Inc. (EPS)
March 8, 2022
EPS #212060
Attachment 4

Table of Contents
Introduction ................................................................................. 1 Study Focus Areas, Approach, and Methodologies .................................... 2 Issues Overview ................................................................................. 4 Chief Findings .............................................................................. 7 Primary Conclusions ............................................................................ 8 Additional Considerations ................................................................... 12 Overview of Cannabis in Sacramento .............................................. 15 Growth of the Industry ...................................................................... 15 Location of Industry Function Groupings ............................................... 25 Economic Trends in the Cannabis Industry ..................................... 29 Introduction ..................................................................................... 29 Macro-Level Trends ........................................................................... 29 National Trends ................................................................................ 39 State Trends .................................................................................... 42 Local Trends .................................................................................... 48 Ownership Considerations .................................................................. 55 Taxation Considerations ..................................................................... 65 Concentration ................................................................................... 74 Real Estate and Neighborhood Impacts ........................................... 81 Overview ......................................................................................... 81 Potential Negative Concerns ............................................................... 87 Contrasting Geographies: Long Beach, Seattle, Denver, and Oakland ....... 92 Real Estate and Neighborhood Impact Indicators and Findings ................. 95 Cannabis Impacts on Industrial Real Estate ........................................ 101 Industrial Findings .......................................................................... 103 Residential Real Estate .................................................................... 110 Cannabis Economic and Fiscal Impacts in Sacramento ..................... 127 Economic Impact Analysis ................................................................ 127 Fiscal Effects of the Cannabis Industry on the City General Fund ............ 131 Selected Bibliography ........................................................................ 135

Appendices
Appendix A: Fiscal and Economic Impa ct Analysis Methodology and Detailed Tables
Appendix B: Initiatives in Other States
Appendix C: Comparison of Cannabis Land Use Regulations: Sacramento, Oakland, Long Beach, Seattle
Appendix D: Comparison of City of Sacr amento and State of California Cannabis Regulations
Appendix E: Real Estate Mark et Analysis Support Figures Appendix F: Cannabis Business Crime Data

List of Figures
Figure 1. Consumer Cannabis Spending at Sacramento Retailers ..................... 16 Figure 2. City Sacramento Consumer Spending in 2021 .................................. 17 Figure 3. Gross Receipts by Industry Function Group ..................................... 18 Figure 4. Trends in Licensed Cannabis Businesses per Year ............................. 21 Figure 5. Cannabis Supply Chain Diagram .................................................... 25 Figure 6. City of Sacramento Distribution of IFGs .......................................... 26 Figure 7. Wholesale Cultivator Profitability .................................................... 33 Figure 8. Cannabis Retailer Revenues and Costs ............................................ 37 Figure 9. Annual Growth of Legal Versus Illicit Cannabis Sales in the US ........... 40 Figure 10. Cannabis Product Composition ..................................................... 41 Figure 11. Estimated Licensed and Unlicensed Retailers by Region ................... 43 Figure 12. Average Price for Cannabis Flower by Retail Type ........................... 43 Figure 13. State of California Cannabis Tax Revenues—2018-2021 .................. 45 Figure 14. Quarterly Licensed Cannabis Sales per Capita by California Region .... 46 Figure 15. Consumer Spending on Legal Cannabis in Sacramento .................... 48 Figure 16. City of Sacramento Gross Receipts by Industry Function Group ........ 49 Figure 17. City of Sacramento Occupied Square Footage by IFG ...................... 50

Figure 18. City of Sacramento Gross Receipts per Square Foot by IFG .............. 51 Figure 19. City of Sacramento Cultivation Floor Area Growth ........................... 52 Figure 20. City of Sacramento Distribution of Cannabis IFGs ........................... 82 Figure 21. Industrial Floor Area by Council District ......................................... 84 Figure 22. City of Sacramento Cannabis Buffers and Available Land ................. 85 Figure 23. Detail of Cannabis Businesses in Council District 2 .......................... 88 Figure 24. Detail of Cannabis Businesses in Council District 3 .......................... 89 Figure 25. Detail of Cannabis Businesses in Council District 4 .......................... 89 Figure 26. Detail of Cannabis Businesses in Council District 5 .......................... 90 Figure 27. Detail of Cannabis Businesses in Council District 6 .......................... 91 Figure 28. Distribution of Cannabis Businesses in the City of Long Beach .......... 93 Figure 29. Distribution of Cannabis Dispensaries in the City of Seattle .............. 94 Figure 30. Retail Occupancy & Rent: Citywide and Cannabis Analysis Zones ...... 96 Figure 31. Retail Occupancy & Rent: D4 Overall and D4 Cannabis Analysis Zones.......................................................................... 97 Figure 32. Retail Occupancy & Rent: Representative D4 Cannabis Analysis Zones.......................................................................... 97 Figure 33. Retail Occupancy & Rent: Districts Overall and Cannabis Analysis Zones.......................................................................... 99 Figure 34. Industrial Real Estate Metrics by Building Size and Class ............... 102 Figure 35. Industrial Occupancy & Rent: Citywide and Cannabis Analysis Zones........................................................................ 103 Figure 36. Industrial Occupancy & Rent: D1 Overall and D1 Cannabis Analysis Zones........................................................................ 104 Figure 37. Industrial Occupancy & Rent: D2 Overall and D2 Cannabis Analysis Zones........................................................................ 105 Figure 38. Industrial Occupancy & Rent: Representative D2 Cannabis Analysis Zones........................................................................ 106 Figure 39. Industrial Occupancy & Rent: D4 Overall and D4 Cannabis Analysis Zones........................................................................ 107 Figure 40. Industrial Occupancy & Rent: Representative D4 Cannabis Analysis Zones........................................................................ 107 Figure 41. Industrial Occupancy & Rent: D5 Overall and D5 Cannabis Analysis Zones........................................................................ 108

Figure 42. Industrial Occupancy & Rent: Representative D5 Cannabis Analysis Zones........................................................................ 108 Figure 43. Industrial Occupancy & Rent: D6 Overall and D6 Cannabis Analysis Zones........................................................................ 109 Figure 44. Industrial Occupancy & Rent: Representative D6 Cannabis Analysis Zones........................................................................ 110 Figure 45. Industrial Occupancy & Rent: D7 Overall and D7 Cannabis Analysis Zones........................................................................ 110 Figure 46. Home Values in the Sacramento Region ...................................... 111 Figure 47. Home Values in Sacramento Neighborhoods ................................ 112 Figure 48. Home Prices within ¼-Mile of Cannabis Production Uses ................ 114 Figure 49. Home Prices Near Cannabis Production Uses in Council District 2 .... 116 Figure 50. Home Prices Near Cannabis Production Uses in Council District 6 .... 118 Figure 51. Single-Family Home Sales within One-Quarter Mile of Dispensaries . 120 Figure 52. Economic Impact Analysis Components ....................................... 129

List of Tables
Table 1. City of Sacramento Gross Receipts by Industry Function Group ........... 15 Table 2. Cannabis Employment by Industry Function Group ............................ 18 Table 3. Top 10 Industries by Employment in City of Sacramento .................... 19 Table 4. Licensed Cannabis Businesses per Year ............................................ 20 Table 5. Overview of Cannabis Industry Function Groups ................................ 24 Table 6. Cannabis Businesses by Function Group per Council District ................ 27 Table 7. Key Multinational Cannabis Companies ............................................ 31 Table 8. Annual Licensed Cannabis Sales per Capita 2018–2021 ...................... 47 Table 9. Industry Function Group Characteristics ........................................... 53 Table 10. Local Tax Comparison .................................................................. 66 Table 11. Licensed Cannabis Businesses by Council District ............................. 83 Table 12. Sacramento Cannabis Businesses by Zoning Classification ................ 86 Table 13. Cannabis Business Floor Area Concentration by Council District ......... 87

Table 14. Home Prices Near of Cannabis Production Uses ............................. 115 Table 15. Home Prices Near Cannabis Production Uses in Council District 2 ..... 117 Table 16. Home Sales Near Cannabis Production Uses in Council District 6 ...... 119 Table 17. Home Sales Near Cannabis Dispensaries ...................................... 121 Table 18. Robberies and Burglaries at Cannabis Businesses in Sacramento ..... 124 Table 19. Robberies and Burglaries by Cannabis Business Type ..................... 125 Table 20. Summary of Economic Impacts ................................................... 130 Table 21. Summary of Fiscal Impacts ........................................................ 132 Table 22. Detailed Summary of Fiscal Impacts ............................................ 132

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Sacramento Comprehensive Cannabis Study
March 8, 2022
Economic & Planning Systems, Inc. (EPS) 1
Introduction
The City of Sacramento (City) has retained a team led by Economic & Planning Systems, Inc. (EPS) to conduct a comprehensive cannabis study (SCCS/Study).

The Study is directed to the City and is intended to inform public policy pertaining to land use, fiscal/economic, and other regulatory/policy topics. The industry is continually on the verge of significant change. After only a handful of years of legalized adult cannabis consumption in Sacramento, the timing for this Study is ideal as the City considers regulatory options. The Study revolves around the following four questions:

1. What is the scale of the industry and its constituent elements in Sacramento?

2. How does the industry affect the City’s economy, real estate, and neighborhoods?

3. Does the industry cover its related City service costs and generate surplus revenue to the City?

4. Based on the literature and case studies, what are some possible directions to explore regarding appropriate municipal oversight of the industry? After a brief overview of the footprint of the industry in Sacramento, national, State of California (State), and local industry performance metrics and trends are discussed relative to industry performance and tax receipts. Case studies of other jurisdictions and key literature review findings are included, providing the basis for comparing and contrasting industry regulatory techniques. Several qualitative trends and issues are examined to establish a foundation on which the components of a successful regulatory framework can be identified. For example:
 Where and under what conditions have jurisdictions regulated industry to ensure sustained health, resulting in a sustainable source of revenue?  Can big tobacco, big pharma, or private equity be combined with local stakeholders in a strategy to capture wealth in the local community?  What tools and techniques are jurisdictions using successfully to ensure that significant benefits accrue to communities in need?
 What is the most direct path to wealth creation? What cities have tried other approaches, and how do the results contrast with Sacramento’s? For example, does it make sense to facilitate major industry interests if the result is a larger and more stable flow of tax proceeds, with expanded funding for local causes or entrepreneurial support beyond the cannabis industry?

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The ideal regulatory framework for the City depends on the City’s expressed priorities. Cannabis is a dynamic, complex, new industry, highly subject to changes in market conditions and federal regulations. There is a total of 5 years of data on operating adult use cannabis in California. It is often cited as an engine for social restitution, economic development, health/wellness, and public services provision. Yet, industry and government are often not aligned in these efforts, which also reflects its relative newness and its challenge to long-time social convention, as well as legitimate concerns regarding youth exposure and other societal ills.

The cannabis industry has been prominent in California for many decades, and the illicit market remains dominant today. The State has been roundly criticized for its high excise tax, which places legal cannabis in California at a consumer price disadvantage and contributes to an overall cost burden that has become problematic for small and medium-sized operations in Sacramento, and which favors larger players with deep pocket investors that can survive a period of minimal or negative cash flow while gaining market share. Cultivating and growing a local niche of small Cannabis Opportunity, Reinvestment and Equity (CORE), woman-owned, and other sought-after owner groups in Sacramento may require a concerted effort, expanded Office of Cannabis Management (OCM) resources, and supportive policies addressing the headwinds these firms face.

A legitimate case can be made for leveraging Sacramento’s excellent geographic and political position in the State to allow arguably inevitable large firm growth to facilitate the generation of more stable and predictable tax revenue. Again, being precise about intended outcomes will help the City sort through candidate options and approaches.

Study Focus Areas, Approach, and
Methodologies
A major priority of the Study is to understand how other jurisdictions have handled these issues and options, as well as understanding the greater body of literature on the emerging practice of cannabis regulation. EPS organized its review of policy approaches across the following categories:

1. Land Use Regulation. Comparable city land use regulations related to the location of the various cannabis industry sectors and adjacent uses.

2. Ownership: Structure and Ability to Transfer. Explore the range of ownership structures in the industry from sole proprietors to large organizational models with the intent to understand current trends and operational specifics across the range. In particular, how is ownership controlled and monitored by various jurisdictions?
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3. Taxation and Fees. Investigate trends regarding the primary sources of tax revenue generation from the cannabis industry. In particular, decreasing or increasing reliance on the use of any types of taxes, changes in the tax rates applied since legalization, and the introduction of exemptions. Identify other jurisdictions’ strategies for allocating additional tax revenues.

A variety of methodologies are leveraged to provide a comprehensive overview of industry dynamics. More specific and detailed discussions of methodologies are included in the following chapters. Highlights are provided here:
 Multi-City Case Studies. Following an initial period of evaluation, several cities were chosen to serve as primary case studies, including Long Beach, Oakland, Seattle, and Denver. Case studies were carried out to compare the industry and regulations comprehensively, including but not limited to dispensary ownership regulations and approaches. These case-study findings are woven into the ensuing report on a topical basis. Interviews were held with City cannabis management leaders in Oakland and Long Beach covering a full range of topics as case-study follow-ups.
 Literature Review. As an augmentation of case studies and interviews, EPS conducted a comprehensive literature review. A list of documents accessed is provided in the Bibliography. Documents were drawn from a combination of academic, industry, government, and popular press sources.  Stakeholder and Key Informant Interviews. The EPS team conducted wide-ranging and confidential interviews among industry practitioners and representatives, government officials, academics, industry associations, Property and Business Improvement Districts (PBIDs), developers, consultants, lobbyists, neighborhood activists, and community members.  Real Estate Performance Evaluations (Leasing and Sale Trends). EPS conducted detailed evaluations of all cannabis concentrations in the City, focusing on performance metrics applying to both commercial district and residential neighborhood impacts. A variety of commercial database applications were used in these evaluations, as described in Chapter 5.  Fiscal Impact Analysis. EPS examined the impact of Sacramento’s cannabis industry on the General Fund of the City to evaluate how the complete set of revenues generated by the industry and related activities relates to public service costs caused by the industry. It should be noted that the analysis builds on departmental funding levels currently in place; however, sensitivity analysis is provided, testing increased service levels for certain departments most acutely impacted by the industry.

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 Economic Impact (Input-Output) Analysis (EIA). The EIA measures the total economic contribution of the industry to Sacramento County,1 in terms of jobs and economic output. This metric includes primary buyer/supplier transactions with the entire spectrum of entities doing business with the industry, as well as the expenditure of employee salaries in the local economy.

Issues Overview
The Study represents an effort to identify best practices in the regulatory oversight of the industry and to assess various options for the City.

The industry is continuously evolving. Over time, it is expected that federal decriminalization and regulation will substantially change the industry dynamics.

In anticipation of sweeping changes, the industry is moving quickly to consolidate and vertically integrate
2 to thrive in a larger but increasingly competitive market.

Consumer acceptance is partially a function of innovative design, packaging, marketing, and branding. Small entrepreneurs are hard pressed, with pressure from larger corporate-backed interests on one side and the black market on the other. Even highly organized and competent enterprises operating in this space in Sacramento are often unable to turn a profit and in some cases are behind on State and federal taxes.

Hence, small locally owned enterprises are also under pressure from both market conditions and tax burdens. Calibrated tax rates and reduced barriers to entry may be needed to bolster these businesses. However, the best opportunity for the industry to fund targeted programs may be reliant on the inevitable advent of big business. On one hand, this may appear to contradict several public policy objectives, including the ongoing goals of the City’s CORE program, but may provide a larger, long-term pool of revenue to fund alternative entrepreneurial and restitutive programs.

Can the City effectively incent collaboration to reduce front-end infrastructure costs? How have other cities managed to sort through these and other challenges? How can the City best harness market forces and an understanding of industry economics to benefit its local citizens and business community?

1 The federal Bureau of Economic Analysis county-based data provide the basis for input-output multiplier analysis; therefore, analysis by county or groupings of counties is more reliable than sub-county areas.
2 Vertically integrated businesses combine one or more industry functions, typically to achieve greater efficiency or to support increased market share.

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Cities such as Denver offer some clues. Several years ahead of Sacramento and other California cities in legalization of both medical and recreational cannabis, Denver has effectively assimilated the industry and the culture around it and become a related tourist destination of sorts. Retail districts are replete with upscale cannabis storefront dispensaries that blend in with a variety of other boutiques.

From an economic development perspective, a key consideration is the spillover effect the industry may have on other sectors in the Sacramento economy.

Is cannabis a viable and worthwhile pursuit as an industry providing broad benefit to the City? Further, is it an appropriate industry worthy of directing persons or groups/cohorts toward, or should more broad-based skills be emphasized across more general categories of employment and business management/ownership? An integrated approach to regulation and taxation will produce maximum benefits such as optimal usage of tax revenues and other industry-generated funds supporting reduced barriers to entry. Tax rates in Sacramento are not excessive compared to other major cities studied. The most vulnerable community entities are highly sensitive to costs of all types, including tax rates. The strongest vertically integrated users have comparatively little sensitivity to tax rates and other imposed costs.

Cannabis is a complex and challenging industry, and not a “training ground” for the inexperienced. Later in this study, EPS posits that training initiatives be spread more broadly across multiple skill sets and industries.

Based on research conducted for and represented by this report, the local legalization and taxation of the industry is related to the following interrelated issues and factors:

1. Restitution. The War on Drugs is generally accepted to have damaged individuals, households, and cultures. There is a national effort among many jurisdictions, including Sacramento, to make reparations through increased access to business equity ownership in a young and volatile cannabis industry.

2. Economic and Community Development. Does cannabis contribute to or harm the City’s efforts to grow and diversify and to train its labor force? How does it affect the neighborhoods proximate to industry facilities? Does it support growth in asset values, attract tourists, and contribute to the local arts and culture milieu? What is the importance of the industry to the City and regional economy?

3. Fiscal. The industry generates significant revenues to the City General Fund, but are current tax rates sustainable in terms of facilitating a healthy and growing local cannabis sector?

4. Health and Well-Being. For many, cannabis-derived products offer alternative and potentially low-harm benefits for medical uses and may offer a growing range of applications as further research and analysis continues.

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This Study concerns itself primarily with topics #2 and #3 stated above. While topic #1 will be further evaluated in planned follow-ups to this analysis, case- study information provided from other U.S. cities is presented as a facilitation of further study. Topic #4 will be informed over time as additional research commences, potentially at such time federal prohibition of cannabis is lifted.

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Chief Findings
A considerable portion of the unregulated industry is large and sophisticated, sharing many practices and a common long-standing culture with the emerging legal industry. Certainly, for elements of the unregulated market that routinely damage the environment, violate labor practices, and create other societal harms as a basis of their operational strategies, a viable case could be made for reduction of illegal grows and their portion of supply. Nevertheless, beyond basic common-sense measures, the correction of the legal cannabis market cannot be based on, or even primarily focused on, enforcement.

Economic incentives are the primary solution. However, the City cannot unilaterally correct the cannabis policy headwinds originating from the State, a partner with which to lobby for reduced excise taxes, introduction of a percentage cultivation tax, and strategic enforcement.

A central problem confronting these businesses is the amount of periodic debt over income. It is not uncommon to see otherwise viable small operations in Sacramento struggling to pay State and federal income taxes. Current Internal Revenue Service (IRS) provisions (Section 280E) preclude otherwise common business practices such as asset depreciation. For Sacramento’s local owners and operators, might it make sense to reduce costs of operation and start-up in support of creating a thriving local culture ahead of the gold rush in the offing? Large and vertically integrated interests are gaining momentum in North America, with a deeply financed mergers and acquisition wave sweeping the U.S., and California in particular. Sacramento is a major focal point in the State’s cannabis industry and has a strong position for future growth, if desired. Is there a rational policy regime the City can advance that provides additional support to vulnerable small and local operations over the next 3 to 5 years, while the industry and the government sort out the rules and regulations on which locals and their investors can base investment decisions?
Success in Sacramento may require the ability to command price premiums and an experiential package that goes beyond cannabis and extends to local culture.

Denver has established success in this regard. Dispensaries in Denver are welcomed in their communities, similar to the mostly positive reception in Sacramento’s Midtown. Increased quality of experience, brand awareness (local preference) on the revenue side, and appropriate training, financial assistance, and reduced unit costs through economies of scale (shared facilities) are further explored in this report based on case studies of other cities.

These case studies and supporting research suggest that cannabis revenues can be targeted to the local equity/entrepreneurial culture, facilitating the opportunity to leverage their skills into emerging opportunities.

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Primary Conclusions

1. The industry is growing and diversifying rapidly at the local, regional, State, national, and global levels.

Based on taxes remitted to the City by cannabis businesses, the cannabis industry in Sacramento took in more than $800 million in 2021. The industry’s 2021 income is more than 3.5 times the income of the industry during the first full year of legalization in 2018. Consumer spending at Sacramento’s cannabis retailers has increased rapidly, with annual year-over-year increases of 51 percent and 42 percent, respectively, in the past 2 years.

2. Dispensary sales indicate Sacramento is a net exporter of cannabis to the region and other parts of California.

With approximately $270 million in estimated taxable (excluding medical use) sales in Fiscal Year (FY) 2020/21, Sacramento experienced sales exceeding $500 per person in the City. As discussed in this report, reliable estimates of legal per capita consumption are under $200, indicating that about 60 percent of sales are oriented to other jurisdictions in the region and to pass-through buyers. As a result, an increase in the number of dispensaries will further strengthen Sacramento’s export position in the short term by adding $40 million to $60 million in additional sales to be profitable. However, it is likely additional jurisdictions may enter the market to compete for a share of the potential tax revenue. In addition, local dispensaries are losing market share to delivery services (also known as “non-storefront dispensaries”), a category that is gaining market share following the e-commerce model.

3. A short-lived spike in industrial rents following legalization appears to have eased.

Many of the industrial areas that are well-suited for cannabis production facilities experienced dramatic spikes in asking lease rates in 2018 on the heels of legalization. The rent spikes, which likely were due to a combination of real demand and speculation, appear to have moderated, though pricing pressure resulting from the growth of e-commerce and distribution remains.

4. Cannabis businesses have not had a negative impact on other nearby retail or industrial uses.

An analysis of lease rates for retail and industrial uses in the areas surrounding cannabis businesses found no pattern of negative impact on the marketability of surrounding areas, as demonstrated by asking lease-rate trends for available spaces.

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5. Cannabis businesses have not had a negative impact on nearby home values.

A comparison of home sales values within one-quarter mile of dispensaries and those within larger control groups for the same areas found that proximity to dispensaries does not reduce home values relative to other homes in the same general area.

6. Cannabis businesses have not created increases in crime beyond the levels generated by other businesses.

The proliferation of cannabis businesses in Sacramento has not generated a proportional increase in crimes targeting these businesses, suggesting that the enhanced security measures employed by these businesses are a strong deterrent to crime.

7. Cannabis is important to the City General Fund.

Cannabis generates a fiscal surplus nearing $20 million annually to the City General Fund. The contribution of cannabis to the City’s General Fund indicates potential to increase OCM resources as needed, including various services to smaller minority- and woman-owned operations that are vulnerable in today’s economic and policy environment, including incentives to sustain CORE entrepreneurs.

8. Cannabis is a significant driver of the Sacramento County and City economies.

The industry generates $2.3 billion in economic activity in Sacramento County, supporting approximately 12,500 jobs annually. Based on the City’s share of total Sacramento County economic activity, it is estimated that $2.0 billion and 11,000 jobs are located in the City.

9. The industry is on the cusp of a profound change with federal legalization combined with massive and ongoing technological innovation.

Vertically integrated companies with deep pockets are already establishing a position in Sacramento and the State. Large, well-capitalized players are able to sustain major losses as they gain market share and future control of the industry. Even without near-term legalization, major research efforts have ramped up, informing diversified product development. Of notable concern, the imposition of additional federal excise taxes on legalization could further create pressure on the industry absent corresponding reductions in costs at the State or local level.

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10. Smaller local players may be partially protected through “protectionist” policies of the City.

Local industry interests have indicated margins are too thin to be sustainable.

Larger corporate interests are also losing money in many cases, often as an overt strategy to gain market share. Examples of useful steps to protect smaller players may include reduced costs across the board, training subsidies, and other tools and techniques suggested by case-study research, combined with assistance and incentives to create local marketing/branding premiums. Absent local intervention, large firms will use deep pockets of funding and operational efficiencies to gain market share and drive small players out. The causes are manifold and cannot be attributed to a single cause. High State excise taxes, combined with federal tax and banking restrictions, as well as the imposition of local industry taxes of normal magnitude all combine to create a cost burden that needs to be addressed.

Importantly, current City limitations on the granting or transfer of ownership is problematic for local operators, and (as discussed in this report), a “hybrid” approach discouraging “permit flipping” such as the City of Oakland’s may strike the right balance.

11. A major cultivation oversupply is working its way through the market, with prices dropping precipitously.

Contributing to the problem, unregulated grows in California maintain an unregulated price advantage, while contributing to a current glut of supply (both legal and illegal). Cultivation in Sacramento has increased dramatically since 2018. However, the high cost burden for legal production makes it infeasible to compete with the unregulated market. Multiple sources report that California cultivators are growing three times as much cannabis as can be consumed in the State, which is both flooding the market and feeding product to the illicit market.
3 Something akin to “price parity” between the legal and illicit market will need to be achieved to eradicate the problem, similar to what Colorado has achieved.

12. Sacramento is well positioned to command a strong position in the State’s trade of legal cannabis, even after federal legalization.

Sacramento is well-located in the State, appealing to the powerful distribution functions, which are at the heart of the industry’s economics. Access to large Northern California consumer populations, relatively low costs of labor and land, and access to State policy makers all place Sacramento in strong position for future cannabis growth and development. However, given the advent of major greenhouse cultivation sites emerging throughout the State’s coastal valleys, it seems likely cultivation will gradually seek out other locations, reducing pressure on Sacramento’s industrial districts.

3 Forbes, Chris Roberts, “It’s gonna be a bloodbath”; Epic Marijuana Oversupply Is Flooding California, Jeopardizing Legalization, August 31, 2021.

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13. The industry does not appear to produce negative economic effects on commercial and residential districts.

The industry has settled into most districts with minimal negative impact. In many cases, the capital investments in cannabis business facilities and other neighborhood improvements have resulted in positive overall impact. Detailed analysis of commercial and neighborhood economic effects in the City’s areas of concentration (Districts 2 and 6 in particular) indicate the industry has not substantially changed local market behavior. Over time, the industry will seek to migrate to areas having a competitive advantage. The Denver case study suggests the industry is likely to be economically and culturally assimilated into the City over time. One important area raised by stakeholders is continued efforts to ensure that youth are protected from inappropriate marketing, such as billboards that promote cannabis use.

14. Local areas of potential saturation concern include cultivation and delivery services in Districts 2 and 6.

This analysis looked at several indicators of over-concentration, including an examination of the root zoning causes of the issue, as well as other measures such as ratios of establishments to population and interviews of stakeholders.

However, as discussed in this report, it is likely that the market will “shake out” over time, and it may not be necessary or productive to place barriers on these uses. Cultivation is currently capped at 2.5 million square feet (approximately 10 percent of total industrial space). While CUPs have been granted for the total amount, space used for cultivation is well below the cap, at about half of the allowed square footage. As discussed in this report, demand for this use in Sacramento appears to have tapered somewhat, suggesting that the cap may not be reached.

15. Many small and local firms need assistance in funding start-up capital or ongoing operations.

The City can help to sustain the local industry until significant business opportunities open up with relaxed federal regulation. In some cases, incentives for providing shared capital benefitting multiple firms can be explored. There is potential for techniques such as creating a local revolving loan fund, seeded by above-referenced General Fund proceeds generated by the industry. Other options for expenditure of tax revenue might include improved City services needs (public safety, permitting times, etc.).

16. While OCM has been successful in obtaining major grants from the State to fund specific needs, a sustained allocation of revenue for said purposes will be more predictable than the pursuit of grants.

OCM budget needs should be further examined, and case-study lessons from Oakland and other locales may offer lessons regarding the need to monitor or enforce the complex types of equity transfers and investment activity that are transpiring in the industry. Also, business operating permits (BOPs) struggle to keep pace with ownership transfers and complex shared-use arrangements Sacramento Comprehensive Cannabis Study
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12 Economic & Planning Systems, Inc. (EPS)
of business operations. Based on supplemental discussion and analysis, the City could increase its OCM resources. At the same time, simplification of ownership transfer and other requirements may reduce demands on staff time. A range of ownership options are offered by Oakland and Long Beach, as discussed in this report.

Additional Considerations
In addition to using the fiscal surplus identified in this report as seed funding for a revolving loan fund program for all cannabis start-ups to reduce operational costs and barriers to entry, it may be advisable to open up the range of industry-funded benefits to establish a broad, cross-sectional skill base for victims of the war on drugs to allow for both non-management employment in this industry and to open the door to participation in other industries.

Sacramento is on the precipice of a new era in its economic development, with epochal projects such as Aggie Square and others expected to grow and diversify several industries related to the life sciences cluster. A strategy of providing broad-based skills training to communities in need may be appropriate as a path to directing interested CORE applicants back into a cannabis industry facing continued federal illegality, intense economic pressures and transformation, and major corporate consolidation and vertical integration.

A potential exists for Sacramento to leverage competitive advantage to extract maximum benefit from the evolving industry as it takes residence in Sacramento and simultaneously provide real opportunities for social equity applicants to gain market share and generate wealth. The question is, how can CORE equity participants and applicants be best served? Existing CORE permit holders absolutely need the ability to transfer ownership to be viable. Currently, all CORE members can transfer ownership interest in their businesses in the same manner as non-CORE businesses, with the exception of the new Storefront permits, which must stay 51 percent CORE for 10 years. However, to retain CORE benefits, the business must stay at least 51 percent CORE.

Similar to a land trust incorporating deed restrictions in the field of affordable housing to the exclusion of realized capital gains, should these permit holders be denied the same opportunity as non-CORE owners to realize their maximum potential nest egg as they sell their business? The 3-year vesting period as is being considered for Oakland social equity owners may be an avenue to providing this opportunity without the threat of permit flipping being seen in Chicago. The argument against CORE owners selling 100 percent of their dispensary ownership to the highest bidder is that if the purchasing owner is a non-CORE owner, then a CORE opportunity is removed from the pool. This is solely predicated on Sacramento’s dispensary limits.

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An alternative scenario may be possible, whereby Sacramento positions itself to accommodate the industry on its regulatory terms, with the goal of levying the maximum sustainable taxes to generate funds applied to a broadened range of training across multiple industries. Tax rates in Sacramento are relatively consistent with other major cities studied. The most vulnerable community entities are highly sensitive to costs of all types, including tax rates. In contrast, the strongest vertically integrated users have comparatively little sensitivity to tax rates and other imposed costs.

Should the City support local players for a defined period of time or pivot to accommodate the large and powerful industry that will influence the industry in Sacramento and California? Depending on expressed priorities, both options are possible. If well integrated, industry forces may be marshaled to constitute a strengthened and better funded local policy program to the benefit of those in need.

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Overview of Cannabis in Sacramento
Growth of the Industry
Based on taxes remitted to the City by cannabis businesses, the cannabis industry in Sacramento is estimated to have generated more than $800 million in gross receipts in 2021, as shown in Table 1. The industry’s 2021 income is more than

3.5 times the income of the industry during the first full year of legalization in 2018. Delivery, distribution, and cultivation now represent a significant portion of the legitimate cannabis economy, accounting for 12 percent, 21 percent, and 24 percent of the total cannabis industry’s income in 2021, respectively.

In addition, these 3 sectors all took in more than $100 million in gross receipts in 2021.

Table 1. City of Sacramento Gross Receipts by Industry Function Group

Industry
Function
Group 2013 2014 2015 2016 2017 2018 2019 2020 2021
Dispensary [1] $35.9 M $57.5 M $84.2 M $117.4 M $129.9 M $138.8 M $161.0 M $219.9 M $295.8 M Delivery [2] - - - $0.001 M $0.001 M $7.5 M $25.2 M $60.6 M $102.0 M Distribution [3] - - - - - $6.7 M $23.4 M $93.9 M $173.3 M Testing [4] - - - - - $0.5 M $1.5 M $4.1 M $9.0 M
Microbusiness [5] - - - - - - $0.9 M $2.9 M $3.8 M Manufacturing [6] - - - - - $49.2 M $40.7 M $8.9 M $41.0 M Cultivation [7] - - - - $0.0 M $15.8 M $36.3 M $69.0 M $195.5 M TOTAL $35.9 M $57.5 M $84.2 M $117.4 M $129.9 M $218.6 M $289.0 M $459.3 M $820.4 M Source: City of Sacramento; EPS.
[1] Dispensary includes storefront only.
[2] Delivery to consumer.
[3] Distribution between industry functions; includes broader logistical services. [4] Testing of cannabis products.
[5] Microbusiness is a small operation with activities crossing functional areas. [6] Manufacturing includes processsing of raw ingredients and production of products. [7] Cultivation is growing and harvesting cannabis plants; only allowed indoors in Sacramento.

Estimated Gross Receipts (Millions, per year)
Note
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Consumer spending on cannabis products in Sacramento, measured by gross receipts at delivery and dispensary businesses, was nearly $400 million in 2021, as shown in Figure 1. The share of consumer spending on cannabis products at delivery-only dispensaries has grown from 10 percent of spending in 2018 to 40 percent in 2021, with nearly $200 million in spending at delivery-only dispensaries in 2021.

For context, bars and restaurants in Sacramento took in approximately $744 million and liquor stores took in approximately $80 million in 2021.

Spending at Sacramento dispensaries in 2021 was roughly comparable to spending at gas stations ($408 million) and more than double the spending at clothing stores ($198 million) in 2021, as shown in Figure 2. 4 Figure 1. Consumer Cannabis Spending at Sacramento Retailers

4 2021 consumer spending in other categories based on ESRI Business Analyst’s Retail Profile. $36 M
$57 M
$84 M
$117 M $130 M $146 M
$186 M
$281 M
$398 M
-
$50 M
$100 M
$150 M
$200 M
$250 M
$300 M
$350 M
$400 M
$450 M
2013 2014 2015 2016 2017 2018 2019 2020 2021
Dispensary Delivery
Source: City of Sacramento Office of Cannabis Management, EPS.

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Figure 2. City Sacramento Consumer Spending in 2021

Gross receipts across most types of cannabis businesses in Sacramento have increased every year since legalization. The various permitted activities in the cannabis industry are generally categorized into 7 major groupings, known as Industry Function Groups (IFGs),5 which are described in detail and summarized in Table 5 later in this chapter). Table 1 and Figure 3 provide citywide summaries of gross receipts for each of the IFGs.

Gross receipts for manufacturers have not followed the same growth trend as the other IFGs. In the first year of legalization, manufacturing was the second-largest cannabis business sector in the City by gross receipts, taking in nearly $50 million. However, revenues for manufacturers have not matched the growth of the overall industry, with manufacturers taking in only $41 million in gross receipts, although this figure is a marked increase over their performance in 2020, when they took in approximately $9 million.

5 A vertically integrated business may include multiple functions, but each function area generally will require a separate business operating permit, unless it is a microbusiness. -
$100 M
$200 M
$300 M
$400 M
$500 M
$600 M
$700 M
$800 M
Consumer Spending in 2021
Source: City of Sacramento Office of Cannabis Management, ESRI Business Analyst Retail Marketplace, EPS.

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Figure 3. Gross Receipts by Industry Function Group

Based on results from a survey of cannabis businesses conducted by the City’s OCM, it is estimated there are approximately 8,000 people employed directly by the cannabis industry in the City, as shown in Table 2. Further, it is estimated that more than half (53 percent) of those employed in the industry are in the cultivation sector, making this by far the most labor-intensive sector of the industry in Sacramento.

Table 2. Cannabis Employment by Industry Function Group (2021)

Dispensary
Delivery
Distribution
Testing
Microbusiness
Manufacturing
Cultivation
-
$50 M
$100 M
$150 M
$200 M
$250 M
$300 M
$350 M
2015
2016
2017
2018
2019
2020
2021
Source: City of Sacramento, EPS.

Square Feet per Full
Time Employee
(FTE) [1]
Estimated Employee
FTE's
Industry Function Group
Cultivation 375 4,224
Manufacturing 450 457
Distribution 150 1,363
Retail 150 709
Delivery 100 1,216
Total 7,970
Source: City of Sacramento; EPS.
[1] Square feet per employee assumptions are based on intial data provided by the Office of Cannabis Research pertaining to a survey of local cannabis businesses within the City.

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As shown in Table 3, cannabis is in the top 10 industries by number of employees in the City, contributing significantly to the local economy. For further discussion of the cannabis industry’s impact on the larger economy and the finances of the City, see Chapter 6.

Table 3. Top 10 Industries by Employment in City of Sacramento (2021)

In addition to increasing gross receipts overall, the number of cannabis businesses has increased each year since legalization in 2018, with particularly strong growth in 2020, when the 112 new licenses issued more than double the amount of licensed cannabis businesses from 2019. Growth in 2021 has slowed somewhat, with only 46 new businesses added.

Rank
Number
Employed in
City of
Sacramento [1]
1 25,000
2 11,500
3 11,400
4 10,800
5 9,000
6 8,900
7 8,500
8 8,300
9 8,000
10 7,800
Source: IMPLAN, EPS.
[1]
Cannabis [2]
Other Real Estate
IMPLAN is a private economics firm that provides data and software for analyzing local and regional economies.

Employment data from IMPLAN is available at the County
level - City estimates for Sacramento were produced from this data by adjusting IMPLAN totals based on the proportion of total County residents that live within the City (83 percent) and rounded to the nearest 100.

Industry
State Government
Local Government - Education
Transit and Passenger Transportation
Individual and Family Services
Full-Service Restaurants
Hospitals
Limited-Service Restaurants
Emploment Services
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As shown in Table 4 and Figure 4, the number of cannabis businesses has increased every year since legalization. Cultivation businesses now account for 35 percent of all licensed cannabis businesses, up from 23 percent in 2019, and growth in delivery businesses has been strong as well, mirroring the growth in delivery businesses’ gross receipts. Despite issuing zero licenses for delivery dispensaries in the first year of legalization, there are now 58 licensed delivery dispensaries, making it the second largest industry function group by number of licenses.

Table 4. Licensed Cannabis Businesses per Year6

6 Real estate, floor area, and crimes analysis is based on data provided by the City’s OCM in July 2021. Data provided in January 2022 show 264 licensed cannabis businesses—to be consistent throughout the Study, any discussion of cannabis businesses in Sacramento refers to the data provided in July 2021.

New Total New Total New Total New Total
Industry Function Group
Cultivation 9 9 13 22 47 69 20 89
Distribution 1 1 7 8 20 28 7 35
Manufacturing 3 3 8 11 9 20 7 27
Transport 0 0 1 1 2 3 0 3
M i c r o 0 00 0 3 33 6
L a b 4 40 4 0 40 4
D e l i v e r y 0 0 1 81 8 3 14 995 8
Storefront 30 30 0 30 0 30 0 30
Total 47 47 47 94 112 206 46 252
Source: City of Sacramento Office of Cannabis Management, EPS. 2020 20212018 2019
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Figure 4. Trends in Licensed Cannabis Businesses per Year7

7 Storefront dispensaries were not included in this chart because their numbers have not changed since legalization. Microbusinesses, testing laboratories, and transport-only businesses were excluded as there are relatively few of these businesses, and excluding them improves the chart’s legibility. See Table 4 for more detailed information.
89 58
35 27
0 10
20 30
40 50
60 70
80 90
100
2018 2019 2020 2021
Active Licenses
Cultivation
Delivery
Distribution
Manufacturing
Source: City of Sacramento, EPS.

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The major IFGs are summarized below:
 Cultivation. Indoor cultivation in Sacramento is heavily concentrated in the City’s industrial zones in Council Districts 2 and 6. Cultivation expanded rapidly in Sacramento and elsewhere in the last few years; however, long- term trends point toward extensive indoor grow operations in California’s coastal regions. While cultivation is land intensive and can introduce odor concerns, it continues to be an important component of smaller-scale, vertically integrated “microbusinesses” that prefer to directly control product from seed to final product. Capital costs are very high at the outset. The use generates a substantial fiscal benefit to the City. While some continued growth is likely advisable for the health of the industry, cities around the country are beginning to place limits on this use.
 Manufacturing. While manufacturing is a relatively small use in terms of industry footprint, is makes a useful contribution to the City’s local economy with skills and other crossovers to other manufacturing. This use is at the center of the creative process in the cannabis industry and features high start- up costs and specific technical skills among employees. Progress on IRS depreciation limitations and banking limitations will be helpful to this function.

Shared facilities are a potential necessity, offering the possibility of pairing CORE participants and other small operators with larger vertically integrated firms where proper incentives can be put in place.
 Distribution and Logistics. Characterized by warehouse, office, and fleet parking uses, distributers occupy a central position in the industry as the “connective tissue” between cultivators, manufacturing, and retail.

Distributors pay cultivation and excise taxes to the State and are at the center of the “burner permit” problem in California, whereby product is legally purchased (and taxes paid) from cultivators, then sold in the unregulated market. Current lawsuits allege the State has turned a blind eye to excessive cultivation resulting in California while realizing the benefits of the flat tax on cultivation (itself an identified problem). This use is a natural fit in the Sacramento Region and generates major fiscal benefits to jurisdictions.

Operator interviews indicate that sustaining operations is more difficult than start-up challenges. The industry requires sophisticated executive skills and relies on various emerging software products. Multi-State Operators (MSOs) are prevalent in this sector.

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 Non-Storefront Dispensaries (Delivery). Delivery services are growing quickly and steadily gaining market share relative to bricks-and-mortar dispensaries. This function has very low barriers to entry and uses mostly unskilled labor, with the exception of management. Like dispensaries, these services provide a major fiscal benefit to the City. These services are heavily concentrated in industrial areas such as District 6. It is expected that these establishments will undergo considerable shake out as the market matures.  Dispensaries. Effectively retail operations, these stores are major fiscal contributors and are heavily staffed by modestly paid and trained “budtenders” and management personnel. Current limitations on the transfer of ownership to non-CORE firms in Sacramento have inhibited the ability of local owners to find buyers.
8 Along with non-retail dispensaries, an estimated
60 percent of product is sold to consumers outside the City. An additional 10 dispensaries, as allocated by Sacramento, would increase the export share and could be met with additional regional competition as additional jurisdictions enter the market. Other cities offer some interesting alternatives to qualifying their respective “equity participants,” as discussed in this chapter. The City of Oakland is considering using a 3-year vesting period 9 after initial BOP issuance to help eradicate “permit flipping” among applicants not otherwise interested in owning and operating. Oakland currently allows an open transfer of ownership for non-equity owners, but only allows equity owners to sell their business to other equity owners. As part of this approach, if a local brand for CORE products can be established which commands a price premium which loyal customers are willing to pay, all manner of retail cannabis outlets in Sacramento may have a basis to compete more effectively on an ongoing basis, providing the potential to continue operations without selling to outside investors.

8 A 1-year moratorium on all ownership transfers is set to expire in May 2022. Otherwise, ownership interest in a permit is allowed to change provided there is continuity in ownership. The permit may not be “sold”.
9 Oakland adopted a 1:1 non-equity to equity ownership policy for all cannabis permits.

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Table 5 provides a synopsis of the characteristics of these components of the cannabis industry in Sacramento.

Table 5. Overview of Cannabis Industry Function Groups (IFGs)

IFG (1) Characteristics
Cultivation Sacramento - indoor only
High power requirements for indoor operations
Odor draws neighborhood complaints from certain facilities Evolved into element of sophisticated corporate operations Some concern of underutilization of urban industrial land Manufacturing Industrial facility small to medium size
Contribution to City economic structure
High start-up costs, significant infrastructure
Requires working knowledge of technical processes
Seamlessly integrated into vertically integrated businesses Good technical sector with cross-over, retain and encourage Supports other sectors of economy
Distribution Warehouse, fleet parking, office
& Logistics Sales, marketing, marketing, customer care, functions High security requirements and costs
Farmer, manufacturing, and sale outlet relationships
Can arrange logistics around testing, packaging, other value adds Can be vertically integrated with emphasis on distribution, Sophisticated multi-disciplinary operations
Executive level skills, knowledge of industry, taxation, packaging, testing, and all other aspects of industry
Regional coverage beyond Sacramento
Sacramento viable as distribution location - good fundamentals Non-retail dispensaries Warehouse plus office
(delivery service) Unskilled labor with exception of management 50% drivers, also dispatch and management
Gaining significant market share from dispensaries following e-commerce trends in general
Have created significant concentrations in industrial areas Dispensary Effectively a retail operation
(bricks and mortar) Performs well in a variety of retail environments Losing market share to delivery companies
Significant start-up costs
Owners transitioned from medicinal to recreational, capped at 30 Major movement among MSOs to control market share (M&A) Budtenders make minimum wage plus or slightly more plus tips Sacramento = major exporter to region
(1) Excludes "microbusinesses", which are a combination of above components, often in a campus.

Also excludes testing, which is normally located in standard office and R&D uses.

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Figure 5 below illustrates the linkages between these major components by way of the industry supply chain. Of note in the supply chain is the relative importance of the distribution function. These entities collect and pay cultivation and excise taxes to the State and have control over what product gets to market through their relationships with cultivators, manufacturers, and retail dispensaries. They are increasingly MSOs as these entities seek market share in California and other domestic U.S. cities ahead of expected federal legalization. This trend is further detailed in Chapter 4.

Figure 5. Cannabis Supply Chain Diagram

Graphic reprinted from the Legislative Analyst’s Office December 2019 report, “How High? Adjusting California’s Cannabis Taxes.”
Location of Industry Function
Groupings
As shown in Figure 6, the cannabis industry is not distributed evenly throughout the City. The central areas of the City, such as Midtown, contain a large proportion of the City’s licensed storefront dispensaries, while Districts 2 and 6 contain the majority of cannabis production, manufacturing, and distribution uses, as shown in Table 6. Based on the new City Council districts adopted in December 2021, Council District 8 is the only district in the City without a licensed cannabis business. However, Council Districts 1, 3, and 7 only have a total of 4 cannabis businesses between them.

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Figure 6. City of Sacramento Distribution of IFGs

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Table 6. Cannabis Businesses by Function Group per Council District

The uneven distribution and concentration of cannabis businesses is due to 2 primary factors: (1) the location of zoning districts that permit cannabis uses and (2) the location and availability of industrial buildings well-suited for cannabis business users. Table 6 shows the distribution of cannabis businesses across the Council Districts. Neighborhood and real estate impacts as a result of this distribution are explored in further detail in Chapter 6.

1234567 T o t a l
Industry Function Group
C u l t i v a t i o n 1 1 9024 6 30 89
D i s t r i b u t i o n 07025 2 10 35
M a n u f a c t u r i n g 06114 1 50 27
T r a n s p o r t 0000030 3
M i c r o 0300120 6
Subtotal Production 1 35 1 5 14 104 0 160
L a b 0300010 4
Delivery 0 10 0 11 3 34 0 58
Storefront 0 7 1 10 3 8 1 30
Total [1] 1 55 2 26 20 147 1 252
Source: City of Sacramento Office of Cannabis Management, EPS. [1] Includes businesses with active licenses as of July 2021.

City Council District
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Key Chapter Findings
 The industry is growing and diversifying rapidly at the local, regional, State, national, and global levels. Based on taxes remitted to the City by cannabis businesses, the cannabis industry in Sacramento took in more than $800 million in 2021. The industry’s 2021 income is more than 3.5 times the income of the industry during the first full year of legalization in 2018.

Consumer spending at Sacramento’s cannabis retailers has increased rapidly, with annual year-over-year increases of 51 percent and 42 percent respectively in the past 2 years.
 While consumer spending at storefront cannabis dispensaries grew steadily from 2013 to 2021, spending on cannabis delivery sales has grown dramatically in the last 4 years, accounting for more than a quarter of cannabis retail sales in Sacramento in 2021.
 The cannabis industry is now among the top 10 employment sectors in the City, with approximately 8,000 workers, half of whom are estimated to be in the cultivation sector.
 Council District 4 (Midtown) continues to have the highest concentration of storefront dispensaries in the City, while District 6 contains more than half of the City’s non-storefront delivery dispensaries.
 District 6 contains a majority of production-related cannabis operations, with 104 of the 160 such operations in the City (as of July 2021); District 2 has the next highest production concentration with 35 operations (as of July 2021).

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Economic Trends in the
Cannabis Industry
Introduction
This chapter describes overarching trends in the industry, followed by trends nationally, statewide, and in the City. It includes case studies of Long Beach, Oakland, Denver, and Seattle on issues of ownership, taxation, concentration, and social equity initiatives.

Macro-Level Trends
For centuries, cannabis has been used for its medicinal, as well as psychotropic, effects. Two events in the 20th century—the 1925 International Opium Convention, which effectively banned its exportation worldwide, and the 1937 Marijuana Tax Act, which banned hemp and cannabis production in the United States—effectively created a worldwide prohibition on cannabis cultivation, distribution, and consumption. During this prohibition, cannabis continued to be cultivated and consumed illegally worldwide. In the 1970s in the Netherlands, cannabis began to be used legally, both medicinally for cancer treatment (and later HIV/AIDS) and recreationally following decriminalization. Over the past half century, cannabis has become increasingly important for both its therapeutic and mood-enhancing qualities.

International Market Dynamics
Increasing legalization for both medicinal and recreational cannabis is driving a global market that is projected to grow from $28.3 billion in 2021 to $197.7 billion in 2028, an annual growth rate (CAGR) of 32 percent.10 North America dominates the international market and was valued at $16 billion in 2020.

As the first of the G12 (industrially advanced) nations to fully legalize cannabis, Canada has become the leader in the medical cannabis sector. During the past couple of years, the nation’s federally licensed industry has expanded into medical cannabis markets such as Australia, Germany, and Brazil. Canadian capital and operating experience are being leveraged in more than a dozen overseas markets.11

10 https://www.fortunebusinessinsights.com/industry-reports/cannabis-marijuana-market- 100219
11 Ibid.

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A 2018 report discussed the dynamic of cross-border stock listings, merger and acquisition deals, partnerships between entities from different countries, and breakthrough export and import policies allowing international movement of cannabis products, primarily for medicinal purposes.
12 However, the international
picture is evolving rapidly; cannabis usage is at varying stages of legality and decriminalization in several countries in Europe, South America, and parts of Asia.

In many countries though, cannabis is expected to remain illegal in the near term.

International research and development are contributing to an evolving product market. Continuous developments in extraction and infusion, along with standardization of products, is contributing to global popularity and demand for both medicinal and recreational cannabis products. More than 130 cannabinoids have been isolated in cannabis plants, and those have fueled wide-ranging research and development efforts for both medical and recreational purposes.

Super clone plants are being developed with the intent to highlight specific elements and significantly increase tetrahydrocannabinol (THC) percentages through concentrates.

Multi-national corporations are consolidating and expanding into international markets. Arena Pharmaceuticals, Inc., a biopharmaceutical company, is focused on developing and delivering medicine to American and Swiss patients.

In addition, it’s expanding into the Asian market via a partnership with Everest Medicines.13 In December 2021, Arena Pharmaceuticals, Inc. was acquired by pharmaceutical giant Pfizer for $100 per share in an all-cash transaction, for a total equity value of approximately $6.7 billion.

Recently, increased legalization and product development have attracted major multi-national corporations across a wide range of interests, including pharmaceuticals, beverages, and plant sciences. Table 7 shows the top multi- national interests in the industry.

12 An Overview of Cannabis Legalization Around the World, Omar Sacirbey, MJBizDaily Report, 2018.
13 Bojana Petković, Insider Monkey, August 13, 2019.

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Table 7. Key Multinational Cannabis Companies

Before legalization of recreational cannabis in California, the State was already considered an international epicenter of cannabis production. This has not changed as a result of legalization. To the contrary, international companies have significantly increased their pursuit and acquisition of California cannabis businesses throughout the supply chain.

Developing a National Industry
Across the nation, the legal cannabis industry has naturally organized itself in a range of industry function groups (IFGs) that make up the seed-to-sale supply chain, as described in Chapter 3. As the industry evolves, new IFGs are becoming more clearly defined as research and development (R&D) becomes increasingly important to the industry and support for consumption lounges potentially generate a new retail IFG.

Cultivation
Cultivation is becoming increasingly sophisticated, gravitating toward greenhouse mixed-light cultivation as a more sustainable approach to indoor growing and producing the highest quality flower product. Mixed-light cultivation focuses on the plant’s growth and maturity with the goal of harvesting high-quality flower in

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significantly reduced growth cycles using a fraction of the electricity and minimizing water usage through advanced irrigation techniques and treating and reusing irrigation water.

Sacramento vertically integrated cannabis company Natura has erected multiple new greenhouses as part of their master plan expansion. Glass House Farms, near Carpentaria, has the capacity to produce 113,000 dry pounds of sellable cannabis with its more than 500,000 square feet of greenhouse space. With its recent acquisition of 5.5 million square feet of former tomato greenhouses in Camarillo, Glass House Farms expects the facility to produce more than 180,000 dry pounds of sellable cannabis. The facility includes an on-site well, water treatment facilities, an automated roof-washing system, supplemental lights, and natural gas cogeneration facilities producing power, heat, and CO2, and at 6 million total square feet, Glass House Farms is the largest California cannabis cultivator.

NUGS, a vertically integrated corporation, recently signed a Memorandum of Understanding (MOU) to acquire a Sacramento cannabis cultivation facility spanning more than 15,600 square feet, with the potential to accommodate an estimated 500 grow lights. It is estimated to produce 2 to 3 pounds of premium exotic cannabis flower per light per harvest across an estimated 5.75 harvests per year, suggesting an upside potential of more than 7,000 pounds of premium cannabis flower per year, or more than 14 pounds per light. At 2021 prices ($1,800/lb. for premium flower), that represents $12,600,000 per year.

Simon Yu, CEO of NUGS, commented, “This deal represents the potential to sharply increase our premium cannabis production capacity and materially augment our status as an emerging leader in the vertically integrated California cannabis marketplace. We have already amassed years of experience refining our cultivation methods and strains in an outdoor framework with our NUGS Farm North site. Adding a top-tier indoor cultivation operation stands to help us further build upon that success and drive more volume in the premium flower market, which has powerful implications, given our recent expansion into the dispensary marketplace with our MDRN Tree downtown LA dispensary location. The combination grants NUGS expanding operations at both ends of the farm-to-sale model.”
14 Although the trend is moving toward more sustainable practices, cultivation continues to include both outdoor and indoor production of cannabis flower.

Nationally, wholesale cultivation has been under severe operational pressure in recent years as the price of flower has dropped dramatically as the number of legal cultivators has increased, but illicit product has continued to circulate in the market. Additional pandemic-related challenges resulted in significant levels of unprofitability in 2020, as shown in Figure 7.

14 Preeti Singh, SA News Editor, SeekingAlpha.

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Figure 7. Wholesale Cultivator Profitability

Manufacturing
Bioavailability is essentially absorption of a product as a percentage of the dose of the product being consumed. In the cannabis industry, increasing bioavailability is driving manufacturing R&D. With vaporizing bioavailability at 36 percent to 61 percent, smoking flower at 25 percent to 27 percent, and edibles at 4 percent to 12 percent, one of the primary areas of R&D in cannabis manufacturing revolves around increasing bioavailability in manufactured products. In cannabis, flower is flower (packaging is the primary area where manufacturing engages flower products), and all other products are manufactured. “Traditionally there were only three types of cannabis products available to most consumers on the black market: flower, hash, and homemade edibles. While flower remains the top- selling product category in today’s legal market, production of concentrates and infused foods and beverages has become more sophisticated over the years, and a much wider array of tetrahydrocannabinol (THC) containing goods—from transdermal patches to dry powder inhalers—are now accessible.”15 One evolving area of extraction technology has been focused on better bioavailability of cannabinoids and the elimination of less desirable and more harmful delivery methods such as smoking or vaping. Other methods of delivery that help with the bioavailability of cannabinoids by circumventing metabolism (including sublingual, or below the tongue; transdermal patches; and topical sprays or creams) continue to be developed and are increasingly in demand by

15 John S. Forrester, Lisa McTigue Pierce, Bob Sperber, May 27, 2021, PowderBulkSolids.com.

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consumers. The isolation of molecules is an extremely high value product as it’s been reported that both cannabigerol (CBG) (16) and cannabinol (CBN) (17) isolates, for example, can bring between approximately $30,000 and $50,000 per kilo.16
These extraction and manufacturing practices are generating infused products ranging from topicals (skin products) to highly concentrated consumables. Unlike the more established cultivation landscape, this product area is highly unpredictable in terms of consumer demand preferences and is subject to the watchful interest of established consumer packaged goods companies. Even with highly publicized efforts announcing household names in alcoholic beverages investing in infused beverage product lines, market surveys of industry revenue figures indicate that consumers have not made a measurable shift towards cannabis infused products at the expense of established competitors. This leaves the door open for smaller regional enterprises to consider developing carefully crafted products, but such initiatives should likely be of a restrained nature to avoid the crippling losses that are more tolerable for publicly traded companies with stable international product lines.

In the City, there are 26 active BOPs ranging from boutique social equity manufacturers to large-scale infusion manufacturers, creating gummies, candies, tinctures, topicals, tablets, and capsules, as well as major extraction facilities.

Nearly all Sacramento manufacturers are operating out of pre-existing industrial buildings. These manufacturers are involved in extraction, infusion, and production, with some providing distribution and services directed at cultivators, as well as vertically integrated seed-to-store operators. Manufacturing in the Sacramento cannabis industry provides broad opportunities in an extremely dynamic market.

Distribution
Distribution companies in the California cannabis product chain have three fundamental responsibilities: collect the pre-sale dry cultivation taxes from the cultivator when they pick up the product, document the track-and-trace sequence through manufacturing and testing, and collect the excise tax from the retail dispensary when delivering the retail product to market. Many of the larger companies provide manufacturing and testing facilities as well.

This vertical integration provides opportunities to develop partnerships with favorable brands and control supply to retail dispensaries. Others develop relationships with premium cultivators and manufacturers, providing them with packaging, storage, quality control, testing, and distribution, in addition to inventory management, order scheduling/tracking, and cash collection services.

16 May 5, 2021, David Hodes Cannabis Science and Technology, May 2021, Volume 4, Issue 4, pages 20 to 26.

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The State’s Type 11 license allows the distributor to provide a wide range of services. The largest of these offer their services statewide, with business relationships extending to hundreds of cultivators, manufacturers, and dispensaries.

The increasing importance of the distribution function is one of the most significant national trends in the cannabis industry. Within the industry, significant competition for market share has led to a drive toward vertical integration, particularly among the manufacturing and distribution IFGs. The prospect of future national legalization provides added incentive for this consolidation, to both respond to new national competition and expand into other markets in anticipation of a national logistics chain.

The industry’s prospects for future profitability are demonstrated by the recent mergers & acquisitions (M&A) activity, with larger corporate or other equity- backed entities seeking to maximize market share across state lines and national borders, even in the absence of any federal regulatory framework enabling interstate commerce. For example, Cresco Labs (Cresco), a Chicago-based vertically integrated company valued at more than $5.8 billion, is making major acquisitions in both the medical and recreational arenas.

Cresco’s cultivation footprint across 8 states is in excess of 828,000 square feet with 221,000 of that in California. In addition, their acquisition of Origin House is unique in that “Cresco wasn't looking to simply buy retail licenses, grow farms, and processing sites. Rather, it found that the best way to grow sales and infiltrate the largest marijuana market in the world (California) was to acquire one of the very few companies to hold a cannabis distribution license in the Golden State. Buying Origin House allows Cresco Labs to get its products into approximately 575 California dispensaries, representing about 65% of all legal retail locations in the state.” In addition, as the nation’s largest legal market and a State synonymous with high-quality marijuana, comparable to its reputation in the wine industry, large cannabis interests from other states and other countries are motivated to find a way to enter the California market.

As the legal cannabis industry continues to expand in California (about 36 percent of California communities allow some form of cannabis), consolidation will continue, and smaller operators will face intensifying competition.

The State also provides Distributor Transport Only licenses, which allow the distributor to transport cannabis goods between non-retail licensees but not to any licensed retailer (or the retailer portion of a licensed microbusiness), except for immature cannabis plants or seeds. A Distributor Transport Only licensee has the option to select “Self-Distribution” during the application process. This distributor may only transport cannabis goods that the licensee has cultivated or manufactured. In addition, a Distributor Transport Only self-distribution licensee is not permitted to transport cannabis goods cultivated or manufactured by other Sacramento Comprehensive Cannabis Study
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licensees or to hold title to any cannabis goods, unless they are authorized to do so under another State-issued license.

Testing Labs
Testing labs provide the services to ensure the cannabis product that gets to the market is consistent with the requirements of the California Department of Cannabis Control. They test for terpenes, pesticides, potency, microbial contaminants, residual solvents, heavy metals, mycotoxins, and water activity.

Some will also offer their customers other services whether they are looking to develop a new product, perfect an existing one, identify potential contamination in their facility, or identify a new strain they are developing. There are only 4 BOPs in Sacramento. With the increased emphasis on new product research, this IFG would appear to have growth potential.

Storefront Retail Dispensaries
Retail storefront dispensaries are the only public onsite venue for cannabis users to view finished product, discuss various strains with budtenders, and purchase cannabis products. Like any retail establishment, they range from extravagant destination centers with classes and events to no-nonsense, low-cost outlets in industrial districts. Upon entering and checking in with a receptionist, customers are often led from the reception area into the primary retail area and greeted by a budtender who provides one-on-one service. Today, dispensaries carry many products such as nearly all forms of cannabis for consumption, equipment, and company lifestyle items.

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Figure 8. Cannabis Retailer Revenues and Costs

Graphic reprinted from MJBizDaily Factbook.

Non-Storefront Retail Delivery
Retail delivery businesses fall into two categories. Most dispensaries operate delivery like mail carriers. Stores receive orders, which are then loaded into a vehicle and sent to the customer. Called “hub and spoke,” this delivery method is reliable and low-cost, but often slow, much to the frustration of the store and consumer alike. There is a large untapped market in California. The State legalized recreational marijuana in 2016, but it is only sold in 35 percent of the State. The remaining 65 percent does not have access to a dispensary. This could be for several reasons, including lack of resources to develop regulations or a legal prohibition on the sale of cannabis in retail stores.

However, in a 2020 ruling, a Fresno, California, judge affirmed the right to deliver to these areas by dismissing a lawsuit by 24 California cities seeking to ban deliveries.
17 Some delivery-only dispensaries are carrying an inventory of product in the vehicle. California allows operators to work out of a vehicle with $3,000 worth of inventory, and $5,000 worth if the merchandise includes pre-orders.

There are legislative efforts to increase the in-vehicle inventory size to between $10,000 and $25,000. With these mobile dispensaries, customers order on an app

17 Matt Burns@mjburnsy / 8:32 AM PST•November 16, 2021

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from the available inventory in a nearby vehicle. But the predominant trend in the industry is to have a bricks-and-mortar warehouse for product and vehicle storage, as well as an office and dispatch center. With this model, customers can order from the entire inventory that the delivery dispensary has on hand.

Consumption Lounges
New California legislation enables local jurisdictions to allow the preparation or sale of non-cannabis food or beverage products by a licensed retailer or microbusiness in an area where cannabis consumption is allowed. This new legislation has the potential to significantly alter the cannabis consumption/food service landscape. A cannabis consumption lounge license in California allows the following activities:
 Smoke, vaporize, and ingest cannabis or cannabis products on the premises of a retailer or microbusiness.
 Prepare and sell non-cannabis food or beverage products in compliance with all applicable provisions of the California Retail Food Code by a retailer or microbusiness.

A cannabis consumption lounge license in California also has multiple restrictions, including age restrictions, visibility, alcohol and tobacco prohibitions, and other operational restrictions.

A cannabis consumption lounge license in California, is a Type 10-Retailer license with a specific consumption cafe/lounge destination. At this time, consumption on site is not allowed in Sacramento. However, the integration of consumption lounges into the City has the potential to significantly increase opportunities for entry into the industry as license holders could partner with existing restaurants and create shared facilities with minimal up-front capital.

Vertical Integration
Eventual federal legalization and the ongoing expansion of legalization in other countries will continue to drive vertical integration in the industry. As it rapidly evolves into a mature industry with a growing global presence, it will begin to resemble other mature industries. The geographic distribution of activities along the supply chain will begin to align along patterns similar to other consumer product industries, as functions gravitate toward locations that provide the optimal combinations of production inputs and costs. For example, large scale cultivation will tend to seek lower land costs and ideal weather conditions (low humidity and cool nights), larger consumables manufacturing facilities will tend to gravitate toward metro fringe locations, and major distribution operations will expand their presence across the transportation network.

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National Trends
The efforts of an increasing number of states to adopt cannabis legalizing frameworks in light of the ongoing federal prohibition and continued listing of cannabis as a Class 1 Drug has led to a patchwork of regulations in each state, without federal oversight.

The legal recreational and medical cannabis industry in the United States developed over the past decade, beginning with Colorado and Washington in 2012. Following legalization in those 2 states, the US Department of Justice issued the Cole Memorandum, stating that the federal government would only intervene in state-sanctioned cannabis production in instances of failure to prevent criminal involvement, sales to minors, or illegal diversion to other states.

These first 2 states were joined by Oregon and Alaska in 2014. All 4 states instituted market-based licensing systems, similar to the regulation of alcohol sales in states without state-run alcohol monopolies. Since then, all but 13 states have legalized medical cannabis sales, and the number of states allowing adult- use sales will likely continue to grow, resulting in estimates of $100 billion in economic impacts annually within the next 5 years.18

18 MJBizDaily Factbook.

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The figure below illustrates recent and projected growth in legal adult-use and medical cannabis sales in the U.S., compared with declining sales of illicit cannabis, as most states that have legalized marijuana sales have seen notable decreases in illicit market sales. Of the remaining illicit sales nationwide, California continues to be a primary supplier.19
Figure 9. Annual Growth of Legal Versus Illicit Cannabis Sales in the US

As the demand for cannabis products has increased, the composition of the product preferences has also evolved, with growth in edible products from 8 percent of total sales in 2018 to 11 percent in 2021. A spike in vaping in 2019 has reduced moderately but continues to account for about a quarter of sales.

Flower product for smoking remains approximately half of sales volume.

Figure 10 provides an illustration of the composition of cannabis product sales.

19 MJBizDaily California Market Woes.
$5.9 B $9.1 B $11.5 B $13.0 B $14.0 B $14.8 B $15.5 B$7.4 B $11.2 B
$13.4 B
$18.2 B
$21.8 B $25.0 B $27.4 B
$66.3 B
$58.9 B
$0 B
$10 B
$20 B
$30 B
$40 B
$50 B
$60 B
$70 B
2019 2020 2021 2022 2023 2024 2025
Billions of Dollars
Estimated Annual Growth of U.S. Legal Cannabis Industry 2019-2025
Adult-Use Sales Medical Sales Illicit Market
Graphic Data Courtesy of New Frontier Data
2021 Mid-Year Market Update
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Figure 10. Cannabis Product Composition

Data preceding widespread legalization found that 30 percent of users in the United States drive approximately 70 percent of demand for cannabis.20 The extent to which these heavier users drive legal versus illicit sales is not clear.

However, it has been found that storefront dispensaries tend to be frequented by older consumers (aged 38+), likely out of a combination of ability to pay higher prices and stronger aversion to illicit activity.

Following the end of Prohibition in the 1930s, the achievement of price parity between legal and illicit alcohol markets was the primary factor reducing the size of illicit operators, and the same patterns will likely hold true for cannabis. Price parity will be the primary path toward eradication of the illicit markets that exist across the country, most notably in California, with its entrenched illegal industry.

In addition, consumers are likely to prefer legal products if there is a perception of good quality control.

But the unregulated industry remains sophisticated in its scale and interstate logistical capabilities, sharing many operating practices and sometimes supply chain partners with their established in-state legal counterparts. Certainly, elements of the unregulated market that systematically damage the environment, violate labor practices, and threaten public safety as a result of their operational practices are prime targets for stepped-up enforcement at the State and local

20 Marijuana Policy Group data cited in June 24, 2016, Econlife article by Elaine Schwartz, “How Price Changes in Marijuana Markets.”
Edible, 11%
Extract, 11%
Flower and
Preroll, 50%
Vape, 26%
Other, 3%
Share of US Cannabis Sales by Product Type
Graphic Data Courtesy of New Frontier Data 2021
Mid-Year Market Update
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levels. However, the daunting challenge of transforming large swaths of labor and resources that power the illicit industry into a legalized framework is more likely to be accomplished by thoughtful regulatory policy design than any targeted surge of law enforcement activity.21
Regulatory requirements for licensing and operating guidelines in some of the largest State cannabis markets have facilitated vertical integration and consolidation of supply chains within plant-touching functions. However, the absence of federal legalization and existing local regulations have prevented these market actors from absorbing licensed medical dispensaries, recreational retailers, specialty product manufacturers, and complementary functions such as technology and transportation. These typically smaller businesses outnumber the vertically integrated ones by an estimated ratio of approximately 10:1, as they are protected in the near-term by the absence of economies of scale (e.g., interstate transportation networks, unrestricted use of complicated transnational financial services) that federal legalization will eventually provide.22 State Trends
California’s illicit marijuana industry has existed for decades and continues to compete with licensed cannabis businesses across the State, in addition to supplying a significant share of the market in states where cannabis remains illegal. As noted previously, while other states that have legalized cannabis have seen illegal activity decline precipitously, the illegal market remains strong in California. The entrenched nature of the industry, combined with the continued demand from states where marijuana remains illegal, contributes to the continued strength of the illegal sector in California. However, both the continued prohibition of sales in many jurisdictions and the impact on product pricing from State taxes help drive the illicit market in the State.

The charts below illustrate the sizable share of unlicensed retailers in various regions of the State and the pricing differentials between licensed and unlicensed purveyors of marijuana flower for storefront and delivery sales.

21 North Bay Business Journal.
22 Marijuana Business Factbook.

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Figure 11. Estimated Licensed and Unlicensed Retailers by Region

Figure 12. Average Price for Cannabis Flower by Retail Type

26 212 132 193 16732
164
194
681 788
0 100
200
300
400
500
600
700
800
900
1000
Northern
California
Greater
Bay Area
Central
California (Incl.

Sacramento)
Los Angeles
County
Other Southern
California
Number Licensed Number Unlicensed
Source: Goldstein et al, Giannini Foundation of Agricultural Economics, University of California. $11.78 $11.49 $10.96
$9.21
$0.00
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
Delivery (7% Licensing Premium) Storefront (25% Licensing Premium) Licensed Unlicensed
Source: Goldstein et al, Giannini Foundation of Agricultural Economics, University of California.

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In addition to impacting taxable sales by licensed retailers, the illicit industry contributes to the current oversaturation of the market for raw cannabis leaf.

However, the dramatic increase in licensed cultivation over the last few years is also a key factor. The current oversupply of flower is inducing rapidly falling prices for the commodity. According to the Northern California Cannabis Alliance, prices of $1,400 to $1,500 per pound (dry weight) are necessary for a profitable cultivation operation. With prices falling well below these levels, a structural oversupply has emerged.

The State has rolled out a flawed, unpopular regulatory system for cannabis and a tax structure that is fueling the illicit market. A key point of contention among the oldest, most entrenched community of cannabis businesses in Northern California starts at the beginning of the supply chain: cultivation, cannabis concentrate extraction, and manufacturing. Many business owners allege that the State failed to accomplish the goals set out in Proposition 64 by allowing large uncapped grows in the wake of its 2018 emergency regulations. Unlike the widespread appreciation by many long-time business owners for the State’s implementation of medical marijuana use legalization in Proposition 215, the combination of Proposition 64’s lack of specific small business initiatives and the patchwork nature of localities’ ordinances has seemed to favor a certain kind of new entrant:
capital-rich corporations that can successfully absorb the cost of a high compliance burden and market fluctuations in the price of flower. More specifically, many experienced business owners report that potential licensed growers are deciding to go back to the unregulated market in a frustrated reaction to some of the administrative roadblocks, as well as the effective tax rates that result from combined assessments at all levels of government.

The recent commitment by the Governor to reduce the State tax burden to support the industry should benefit the industry, particularly if the flat cultivation tax is eliminated. Legislation proposed in February 2022 would discontinue imposition of the cultivation tax as of July 1, 2022. However, the bill would increase the excise tax by an additional 1 percent starting at some point between July 1, 2025, and July 1, 2026. The Department of Finance estimates will generate half the amount of revenue that would have been collected with the cultivation tax. While the elimination of the cultivation tax would benefit wholesale cultivation businesses or functions, the additional State excise tax will create a further disadvantage for retailers relative to the illicit market. It is unclear how the State will use the excise tax revenues.

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Despite the issues noted above, the State has experienced strong year-over-year tax receipt growth. However, major concerns are emerging regarding the effects of falling commodity prices, and it is expected that growth rates could diminish or potentially turn negative. The chart below illustrates the growth in cannabis- derived taxes collected by the State from 2018 to 2021. While revenue continued to increase from 2020 to 2021, the rate of growth was significantly below that of the previous 2 years.

Figure 13. State of California Cannabis Tax Revenues—2018-2021

$191.4 M
$310.7 M
$571.9 M $675.4 M
$36.8 M
$87.6 M
$144.3 M
$166.4 M
$169.5 M
$240.4 M
$394.3 M
$460.6 M
$0 M
$200 M
$400 M
$600 M
$800 M
$1,000 M
$1,200 M
$1,400 M
2018 2019 2020 2021 [1]
Sales Tax
Cultivation
Tax
Excise Tax
[1] 2021 estimates extrapolated from Q1-Q3 revenues.

Source: CDTFA; EPS.

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State Cannabis Sales Dynamics
The 8 northernmost counties in California with licensed cannabis as a group have the highest per capita cannabis sales in the State. The area is known for high- quality cannabis and is a net exporter. Per capita cannabis sales in Sacramento County have typically been close behind those of the northern counties, in part likely because of sales to residents of Placer and lower El Dorado Counties. Sales in El Dorado County increased dramatically in the second quarter of 2021, possibly because of resumption of tourism to South Lake Tahoe.

Figure 14. Quarterly Licensed Cannabis Sales per Capita by California Region

Sacramento Co.

Yolo Co.

El Dorado Co.

Bay Area
Central Coast
Central Valley
Metro. So. Cal.

North State
Statewide Avg.
$0.00
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
$70.00
$80.00
$90.00
$100.00
2018 - Q2
2018 - Q3
2018 - Q4
2019 - Q1
2019 - Q2
2019 - Q3
2019 - Q4
2020 - Q1
2020 - Q2
2020 - Q3
2020 - Q4
2021 - Q1
2021 - Q2
Cannabis Sales per Capita
Source: CDTFA; EPS.

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Annual spending per capita in each of the regions from 2018 through 2021 is detailed in the table below.

Table 8. Annual Licensed Cannabis Sales per Capita 2018–2021

State Tax Trends
A comparison of the taxes for all states that have approved legal adult-use cannabis yields a range of potential approaches, both at the State and local level.

Some states like California charge wholesale taxes (which are cumulative and built into the purchase price); many states also charge excise taxes (which are cumulative and are built into the purchase price), and most states have state sales taxes and local sales taxes. Alaska’s tax is based purely on weight.

Based on the comparison by state, California is on the high end of recreational cannabis taxes at the State level, and largely is consistent with other states at the local and county level. The State’s 6 percent sales tax mandates an additional

1.5 percent local sales tax and allows an additional 2.5 percent optional local tax.

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Local Trends
Sacramento’s cannabis industry reveals strong growth in consumer demand and receipts, but local cultivators, retail storefront owners, and delivery operators are struggling with high taxation, the price pressures of an aggressive and successful illicit market, and the financial pressures of lack of access to banking and the current limitations on outside investment.23 Much of this is due to federal restrictions, 280E, and State taxation. But there are areas of local taxation, ownership, and ownership restrictions that are under the control of Sacramento policies. These local trends are explored and compared to the case-study cities of Seattle, Denver, Oakland, and Long Beach.

Industry Metrics
Consumer spending at cannabis dispensaries in the City has grown steadily, with a CAGR of 30 percent between 2013 and 2021. Since 2018, however, spending on cannabis delivery has grown far more dramatically, with a CAGR of 138 percent.

Figure 15. Consumer Spending on Legal Cannabis in Sacramento (2013-2021)

23 Storefront retailers are under a 1-year moratorium that prohibits changes in ownership interest. It will expire in May 2022.
$36 M
$57 M
$84 M
$117 M $130 M $146 M
$186 M
$281 M
$398 M
-
$50 M
$100 M
$150 M
$200 M
$250 M
$300 M
$350 M
$400 M
$450 M
2013 2014 2015 2016 2017 2018 2019 2020 2021
Dispensary Delivery
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Gross receipts have increased dramatically across most IFGs in Sacramento since legalization in 2018, but manufacturing has experienced a much greater degree of variability than other IFGs. Microbusinesses, which include a range of functions including manufacturing, have also experienced greater variability. Much of the decline in manufacturing revenues during 2020, however, likely was due to pandemic-related production interruptions.

Figure 16. City of Sacramento Gross Receipts by Industry Function Group

-
$100 M
$200 M
$300 M
$400 M
$500 M
$600 M
$700 M
$800 M
$900 M
2015 2016 2017 2018 2019 2020 2021
Cultivation
Manufacturing
Microbusiness
Testing
Distribution
Delivery
Dispensary
Source: City of Sacramento Office of Cannabis Management, EPS.

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For some IFGs, a correlation exists between gross receipts and the amount of space occupied in the City. However, the space occupied by cultivation has increased far more dramatically than the gross receipts from cultivation, primarily because of falling prices of marijuana leaf because of both overcultivation and pressure from the illicit market. Conversely, dispensary square footage has been static in recent years as gross revenues have continued to grow. As a result, revenue per square foot of cultivation space has declined, while revenue per square foot of dispensary space has increased, as shown below.

Figure 17. City of Sacramento Occupied Square Footage by IFG

0.0M sq ft

0.5M sq ft

1.0M sq ft

1.5M sq ft

2.0M sq ft

2.5M sq ft
2015
2016
2017
2018
2019
2020
2021
Cultivation
Manufacturing
Microbusiness
Testing
Distribution
Delivery
Dispensary
Source: City of Sacramento Office of Cannabis Management, EPS.

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Figure 18. City of Sacramento Gross Receipts per Square Foot by IFG

The 2018 spikes in revenues per square foot for several IFGs, particularly manufacturing, correspond with spikes in asking lease rates (rents) in industrial zones throughout the City in 2018, as discussed in Chapter 5.

Dispensary
Delivery
Distribution
Testing
Microbusiness
Manufacturing
Cultivation
$0
$500
$1,000
$1,500
$2,000
$2,500
$3,000
2015
2016
2017
2018
2019
2020
2021
Source: City of Sacramento, EPS.

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The chart below illustrates the increase in cultivation floor area between 2018 and 2021. The dramatic expansion of cultivation area in 2020 coincided with the severe decline in flower prices throughout the State, potentially contributing to the much smaller expansion of cultivation area since.

Figure 19. City of Sacramento Cultivation Floor Area Growth

Sacramento Industry Function Group Characteristics Overview The range of IFGs that make up the seed-to-sale supply chain in Sacramento are consistent with both the national and State trends. These IFGs are considered for their particular regulatory, economic, employment, land use, physical plant, and locational advantages and characteristics, as well as issues of taxation, ownership, and concentration. Table 9 below condenses these characteristics for comparison. As the industry evolves, new IFGs are becoming more clearly defined as R&D becomes increasingly important to the industry and support for consumption lounges potentially generates a new retail IFG. -
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
2018 2019 2020 2021
Square Feet
New Cumulative
Source: City of Sacramento Office of Cannabis Management, CIty of Sacramento Planning Department, EPS.

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Table 9. Industry Function Group Characteristics

IFG Characteristics Taxation
Sacramento - indoor only, substantial range in size Major fiscal benefit High power requirements for indoor operations State excise tax on weight needs to be dynamic, not flat Vertically integrated may have more merit than stand-alone for Sac Required at front end Can buy cheaper elsewhere Compound effect as "tax on tax" Only important to extent needed to control quality State applies 1.8% mark-up Land intensive City could lobby State regarding reduction/change Odor draws neighborhood complaints from certain facilities Combine forces with other cities as appropriate Resource intensive (may be changing - water conservation tech) High infrastructure cost at front end
- relatively high barriers to entry across board
Industrial facility small to medium size Modest fiscal benefit, important economic driver Contribution to City economic structure Possible to control tax exposure by taking possession but not title High start-up costs, significant infrastructure IRS 280E (limiting write-offs) is particularly large issue Requires working knowledge of technical processes Consider reduction of local tax burden to equity participants Can be advanced - R&D and testing: scientist to "executive chef" and higher value added manufacturing operations (economic dev) Mature processes can be automated/limited training requirements Small scale facilities and land requirement compared to cultivation Seamlessly integrated into vertically integrated businesses Warehouse, fleet parking, office Major fiscal benefit
Sales, marketing, marketing, customer care, functions Pass through of State cultivation tax Compliance software designed for cultivators Collect on cultivation side, collect State excise from retailer, Storage, trucking functions paramount provide both to the State (outside of City taxes) High security requirements and costs
Ideally located on central point in freeway system (trucking) Farmer, manufacturing, and sale outlet relationships
Can arrange logistics around testing, packaging, other value adds Can be vertically integrated with emphasis on distribution, but with multiple BOPs
Uses owned or leased vehicle fleet
Truck driver and warehousing jobs
Warehouse plus office Major fiscal benefit
12,000 SF facility can provide Statewide service Collects 15% SET from consumer, State/local sales tax, Sac BOT sales tax Target range similar to grocery delivery radius Incidence of SET payment to distributor presents cash flow hit Unskilled labor with exception of management Also pays taxes on vehicles and fuel 50% drivers, also dispatch and management Sensitive to rising fuel costs Gaining significant market share from dispensaries following e-commerce trends in general
Consumer credit transactions - Ledger Green/MC - viable (also disp) Effectively a retail operation Major fiscal benefit
Performs well in a variety of retail environments Collects 15% SET from consumer, State/local sales tax, Sac BOT sales tax Requires an estimated $4 to $6 million in gross sales Amounts to 28% wholesale price up front 10 additional stores implies capture of $40-60 million in spending Incidence of SET payment to distributor presents cash flow hit Losing market share to delivery companies May need to reduce local sales taxes to compete with illicit market Budtenders make minimum wage plus or slightly more plus tips Price parity with unregulated market required to "move the needl e" Declining margins resulting in reduced benefits in urban locations Can possibly avoid local tax reduction if State reduces SE T Sophisticated operators unable to pay income taxes and maintain profit Many waiting for investor buy-out
Investor buy-outs are often calibrated to accrued debt levels Debt to net income is becoming unsustainable
Potential for continued retail dispensary cash flow issues Future shaky for operations needing to sell asset to raise cash Unable to obtain loans (banking restrictions)
IRS 280E (write-off restrictions)
Significant start-up costs
Complex staffing, payroll, etc.

Source: EPS.

Non-retail
Dispensaries
(delivery service)
Dispensary (bricks
& mortar)
Taxation, Ownership, and Concentration Characteristics of Sacramento Cannabis Industry Functional Classification (IFG) Cultivation
Manufacturing
Distribution &
Logistics
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(continued)
IFG Ownership Concentration/Land Use
Initially controlled by legacy illicit cannabis farmers in rented facilities Appropriate use of industrial land? Limited control on leasing costs Small vertically integrated firms may prefer control Evolved into element of sophisticated corporate operations Denver issued moratorium in oveer concentrated neighborhoods Consider limiting to: Long Beach, no constraints other than buffers 1) vertically integrated WA has a 2 million square foot limit on cultivation 2) owner occupied Critical to install appropriate security Offsite grows in coastal regions (e.g., Glass House) - key trend Shared facilities avoid duplicating infrastructure Limited concentration issues particular to this use What models most applicable? Market versus subsidized? Volatile extraction - special fire protection considerations Induce through tax incentives and grant funding? Good technical sector with cross-over, retain and encourage Shared manufacturing ordinance could facilitate equity Supports other sectors of economy participation in certain facets, with specialized training Some vertically-integrated firms interested in incubating equity participants Sophisticated multi-disciplinary operations Storage function is of potential concern Executive level skills, knowledge of industry, taxation, packaging, Sacramento viable as distribution location - good fundament als testing, and all other aspects of industry Central point on transportation grid Regional coverage beyond Sacramento Low cost of operating Primary acquisition target for large industry Proximity to major population Mullti-State Operators (MSOs) are prevalent Improving manufacturing prospects would be mutually reinforcing Potentially some opportunities for equity participants Compares favorably to cultivation if there is a need to limit uses High concentration of small operators Significant concentrations in industrial areas Origin with medical cannabis, have scaled up with recreational product High concentrations of establishments/capita Easy to form business and initiate operations, challenge in sustaining Likely to see continual stream of new entrants sans limit Candidate for operational assistance in the form of low interest loans Potential preference accruing to major players - good opportunity for equity participants Amazon? Uber? How long will the current model last?
Major movement among MSOs to control market share (M&A) Major export sector - 60% leaves City Owners transitioned from medicinal to recreational, capped at 30 New entrants in Sacramento County and eslewhere likely CORE members have fees waived (remove barrier to entry) C-1 areas may need to be phased-in as blight is addressed Moratorium to be released - attract business partners Midtown developers and brokers have accepted this use Concern: permit flippers Compares favorably to many other uses Oakland approach: merit-based with 3 year hold Success in integrating with retail/entertainment Eligibility is from police beats - arrest rate stats Positive evidence of investment in area Long Beach: Census Tract with socio-economic criteria Consumption lounges worth exploring New social equity permits: Interview favored over lottery Source: EPS.

Cultivation
Manufacturing
Distribution &
Logistics
Non-retail
Dispensaries
(delivery service)
Dispensary (bricks
& mortar)
Taxation, Ownership, and Concentration Characteristics of Sacramento Cannabis Industry Functional Classification (IFG) Sacramento Comprehensive Cannabis Study
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Ownership Considerations
The nascent legal cannabis industry is evolving so rapidly that it is almost impossible to capture a current profile of the industry before a new significant development alters the landscape. With states legalizing both through ballot measures and legislative actions, new laws and regulations are expanding the national cannabis footprint, and there is significant pressure at the national level in support of full legalization.

States and cities are creating new legislation based on what they perceive as the best legislative efforts of other states and cities. Sacramento and the case-study cities analyzed for this report have ownership structures that are as dynamic as the industry in that they are experiencing the significant financial pressures of volatile wholesale flower prices, dramatic increases in extraction products, State taxation rates well beyond any other industry, and competition from thriving illicit operators. This discussion looks to contrast and compare Sacramento’s ownership limitations, tracking, and transfer.

Local Ownership
Major corporate interests are absorbing small local stakeholders nationwide to gain market share. Because it remains illegal to transport cannabis across state lines, major operators must establish a market footprint in each state to build a national presence. California’s size makes it an extremely valuable part of the national market. Within the State structure of the law, it is useful to consider paths that Sacramento can take to both provide support to local craft entrepreneurs and capture the economic benefits of a nationalized industry.

The California Department of Cannabis Control is the agency that issues and regulates State licensing for all aspects of cultivation, manufacturing, distribution, testing, and sale of cannabis products. While the State also regulates the taxes and other industry specifics (see Appendix D), it is silent on issues of ownership, deferring to each community to craft its own regulations. California was able to look to the early legalization efforts of Washington, Colorado, Alaska, and Oregon to craft the State proposition, but these efforts did not foresee how dynamic the industry has become
.

The City’s OCM is responsible for granting and monitoring BOPs and ownership requirements for all cannabis businesses in the City. Both the State-granted licenses and City-granted BOPs are based on the individual applicant’s/entity’s qualifications and have no value. They cannot be transferred, sold, or assigned.

The State language does allow ownership in a cannabis business to be transferred. Partial ownership transfer is allowed when the new owner is deemed to be qualified by the State. Full transfer requires a new license.

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Sacramento does not limit the number of permits an individual or entity can have, with the exception of retail storefront dispensaries in which no single person or entity is allowed to have ownership interest in more than one dispensary. In the current cap of 30 dispensaries, past practices of ownership entities have compromised the ownership restrictions, resulting in a consolidation of several licenses under multi-corporate ownership. The 10 new CORE dispensary BOPs will also be subject to this restriction. There are other limiting factors on the issuance of BOPs, which are discussed below in the Concentration section of this chapter.

In the seed-to-sale discussion, Sacramento does not prohibit current dispensary owners from vertical integration. These owners have the opportunity to obtain licenses and BOPs throughout the supply chain, including cultivation, and when the moratorium on transfer of non-CORE dispensary licenses ends, they will be allowed to be acquired or partner with larger corporate interests as part of the national consolidation trend.

Tracking Ownership
Sacramento city code requires that every director and any individual/entity who owns more than 20 percent of a cannabis business, regardless of their authority over that business, must submit for a background check and be tracked by the OCM. If the cannabis business is a storefront dispensary, every director and owner, regardless of percentage of ownership, must be tracked. When surveying most of the cannabis businesses licensed in the City, it is clear that an overwhelming majority have opted to structure themselves as corporations.

As has been seen in multiple City documents, many of these corporate entities have the potential themselves to be owned by other corporate entities and even holding companies. This multi-layering of ownership presents considerable challenges in uncovering and tracking a complete ownership structure. The importance of this in all IFGs except retail storefront dispensaries is primarily limited to qualifying owners through the background check. Recently proposed adjustments to Sacramento’s ordinance will simplify this further for background check purposes. But for the retail storefront dispensaries, ownership in more than one dispensary is prohibited, and with a cap on dispensaries, ownership can be extremely valuable. Identifying individual ownership in complex corporate structures and holding companies will require significant resources to ensure that individuals have ownership in only one retail storefront dispensary. And as the City cannot restrict ownership individuals or entities from adopting corporate structures, other solutions will need to be explored.

Transfer of Ownership
The City allows the transfer of part or all of a cannabis business ownership with the exception of retail dispensaries. There is a moratorium on selling dispensary ownership that is set expire May 11, 2022. For businesses other than storefront dispensaries, transfer of ownership must be reported to the OCM on the Cannabis Sacramento Comprehensive Cannabis Study
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Business Information Change Form, which must be completed with both the information of any entity relinquishing ownership, regardless of the percentage owned, and the information of any potential new ownership.

Language from the form reads, “List any new person who has an aggregate ownership interest of 20% or more in the cannabis business. If a holding company has an ownership interest of 20% or more in the business, that holding company and its ownership percentage must be listed as well as the individuals that own the company. The CEO and members of the board of directors of the cannabis business and any holding company must be listed regardless of the percentage of their ownership interests.”
Ownership Case Studies
As the national and State cannabis industry continues to evolve, ownership structures will most likely continue the trend of consolidation. Vertical integration and market share expansion are important trends in the industry. Denver, Oakland, and Long Beach are among the many cities that allow for outside investment and vertical integration. Unlike Seattle, which does not allow cannabis producers to provide retail sales, Sacramento’s allowance of vertical integration from seed to sale is consistent with national and State trends.

It is useful to consider the experiences of other regulators wrestling with the travails of managing the fiscally lucrative cannabis industry.

The following case-study discussions provide a range of tools and techniques being used by various jurisdictions. To capture the maximum range of content and ideas for consideration, creative State policies have been evaluated in addition to those of cities and counties.

Seattle
Seattle Ownership
The Washington State Liquor and Cannabis Board (WSLCB) is the licensing authority for the state’s cannabis program that combines the recreation and medical markets. The WSLCB is not accepting applications for new retail, producer, or processor licenses. There are 3 primary cannabis business license categories in Washington: production/cultivation, processing, and retailing.

Companies can grow and process cannabis, but producers can’t also sell cannabis, and retailers can’t grow and process their own cannabis. In addition to not allowing for full seed-to-sale vertical integration, Washington cannabis businesses cannot accept investment from non-Washington state entities. Individuals must live in Washington state for at least 6 months before applying for a cannabis license. All business entities applying for a cannabis license must be formed in Washington and all individuals listed as “true parties of interest” must meet and Sacramento Comprehensive Cannabis Study
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maintain the Washington state residency requirement. There are more than 100 producer/processer licenses in Seattle and 77 dispensary licenses.24 Until recently, Seattle did not have a social equity program and conducted a Cannabis Equity Survey and Analysis. This has led to the recently appointed Social Equity Task Force that is working to provide recommendations to the WSLCB to establish the social equity program. Recently, the state has directed that all cannabis retail licenses that have been subject to forfeiture, cancellation, or revocation or licenses that were not previously issued by the WSLCB will be filled through the Cannabis Social Equity Program.

The WSLCB is also accepting applications for new Transportation and Research licenses and new Cannabis Cooperative registrations. The practice of home cultivation for adult use is prohibited in Washington state, though limited home grows are permitted for medical marijuana patients. There is a growing effort to change this, although a recently introduced bill to allow it failed.

Seattle has also seen at least one financial institution, a credit union, make a full transition to supporting the cannabis industry, including:
 Cash management checking accounts with designated Account Managers providing one-on-one service.
 Employee accounts.
 Online banking and vendor payments.
 Direct deposit payroll.
 Remote deposit capture via check scanner with same day credit.  Cash pick-up and delivery services.
 ACH transfer processing.

Seattle Ownership Tracking

Washington has multiple levels of ownership, including sole proprietorship partnerships, corporations, multi-level structures, and nonprofits. The tracking of ownership is done both at the initial application process and through their transfer of ownership process. These applications require the listing all true parties of interest. The WSLCB conducts financial and criminal background investigations on all true parties of interest, including:
 Sole proprietorship—the sole proprietor.
 General partnership—all partners.

24 http://magazine.cannabisbusinesstimes.com/article/june-2021/state-of-washington-state- cannabis.aspx
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 Limited partnership, limited liability partnership, or limited liability limited partnership—all general partners and all limited partners.  Limited liability company (LLC)—all LLC members and all LLC managers.  Privately held corporation—all corporate officers and directors (or persons with equivalent title) and all stockholders.
 Multilevel ownership structures—all persons and entities that make up the ownership structure.
 Any entity(ies) or person(s) with a right to receive revenue, gross profit or net profit, or exercising control over a licensed business—any entity(ies) or person(s) with a right to receive some or all of the revenue, gross profit, or net profit from the licensed business during any full or partial calendar or fiscal year, and any entity(ies) or person(s) who exercise(s) control over the licensed business.
 Nonprofit corporations—all individuals and entities having membership rights in accordance with the provisions of the articles of incorporation or bylaws.

In addition, it tracks married couples’ ownership and stipulates that a married couple may not be a true party of interest in more than 5 retail marijuana licenses, more than 3 producer licenses, or more than 3 processor licenses.

A married couple may not be a true party of interest in a marijuana retailer license and a marijuana producer license or a marijuana retailer license and a marijuana processor license.

Seattle Ownership Transfer

Washington allows working with existing licensed businesses to either purchase a licensed business through a new entity, which is called an Assumption, or purchase some or all interest of a licensed business via a Change in Governing People, Percentage Owned, or Stock/Unit Ownership. Applications and qualifications of license ownership are required to be secured through the state before purchasing any interest in the business.

Oakland
Oakland Ownership
The City of Oakland took a very different road to ownership in the industry.

Oakland has been a national leader in creating systems that help cannabis businesses thrive. In 2015, in an attempt to create an institutional culture shift toward placing greater weight on equity and inclusion of historically marginalized communities, the Oakland City Council voted to create the nation’s second Department of Race and Equity (following Portland) and tasked it with analyzing policies and systems through a racial equity lens. The City of Oakland decided on a policy that would award permits to equity applicants and general applicants on a 1:1 ratio. It also put an initial cap on dispensary permits at 4 and included a Sacramento Comprehensive Cannabis Study
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provision for the Oakland City Administrator to allow up to 8 new dispensary licenses per year. It also directs that no individual or entity shall have a direct or indirect interest in more than 2 dispensary permits. The process for general applicants to obtain a dispensary permit is via scoring of the application by city staff. Equity applicants who submit complete applications are selected through a public drawing. There are 14 storefront dispensary permits in the city and an additional 12 that are approved but not yet operational. The City of Oakland did not put the caps on non-storefront retail delivery permits, and there are no other limits on the number or type of permits individuals or entities can hold. The City of Oakland allows for both outside investment and vertical integration.

Oakland Ownership Tracking

The City of Oakland does not expressly define a methodology of tracking ownership other than the information that is required in the initial application. The application requires definition of the type of business structure being used, as well as a list all persons directly or indirectly interested in the permit sought, including all officers, directors, general partners, managing members, stockholders, and partners. Equity applicants are required to file additional qualifying information.

Oakland Ownership Transfer

Oakland does not limit the sale of cannabis ownership for general permit holders.

It does require any new ownership interest to acquire State licensing. In addition, the Oakland zoning code states that permits only “apply to the premises and the entities or individuals originally specified, except upon written permission of the City Administrator’s Office granted upon written application to the City Administrator’s Office made in the same manner as required in the original application process.” Anyone with a direct or indirect interest in the permit that was not listed on the original application must undergo a live scan background check, and inspections of the originally permitted premises by relevant agencies may be required. In other words, a general applicant can transfer their ownership in a cannabis business to anyone, provided the new permittee submit their own application and go through the permit process.

The city’s general business transfer code has language that the city interprets to preclude transfer of their interest to a non-equity business; however, the city is exploring allowing the transfer of equity permits to anyone after a 3-year vesting period. Because of Oakland’s initial requirement of 1:1 equity to general cannabis permits, the pool of equity owners will continue to be replenished.

Long Beach
Long Beach Ownership
When Long Beach set their original ordinance, the city limited dispensary licenses to 32, which were quickly spoken for by the existing medical dispensaries. It did not set caps on other permits, although it did not allow for non-storefront retail Sacramento Comprehensive Cannabis Study
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delivery permits. It also does not allow for processor cultivation permits. The city allows for vertical integration under the State’s microbusiness license designation, and it does not have language in its ordinance limiting the number of cannabis businesses any single individual or entity can own.

In its efforts to provide social equity applicants a path to entry into the industry, Long Beach is introducing 8 new dispensary permits, shared manufacturing uses, and introducing an unlimited number of retail delivery opportunities exclusive to equity applicants. The goal is to provide equity applicants opportunities in the industry with lower initial capital investment requirements than the higher initial investment cultivation and retail dispensary opportunities.

Long Beach Ownership Tracking

The City of Long Beach does not expressly define a methodology of tracking ownership other than the information that is required in the initial application. The application requires definition of the type of business structure being used, as well as a list of all owners and managers in the permit sought, including all officers, directors, general partners, managing members, stockholders, and partners.

Equity applicants are required to file additional qualifying information.

The city does define what constitutes an owner in its ordinance. “Owner” means any of these:
 Any person with an ownership interest of 10 percent or more in the Adult-Use Cannabis Business applying for a permit.
 The chief executive officer of an entity, including nonprofits.  A member of the board of directors of a for-profit or nonprofit entity.  All persons in an entity that have a financial interest of 10 percent or more in the proposed Adult-Use Cannabis Business, including but not limited to:
‒ A general partner of an Adult-Use Cannabis Business that is organized as a partnership.
‒ A non-member manager or managing member of an Adult-Use Cannabis Business that is organized as a LLC.
‒ Any person holding a voting interest in a partnership, association, or LLC. ‒ All officers or directors of an Adult-Use Cannabis Business that is organized as a corporation, and all shareholders who individually own more than 10 percent of the issued and outstanding stock of the corporation.

Long Beach Ownership Transfer

Long Beach allows for the transfer of ownership of cannabis permits through a process with the Office of Financial Management. A Minor Cannabis Transfer of Ownership Application is required when a business is adding owners to their Sacramento Comprehensive Cannabis Study
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license whose ownership percentage totals between 10 percent and 49 percent of the business. The City of Long Beach Office of Financial Management does not stipulate a process for more than 49 percent but does have an application and review process when a business owner is transferring their interest to another party through a business license application. It is an administerial process, and the policy has generated multiple brokers advertising businesses for sale. The new equity-focused shared use is not intended as a salable license but rather an opportunity to provide equity applicants an existing facility in which to operate without significant start-up costs. Long Beach is crafting the ordinances for non- storefront delivery and the 8 new equity applicant retail dispensaries.

In interviews, they are working through how the ordinance will address sales of equity dispensary ownership.

Denver
Denver Ownership
Denver, along with Seattle, approved recreational cannabis on January 1, 2014, but had allowed medical cannabis since 2000. Denver has more than 1,100 cannabis licenses operating out of nearly 500 locations.

Denver’s moratorium on licensing new medical marijuana stores and medical marijuana cultivation facilities continues to be in effect; however, the bill reserves new applications for new medical marijuana products manufacturer, medical marijuana transporter, and retail marijuana business licenses from social equity applicants until July 1, 2027, to provide social equity applicants an opportunity for ownership of cannabis businesses. Denver is only accepting applications from non-social equity applicants for a medical or retail testing facility or R&D license or is applying for a retail marijuana business license that will be co-located with a medical marijuana business of the same type.

In addition, Denver has instituted a consumption lounge pilot program that will provide additional ownership opportunities.

Denver Ownership Tracking

Denver keeps a database for active individual and business licenses, as well as inactive licenses; however, it is for all business license types and is limited to identifying the applicant. It does not address ownership structure. As Denver rolls out its opportunities for social equity applicants and attempts to regulate the transfer of social equity ownership to maintain 51 percent social equity through July 1, 2027, a more advanced tracking system will be imperative.

Denver Ownership Transfer

In general, all cannabis businesses are transferable from one person to another on approval by the Director of Marijuana. There are additional requirements for transfers of marijuana transporter businesses, which are subject to limitations set by Colorado state law. Transfer of ownership of cannabis off-premises storage Sacramento Comprehensive Cannabis Study
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facility permits or cannabis delivery permits have additional requirements. Denver recently adopted language so that before July 1, 2027, equity applicants are allowed to transfer business interests to either other social equity applicants or to non-social equity applicants, as long as 51 percent or more of the business is held by one or more social equity applicants. After July 1, 2027, businesses held by social equity applicants are transferable either to other social equity applicants or non-social equity applicants following an approval process. Non-social equity owners are not limited and can transfer their entire interest to another individual/entity.

Denver also has a common ownership restriction in that if one or more licenses share the same licensed premises, an application to transfer ownership of any one of the licenses shall not be approved if the transfer would result in that license no longer having common ownership with the licenses sharing the same licensed premises.

Ownership Conclusions
The case studies on ownership, ownership tracking, and transfer of ownership provide several important comparisons to be made.

Ownership
There are distinct attributes of how ownership has a direct correlation with how the initial cannabis ordinances were crafted:
 Seattle is, on the one hand, the most restrictive in the sense of requiring a 6-month residency requirement, prohibiting outside investment, and not allowing seed-to-sale vertical integration. Ownership requirements initially did not include an equity component and were among the least restrictive, favoring well-capitalized legacy owners. The state is now focused on a social equity program and is identifying ownership opportunities dedicated to social equity applicants.
 Both Sacramento and Long Beach placed caps on dispensaries in particular and allowed the previous medical permit holders to convert to recreational permits, effectively closing out any new ownership opportunities. Both cities are using similar social equity initiatives to create a more diverse ownership playing field through additional dispensary ownership opportunities. Long Beach is taking this a step further through their shared manufacturing facility program and opening non-storefront retail opportunities for social equity applicants.
 Denver was also without a social equity program and implemented a dynamic and fast-growing cannabis industry that was market driven and allowed to succeed and fail based on consumer preference. While current ownership is rapidly consolidating through major mergers and acquisitions, Denver has Sacramento Comprehensive Cannabis Study
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selectively identified several IFGs for new social equity ownership, including a consumption lounge pilot program.
 Oakland’s approach to requiring a 1:1 social equity to general ownership model for all cannabis permits is widely considered one of the most innovative and fair in the country. In addition, allowing up to 8 additional dispensaries per year provides a growth approach that is measurable and adjustable.

Some interesting opportunities exist for Sacramento to build on the success of previous policy initiatives and interesting new initiatives in the industry:
 The potential to adopt a 1:1 social equity to general ownership model for all IFGs moving forward.
 The potential to identify ownership growth areas in the industry and direct those opportunities to social equity applicants.
 The potential to adopt a more fluid and less reactive approach to ownership by allowing “up to” growth models for the IFGs.
 The potential to open an entirely new IFG and perhaps restaurant niche in the space of consumption lounges, combined with food production and service.

Ownership Tracking
Given the complex ownership structures of both individual IFG owners, as well as vertically integrated corporations already establishing footholds in Sacramento, ownership tracking is one of the more difficult puzzles to solve in the current ownership cap structure, while allowing for vertical integration. There appear to be 3 potential avenues for the City to explore:

1. Hire an outside consultant/firm to manage and implement the tracking through IRS, banking, and other industry methods.

2. Create a position or positions in the OCM, and hire experienced staff to manage and implement the tracking in house.

3. Remove the one permit restriction on retail storefront dispensary ownership and streamline the individual/entity ownership reporting requirements to promote transparency.

Avenues 1 and 2 both would require significant resources to implement but, given the complexity of the corporate structures, may be necessary to uphold the provision of the ordinance. A hybrid approach would be to hire a consulting firm to train staff to manage and implement the tracking internally, but this would still require significant additional resources. The threat of Avenue 3 is that the recent trends of publicly traded companies buying multiple dispensary licenses in locales contribute to a consolidation and monopolization of the market. This is only exacerbated by the allowance of vertical integration. A remarkable example of this Sacramento Comprehensive Cannabis Study
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is the Florida-based and Canadian-traded company Trulieve. Following the recent acquisition of a major competitor, they will now have 149 retail locations in 11 states, including Florida, and more than 3.1 million square feet of cultivation, with 6 of those dispensaries in California.

Ownership Transfer
Each of the case studies have some version of ownership transfer and, with the exception of Seattle, they all offer vertical integration and outside ownership.

Denver, Sacramento, and Long Beach all provide protection for social equity ownership interests to maintain the social equity aspect of the permits. Oakland’s ordinance provides for an ongoing social equity ownership model and is looking to see how to allow social equity businesses to sell to the highest bidder.

If Sacramento looks to make adjustments to the ownership model in line with Oakland’s (1:1 ratio and an “up to” policy), selling a dispensary should not reduce the social equity pool of ownership. Under the current policy, Sacramento will need to look to other ways to allow social equity dispensary owners to maximize their investment.

Taxation Considerations
The cannabis industry is federally illegal, and the product is taxed at the State level at higher rates than other “sin” products, largely out of tax generation aspirations. Early states to legalize have generated high excise taxes that they have directed to the General Fund. California pursued this approach as discussed in the State Taxation Trends, and as a result, Sacramento and other California communities have real dilemmas regarding their relationship to the State taxes, their local concerns, and the health of the industry.

The confusing nature of the opt in/opt out State legalization structure creates different taxation metrics across counties and cities. This decentralized approach pits communities against each other to reduce local tax rates in an effort to capture market share.

The table below provides a comparison of Sacramento to neighboring jurisdictions. It is important to note that while a significant number of these communities do not allow cannabis, the lure of cannabis tax revenue has many of them contemplating entering the market, which will potentially put additional pressure on Sacramento’s local tax rates.

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Table 10. Local Tax Comparison

County/City [1] Local Taxes
Sacramento County Does not allow.

Sacramento 4% gross receipts for all cannabis businesses.

Sutter County Does not allow.
4% gross receipts for cultivation.
5% gross receipts for all other activities.
10% gross receipts for retail, distribution, and cultivation.

For Manufacturing, R&D, and Testing:
5% for receipts between $0 - $50,000/month;
4% for receipts from $50,001 - $100,000/month.

West Sacramento No adopted cannabis business tax; taxes levied via development agreements.

Woodland No cannabis business tax.

Solano County Does not allow.
1% gross receipts for testing and distribution.

Manufacturing:
2% gross receipts Year 1;

2.5% gross receipts Year 2;

3.5% gross receipts Year 3.

Cultivation:
$5 PSF Year 1;
$6 PSF Year 2;
$7 PSF Year 3.

Dixon 15% gross receipts for businesses that do not obtain a Development Agreement or CUP. No cannabis business tax otherwise.

Rio Vista No cannabis business tax.
7% gross receipts for retail.
5% gross receipts for cultivation.
5% gross receipts for manufacturing.
2% gross receipts for distribution.

Yuba County Does not allow.

Cultivation:
$10 PSF for artificial lighting;
$7 PSF for mixed lighting;
$4 PSF for natural lighting;
$2 PSF for nursery.

2.5% gross receipts for testing.
6% gross receipts for retail.
3% gross receipts for distribution.
4% gross receipts for manufacturing.

Vallejo
Marysville
Yolo County
Benecia
Davis
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County/City [1] Local Taxes
Placer County Does not allow.

Colfax $7 PSF for cultivation.
4% gross receipts for retail.
2% gross receipts for distribution.

2.5% for manufacturing and testing.

El Dorado Count
y Cultivation:
$2 PSF for natural light;
$4 PSF for mixed light;
$7 PSF for indoor;
4% gross receipts for nursery.

Manufacturing:

2.5% gross receipts for Level 1 (solvent manufacturing); 0% for Level 2 (non-solvent manufacturing).
4% gross receipts for retail.
2% gross receipts for distribution.

0.5% gross receipts for testing.

South Lake Tahoe No cannabis business tax.

Amador Count
y Does not allow.

Calavaras Cultivation:
$2 PSF for natural and mixed light;
$5 PSF for indoor.
7% gross receipts on retail and manufacturing.

An
gels Camp Does not allow.

San Joaquin County No set tax rate. Development agreement required through which County may establish gross receipts impact fees. PA-20000070 sets rates at 3.5 percent gross revenue for all cannabis businesses.

Stockton 5% gross receipts for retail.
1% gross receipts for distribution.
3% gross receipts for manufacturing.
5% gross receipts for cultivation.
0% gross receipts for testing.
5% gross receipts for microbusiness.

Contra Costa Count
y Cultivation:
$7 PSF for indoor;
$3 PSF for mixed-light;
$2 PSF for outdoor;
$1 PSF for nursery.
2% gross receipts for distribution.

2.5% gross receipts for manufacturing.
4% gross receipts for retail.
0% gross receipts for testing.
4% gross receipts for microbusiness (2.5% if not including retail).

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In addition, several nearby cities such as West Sacramento have no specific cannabis business tax but collect cannabis tax revenues through development agreements. Under California law, retail delivery of cannabis cannot be prohibited by local jurisdictions. Therefore, delivery services in communities with lower taxes (and resulting lower sales prices) can deliver into areas with higher taxation, potentially impacting the gross sales and resulting local taxes from Sacramento’s retail dispensaries and delivery companies.

Sacramento Tax Revenues
Overall, Sacramento charges 13.75 percent on retail sales, made up of

8.75 percent State and local sales tax and a 4 percent business operating tax.

Sacramento’s estimated $27.3 million in cannabis industry General Fund revenues comes from a combination of the 4 percent BOP tax, as well as licensing fees and fines, property taxes, utility taxes, and transient occupancy taxes. The General Fund expenditures due to cannabis businesses operating in the City are estimated at $7.5 million, resulting in net revenue of $19.8 million to the City General Fund. (See Chapter 6 for discussion of the fiscal impact analysis.) In addition to the General Fund revenues attributable to cannabis, Sacramento’s neighborhood responsibility plan fee, which seeks to mitigate negative impacts from “novel business activities” like marijuana, has imposed a fee equivalent to 1 percent of gross revenues on cannabis businesses. The neighborhood responsibility plan fee is estimated to generate an additional $5.2 million in revenues for Fiscal Year 2021/2022, not included in the City’s General Fund.

County/City [1] Local Taxes
Richmond 5% gross receipts for all businesses.

Pittsburg 10% gross receipts.

Oakley Does not allow.

Antioch No cannabis business tax.

Concord No cannabis business tax.

El Cerrito No cannabis business tax.

Martinez No cannabis business tax.

Napa County Does not allow.

City of Napa Does not allow.

American Canyon No cannabis business tax.
[1] Tax rates for counties apply to unincorporated portions of that county only. Cities within each county may set their own tax rates for cannabis businesses within their city limits.

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State Grant Programs
Some State tax revenues are returned to the City through State grant programs.

Sacramento was recently awarded a grant of up to $5.78 million, authorized by Senate Bill (SB) 129 Local Jurisdiction Assistance Grant Program, to assist business owners with meeting California Environmental Quality Act (CEQA) requirements, enabling licenses to transition from provisional to permanent. 25 Clearing CEQA requirements has been a major hurdle in transitioning the provisional licenses across the range of IFGs. In addition, in May 2021, the Governor announced a $15 million grant program to support community social equity efforts.

Tax Revenue Case Studies
To provide information for future study, here are approaches that other cities have used in developing their cannabis tax structures. The City of Oakland has structured a policy that is both variable in regard to social equity and size and directs a portion of tax revenues to equity owners.

Each of the case-study cities was considered in terms of how they are allocating cannabis tax revenue. In addition, several new states that allow legal recreational cannabis are developing policies for tax expenditures, and they are found in Appendix B.

The Oakland Case
All cannabis tax proceeds in Oakland are deposited into the General Fund.

In 2017, the Oakland City Council determined that a loan program was needed to assist historically marginalized cannabis operators, given the lack of personal wealth in low-income communities and federal restrictions on bank lending. The Equity Loan Program re-invests cannabis tax revenue into economic opportunities for those most impacted by the War on Drugs.

Oakland’s 2020 tax has yielded $13.7 million for the General Fund, of which $3.4 million is dedicated toward technical assistance and the revolving no-interest loan program for low-income cannabis “equity applicants.” Sacramento also uses a revolving no-interest loan fund. The CORE Capital Loan Program is funded with more than $3 million.

Loan Program Summary
Oakland’s loan program establishes tiers of business development that are awarded specific amounts of funds up to a cumulative maximum of $115,000.00 for 100 percent social equity businesses. The Equity Loan Program consists of

25 Sacramento was earmarked for the fourth highest allocation in the State at $1,813,612.38.

The funding has not yet been received. While the funding cannot be set aside for social equity members only, it is anticipated that social equity members will be a primary beneficiary of the programs launched with the grant.

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public funds, and repayments need to be made to make loans to equity applicants in the future. The program has seen mixed results as several loan participants have not made repayments and have been sent to collections.

Sacramento’s loan program, CORE Capital, is a 6-year interest-free loan program for cannabis businesses made available through grant funds from the Governor’s Office of Business and Economic Development (Go-Biz). The largest amount available for an initial, or first-time, loan is $50,000 if an applicant has a signed business lease for a location/premise or owns a location. Loan applicants may apply for additional loans (“Follow-on Loans”) in increments of up to $50,000, without fully repaying their prior loan(s), as long as they have spent the funds on eligible expenses, are not delinquent, and are compliant with CORE requirements.

In 2019, Oakland lowered the tax rate to 0.12 percent per year for all equity businesses with gross receipts under $1.5 million. It also created a phased-in system that lowered the tax rates for non-equity businesses and larger equity businesses to between 2.5 and 5 percent for non-equity businesses by 2022, depending on the size and sector of the business. In addition, non-equity businesses can receive 0.5 percent rebates for equity activities such as incubating an equity business, local hiring, equity supply chain contractors, and workforce quality of life. However, businesses are limited in the number and frequency of rebates they can receive and still must pay a minimum tax rate of 2.5 percent in 2022. Most business tax classifications in Oakland pay below 2 percent per year.

Cannabis businesses assessed at 2.5 percent will pay the highest business tax rate in Oakland, followed by the classification for “Firearms Dealers” that pay

2.4 percent. So far, the 0.5 percent rebate program has not yielded the intended results as operators see the reporting requirements outweighing the benefit.

While Oakland’s tax reductions for IFGs across the board initially reduce the city’s cannabis tax revenue, it is argued that they further strengthen the local industry’s ability to be profitable, compete with the illicit market, and have the potential to generate higher revenues if demand for regulated product increases.

The Long Beach Case
In 2019, a broad-based coalition of cannabis industry professionals, policy advocates, patients, consumers, and city officials came together to support the city’s legal cannabis industry in reducing taxes. In the face of a significant budget deficit, the Long Beach City Council voted in 2019 to lower the tax rate for cannabis businesses from 6 percent to 1 percent. The city collected $10.3 million in cannabis tax revenue for the fiscal year with the tax revenue flowing into the City’s General Fund. This was a $6.3 million surplus over the $4 million in projected revenue. According to a report, local dispensaries “felt a boom” from the lower tax rates, and a city analysis projects that some levels of increased Sacramento Comprehensive Cannabis Study
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sales will continue.26 Just as Sacramento is, Long Beach was facing increased pressure from the illicit market and sought to reduce taxes to be more competitive, preserve jobs in the legal industry, and reduce public safety concerns.

Sacramento and Long Beach share nearly the same amount of retail storefront dispensaries. However, Sacramento has a significant non-storefront retail delivery IFG that is only recently being proposed in Long Beach. Extrapolating the incremental success of Long Beach’s tax reduction to revenue increase over Sacramento’s retail sales has the potential to increase the viability of the retail IFGs, produce additional revenue, and provide more stiff competition with the illicit market.

The Denver Case
Denver cannabis tax is imposed with a 15 percent state excise tax and a local tax of 9.81 percent. The City of Denver collected more than $70 million in sales tax revenue from $715 million in cannabis sales in 2020, a 17 percent jump from the $60 million collected in 2019, according to the Department of License and Excise.

Denver is projected to earn the same amount of tax revenue in 2021.

In November 2013, Denver voters approved adding a special sales tax on retail marijuana that could vary from 3.5 percent to 15.0 percent. The tax is in addition to standard sales tax and all other applicable state taxes. Since 2017, retail marijuana is exempt from the state standard sales tax but is subject to both state and local special sales taxes:
 Denver standard sales tax: 4.31%.
 Denver special sales tax on retail cannabis: 5.50%. This tax can fluctuate between 3.5% and 15% by Denver City Council authorization.  State special sales tax on retail cannabis: 15.0%.
 Total retail cannabis sales tax: 24.81%. Since 2017, 10% of the state special sales tax has been shared with local jurisdictions.
27 During the 2021 elections, two ballot measures, one state and one local to increase taxes on cannabis were defeated as opponents debated the health of the industry against programs the taxes would fund. Yet in the face of one of the highest major city tax structures in the industry, there appears to be little momentum to lower taxes. Instead, Denver is experiencing continued illicit cannabis production and sales throughout the city.

26 CalliforniaCityNews.org, After Lowering its Cannabis Taxes Long Beach Saw a Windfall, 2/23/2021.
27 The Denver Collaborative Approach, Leading The Way In Municipal Marijuana Management, 2020.

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What is relevant in Denver’s tax model is how the revenues are spent, with 37 percent allocated to homeless housing, 6 percent to education, and 5 percent to public health. This is a significant investment in homeless housing as Denver grapples with many of the same homeless issues confronting communities throughout the state.

The Seattle Case
Washington taxes cannabis with a 37 percent excise tax and an optional 10 percent local tax. As approved by voters in 2012, Initiative Measure No. 502 did not set aside any money for local governments when it legalized recreational cannabis in Washington. City and county officials later asked the legislature for a share of the state’s marijuana tax revenue with the goal of helping to defray some of the costs they might accrue from the new law, such as the cost of enforcing the ban on using marijuana in public places. The legislature reworked the state’s legal cannabis laws significantly in 2015 and, as part of that overhaul, gave local jurisdictions a share of the tax money, provided they did not ban cannabis businesses within their boundaries. Seattle is receiving a reported $30 million per year in revenues.

Like California, Washington has dedicated funds toward social equity programs.

The cannabis revenues must allocate $1,650,000 for Fiscal Year 2022 and the same amount for Fiscal Year 2023 to the Department of Commerce to fund the marijuana social equity technical assistance competitive grant program.

In addition, Washington has established a fund for mentors as part of the cannabis social equity technical assistance grant program.

Nearly half of all cannabis revenues for Fiscal Years 2015 through 2020 went to Washington’s Basic Health Plan Trust Account. That account is described by the Office of Financial Management as providing “necessary basic health care services to working persons and others who lack coverage, at a cost to these persons that does not create a barrier to the utilization of necessary health care services.” Washington, and by extension Seattle, has the highest excise tax in the nation on retail sales; however, there is no wholesale tax, as is the case with California and, by extension Sacramento. The Seattle model places the entire tax burden on the retail transaction and relieves the cultivator from having to pay taxes on raw product with variable pricing. This effectively eliminates the incentive to grow and distribute to the illicit market to avoid wholesale taxation.

Options for Sacramento
As noted previously, the State levies a flat cultivation tax based on product weight, not value. This flawed approach places a tremendous burden on small cultivators when the sales price of raw product declines and pressures local jurisdictions to lower tax rates to sustain the viability of local cannabis businesses.

It has also incentivized the sale of raw product into the illicit market through what Sacramento Comprehensive Cannabis Study
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is known as burner permits28 and “track-and-trace” manipulation.29 However, the Governor of California’s recent commitment to make adjustments to State regulations and taxes could allow Sacramento greater leeway in adjusting the local tax to support local programs. A proposed bill being circulated would eliminate the wholesale cultivation tax entirely and increase the retail excise tax initially to 50 percent of the anticipated revenue of the cultivation tax and then raise to capture 100 percent of the cultivation revenue.

It is uncertain how the bill will look once passed through the State legislature, and what impact it will have on retail pricing; however, it will certainly benefit the viability of cultivators. This significant tax adjustment makes it difficult to predict what, if any, adjustments to the Sacramento tax model should be made.

As seen in Table 10, several Northern California communities add an additional tax on cultivation, primarily by square footage. While this method, or a tax on sales price, are more predictable than the State’s tax by weight, they create additional pressure for cultivators to sell to the illicit market.

Sacramento’s 4 percent local tax does not appear to be out of line with other nearby communities, although it will bear watching how neighboring communities contemplating allowing cannabis businesses set their local taxes, as this development could have a direct impact on local sales and tax revenue.

Taxation Conclusions
 Sacramento could look to a modified Oakland model and reduce the 4 percent local tax for all social equity businesses while maintaining the current tax for non-equity.
 Sacramento could look to the success of Long Beach and reduce the local tax across the board as a means to stimulate sales revenue in the regulated market.
 If the cultivation tax is eliminated and the excise tax is increased by half of the projected cultivation tax revenues, Sacramento could increase the local sales tax by an increment that would fall within 50 percent of the cultivation tax. This approach would need to be re-evaluated once the excise tax reverts to 100 percent of the cultivation tax revenues.

28 Burner permits are associated with distributors who purchase raw product from a cultivator, pay the cultivation tax to the states, and sell the product to the illicit market. 29 Track-and-trace manipulation is when cultivators track only a fraction of the actual flower produced by a plant and then sell the rest to the illicit market.

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Concentration
Land use regulations, sensitive receptor buffers, and facility availability are the primary drivers of cannabis business concentration. Many cities have used zoning in industrial areas to create what are known as “green zones,” where the cities allow all cannabis IFGs to locate. Cultivation, distribution, manufacturing, and testing businesses are industrial in nature and are better located in industrial districts. Delivery is dependent on proximity to its regional market business size, but it is also primarily a small warehouse-type use. Dispensaries are essentially retail stores and are generally located in neighborhood retail areas or along commercial corridors. Sacramento’s ordinance also directs the industrial aspects of the cannabis community to specific land use zones, and these are primarily in Council Districts 2 and 6.

Chapter 5 of this Study details the concentration of the various IFGs and the real estate and neighborhood impacts. Sacramento is similar to other cities in that older industrial and residential districts are often adjacent and even comingled, as can be seen in both Districts 2 and 6. The land use tables in Appendix C identify the allowed zoning classifications for the range of IFGs. Sacramento has 2 additional concentration restrictions in District 6. In 2018, the City Council passed a limit on cannabis cultivation, capping it at 10 percent of the industrial real estate or approximately 2.5 million square feet. In addition, the City limits retail non-storefront delivery permits in the southeast industrial area to 50 permits. As shown in Table 11 (Chapter 5), there are 34 active delivery BOPs in the district. One additional restriction in Sacramento limits retail storefront dispensaries to the C-2 General Commercial Zone and C-4 Heavy Commercial Zone and restricts it from the C-1 Limited Commercial Zone and the C-3 Central Business District Zone.

Looking to Other Cities
Denver has not limited its number of dispensaries. However, like Sacramento, some surrounding cities in the area didn’t allow recreational cannabis, allowing Denver to capitalize as the regional epicenter for the cannabis industry. Denver has effectively let the market decide what dispensaries survive. As the Denver cannabis industry has matured, the city has concerned itself with dispensary and cultivation oversaturation in neighborhoods, despite their generally positive reception. Now, Denver does not allow either of these licenses in the 5 most impacted neighborhoods, recalibrated each year. The impact is measured in the number of cannabis business permits per capita. In one of the most impacted neighborhoods, there is 1 business permit for every 91 inhabitants.

Oakland was about initial quantity limits, beginning with 4 dispensaries, and allowing up to 8 new dispensaries per year, with their social equity requirements in all other licenses requiring a 1:1 ratio of equity licenses to non-equity licenses and did not limit other licenses. Oakland used its zoning ordinance to create a Sacramento Comprehensive Cannabis Study
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defined green zone and uses buffers from sensitive receptors as a second limiting factor. Growth has continued since legalization, but there does not appear to be any organized concern about oversaturation.

In Long Beach, available land with the correct zoning is their concern, and they are also introducing reduced buffers in some cases to expand their green zone.

Long Beach doesn’t limit concentration or location other than dispensaries must be a minimum of 1,000 feet apart. The City of Long Beach relies on consumer demand and available property to limit concentration. They have even recently allowed a dispensary in a residential mixed-use building. Previously, non- storefront retail delivery was not allowed in the city, but along with 8 new dispensaries for social equity applicants, they are opening the delivery business permit to social equity applicants as well. In discussion with their cannabis department, there was not a concern for overconcentration. This may be due in part to the overwhelming industrial footprint in the south Los Angeles area, including Wilmington.

Cultivation
With the exception of Seattle, the case-study cities have a range of approaches to concentration of cultivation licenses.

Initially, Denver’s rush to the market saw cultivators swarm Denver’s older industrial districts, with older Class B and Class C space. As their market has matured, Denver introduced a moratorium on the licenses and only recently opened new cultivation licenses to equity applicants. As discussed previously, Denver is maintaining moratoriums on those communities (top 5 each year) most impacted by concentration.

Long Beach does not limit the number of cannabis cultivation licenses, but according to the city’s zoning restrictions, it is allowed in light, medium and heavy industrial zones and in general industrial areas but not in residential, institutional, park, commercial, and port zones, and the lack of available facilities limit the concentration.

Oakland limits cultivation licenses by zoning not by number, and facilities that meet the zoning are prolific as Oakland has an extensive industrial green zone with facilities appropriate to indoor cultivation. Cultivation is allowed by right in all industrial zones. The tables in Appendix C provide a summary of land use regulations for Sacramento and the case-study cities for comparison.

Sacramento has 93 cultivation BOPs producing far more product that is consumed in the City. Based on the consumption per capita data shown previously in Table 8, there appears to be far more product being cultivated than is locally consumed. However, cultivators are free to move their product throughout the State, and as such, it is not possible to say with certainty how saturated the Sacramento market is. In addition, the burner permits and the track-and-trace Sacramento Comprehensive Cannabis Study
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manipulations discussed earlier make it even more difficult to assess. But with the number of cities and counties adjacent to Sacramento and the high number of non-dispensary delivery services, regional consumption will capture a percentage of the cultivation.

Manufacturing and Distribution
Manufacturing and distribution are both growth opportunities in Sacramento.

These are complex industries on which the supply chain relies and are evolving daily. They are scientific, technological, logistical, fabricating, packaging, and marketing. Larger, well capitalized entities are well positioned to gain ownership in these components of the industry.

Would Sacramento be better served to welcome these large corporate companies and incorporate specific jobs training and local hiring practices into their licensing requirements? Colorado and Washington represent 2 different approaches.

Washington makes a concerted effort to limit consolidation and support small local businesses, but that may change soon as many fear that without outside capital investment, Washington will not be able to thrive in a national legal industry.

Colorado invites the industry to “come on in” for investment, which appears to have resulted in significant consolidation.

What is clear is that these 2 IFGs are the center of vertical integration and will dominate this young industry through their relationships with cultivators and dispensaries, their abilities to continually advance product quality, and their brand control.

Retail
Retail dispensaries are simply retail stores, and there is little if any evidence of negative impacts on their surroundings in the case-study cities. In fact, these outlets tend to meld into their respective communities, as illustrated in Midtown Sacramento, and are good neighbors. However, there is clear and direct evidence from the interview process and recent press that many are struggling. When the moratorium on outside investment ends in May, outside investment will be important in stabilizing this aspect of the industry. With 10 new dispensaries coming online in the future, could the concentration concerns around these stores be lessened by opening up additional zoning and districts to them? Non-storefront retail or delivery is being looked to by several cities as a means of increasing local ownership, particularly for social equity applicants. Long Beach is at the forefront of this as delivery has not been allowed in the city but will now open up to social equity applicants. According to one of the interviewees for this Study, larger examples of this business can make about 600 deliveries a day, with capital facilities including a warehouse to store product, a fleet of vehicles, an office, and dispatchers.

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In contrast to the cost of cultivation and dispensaries, retail delivery businesses have a relatively low cost to entry but may face challenges in terms of high ongoing operational costs. While authorized to deliver to other markets in the State approved for sales, limits on carried inventory and practical considerations result in a high number of establishments serving local and even regional consumers.

With the growing use of online purchases and rapid delivery times, these delivery companies should continue to see growth. The threat to them in the near term appears to be a combination of rising costs, particularly fuel and insurance, the tax structure, and the volatility of the retail prices. In the long term, competition from large fleet, multi-platform companies such as UBER may prove to be a much larger threat. And with Amazon now backing federal legalization, it may be inevitable that these mega players will dominate the procurement and delivery sectors of the industry.

While there is concern, particularly in District 6, of an overconcentration of the delivery businesses, the City has already introduced policy to limit the number of these permits to 50, with 34 current BOPs.

Concentration Conclusions
 Concern with oversaturation in particular neighborhoods or districts of cultivation could be regulated in the same manner that the City is regulating the concentration of cultivation in District 6.
 With 10 new social equity dispensary permits approved, the City may need to open additional Council Districts and potentially the C-1 and C-3 zones to avoid overconcentration in Midtown and District 6.

Youth Impacts
Dispensary and Delivery Advertising and Packaging
There is general consensus among public health experts that abuse of cannabis among youth is associated with a range of negative consequences such as reduced high school graduation rates and certain mental and physical health outcomes.30 In Sacramento, groups such as California Youth Forward and others have noted a tendency for billboards and other advertising that may be “suspect” in terms of messaging and imagery that could be construed as appealing to youthful sentiments. In addition, packaging and wrapping has come under fire for

30 Fischer, Benedikt, et. al. 2022. Lower-Risk Cannabis Use Guidelines (LRCUG) for reducing health harms from non-medical cannabis use: A comprehensive evidence and recommendations update. International Journal of Drug Policy.

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mimicking various candies (e.g., gummies), often appealing to youth in non- cannabis settings.

While these concerns are substantial, this issue is largely outside the purview of this Study. The State’s Department of Cannabis Control is tasked with enforcing the advertising restrictions that were enacted by Proposition 64, which include bans on cannabis advertising within 1,000 feet of schools, daycare centers, or playgrounds. Local efforts to monitor product packaging targeted to children are likely to be ineffective, given that products are manufactured and sold throughout the State, although the City should lobby the Department of Cannabis Control to more strongly enforce Proposition 64’s restrictions on youth-oriented packaging.

Clearly the City should evaluate its ability to influence advertising and packaging in its jurisdiction. These efforts could include allowing residents to report cannabis advertising that violates restrictions on youth-oriented advertising via the City’s 311 service, or even explore adding an additional level of City review for cannabis billboards, as is being considered in the City of San Diego. 31 Lastly, the City could
enact a local ordinance restricting the location of cannabis advertising, similar to the City of Oakland’s sign ordinance,
32 which restricts outdoor tobacco and alcohol
advertisements within 1,000 feet of schools, youth centers, and churches.

However, enforcement of this measure would require a significant dedication of City resources. To the extent possible, the local industry could potentially be expected to follow certain guidelines in return for receiving City services.

However, it is less clear that the mere existence of dispensaries and delivery services has an influence on youth participation. While some research has indicated a possible relationship between knowledge of nearby cannabis resources and propensity to use cannabis,
33 one advantage of regulated cannabis is the
ability to verify age. As discussed throughout this report, dispensary customers tend to skew toward older age groups, generally in their mid-30’s and older, reflecting economic ability to shoulder the tax structure. The balance of consumer demand, including among youth, continues to be met through illicit supply, based both on price and availability.

Overall, there is limited evidence that legalization has influenced youth participation. As stated by the International City/County Management Association, “evidence that legalization of cannabis significantly changes patterns of youth use/abuse is lacking.”

31 Garrick, David. 2018. San Diego plans to crack down on marijuana ads, especially billboards.

Los Angeles Times. October 20, 2018.
32 City of Oakland Municipal Code Section 14.04.280.
33 International City/County Management Association. 2018. Local Impacts of Commercial Cannabis. Available at
https://icma.org/sites/default/files/Local%20Impacts%20of%20Commercial%20Cannabis%20Fin al%20Report_0.pdf
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Many municipalities are applying substantial sums of both earmarked and General Fund resources to address a range of societal objectives related to childhood well- being. For example, the City of Santa Cruz recently asked its voters to approve a charter amendment, allowing for the creation of a Children’s Fund for early childhood development programs, funded by a permanent allocation of 20 percent of all cannabis tax revenue. Further examples of cities using cannabis tax revenues to fund youth well-being are the City of Santa Ana, Monterey County, and Humboldt County, as detailed in the California Cannabis Tax Revenues report.
34 34 Youth Forward. 2020. California Cannabis Tax Revenues: A Windfall For Law Enforcement or an Opportunity for Healing Communities?
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Real Estate and Neighborhood Impacts
Overview
Of the original 30 medical cannabis dispensaries, 13 were located in or immediately adjacent to Midtown. Following legalization of adult-use cannabis, these locations transitioned into the first recreational cannabis retail options, cementing Midtown’s role as a primary location for retail dispensaries. Other locations throughout the City are generally located along major commercial corridors. Other non-retail cannabis operations have largely been defined as industrial uses and have therefore located in the City’s existing industrial zones in those Council Districts where they are allowed. As start-ups with cash flow limitations, the operations generally sought out less-expensive spaces in the smaller, older Class B and Class C industrial buildings common in several of the City’s industrial areas.

The map shown below illustrates the geographic dispersion of the different IFGs in each of the Council Districts. For detailed descriptions of each of the IFGs, see Chapter 3.

As shown in Figure 20 and Table 11, the majority of cannabis businesses are in Council Districts 2 and 6.
35 Only 8 of Sacramento’s 93 licensed cultivation
businesses are located outside of these 2 Council Districts, and 80 percent of the licensed production businesses are located in these 2 districts. In addition, half of the City’s 30 storefront dispensaries are located in these 2 Council Districts as well.

35 There are 264 licensed cannabis businesses in the City. The analysis in this section relies on data provided by the OCM in July 2021 when there were 252 licensed cannabis businesses in the City.

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Figure 20. City of Sacramento Distribution of Cannabis IFGs

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Table 11. Licensed Cannabis Businesses by Council District

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The existing Class B and Class C industrial buildings in Districts 2 and 6 are appealing for start-up operations, as the lower rents of these spaces puts less strain on low cash flows during the early stages of the business. As shown in Figure 21, these 2 Council Districts contain the vast majority of buildings and floor area classified as “Industrial” by the Sacramento County Assessor’s Office.

Figure 21. Industrial Floor Area by Council District

The City’s zoning policy contributes to the concentrations of uses in Districts 2 and 6, as shown in Figure 22, with cannabis production uses allowed in the C-2 General Commercial, C-4 Heavy Commercial, A-Agriculture, or Manufacturing and Industrial zoning districts. Within the C-2 zoning district, manufacturing and distribution uses are limited to 6,400 square feet of floor area, and distribution cannot be a stand-alone use. In addition, all cannabis uses must be at least 600 feet away from any K-12 school, and businesses within ½-mile from any existing or future light rail station face additional permitting conditions. 36 In Figure 22, which shows the zoning districts where cannabis uses are permitted and where there are restrictions, the restriction on areas around schools is increased to 1,000 square feet to account for the distance from the center of the school to the edge of school grounds, from where the 600-foot regulatory buffer is measured.

36 Per Sacramento Municipal Code Section 17.228.127, if within a ½-mile of an existing or future light rail station, the project must include “pedestrian features” such as lighting, benches, tree shading, and landscaping. If the project involves new construction, the City has several other requirements related to facade design and parking that the project must implement. 0 M
5 M
10 M
15 M
20 M
25 M
30 M
12345678
Floor Area (Millions of Square Feet)
City Council District
Industrial Floor Area by Council District
Source: City of Sacramento, Sacramento County Assessor's Office, EPS.

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Figure 22. City of Sacramento Cannabis Buffers and Available Land

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As seen in Figure 22, there are large areas with no restrictions on cannabis uses in the industrial zone at the eastern boundary of District 6, as well as at the northeastern edge of District 2. However, the northern half of the large industrial zone in the northeastern corner of District 2 is composed of vacant, undeveloped land with several development constraints, such as existing wetlands and the ownership of a large portion of the area by the federal government. Overall, 78 percent of cannabis businesses in the City are located in industrial zoning classifications, as shown in Table 12.

Table 12. Sacramento Cannabis Businesses by Zoning Classification

As seen in Table 13, the total floor area occupied by cannabis businesses reflects the concentration of cannabis businesses in Districts 2 and 6 and a lesser degree of concentration in District 3. As a result of cannabis businesses being largely concentrated in Districts 2 and 6, these districts have a much larger portion of their commercial floor area occupied by cannabis businesses. Approximately

3.6 percent of all commercial floor area in District 6 is occupied by licensed cannabis businesses.

The concentration of cannabis floor area in Districts 2 and 6 is the result of both the overall concentration of cannabis businesses in these districts, and specifically, the concentration of cultivation businesses in these districts, which require much more floor area than other business types. As noted in the August 17, 2021, staff report to the Law and Legislation Committee of the City Council, the amount of square footage that has received land use approval is much greater than the square footage currently occupied by licensed cannabis businesses.

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Table 13. Cannabis Business Floor Area Concentration by Council District

Potential Negative Concerns
Potential concerns with retail cannabis operations (dispensaries) cited by citizens, officials, and a study completed shortly after legalization (Matrix Consulting Group37), range from blighting effects brought about by undesirable clientele in non-Midtown locations to gentrifying effects from increased retail activity and resulting higher retail rents because of Midtown retail cannabis facilities. Potential concerns with industrial cannabis uses vary depending on the function and Council District. A key concern in Council District 2, which includes older and comingled industrial and residential uses north of the Center City, is the impact cannabis production and distribution facilities have on the nearby residential uses. A key concern in Council District 6, which includes the Power Inn area, is the impact on industrial rents and the potential for displacing long-term tenants and their associated jobs and services.

To assess the potential negative impacts of cannabis businesses on the surrounding commercial uses, EPS analyzed commercial occupancy and leasing rate (rent) trends in the areas surrounding cannabis business operations relative to trends in their respective Council Districts and the City overall. Potential negative effects on residential property values were assessed through a comparison of home sales value trends in areas proximate to cannabis businesses relative to trends in the wider surrounding geographies.

37 Completed in January 2019 by the Matrix Consulting Group, the Analysis of Cannabis Impacts study has a dedicated section reporting neighborhood impact concerns voiced by commercial and residential stakeholders at that point in time.

Industry
Function
Group
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cannabis
Commercial
Space [1]
% of
Total
[2]
Cultivation 26,565 398,105 - 8,577 51,325 971,018 - Manufacturing - 25,652 6,081 1,443 14,060 100,937 - Distribution - 25,071 - 9,305 13,725 126,219 - Transport - - - - - 12,413 - Micro - 46,051 - - 3,085 73,111 - Delivery - 32,989 - 11,642 6,307 53,815 - Production
Subtotal 26,565 527,868 6,081 30,967 88,502 1,337,514 -

Storefront - 27,305 4,000 34,394 9,811 29,265 3,232 Lab - 18,313 - - - 7,942 - Total 26,565 0.2% 573,486 2.5% 10,081 0.1% 65,361 0.1% 98,314 0.9% 1,374,721 3.7% 3,232 0.0% Source: City of Sacramento Office of Cannabis Management, Sacramento County Assessor's Office, EPS. [1] Includes only the square footage of businesses with an active Cannabis Business Operating Permit [2] Includes properties categorized by the Sacramento County Assessor's office as Industrial, Retail/Commercial, Office.

Council District 1 Council District 7Council District 6Council District 5Council District 4Council District 3Council District 2 Sacramento Comprehensive Cannabis Study
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Details of the commercial leasing market analysis and the residential sales pricing analysis are discussed in their respective sections below.

Figure 23. Detail of Cannabis Businesses in Council District 2 Sacramento Comprehensive Cannabis Study
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Figure 24. Detail of Cannabis Businesses in Council District 3

Figure 25. Detail of Cannabis Businesses in Council District 4 Sacramento Comprehensive Cannabis Study
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Figure 26. Detail of Cannabis Businesses in Council District 5 Sacramento Comprehensive Cannabis Study
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Figure 27. Detail of Cannabis Businesses in Council District 6 Sacramento Comprehensive Cannabis Study
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Contrasting Geograph ies: Long Beach,
Seattle, Denver, and Oakland
Comparative Mapping Exhibits
Sacramento’s approach is consistent with most other cities reviewed in that there are significant concentrations of industrial cannabis IFGs in the District 2 and 6 locations that have a large concentration of industrial zoning, although Sacramento is distinct in that the retail storefront dispensaries and in fact all cannabis activity is not allowed in some Council Districts.

Long Beach on the other hand does not limit the location of retail storefront dispensaries and allows them in any retail zone in the city. The core of the industrial footprint in Long Beach is concentrated in its southwest corner adjacent to the Port of Long Beach and the industrial community of Wilmington.

Oakland similarly focuses the industrial uses in the long industrial stretch along the Oakland Estuary and in the industrial areas of West Oakland, while allowing retail uses in any retail district in the city.

These patterns also hold true for Denver. However, because of concentration concerns, Denver now has a moratorium on licenses in the five most impacted communities for both dispensaries and cultivation.

Seattle also allows dispensaries in retail districts but identifies specific historic and cultural areas that prohibit all cannabis businesses.

Lessons Learned
 Sacramento is consistent with most other cities in terms of concentration and restrictions on industrial cannabis operations and, as a result, pushes these uses into existing industrial zones, causing potential overconcentration issues.  Sacramento excludes retail dispensaries from the downtown district through zoning, when other cities allow them in any commercial zone, subject to buffers and other cultural restrictions.
 Denver, like Sacramento, is showing concern for over-impacted neighborhoods and is limiting concentrations of retail dispensaries and cultivation in 5 most impacted communities for each IFG.

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Figure 28. Distribution of Cannabis Businesses in the City of Long Beach Sacramento Comprehensive Cannabis Study
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Figure 29. Distribution of Cannabis Dispensaries in the City of Seattle

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Real Estate and Neighborhood Impact
Indicators and Findings
The Analysis of Cannabis Impacts report, prepared for the City in January 2019 (Matrix Report), identified several potential impacts to neighborhoods that could result from the legalization of cannabis businesses in the City. The Matrix Report identified the following potential impacts:
 Increase in nonresidential rental and lease rates because of increased demand from cannabis businesses.
 Downsizing of employment opportunities because of a lower number of employees per square foot for cannabis production compared to other industrial businesses.
 Influence on neighborhood reputation because of stigma and stereotypes about cannabis businesses.
 Decreased residential property values for properties located near cannabis businesses.

At the time the Matrix Report was published, adult-use marijuana had been legal for only 1 year, an insufficient amount of time to analyze the impacts that cannabis businesses have had on these neighborhoods.

The Real Estate and Neighborhood Analysis is divided into 2 main sections below, with the first section focusing on potential effects of cannabis business clusters on commercial real estate, and the second section evaluating the potential effects on residential neighborhoods.

Real Estate Indicators and Findings
Commercial Real Estate
Cannabis Retail Analysis
Citywide retail zones overall and those with cannabis businesses differ considerably because most retail nodes in the City do not include any cannabis business and generally have different market characteristics than those retail areas that do include cannabis businesses. Retail areas without cannabis businesses include significant square footage in areas ranging from Arden Fair Mall to various big box retailers to numerous grocery store-anchored shopping centers. Cannabis retail, however, tends to be located in areas with smaller, free- standing retail in more urban settings such as Midtown, in smaller parcel/non- shopping center sections of commercial corridors, and several are in light industrial areas.

Citywide, retail rents declined as square footage was added between 2015 and 2018, followed by increasing retail lease rates since.

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Retail areas near cannabis businesses have had consistently high occupancy levels and steady space inventories, with the exception of additional square footage in District 4 in 2018. However, retail asking rents in the areas analyzed near cannabis businesses (referred to herein as cannabis analysis zones) have increased much more than citywide, with a dramatic rise from 2016 to 2020.

Figure 30. Retail Occupancy & Rent: Citywide and Cannabis Analysis Zones

District 4
As noted previously, cannabis dispensaries in District 4 predate the legalization of recreational-use sales. However, the legalization of recreational-use marijuana has likely increased the foot traffic in those blocks where cannabis dispensaries are located. Furthermore, retail space near District 4 cannabis businesses has seen significant increases in asking rents in recent years. However, cannabis businesses in District 4 also tend to be located in areas that were existing neighborhood commercial nodes or have evolved into commercial nodes as significant new mixed-use developments have responded to the increasing demand for dense urban housing with nearby walkable amenities.

The rise in retail rents in Midtown is likely driven by the upscale restaurants and retailers responding to the increasing share of higher educated, higher earning persons and households present in the area and the “retail synergy” created by co-locating with other retailers catering to the same populations. It is unlikely cannabis dispensaries induce higher spin-off customer traffic to trendy local restaurants or national retail chains such as upmarket apparel or home goods stores than any other successful retail establishments that may exist in Midtown.

The District 4 retail market trends show steady additions of new square footage and rising rents since 2016. The District 4 cannabis analysis zones saw the addition of retail space in 2018 following a spike in asking rents in 2017, potentially resulting from the marketing of the new Ice Blocks spaces coming online.
94%
94%
95%
95%
95%
93%
93%
$-
$5.00
$10.00
$15.00
$20.00
$25.00

0.0 M SF

5.0 M SF

10.0 M SF

15.0 M SF

20.0 M SF

25.0 M SF
2015 2016 2017 2018 2019 2020 2021
Citywide Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
95%
97%
97%
96%
97%
97%
98%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF
2015 2016 2017 2018 2019 2020 2021
All Cannabis Zones Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Sacramento Comprehensive Cannabis Study
March 8, 2022
Economic & Planning Systems, Inc. (EPS) 97
Figure 31. Retail Occupancy & Rent: D4 Overall and D4 Cannabis Analysis Zones

District 4 Area Highlights
The following charts illustrate the retail occupancy and rent trends in some of the cannabis retail zones in District 4. Given the relatively tight 500-foot zones analyzed around the Midtown cannabis locations, the specific spaces and buildings marketed during a calendar year can significantly affect asking rate trends.

Figure 32. Retail Occupancy & Rent: Representative D4 Cannabis Analysis Zones

95%
95%
96%
95%
95%
94%
94%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00

0.0 M SF

1.0 M SF

2.0 M SF

3.0 M SF

4.0 M SF

5.0 M SF

6.0 M SF

7.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 4 Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
99%
100%
97%
97%
97%
98%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
$45.00

0.0 M SF

0.2 M SF

0.4 M SF

0.6 M SF
2015 2016 2017 2018 2019 2020 2021
D4 Cannabis Zones Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
99%
99%
97%
95%
96%
96%
$50.00
$51.00
$52.00
$53.00
$54.00
$55.00
$56.00
$57.00
$58.00
$59.00
$60.00
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
96%
100%
100%
96%
92%
96%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
1404 28th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
96%
100%
97%
95%
97%
97%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
50,000 SF
2015 2016 2017 2018 2019 2020 2021
1918 16th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
160,000 SF
2015 2016 2017 2018 2019 2020 2021
1716 J St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Sacramento Comprehensive Cannabis Study
March 8, 2022
98 Economic & Planning Systems, Inc. (EPS)
Other Council Districts with Cannabis
Retail rent and occupancy trends near cannabis businesses in the non-Midtown districts vary widely but generally follow similar patterns to the rest of their respective Council District, with some key differences noted below:

1. High occupancy rates in District 2, both districtwide and in the cannabis analysis zones, appear to have been the driver for a rise in retail rents in 2018, with the district average asking rates declining recently in response to lower occupancy, while the cannabis analysis zones have remained fully occupied.

2. The cannabis analysis zones in District 3 have historically had lower rents and occupancy levels than the district overall; however, asking rents in the cannabis analysis zones now exceed the district average, though occupancy rates remain moderately lower.

3. The District 5 cannabis zone rent surge in 2018 appears to be related to the addition of approximately 25,000 square feet of new retail space that was added to the inventory and likely commanded a lease-rate premium.

4. The District 6 cannabis zone retail rents spiked in 2019 with full occupancy.

Retail rents in the areas near cannabis facilities have since moderated; however, occupancy remains stronger than the district overall.

Sacramento Comprehensive Cannabis Study
March 8, 2022
Economic & Planning Systems, Inc. (EPS) 99
Figure 33. Retail Occupancy & Rent: Districts Overall and Cannabis Analysis Zones

95%
97%
96%
99%
99%
93%
86%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF

2.5 M SF

3.0 M SF

3.5 M SF

4.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 2 Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
96%
96%
97%
100%
99%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00

0.20 M SF

0.25 M SF

0.30 M SF

0.35 M SF

0.40 M SF

0.45 M SF
2015 2016 2017 2018 2019 2020 2021
D2 Cannabis Zones Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
94%
95%
95%
95%
96%
97%
$-
$5.00
$10.00
$15.00
$20.00
$25.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF

2.5 M SF

3.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 3 Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
91%
91%
93%
93%
94%
92%
93%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF

2.5 M SF

3.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 5 Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
98%
98%
94%
94%
96%
97%
$-
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
$70.00

0.00 M SF

0.05 M SF

0.10 M SF

0.15 M SF

0.20 M SF

0.25 M SF

0.30 M SF
2015 2016 2017 2018 2019 2020 2021
D5 Cannabis Zones Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
88%
90%
93%
93%
93%
93%
93%
$12.00
$12.50
$13.00
$13.50
$14.00
$14.50
$15.00
$15.50

0.00 M SF

0.02 M SF

0.04 M SF

0.06 M SF

0.08 M SF

0.10 M SF

0.12 M SF

0.14 M SF

0.16 M SF
2015 2016 2017 2018 2019 2020 2021D3 Cannabis Zones Retail Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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92%
91%
92%
92%
89%
90%
92%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00

1.0 M SF

1.2 M SF

1.4 M SF

1.6 M SF

1.8 M SF

2.0 M SF

2.2 M SF

2.4 M SF

2.6 M SF

2.8 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 6 Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
92%
96%
96%
95%
100%
96%
99%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00

0.10 M SF

0.12 M SF

0.14 M SF

0.16 M SF

0.18 M SF

0.20 M SF

0.22 M SF
2015 2016 2017 2018 2019 2020 2021D6 Cannabis Zones Retail Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
94%
94%
94%
94%
91%
92%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00

0.00 M SF

0.20 M SF

0.40 M SF

0.60 M SF

0.80 M SF

1.00 M SF

1.20 M SF

1.40 M SF

1.60 M SF

1.80 M SF

2.00 M SF
2015 2016 2017 2018 2019 2020 2021Council District 7 Retail Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
85%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20

0.000 M SF

0.005 M SF

0.010 M SF

0.015 M SF

0.020 M SF

0.025 M SF

0.030 M SF

0.035 M SF
2015 2016 2017 2018 2019 2020 2021
D7 Cannabis Zones Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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Economic & Planning Systems, Inc. (EPS) 101
Cannabis Impacts on Industrial Real
Estate
Sacramento Industrial Real Estate Market Overview
For several years following the Great Recession, the Sacramento Region’s industrial market continued to experience lackluster performance, characterized by high vacancy rates and average lease rates generally below the levels required for new development to be feasible without a major signed tenant preceding construction. Much of the drag on the region’s industrial market was due to older, smaller spaces considered functionally obsolete for most larger users of industrial space, in addition to some significant vacated purpose-built spaces. Larger industrial spaces constructed since the 1990s generally include significantly higher unobstructed spaces below the roof supports, known as Clear Height, of at least 30 to 36 feet and ultra-flat floors to accommodate modern equipment.

Over the last several years, the market for industrial real estate in the Sacramento Region has strengthened considerably. The advent of cannabis legalization coincided with the industrial market’s first significant signs of recovery since the recessionary period. However, the continued growth and evolution of the distribution sector, combined with the region’s location at the nexus Interstate 80 (I-80) and Interstate 5 (I-5) transportation corridors, and tightening of the Tracy-Lathrop logistics hub, have supported the region’s emergence as a logistics center. The COVID-19 pandemic has provided further acceleration of these trends.

Commercial brokerages report the Sacramento Region has absorbed more than

10.0 million square feet over the last 4 years, driving vacancy rates low and contributing to increasing lease rates. The charts below summarize industrial real estate market activity in the Sacramento market (defined by Costar as Sacramento, Yolo, Placer, and El Dorado Counties).

While absorption of Class A spaces in larger buildings has dominated market activity throughout the Sacramento Market
38 recently (largely because of the
development of Metro Air Park), a significant share of absorption occurred in smaller Class B and Class C buildings in the years leading up to 2018, driving up occupancy levels and asking rents in these spaces, as shown in the figures below.

38 The Sacramento Market is defined by Costar as Sacramento, Yolo, Placer, and El Dorado Counties.

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March 8, 2022
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Figure 34. Industrial Real Estate Metrics by Building Size and Class

Cannabis Industrial Analysis
As noted previously, non-dispensary cannabis businesses are generally limited to the City’s industrial areas because of zoning restrictions. Therefore, a fair amount of clustering in these zones is inevitable. The areas analyzed for each individual business or cluster of businesses vary depending on the number of clustered cannabis businesses and density of surrounding uses. For clusters of a few neighboring cannabis manufacturing and distribution establishments, such as found in several District 2 locations, a 1,000-foot radius from the center of the cluster was analyzed, with some adjustments to avoid areas separated by freeways. In the Power Inn area, where numerous cannabis businesses are scattered throughout industrial zones, larger geographies were analyzed (e.g., for the area around Power Inn Road and 14th Avenue, the area of analysis included the area between the railroad tracks and Granite Regional Park).

Sacramento Comprehensive Cannabis Study
March 8, 2022
Economic & Planning Systems, Inc. (EPS) 103
For individual retail dispensary locations in densely developed Midtown, the area analyzed was limited to a 500-foot radius from the establishment, while areas within a 700-foot radius were analyzed for retail establishments along major corridors and other less densely developed areas, such as Stockton Boulevard or Fruitridge Road.

Maps of the analysis zones are located in Appendix E.

Industrial Findings
In the City, industrial occupancy levels peaked at 98 percent in 2018, with an accompanying spike in average asking rents, which softened to 2020, followed by a further increase in 2021.

Figure 35. Industrial Occupancy & Rent: Citywide and Cannabis Analysis Zones

The City’s industrial zones surrounding cannabis uses, which tend to include a higher share of older, smaller spaces (Class B and Class C), generally mirrored those in the City overall but saw a higher spike in rents in 2018 than found citywide. Conversely, the recent uptick in industrial rents in the City overall, largely driven by warehouse and fulfillment demand, is less pronounced in the cannabis analysis zones because these areas tend to have fewer of the large, high-ceiling spaces sought by larger distribution operators.

Council District Cannabis Analysis Zones Industrial Analysis The following sections provide comparisons of industrial occupancy and lease rate trends for the areas surrounding cannabis businesses (cannabis analysis zones) in each of the Council Districts with the overall trends found in the districts. The districtwide trends are presented first, followed by the cannabis analysis zones.

In addition, market data for several specific analysis zones are provided for illustrative purposes.
93%
96%
97%
96%
97%
94%
97%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00

0.0 M SF

10.0 M SF

20.0 M SF

30.0 M SF

40.0 M SF

50.0 M SF

60.0 M SF
2015 2016 2017 2018 2019 2020 2021
Citywide Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
95%
97%
97%
96%
91%
95%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00

0.0 M SF

5.0 M SF

10.0 M SF

15.0 M SF

20.0 M SF

25.0 M SF
2015 2016 2017 2018 2019 2020 2021All Cannabis Zones Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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While several locations lacked sufficient commercial real estate leasing activity to provide sufficient data for analysis, either because of small inventories or high occupancy levels with little turnover, many of the cannabis analysis zones with adequate data for analysis showed similar patterns, as discussed below. (Note that years with insufficient reported lease rate data show as breaks in the asking rent trend lines in the charts below.)
District 1 Industrial
The District 1 cannabis zone industrial is confined to the vicinity of 135 Main Avenue, where a spike in asking rent was noted in 2018 when the area was at full occupancy. After some movement returned to the market the following year, asking rents declined moderately.

Figure 36. Industrial Occupancy & Rent: D1 Overall and D1 Cannabis Analysis Zones

90%
95%
97%
92%
96%
96%
97%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF

2.5 M SF

3.0 M SF

3.5 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 1 Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
93%
100%
100%
94%
93%
94%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
$10.00

0.0 M SF

0.1 M SF

0.2 M SF

0.3 M SF

0.4 M SF

0.5 M SF

0.6 M SF

0.7 M SF

0.8 M SF

0.9 M SF
2015 2016 2017 2018 2019 2020 2021
D1 Cannabis Zones Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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District 2 Industrial
The District 2 cannabis analysis zones exhibited similar industrial market trends as the district overall. However, asking rents near cannabis businesses dropped somewhat more rapidly from their 2018 peak and have seen a smaller spike in 2021.

Figure 37. Industrial Occupancy & Rent: D2 Overall and D2 Cannabis Analysis Zones

92%
95%
96%
97%
97%
95%
98%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00

0.0 M SF

1.0 M SF

2.0 M SF

3.0 M SF

4.0 M SF

5.0 M SF

6.0 M SF

7.0 M SF

8.0 M SF

9.0 M SF

10.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 2 Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
91%
94%
95%
99%
98%
91%
96%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00

0.0 M SF

0.5 M SF

1.0 M SF

1.5 M SF

2.0 M SF

2.5 M SF

3.0 M SF

3.5 M SF
2015 2016 2017 2018 2019 2020 2021
D2 Cannabis Zones Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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District 2 Area Highlights
In each of the District 2 industrial-oriented cannabis analysis zones, the findings vary because of the specific mix of buildings, tenants, and leasing activity. For example, the area near Blumenfeld Drive and Joellis Way roughly aligns with trends found citywide, while the area in the vicinity of 1500 El Camino Avenue experienced a much less dramatic spike in industrial lease rates in 2018 but a much more pronounced increase in average asking rates in the last 2 years. The area around Lathrop Way has experienced continued softening in rates. The Railroad Drive area has seen a dramatic increase in industrial asking rates following the lease up of a significant amount of previously unoccupied space in 2018 that followed a period of low rental rates.

Figure 38. Industrial Occupancy & Rent: Representative D2 Cannabis Analysis Zones

87%
92%
92%
100%
100%
97%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
500,000 SF
600,000 SF
700,000 SF
800,000 SF
900,000 SF
1,000,000 SF
1,100,000 SF
2015 2016 2017 2018 2019 2020 2021
Blumenfeld & Joellis Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
100%
96%
100%
93%
100%
96%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
300,000 SF
320,000 SF
2015 2016 2017 2018 2019 2020 2021
1500 El Camino Ave Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
97%
99%
94%
99%
100%
83%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
400,000 SF
450,000 SF
2015 2016 2017 2018 2019 2020 2021
241 Lathrop Way Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
73%
73%
90%
100%
100%
74%
79%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00
0 SF
50,000 SF
100,000 SF
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
2015 2016 2017 2018 2019 2020 2021
1955 Railroad Dr Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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District 4 Industrial
The industrial square footage in District 4 is scattered over several areas but mostly located along the northern fringe of Midtown, or adjacent to railroad lines or freeways. The industrial square footage located in the District 4 cannabis analysis zones is generally fairly small compared to some of the other more industrially focused areas of the City. The small inventory combined with relatively convenient location (depending on use) results in very little available vacant space and therefore little to no data on asking lease rates, particularly in the cannabis analysis zones.

Figure 39. Industrial Occupancy & Rent: D4 Overall and D4 Cannabis Analysis Zones

District 4 Area Highlights
The area near 1900 19th Street illustrates the low inventory combined with high occupancy levels and resulting lack of industrial asking lease rate data, typical of District 4 cannabis analysis zones.

Figure 40. Industrial Occupancy & Rent: Representative D4 Cannabis Analysis Zones

Note: The area near 12th and C Streets includes periods with sizeable vacancy (15 percent), but no available asking lease rate data, suggesting the vacant space may not be on the market.
94%
97%
97%
98%
99%
95%
94%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00

0.0 M SF

1.0 M SF

2.0 M SF

3.0 M SF

4.0 M SF

5.0 M SF

6.0 M SF

7.0 M SF

8.0 M SF
2015 2016 2017 2018 2019 2020 2021
Council District 4 Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
97%
95%
100%
100%
98%
98%
$-
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00

0.0 M SF

0.1 M SF

0.2 M SF

0.3 M SF

0.4 M SF

0.5 M SF

0.6 M SF

0.7 M SF

0.8 M SF

0.9 M SF
2015 2016 2017 2018 2019 2020 2021
D4 Cannabis Zones Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
50,000 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
95%
92%
100%
100%
100%
100%
$-
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
400,000 SF
450,000 SF
500,000 SF
550,000 SF
2015 2016 2017 2018 2019 2020 2021
241 N 10th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

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District 5
Industrial areas around cannabis businesses in District 5 exhibited similar lease rate patterns as the district overall. However, the cannabis analysis zones peaked at a lower average asking rate in 2018 and have remained lower than the district overall.

Figure 41. Industrial Occupancy & Rent: D5 Overall and D5 Cannabis Analysis Zones

District 5 Area Highlights
The Otto Circle analysis area has exhibited very high occupancy levels for the past several years. Following a period of 100 percent occupancy, vacant inventory that was added to the market in 2018 appears to have initially followed the same asking rate spike found elsewhere, with rates falling in subsequent years.

However, the area does not appear to have experienced the recent uptick in industrial rents.

Figure 42. Industrial Occupancy & Rent: Representative D5 Cannabis Analysis Zones

The 47th Avenue cannabis analysis zone closely mirrors citywide asking rate trends, with a moderate peak in 2018, followed by a tapering and recent increase.

The area has had high occupancy levels since 2016.
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District 6
The areas identified as cannabis analysis zones for this analysis comprise a significant share of the total District 6 industrial square footage. As such, the similar lease rate trends from 2015 to the 2018 spike illustrated in the charts are understandable. However, the cannabis analysis zones have seen asking rates drop since the 2018 spike, while asking rates for the district overall have largely remained near the level reached in 2018. This suggests that some of the more desirable industrial space in the district is outside the cannabis analysis zones.

Figure 43. Industrial Occupancy & Rent: D6 Overall and D6 Cannabis Analysis Zones

District 6 Area Highlights
The Florin Perkins analysis zone epitomizes the cannabis industrial zone lease rate trend, with a dramatic peak in 2018, followed by a decline and slight rebound.

Moreover, with approximately 13 million square feet, the area was a key driver of the citywide spike in 2018. The following drop in occupancy in part may be attributable to cases of rent speculation cited by individuals close to the local submarket, where landlords declined to renew existing leases in a quest for higher paying cannabis tenants. While such a strategy may have rewarded some property owners, it does not appear to have been sustainable, given the increased vacancy and decreased rents.

The growth in industrial asking lease rates throughout the district has spread to the traditionally economically depressed Lemon Hill area, with rates approaching levels found elsewhere in the district. However, given the higher sustained lease levels since 2018 in the district overall than found in the cannabis analysis zones, it does not appear that cannabis has been the driver of the recent run-up in asking rents in Lemon Hill.
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Figure 44. Industrial Occupancy & Rent: Representative D6 Cannabis Analysis Zones

District 7
District 7 has limited industrial area, with full occupancy in the cannabis zone and districtwide.

Figure 45. Industrial Occupancy & Rent: D7 Overall and D7 Cannabis Analysis Zones

Residential Re al Estate
EPS analyzed the impact of cannabis businesses on residential property values.

The Matrix Report found that community members were concerned that proximity to cannabis businesses could lower residential property values. To assess the impact of cannabis businesses on residential property values, this section provides an overview of the housing market in Sacramento, summarizes available literature on this issue, and presents the findings of a quantitative analysis of property values near cannabis businesses.

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Although the Matrix Report does not identify the exact characteristics of cannabis businesses that could drive down home values, EPS’s research has identified the following issues:
 Unpleasant odor of cannabis plants from cultivation or manufacturing processes.
 Blight and urban decay from poorly maintained structures used by cannabis businesses.
 Increased crime around cannabis businesses.

Overview of Sacramento Housing Market
The City is the central city of the Sacramento-Roseville-Arden Arcade Metropolitan Statistical Area (Sacramento MSA). As of November 2021, the Sacramento MSA has the 14th highest home prices of the 34 MSAs in California for which Zillow tracks data. In the Sacramento MSA, where Zillow tracks home values for 77 cities, the City has the 69th highest home prices. As shown in Figure 46, the typical home value in Sacramento is slightly lower than in neighboring jurisdictions.

Figure 46. Home Values in the Sacramento Region

Over the past 20 years, home values in the City and the broader region increased sharply from 2000 to 2007 before the Great Recession. Home values reached their Recession-induced nadir in 2012 and have been increasing steadily ever since. Over the past 2 years, home values in the region have begun to increase more rapidly because of restricted supply and in-migration to the region from the more expensive San Francisco Bay Area.
$100,000
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2000 2005 2010 2015 2020
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Roseville
Elk Grove
Woodland
Rancho
Cordova
West
Sacramento
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Source: Zillow, EPS.

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In the City, home values are generally highest in the legacy neighborhoods immediately to the south and east of the central business district and in the Pocket neighborhood (ZIP code 95831) in southwest Sacramento, as shown in Figure 47. The lowest home values are found in the northeast and southeast portions of the City, which also contain the majority of the land available for industrial and heavy commercial uses.

Figure 47. Home Values in Sacramento Neighborhoods

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Drivers of Home Prices
Studying the impact of nearby cannabis businesses on home values is somewhat difficult, as most cannabis businesses are located in industrial zones. Because of the impact of industrial activity, which can include air pollution, noise and odor from industrial processes, neglected properties, and heavy truck traffic, residential values near industrial zones are typically lower than in other areas of cities.
39 This impact on prices is strongest on homes within a short distance of industrial uses, about one-half to two-thirds of a mile.40 While cannabis production uses presumably share many of the disamenity characteristics of general industrial uses, cannabis retail does not. Although the Matrix Report did not identify specific neighborhood concerns regarding cannabis dispensaries, public comments show that residents are concerned about the potential for illegal activity, blight, and impacts to neighborhood reputation arising from dispensary locations. Because of the difference in how dispensaries and production uses are presumed to impact property values, this Study analyzes home value impacts from dispensaries separately from production uses.

Because legalized cannabis is a relatively new industry, there are few studies on the impact of cannabis businesses on residential property values. The available studies show conflicting results. A study in Seattle showed that homes located within 0.36 mile of a dispensary had negative price impacts of 3 to 4 percent compared to homes located outside of this distance.
41 However, a study from
Denver, Colorado, showed that homes within 0.1 mile of a dispensary were worth approximately 8 percent more than their neighbors outside of this distance. 42 At a larger scale, a study of 12 states and Washington, D.C., found that legalization of adult-use cannabis was associated with increases in home values statewide, and that neighborhoods in Washington, D.C., and Colorado experienced increased prices after nearby cannabis dispensaries opened. 43 Cannabis Businesses and Home Prices in Sacramento
Using data on home sales from the Sacramento County Assessor’s office, the per- square-foot (PSF) sales prices of single-family homes within one-quarter mile of cannabis businesses are compared to those within one-quarter to one-half mile from a cannabis business. Homes within the quarter-mile to half-mile distance were chosen to control for the general price effects of the neighborhood, including access to jobs, transportation, and amenities. In Figures 50 through 52, later in

39 Wiley, Jonathan. 2015. The Impact of Commercial Development on Surrounding Residential Property Values. Georgia Multiple Listing Service. Available at https://www.gamls.com/images/jonwiley.pdf [Accessed November 2021]. 40 De Vor, Friso & De Groot, Henri. 2009. The Impact of Industrial Sites on Residential Property Values: A Hedonic Pricing Analysis from the Netherlands. Tinbergen Institute Discussion Papers.

Available at https://papers.tinbergen.nl/09035.pdf [Accessed December 2021]. 41 Thomas, Danna & Tian, Lin. 2021. "Hits from the Bong: The impact of recreational marijuana dispensaries on property values." Regional Science and Urban Economics. Elsevier. Vol. 87(C). 42 Conklin, J., Diop, M., & Li, H. 2021. Contact High: The External Effects of Retail Marijuana Establishments on House Prices. Real Estate Economics.
43 Kim,D., O’Connor, S., Norwood, B. 2020. Retail Marijuana Deregulation and Housing Prices.

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this chapter, these sales are labeled “control.” In addition, the impact of proximity to production uses (cultivation, manufacturing, or microbusiness) and retail dispensaries are also analyzed separately in the manner described above.

Home prices in candidate neighborhoods are evaluated over the time period extending from 2015 through 2021 to allow comparison of values both before and after the establishment of legalized commercial cannabis businesses in 2018. The analysis did not include any home sales under $20,000 as these are assumed to be non-arms-length transactions.

Home Values Near Production Uses
Overall, the analysis found that homes within one-quarter mile did not suffer any decrease in home value relative to their neighbors slightly farther away, as shown in Figure 48. Based on an average of 92 sales per year for homes within a quarter-mile of a cannabis production business, and 309 sales per year for homes within a quarter-mile to a half-mile, both groups of homes experienced sales price appreciation between 2015 and 2021 as Sacramento continued its recovery from the Great Recession, but as shown in Table 14, homes within a quarter-mile of a cannabis production business are sold for approximately $40 more PSF than homes within a quarter-mile to a half-mile away from these businesses.

In addition, sales price growth for those homes nearer to these cannabis businesses has been greater than homes slightly further away in each of the last 3 years.

Figure 48. Home Prices within ¼-Mile of Cannabis Production Uses

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Table 14. Home Prices Near of Cannabis Production Uses (Citywide)

As noted previously, Council District 2 and Council District 6 contain the majority of cannabis production businesses. As such, this Study examines impacts on home values for homes in those districts that are near cannabis businesses.

Council District 2
As of July 2021, Council District 2 had 55 of the 264 actively licensed cannabis businesses, as shown in Table 5 (Chapter 3). These 55 businesses are largely concentrated along Business Interstate 80/Capitol City Freeway and Del Paso Boulevard, as shown in Figure 22 (Chapter 3). Data from the Sacramento County Assessor’s office identified an average of 134 sales per year of homes within one-quarter to one-half mile from cannabis production uses and 66 sales per year of homes within one-quarter mile of cannabis production uses. These data show similar results to the citywide analysis in that both groups of homes experienced price appreciation during the Study period. However, in District 2, homes sold in 2021 near cannabis businesses sold for approximately $20 less PSF than homes slightly further away, as shown in Table 15.

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Figure 49. Home Prices Near Cannabis Production Uses in Council District 2

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Table 15. Home Prices Near Cannabis Production Uses in Council District 2

Council District 6
As of July 2021, Council District 6 had the highest concentration of cannabis businesses. The district contained 65 percent of the 160 licensed cannabis production businesses in the City, and 58 percent of all cannabis businesses.

However, as shown in Figure 29, cannabis uses in District 6 are largely located in the industrial areas east of Power Inn Road, segregated from the residential areas. Because of this separation of residential and industrial uses in District 6, EPS’s analysis of home sales includes fewer sales than the analysis of District 2.

In District 6, there were approximately 47 single-family home sales per year in the control group and 13 sales per year of homes within one-quarter mile of a cannabis production use.

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As seen in Figure 50 and Table 16, sales prices of homes in District 6 were between $20 and $40 PSF lower for homes within one-quarter mile of cannabis uses between 2018 and 2020. However, in 2021, homes within one-quarter mile of cannabis uses were selling for approximately $30 more PSF than homes within one-quarter to one-half miles of cannabis production businesses.

Figure 50. Home Prices Near Cannabis Production Uses in Council District 6

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Table 16. Home Sales Near Cannabis Production Uses in Council District 6

Home Values Near Dispensaries
The City’s land use policies are more permissive for storefront dispensaries than other cannabis uses because they are essentially retail businesses and therefore are more readily able to locate in General Commercial (C-2) zones. As seen in Table 12 earlier in this chapter, storefront dispensaries make up nearly half of the 27 cannabis businesses located in General Commercial zones. General Commercial zones are generally either interspersed within residential neighborhoods, such as in Midtown, or along commercial corridors.

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Based on an average of 338 sales per year for the control group and 86 sales per year for homes within one-quarter mile of dispensaries, the analysis finds that proximity to dispensaries does not reduce home values relative to other homes in the same general area. As seen in Figure 51, homes within one-quarter mile of dispensaries had higher sales prices PSF from 2015 to 2020. Only in 2021 did the PSF price for homes within one-quarter mile of dispensaries fall below the PSF price for homes within one-quarter to one-half mile away.

Figure 51. Single-Family Home Sales within One-Quarter Mile of Dispensaries (Citywide)

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As shown in Table 17, in 2021, homes within one-quarter mile of a dispensary were sold for approximately $13 less PSF than homes between one-quarter and one-half mile away from a dispensary. While this is a reversal of the 2015 to 2020 trends, more years of data and observation will be needed to see if the current trend continues.

Table 17. Home Sales Near Cannabis Dispensaries (Citywide)

Year
Price Per Square
Foot
Change
from
Previous
Year
Price Per Square
Foot
Change
from
Previous
Year
2015 $218.34 N/A $251.72 N/A
2016 $232.20 6% $257.03 2%
2017 $268.15 15% $287.96 12%
2018 $307.00 14% $316.35 10%
2019 $299.21 -3% $395.65 25%
2020 $330.16 10% $349.59 -12%
2021 $364.41 10% $351.22 0%
Total Change
(2015 - 2021) $146.07 67% $99.50 40%
Source: City of Sacramento, Sacramento County Assessor, EPS. [1] Includes properties between 1/4-mile and 1/2-mile away from a dispensary. [2] Includes properties within 1/4-mile of a dispensary. [3] Includes all single-family residential sales above $20,000. Sales below $20,000 are presumed to be non arms-length transactions.

Control [1] Test [2]
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Crime and Cannabis Businesses
Although the Matrix Report did not specifically identify crime as a concern, it did describe the concern that cannabis businesses could have a negative impact on “neighborhood reputation,” of which the local crime rate is presumably a major component. In addition, public testimony on the District 2 Land Use Study, heard before the City’s Law and Legislation Committee on August 17, 2021, specifically identified crime at cannabis businesses as a major concern.

Before legalization of recreational cannabis in 2016, trade in recreational cannabis was, by definition, a criminal activity. Cultivation, distribution, and retail sale of marijuana had strong links to organized crime.
44 Even post legalization, there
remains a strong black market for illicit cannabis, and the stigma linking cannabis businesses to criminal activity also remains. Public concern about criminal actors operating cannabis businesses is compounded by concern about criminal actors targeting legitimate cannabis businesses. With a large market for illicit cannabis and cannabis products, as well as the tendency of cannabis businesses to hold large amounts of cash, cannabis businesses may present attractive targets for robberies and theft. In recent months, cannabis businesses have made high- profile news stories as both perpetrators and victims of crimes. In Alameda County, sheriffs targeting an illegal grow operation seized more than $10 million in cash and 100,000 cannabis plants.
45 In addition, in November 2021, news
organizations reported on a series of more than 2 dozen robberies of licensed cannabis delivery businesses in Oakland in less than a week, with business owners claiming losses of up to $5 million.46
At the state level, cannabis legalization is generally associated with a decrease in crime, likely because of the disruption of illicit markets by legal ones.47 Previous studies of the relationship between the location of cannabis businesses and crime

44 National Drug Intelligence Center, 2008. National Drug Threat Assessment 2009. Available at https://www.justice.gov/archive/ndic/pubs31/31379/dtos.htm [Accessed December 2021]. 45 Cordova, Gilbert. 2021. Upwards of $10M in cash alone seized in illegal marijuana grow operation in Alameda County. ABC10.Com. Available at
https://www.abc10.com/article/news/crime/alameda-county-sheriffs-office-seize-large-amounts- of-marijuana-in-bust/103-80dcef91-2d69-42bd-ab36-fee4553672d8 [Accessed December 2021]. 46 Anthony, Laura. 2021. 'I fear for my business': Oakland cannabis dispensaries say they've lost $5M in recent thefts. ABC7News.Com. Available at https://abc7news.com/oakland-thefts- cannabis-dispensaries-police/11282132/ [Accessed December 2021]. 47 Huber, Arthur; Newman, Rebecca; & La Fave, Daniel. 2016. Cannabis Control and Crime:

Medicinal Use, Depenalization and the War on Drugs. The B.E. Journal of Economic Analysis & Policy. Available at
https://www.researchgate.net/publication/335379896_Not_in_my_backyard_Not_so_fast_The_ef fect_of_marijuana_legalization_on_neighborhood_crime [Accessed December 2021].

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at smaller spatial scales have produced mixed results. A 2009 study48 of the distribution of medical cannabis dispensaries in Sacramento found that census tracts with a higher density of medical marijuana dispensaries did not have higher property and violent crime than other census tracts and posited that the additional security measures that dispensaries typically use—security guards, video cameras—may serve to deter criminals seeking to target the dispensary.

At a slightly larger scale, a study in Los Angeles found that census block groups with medical cannabis dispensaries had higher crime rates than nearby block groups without dispensaries.
49 A 2016 study in Long Beach found that higher numbers of medical marijuana dispensaries were associated with higher crime rates in surrounding areas, leading the authors to suggest that the additional security measures deployed by dispensaries may push crime to surrounding areas. In Denver, researchers found that recreational cannabis dispensaries were associated with lower violent crime but slightly higher property crime rates on the block-long street segments on which the dispensaries were located.
50 However, a second study in Denver
occurring at the same time examined the impact of dispensaries and found that the opening of a dispensary in a census tract led to a 19 percent decrease in crime rates compared to other census tracts, attributing this effect to both the disruption of organized criminal cannabis trade and the additional security measures employed by dispensaries.

While criminal activity around the production and distribution of illicit cannabis remains a concern, this report focuses on the latter portion of crime—that of criminal opportunists targeting cannabis businesses, as this is the more relevant concern when examining the neighborhood impact of licensed cannabis businesses. Since licensed cannabis operations began in 2018, the Sacramento Police Department (SPD) has tracked burglaries and robberies at cannabis businesses. As shown in Table 18, there were between 30 and 84 robberies and burglaries per year targeting cannabis businesses. Over these 4 years, robberies and burglaries at cannabis businesses accounted for less than 1 percent of all robberies and burglaries reported to the SPD.

48 Kepple, Nancy and Freisthler, Bridget. 2012. Exploring the ecological association between crime and medical marijuana dispensaries. Journal of Studies on Alcohol and Drugs. Available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3364319/ [Accessed December 2021]. 49 Contreras, Christopher. 2017. A block-level analysis of medical marijuana dispensaries and crime in the City of Los Angeles. Justice Quarterly. Available at https://www.tandfonline.com/doi/full/10.1080/07418825.2016.1270346 [Accessed January 2022].
50 Connealy, Nathan; Piza, Eric; & Hatten, Dave. 2019. The Criminogenic Effect of Marijuana Dispensaries in Denver, Colorado: A Microsynthetic Control Quasi-Experiment and Cost Benefit Analysis. City University of New York Academic Works. Available at https://academicworks.cuny.edu/cgi/viewcontent.cgi?article=1349&context=jj_pubs [Accessed December 2021].

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Table 18. Robberies and Burglaries at Cannabis Businesses in Sacramento (2018–2021)

While overall robberies and burglaries have trended downward since 2019, the number of crimes targeting cannabis businesses has been much more volatile, with no discernable trend. Although crimes targeting cannabis businesses have not shown any sign of trending downward, crimes involving illicit cannabis have declined significantly since commercial cannabis businesses were legalized.

Crimes involving possession (of more than 28.5 grams of cannabis), unlicensed cultivation, or transportation and sale of illicit cannabis declined from a high of 213 in 2019 to just 94 in 2021, as seen in Table 18.

Year 2018 2019 2020 2021
All Crime
Robberies Total 1,053 1,053 894 984 Change from Previous Year - 0% (15%) 10%
Burgalries Total 6,207 7,138 5,853 5,124 Change from Previous Year - 15% (18%) (12%)
Crimes at Cannabis Businesses
Robberies Total 3 17 4 9 Change from Previous Year - 467% (76%) 125%
Burgalries Total 28 67 26 77 Change from Previous Year - 139% (61%) 196%
Total Total 31 84 30 86 Change from Previous Year - 171% (64%) 187%
Marijuana Related Crime [1]
Total 197 213 116 94
Change from Previous Year - 8% (46%) (19%)
Source: City of Sacramento Police Department, EPS.
[1] Marijuana-related crimes include posession (of greater than 28.5 grams), unlicensed cultivation, posession of marijuana for sale, transportation of marijuana, and posession of marijuana in a vehicle.

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While the total number of crimes targeting cannabis businesses has not declined significantly since 2018, as general property crime has, the number of cannabis businesses has increased significantly in that time frame. As seen in Table 19, the number of crimes per cannabis business has declined significantly since 2018.

Throughout the Study period, cultivation, delivery, and storefront dispensaries are the most commonly targeted types of businesses, both in terms of overall numbers of crimes and the number of crimes per licensed business.

Table 19. Robberies and Burglaries by Cannabis Business Type (2018–2021)

Overall, this analysis of crime at cannabis businesses, as well as review of the available literature, shows mixed results. On a regional level, the legalization of cannabis and the expansion and maturation of a legitimate cannabis industry will likely reduce crime, as licensed cultivators, distributors, and retailers continue to displace the criminal organizations that ran this industry before legalization.

At the neighborhood level, cannabis businesses will likely remain an attractive target for thieves, although their attractiveness will decrease if federal legalization proceeds and allows these businesses to join traditional financial institutions and decrease the amount of cash they process and store on site. Despite this attractiveness, the proliferation of cannabis businesses in Sacramento has not generated a proportional increase in crimes targeting these businesses, suggesting that the enhanced security measures employed by these businesses are a strong deterrent to crime.

Year
Total
Per
Licensed
Business Total
Per
Licensed
Business Total
Per
Licensed
Business Total
Per
Licensed
Business
Total
Crimes
(2018 -
2021)
Average
Annual
Crimes per
Licensed
Business
Industry
Function Group
Cultivation 9 1.00 23 1.05 13 0.19 47 0.53 92 0.69
Delivery 6 [1] 30 1.67 5 0.10 17 0.29 58 0.69
Distribution 3 3.00 3 0.38 2 0.07 1 0.03 9 0.87
Manufacturer 2 0.67 4 0.36 0 0.00 11 0.41 17 0.36
Microbusiness 0 0.00 0 0.00 0 0.00 5 1.25 5 0.31
Lab 1 0.25 2 0.50 0 0.00 0 0.00 3 0.19
Storefront 9 0.30 22 0.73 10 0.33 5 0.17 46 0.38
Total 30 0.64 84 0.89 30 0.15 86 0.34 230 0.50
Source: City of Sacramento Office of Cannabis Management, City of Sacramento Police Department, EPS. 2018 2019 2020 2021
[1] The Sacramento Police Department reported 6 crimes at cannabis delivery businesses in 2018, although no delivery businesses were licensed until 2019.

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Key Chapter Findings
 Many of the industrial areas that are well-suited for cannabis production facilities experienced dramatic spikes in asking lease rates in 2018 on the heels of legalization. The rent spikes, which were likely due to a combination of real demand and speculation, appear to have moderated, though pricing pressure resulting from the growth of e-commerce and distribution remains.  An analysis of lease rates for retail and industrial uses in the areas surrounding cannabis businesses found no pattern of negative impact on the marketability of surrounding areas, as demonstrated by asking lease rate trends for available spaces.
 A comparison of home sale values within one-quarter mile of dispensaries and those within larger control groups for the same areas found that proximity to dispensaries does not reduce home values relative to other homes in the same general area.
 The proliferation of cannabis businesses in Sacramento has not generated a proportional increase in crimes targeting these businesses, suggesting that the enhanced security measures employed by these businesses is a strong deterrent to crime.

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Cannabis Economic and Fiscal
Impacts in Sacramento
Economic Impact Analysis
Employment Overview and Trends
While the cannabis industry is comparable to other industries in several ways, there are also significant additional benefits and industry synergies beyond those seen by other similar operations. Cannabis cultivation and manufacturing are prime examples of this dynamic. Based on guidance provided by IMPLAN, the economic impacts of cultivation operations were estimated to be consistent with the impacts associated with indoor greenhouse industry operations.

Cannabis cultivation has similar needs to indoor greenhouses in terms of employment and output potential but serves as a significant catalyst for R&D beyond a standard greenhouse operation. Sacramento cannabis operations encourage significant agricultural research in the region, including the genetic innovations resulting in new strains of cannabis and development of new innovative growing technologies.

Proximity to the University of California at Davis, a university with significant agriculture research facilities, creates the opportunity for the Sacramento Region to become a hub for cannabis growing technology and research. Major agricultural companies, such as Scott’s Miracle Grow, have begun to enter the cannabis R&D sphere, creating a catalytic effect and infusing the cannabis industry with much- needed research funding.

Similarly, the cannabis manufacturing industry is most closely akin to food manufacturing operations with some key distinctions. Where the cannabis industry diverts from the typical food production manufacturing industry related to the more scientific nature of cannabis operations as dosage in goods and specific manufacturing techniques require more intensive laboratory research and development. Maintaining proper dosage throughout the manufacturing requires very specific technology and, at times, a more intensive manufacturing operation.

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These are some tie-ins to other prominent sectors in Sacramento:
 Cannabis manufacturing is commonly compared to craft brewery operations, which often undertake similar stages of testing and development of new brewing methods.
 Seed variety innovations relate strongly to life science and seed science research activity, including genetics research and tie-in to wider innovation in the ag industry.
 Delivery companies resemble (and may someday be directly influenced by) e-commerce-oriented companies.
 Distribution operations of the cannabis industry are similar to many non- cannabis operations choosing Sacramento as a central hub for transportation and distribution infrastructure, serving growing markets throughout the western United States.
 Value-added packaging and manufacturing of consumer-oriented packaged goods in the cannabis industry are reflective of other small- to medium-sized manufacturing in the region.

Cannabis Industry Multiplier Effects
This Study includes an Economic Impact Analysis of cannabis-related operations in the City. The purpose of this Economic Impact Analysis is to estimate the quantifiable economic impacts of ongoing cannabis operations on the City and the regional economy with respect to jobs, income, and total economic output. The economic stimulus generated by cannabis operations has a multiplying effect throughout the local economy as businesses, consumers, and the households of employees associated with cannabis operations make local expenditures.

The Economic Impact Analysis quantifies these impacts using an input/output (I/O) economic modeling system, which measures the change in regional economic activity resulting from an economic stimulus. The purpose of this analysis is to estimate the existing ripple effect of economic activity generated by cannabis operations.

This estimate of the economic impacts of cannabis operations relies on the I/O modeling system called IMPLAN, which encompasses fixed relationships and linkages between households, businesses, and government entities within a regional economy. In this Economic Impact Analysis, the regional economy is defined as the County of Sacramento and is based on the 2019 IMPLAN dataset, which represent the latest available data from IMPLAN, although all economic impacts are presented in current 2021$.

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IMPLAN models are most useful in examining small, incremental changes in an economy and are most often used to reflect the growth in economic activity in a region as new economic stimuli develop. As this Study is assessing the economic activity of existing, ongoing operations, adjustments to the standard IMPLAN modeling have been made. Specifically, this analysis uses an industry contribution analysis methodology, which estimates the economic activity generated by existing business in an economy and limits the ripple effect to existing business in the economy.

The economic impacts measured in this Economic Impact Analysis include the direct contributions of the cannabis operations, as well as indirect and induced impacts of cannabis operations, including those impacts related to employment and associated households, and local contract expenditures. Figure 52 illustrates the components described in this Economic Impact Analysis.

Figure 52. Economic Impact Analysis Components

DIRECT IMPACTS

INDIRECT IMPACTS

INDUCED IMPACTS
Operating revenues and
employment
Example: Operational
spending and onsite
employment of
cannabis operations.

Business-to-business
transactions
Example: Cannabis
businesses purchases
goods, such as office
supplies and
equipment from
businesses in the
County.

Spending of employee
income
Example: An office
employee spends their
salary on groceries and
household expenses,
generating sales for
other local businesses.

Total Economic Impacts
Source: EPS.

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Key Findings
This Study includes an estimate of the economic impacts generated by cannabis operations by broad business group categories, including cultivation, manufacturing, distribution, and retail. A summary of economic impacts by business group is shown in Table 20.

Table 20. Summary of Economic Impacts

1. Cannabis operations in the City are estimated to result in $2.2 billion in total economic output in the local economy, annually, inclusive of direct, indirect, and induced impacts.

Of the $2.2 billion in activity, $606.3 million will be retained by employees of local businesses in the form of income. Cannabis operations generate $1.5 billion in direct economic activity, $357.1 million of which is income. The remaining $746.2 million of economic activity reflects the estimated indirect and induced impacts supported by cannabis operations as spending ripples through the local economy. This level of economic activity generates support for approximately 12,500 full- and part-time jobs in the region, including 8,000 direct, 2,600 indirect, and 1,800 induced jobs.

2. The majority of economic activity created by cannabis operations are estimated to be captured by the City.

All $1.5 billion in direct economy activity generated annually is captured in the City, and a significant portion (65 percent) of indirect and induced impacts are estimated to be retained by the City, for a total City impact of $2.0 billion, annually, supporting 11,000 jobs.
51 51 City capture or Sacramento County economic activity is based on the percentage of total annual economic activity occurring in the City, based on total economic impact estimates provided by IMPLAN.

Activity/Impact Categories Cultivation Manufacturing Distribution Retail Delivery Total Source Table A-14 Table A-15 Table A-16 Table A-17 Table A-18 Table A-13 Annual Ongoing Economic Impacts
Annual Ongoing Operational Impacts [1] $1,550.3 M $238.3 M $229.8 M $79.2 M $135.8 M $2,233.4 M Annual Ongoing Operational Jobs (Annual Average) [2] 7,005 889 2,047 912 1,565 12,418 Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[1] Includes direct, indirect, and induced impacts of cannabis activity. [2] Employment includes both full-time and part-time workers.

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3. Cultivation activities generate the most significant economic impacts of all cannabis operations, followed by manufacturing and distribution.

Cannabis cultivation activities are estimated to generate $1.6 billion in economic activity annually, supporting 7,000 jobs, the greatest level of impact generated out of all cannabis business groups analyzed. Manufacturing and distribution reflect the next largest economic drivers in the local economy, generating $238.3 million and $229.8 million in economic output, respectively.

4. Economic activity attributable to cannabis operations accounts for approximately 2 percent of the local economy.

Based on regional data provided by IMPLAN, $151.4 million in economic output is generated in Sacramento County, of which cannabis operations account for approximately 2 percent.

Fiscal Effects of the Cannabis Industry
on the City General Fund
A City Fiscal Impact Analysis (Fiscal) has been prepared for its cannabis industry, which estimates the annual fiscal revenues, expenditures, and resulting fiscal surplus or deficit to the City General Fund attributable to cannabis operations.

This Fiscal examines the estimated annual net fiscal impact on the City’s General Fund budget resulting from cannabis operations, based on the approved Fiscal Year (FY) 2021/22 City budget.

Specifically, the Fiscal estimates whether estimated General Fund revenues from cannabis operations adequately cover the cost of delivering General Fund municipal services (e.g., police and fire protection) to the cannabis businesses, as well as provide ongoing funding for the OCM. The fiscal impacts of cannabis operations were estimated for each major cannabis business group, cultivation, manufacturing, distribution, and retail.

Key Findings
Table 21 shows the annual fiscal surplus resulting from each cannabis business group. A detailed accounting of all fiscal revenues and expenditures included in this analysis is included on Table 22.

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Table 21. Summary of Fiscal Impacts

Table 22. Detailed Summary of Fiscal Impacts

Item Cultivation Manufacturing Distribution Retail Delivery Total City General Fund Net Fiscal Impacts
Annual General Fund Revenues $6.5 M $1.2 M $5.8 M $13.8 M $4.8 M $27.3 M Annual General Fund Expenditures $2.2 M $0.4 M $1.7 M $2.5 M $1.1 M $7.5 M Annual Net General Fund Surplus/(Deficit) $4.3 M $0.9 M $4.1 M $11.3 M $3.7 M $19.8 M Additional Cannabis Fiscal Revenues
Local Neighborhood Responsibility Fee $0.9 M $0.2 M $1.2 M $2.2 M $0.7 M $5.2 M Source: EPS.

Annual Fiscal Impact Summary by Business Group (Millions) Item Cultivation Manufacturing Distribution Retail Delivery Total City General Fund
Annual Revenues
Property Tax $716,000 $93,000 $69,000 $60,000 $69,000 $938,000 Property Tax in lieu of VLF $333,000 $43,000 $32,000 $28,000 $32,000 $436,000 Real Property Transfer Tax $44,000 $6,000 $4,000 $4,000 $4,000 $58,000 Sales Tax $76,000 $8,000 $25,000 $2,082,000 $663,000 $2,191,000 Sales Tax - Measure U $76,000 $8,000 $25,000 $2,082,000 $663,000 $2,191,000 Sales Tax - Prop. 172 (Public Safety) $4,000 $0 $1,000 $122,000 $39,000 $127,000 Transient Occupancy Tax (TOT) $6,000 $1,000 $2,000 $1,000 $2,000 $10,000 Utility Taxes $93,000 $10,000 $30,000 $16,000 $27,000 $149,000 Business Operations Tax - Cannabis $3,617,000 $814,000 $4,846,000 $8,703,000 $2,671,000 $17,980,000 Business Operations Tax - Other $43,000 $5,000 $14,000 $7,000 $12,000 $69,000 Franchise Fees $7,000 $1,000 $2,000 $1,000 $2,000 $11,000 Cannabis Business Permit Fees $1,434,000 $251,000 $724,000 $714,000 $590,000 $3,123,000 Fines and Forfetitures $21,000 $2,000 $7,000 $4,000 $6,000 $40,000 Total Annual GF Revenues $6,470,000 $1,242,000 $5,781,000 $13,824,000 $4,780,000 $27,323,000 Annual Expenditures
General City Operations $1,252,136 $135,564 $404,020 $210,258 $360,484 $2,001,978 Cannabis Operations
Cannabis Management $247,889 $55,774 $332,089 $596,429 $183,019 $1,415,200 City Attorney $184,621 $41,539 $247,330 $444,203 $136,307 $1,054,000 Community Development $117,201 $26,370 $157,010 $281,989 $86,530 $669,100 Finance $17,674 $3,977 $23,677 $42,524 $13,049 $100,900 Fire $13,925 $3,133 $18,655 $33,505 $10,281 $79,500
Police $220,755 $49,669 $295,738 $531,144 $162,986 $1,260,292 Auditor $29,094 $6,546 $38,977 $70,002 $21,481 $166,100 Community Outreach and Education $131,372 $29,558 $175,994 $316,084 $96,993 $750,000 Total Cannabis Operations Expenditures $962,532 $216,564 $1,289,470 $2,315,881 $710,645 $5,495,092 Total Annual GF Expenditures $2,214,668 $352,128 $1,693,490 $2,526,139 $1,071,130 $7,497,070 Annual General Fund Surplus/(Deficit) $4,255,332 $889,872 $4,087,510 $11,297,861 $3,708,870 $19,825,930 Additional Cannabis Fiscal Revenues
Local Neighborhood Responsibility Fee $904,318 $203,466 $1,211,483 $2,175,817 $667,666 $5,162,750 detsum
Source: EPS.

Note: All values are rounded to the nearest $1,000.

Annual Fiscal Impacts by Business Group
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1. Cannabis operations generate a significant fiscal surplus of $19.8 million to the City’s General Fund annually.

Cannabis operations are estimated to generate $27.3 million in General Fund revenues annually, well above the estimated $7.5 million in General Fund expenditures required to fund municipal services for cannabis-related businesses. Cannabis-related revenues are estimated to account for approximately 5 percent of all General Fund revenues budgeted for FY 2021/22. Retail operations are the largest driver of fiscal surpluses, with an estimated surplus of $11.3 million attributable to retail cannabis operations.

2. Business operations taxes are the largest revenue source for cannabis operation in the City.

Based on the FY 2021/22 City budget, it is anticipated that cannabis uses will generate $20.7 million in business operations taxes. Cannabis uses are anticipated to contribute approximately 73 percent of all business operations taxes generated in the City.

3. Cannabis operations are anticipated to generate approximately $4.5 million in sales tax revenue in FY 2021/22, including all City sales tax revenues.

At the time of retail sales, non-medical adult-use cannabis products are assessed multiple sales taxes, including the general 1 percent sales tax, the City Supplemental General Fund Measure U transaction and use tax, and Proposition 172 public safety sales tax, all of which provide revenues to the City General Fund. Cannabis sales in the City are anticipated to generate approximately 5 percent of all budgeted City sales tax revenues for FY 2021/22.

4. Revenues generated are significantly greater than the cost of operating the OCM.

The approved City budgeted expenditures for the OCM are estimated at $3.2 million for FY 2021/22, accounting for less than 1 percent of all budgeted General Fund expenditures.

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5. Based on conversations with the City Police and Fire Departments, cannabis uses have not been shown to be overly taxing on the respective departments beyond a typical commercial or industrial user.

Using a per-persons-served multiplier effect, it is estimated that cannabis operations will require $1.0 million in police services and $760,000 in fire services for a total public safety expenditure budget of $1.8 million for FY 2021/22.

6. In addition to the estimated General Fund revenues, cannabis operations are estimated to generate an additional $5.2 million in non-General Fund revenues through the neighborhood responsibility plan fee.

Estimated as 1 percent of all activity related to cannabis operations, the neighborhood responsibility plan fee is anticipated to generate an additional $5.2 million in revenues beyond those captured by the City’s General Fund.

The above-referenced fiscal surplus indicates the possibility of introducing several industry-supportive measures, as discussed in Chapter 4 of this report.

Key Chapter Findings
 Cannabis operations in the City are estimated to result in $2.2 billion in total economic output in the local economy, annually, inclusive of direct, indirect, and induced impacts, supporting nearly 12,500 jobs. Cannabis operations generate $1.5 billion in direct economic activity, $357.1 million of which is income. The remaining $746.2 million of economic activity reflects the estimated indirect and induced impacts supported by cannabis operations as spending ripples through the local economy. The City is anticipated to capture the majority of economic activity attributable to cannabis, with $2.0 billion of the estimated economic activity anticipated to be captured in the City, annually, supporting 11,000 jobs.
 Cannabis operations generate a significant fiscal surplus of $19.8 million to the City’s General Fund, annually. Cannabis operations are estimated to generate $27.3 million in General Fund revenues annually, well above the estimated $7.5 million in General Fund expenditures required to fund municipal services for cannabis-related businesses. Cannabis-related revenues are estimated to account for approximately 5 percent of all General Fund revenues budgeted for FY 2021/22. The neighborhood responsibility plan fee is anticipated to generate an additional $5.2 million in revenues beyond those captured by the City’s General Fund.

Selected Bibliography
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Aziz, N. (2021). Oakland’s Cannabis Social Equity Program: Reversing The War on Drugs. UC Berkeley: Institute of Governmental Studies
Boeson, U. (2020). A Road Map to Recreational Marijuana Taxation. Retrieved from https://taxfoundation.org/recreational-marijuana-tax/
Brinkman, Jeffrey & Mok-Lamme, David. (2019). Not in my backyard? Not so fast.

The effect of marijuana legalization on neighborhood crime. Regional Science and Urban Economics. 78. 103460. 10.1016/j.regsciurbeco.2019.103460 California Department of Fee and Tax Administration. (2021). Cannabis Tax Revenues. Retrieved from
https://www.cdtfa.ca.gov/dataportal/charts.htm?url=CannabisTaxRevenues City of Sacramento Department of Finance. (2021). Approved City of Sacramento Fiscal Year 2021/22 Budget. Retrieved from
http://www.cityofsacramento.org/-
/media/Corporate/Files/Finance/Budget/Approved_22/FY2021_22-Approved- Operating-Budget_for-Web.pdf?la=en
Cordova, Gilbert. 2021. Upwards of $10M in cash alone seized in illegal marijuana grow operation in Alameda County. ABC10.Com. Retrieved from:
https://www.abc10.com/article/news/crime/alameda-county-sheriffs-office- seize-large-amounts-of-marijuana-in-bust/103-80dcef91-2d69-42bd-ab36- fee4553672d8
Fischer, Benedikt, et. al. 2022. Lower-Risk Cannabis Use Guidelines (LRCUG) for reducing health harms from non-medical cannabis use: A comprehensive evidence and recommendations update. International Journal of Drug Policy.

Garrick, David. 2018. San Diego plans to crack down on marijuana ads, especially billboards. Los Angeles Times. October 20, 2018.

Goldstein, R., Sumner, D. A, & Fafard, A. (2019). Retail cannabis prices in California through legalization, regulation and taxation. California Agriculture, 73(3)

International City/County Management Association. (2018). Local Impacts of Commercial Cannabis. Retrieved from:
https://icma.org/sites/default/files/Local%20Impacts%20of%20Commercial% 20Cannabis%20Final%20Report_0.pdf
Ju, S. (2021). How Connected Came Into Fruition, With A Goal Of Being The Best in Cannabis. Retrieved from https://flaunt.com/content/how-connected-came- into-fruition
Kary, T. (2021). Marijuana M&A boom awaits, in California and beyond. Retrieved from https://www.latimes.com/business/story/2021-02-07/marijuna-m-and- a-boom-awaits-in-california-and-beyond
Kolmar, C. (2021). 15 Largest Cannabis Companies In The World. Retrieved from https://www.zippia.com/advice/largest-cannabis-companies/ Marijuana Business Daily. (2020). California Market Report: Illicit Market Woes Marijuana Business Daily. (2021). Annual Marijuana Business Factbook 2021 9th Edition
Marijuana Policy Group. (2016). The Economic Impact of Marijuana Legalization in Colorado
National Drug Intelligence Center (2008.) National Drug Threat Assessment 2009 New Frontier Data. (2021). Cannabis in the U.S. 2021 Mid-Year Market Update Nichols, K. (2021). High inflation is latest threat to marijuana businesses. Retrieved from https://mjbizdaily.com/high-inflation-is-latest-threat-to-cannabis- businesses/?utm_medium=email&utm_source=newsletter&utm_campaign=MJ D_20211217_NEWS_Daily
North Bay Business Journal. (2021). Northern California’s billion-dollar cannabis industry sees big issues to resolve. Retrieved from
https://www.northbaybusinessjournal.com/article/industrynews/northern- californias-billion-dollar-cannabis-industry-sees-big-issues-to-r/ Petek, G. (2019). How High? Adjusting California’s Cannabis Taxes. California Legislative Analyst’s Office
Rodd, S. (2019). Sacramento-based cannabis edibles company Good Co-op acquired for $1.5 million. Retrieved from
https://www.bizjournals.com/sacramento/news/2019/01/25/sacramento- based-cannabis-edibles-company-good-co.html
Rychert, M., Emanuel, M.A. & Wilkins, C. Foreign investment in emerging legal medicinal cannabis markets: the Jamaica case study. Global Health 17, 38 (2021)

Sandy, E. (2020). Stem Holdings to Close Acquisition of Driven Deliveries in Data- Centric Rebrand. Retrieved from
https://www.cannabisbusinesstimes.com/article/stem-holdings-cannabis- delivery-driven-by-stem-mergers-acquisitions/
Sharon, J. (2021). A Comparative Analysis for Oakland’s Cannabis Industry. City of Oakland Cannabis Regulatory Commission
Schiller, M. (2019). Natura Life + Science Secures $91 Million to Build California’s Largest Vertically Integrated Cannabis Campus. Retrieved from https://www.cannabisbusinesstimes.com/article/natura-life-and-science- secures-91-million-to-build-california-cannabis-campus/ Schroyer, J. (2021). California marijuana regulators could be deposed for ‘burner distribution’ lawsuit. Retrieved from https://mjbizdaily.com/california- marijuana-regulators-could-be-deposed-for-burner-distribution-lawsuit/ Schroyer, J. (2021). California marijuana veteran selling businesses in sign of wider market woes. Retrieved from https://mjbizdaily.com/california-marijuana- veteran-selling-businesses-in-sign-of-wider-market-
woes/?utm_medium=email&utm_source=newsletter&utm_campaign=MJD_20 211112_NEWS_Daily
Schroyer, J. (2021). ‘Millions of pounds’ of legal marijuana diverted to underground market, California lawsuit alleges. Retrieved from
https://mjbizdaily.com/millions-of-pounds-of-legal-marijuana-diverted-to- illicit-market-california-lawsuit-alleges/
Staggs, B. (2020). New cannabis coworking space in Santa Ana aims to boost industry access, diversity. Retrieved from
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APPENDICES:

Appendix A: Fiscal and Economic Impact
Analysis Methodology and
Detailed Tables
Appendix B: Initiativ es in Other States
Appendix C: Comparison of Cannabis Land
Use Regulations: Sacramento,
Oakland, Long Beach, Seattle
Appendix D: Comparison of City of
Sacramento and State of
California Cannabis Regulations
Appendix E: Real Estate Market Analysis
Support Figures
Appendix F: Cannabis Business Crime Data
Appendix G: Cannabis Industry Survey
Responses

APPENDIX A:

Fiscal and Economic Impact Analysis
Methodology and Detailed Tables

Appendix A
Economic & Planning Systems, Inc. (EPS) A-1
Fiscal and Economic Impact Analysis
Methodology and Detailed Tables
This section details the underlying methodology and assumptions used to estimate the fiscal impact of cannabis operations on the City. It describes assumptions concerning municipal service delivery and General Fund budgeting. In addition, it details the methodology used to estimate the General Fund revenues and municipal service expenditures attributable to cannabis operations. The municipal services analyzed in this Analysis comprise General Fund services only (e.g., police, fire). The Analysis excludes any services that may be funded privately. Further, this Analysis does not address activities budgeted in other City Governmental Funds or Proprietary Funds (e.g., enterprise funds), nor does it include an evaluation of capital facilities or the funding of capital facilities needed to serve new development.

General Assumptions
The Analysis is based on the City’s Approved Budget for FY 2021–22, estimated citywide residential and employment populations as of 2021, tax regulations and statutes current as of December 2021, and other general assumptions discussed herein. Each revenue item is estimated based on current State legislation and current City practices. Future changes by either State or City legislation or practices may affect the revenues and expenditures estimated in this Analysis. All costs and revenues are shown in constant 2021 dollars. General fiscal and demographic assumptions are detailed in Table A-1.

EPS consulted the City’s budget documents to develop forecasting methodologies for specific revenues and expenditures affected by cannabis operations. In addition, EPS consulted with City staff to clarify budget data and review assumptions.

Cannabis Business Assumptions
Listed below are summaries of cannabis business operations-related assumptions used in this Analysis:
 Building Square Footage. Building square footage of cannabis businesses was obtained from building permit application data for all cannabis uses with the City.

Building square feet by business group is shown in Table A-2.  Estimated Population. Employment estimates are based on an assumed employment density for each cannabis business group. A building square foot per employee assumption was developed based on preliminary data provided by the City pertaining to a survey of cannabis business. The City data provided an estimate of full and part time employees for each business group. To estimate the full-time Appendix A
A-2 Economic & Planning Systems, Inc. (EPS)
equivalent employees, this study assumes all part time employees are one half of a full-time employee. In estimating certain annual revenues and expenditures (service demands), EPS developed a “persons-served” population estimate to approximate the impacts of an employee relative to a City resident. EPS uses a factor of

0.5 employees plus all residents to derive the persons-served population. As this analysis is an assessment of business-related costs and revenues, persons served is equal to one half of all employees. Table A-2 shows the estimated employees, and persons served generated by cannabis uses.
 Assessed Value. The assessed value for cannabis uses is estimated in this analysis utilizing assessed value per square foot assumptions based on available data for similar nonresidential uses located in and around the Sacramento region. The estimated assessed value for cannabis uses includes the value of both secure and unsecure property. The estimated assessed value is presented in Table A-12.  Property Turnover Rates. It is assumed in this analysis that all property will turn over once every 20 years and an annual turnover rate of 5 percent is assumed for all business groups.

General Fund Assumptions
This Fiscal Analysis considered only discretionary General Fund revenues that are generated by cannabis operations. Offsetting revenues, provided by City Finance Department staff, are General Fund revenues dedicated to offset the costs of specific General Fund department functions and are excluded from this Analysis for both revenue and cost estimates. Offsetting revenues by revenue and cost categories are shown in Table A-4 and Table A-10, respectively.52
In addition, this Fiscal Analysis excluded revenue and expenditure items that are not expected to be impacted by cannabis operations.

General Fund Revenue-Estimating
Methodology
EPS used either an average-revenue approach or a marginal-revenue case-study approach to estimate Project-related General Fund revenues:
 The average-revenue approach uses the City’s FY 2021-22 budgeted revenue amounts on a citywide per capita, per-employee, or per-persons-served basis to forecast revenues derived from cannabis employees, or persons served.

52 Although commonly included as an offsetting revenue source, a portion of funding from fines and forfeitures is used to fund services related to cannabis. As such, this revenue source is estimated using a per persons served multiplier, which assumes that fine and forfeitures collected from cannabis operations is consistent with the collection from other sources on a per persons served basis.

Appendix A
Economic & Planning Systems, Inc. (EPS) A-3
 The marginal-revenue case-study approach simulates actual revenue generation resulting from new development. The case-study approach for estimating sales and use tax revenues, for instance, forecasts market demand and taxable spending from the cannabis employees and direct cannabis taxable sales. Case studies used in this Analysis are discussed in greater detail later in this section.

Revenue sources not expected to be impacted by cannabis operations are excluded from this Fiscal Analysis. These sources of revenue are not affected by cannabis operations because they are either one-time revenue sources not guaranteed to be available in the future or there is no direct relation between cannabis operations and increased revenue.

A listing of all City General Fund revenue sources and the corresponding estimating procedure used to estimate revenues attributable to cannabis operations is shown in Table A-4. A summary of estimated annual General Fund revenues generated by cannabis operations is provided in Table A-5. As shown, cannabis operations are estimated to generate nearly $27.3 million in annual General Fund revenues. In addition to the General Fund revenues, cannabis operations are estimated to generate an additional $5.2 million in non-General Fund revenues in the form of neighborhood responsibility plan fees.

Average-Revenue Categories
An average revenue multiplier was used to estimate a variety of revenue sources, including transient occupancy taxes (TOT), utility taxes, business operations taxes (non- cannabis related), franchise fees, other license and permit fees, and fines and forfeitures.

All sources were estimated using a per-persons-served revenue multiplier, except business operations tax revenue, which was estimated based on a per-employee revenue multiplier.

An adjustment factor was applied to the average revenue multiplier for the all categories to account for the unpredictable, historical ebbs and flows of these revenue sources. As a conservative approach to prevent potentially overestimating revenues, this Fiscal Analysis discounts all revenues estimated via multiplier by 50 percent.

The average revenue methodologies used in this Analysis are based on EPS’s previous experience in forecasting these revenue sources and conversations with City Finance staff to determine specific circumstances related to these City General Fund revenues.

Marginal-Revenue Categories
Property Tax
Estimated annual property tax revenue resulting from cannabis operations is presented in Table A-6. The estimate of property taxes the City receives is derived from the estimated assessed values of all cannabis uses, shown in Table A-12, and the City Appendix A
A-4 Economic & Planning Systems, Inc. (EPS)
average General Fund’s post-Educational Revenue Augmentation Fund (ERAF) share of the 1 percent ad valorem property tax rate.

Property Tax in Lieu of Vehicle License Fee
The Analysis uses a formula provided by the State Controller’s Office to forecast Property Tax in Lieu of Vehicle License Fees (PTIL VLF). PTIL VLF is calculated by taking the percentage of the City’s assessed value resulting from the assessed value of cannabis uses and applying that percentage increase to the City’s current State allocation of PTIL VLF revenue, as shown in the City’s FY 2021-22 budget. This calculation of PTIL VLF based on the Project’s estimated total and marginal assessed values is shown in Table A-6.

Real Property Transfer Tax
Real property transfer tax is based on the assessed value of cannabis uses and the anticipated turnover of properties over time. This Analysis is based on the assumption that all property will transfer once every 20 years. An estimate of real property transfer revenue attributable to cannabis uses is shown on Table A-7.

Sales Tax
Sales tax revenue is based on estimated taxable sales, the Bradley-Burns local 1 percent Uniform Local Sales Tax rate and the Measure U 1 percent rate as summarized in Table A-8. Measure U was a supplemental half-cent transactions and use tax rate approved by voters in 2012 as a temporary tax. In November 2018, Sacramento voters approved a new version of the City’s Measure U tax, extending it and raising it from a half-cent to a full cent.

EPS uses a combination of methodologies to account for taxable sales generated by the Project:

1. Market Support Method. This methodology measures taxable sales generated from cannabis business employees spending money within the City’s boundaries.

2. Retail Space Method. This methodology estimates direct taxable sales from retail sales of cannabis.

Annual Taxable Sales fr om Market Support
(Employees)
Based on estimates gleaned from the 2012 International Council of Shopping Centers’ Office-Worker Spending in a Digital Age report and conversations with the City’s sales tax consultant, employees within the City are estimated to spend an average of $10 in taxable retail expenditures per day for each of the 240 work days annually. To remain Appendix A
Economic & Planning Systems, Inc. (EPS) A-5
conservative, this Fiscal Analysis estimates the City will capture approximately 75 percent of taxable expenditures from the Project’s employees.

Refer to Table A-8A for estimated annual taxable sales from market support.

Direct Annual Taxable Sales from Retail Cannabis Sales
Retail and delivery operations generate both medical and adult use sales. While medical sales will result in business operations tax and other revenues, medical sales of cannabis is not eligible for general sales tax collection. The Fiscal Analysis estimated total annual retail sales for both retail category for FY 2021-22 based on the amount of business operations taxes allocated to both sale categories for FY 2020-21, as provided by City staff. The Fiscal Analysis assumes that FY 2021-22 retail sales will be consistent with levels seen in FY 2020-21. Based on data provided by the City, it is estimated that $290 million in taxable sales will occur in FY 2021-22, $271 million of which is adult use. EPS further allocated retail sales to retail and delivery uses based on the share of business operations tax collected for each category in the previous year.

Refer to Table A-8B for estimated annual taxable sales from onsite retail development at buildout of the Project
Proposition 172 Public Safety Sales Tax
Public safety sales tax is collected on a countywide basis and allocated principally to the County, with a small portion of revenues allocated to incorporated cities in the County.

This revenue source is used to fund police and fire services in the City. The Analysis estimates these tax revenues using the current FY 2021-22 relation between total sales tax revenue and Proposition 172 public safety sales tax revenue. This relation may vary in the future because actual revenues received by the City are affected by several factors in the rest of the County. The estimated FY 2021-22 revenues shown in this Analysis reflect existing fiscal conditions. Estimated revenues from the City’s share of the half-cent sales tax for public safety are shown in Table A-8.

Business Operations Tax
Project business operations taxes for cannabis uses are included in the FY 2021-22 approved budget for City and are fully allocable to cannabis operations. The Fiscal Analysis assumes that projected business operations tax revenues will be generated by each business group, consistent with that group’s proportional share of revenues seen in the previous year. Allocation of business operation taxes to each business is shown in Table A-9.

Neighborhood Responsibility Plan Fee
The neighborhood responsibility plan fee is a 1 percent fee applied to all cannabis uses in the City. This revenue source is not allocated to the General Fund and has been estimated in this analysis as an independent revenue not contributing to the estimated Appendix A
A-6 Economic & Planning Systems, Inc. (EPS)
annual General Fund surplus. Estimated as 1 percent of all cannabis related activity for each business group, the local neighborhood responsibility plan fee is estimated to result in an additional $5.2 million in revenues. The obligation is occasionally met in whole or in part through in-kind services. For purposes of this analysis, the value of any in-kind services are assumed to have a value similar to the 1% fee. Estimated revenues from the neighborhood responsibility plan fee are estimated on Table A-9.

Expenditure-Estimating Methodology
Expenditure estimates are based on the City’s FY 2021-22 approved budget and supplemental information from City staff. The Fiscal Analysis shows estimates of General Fund expenditures attributable to cannabis operations, including direct Cannabis expenditure and general City operational expenditures. General city operationsal expenditures are defined as General Fund department expenditures not directly attributable to cannabis operations. These expenditures that are expected to be affected by the Project are forecasted using an average-cost approach. The average-cost approach uses the City’s FY 2021-22 budgeted expenditures on a citywide per capita or per-persons-served basis to forecast expenditures required to serve new development.

A listing of all City General Fund expenditures and the corresponding estimating procedure used to forecast future expenditures is shown in Table A-10. A summary of estimated annual General Fund expenditures required to serve cannabis operations is provided in Table A-11. As shown, the Project is estimated to result in about $7.5 million in annual General Fund costs. Expenditures directly related to cannabis operations were provided by the City based on the approved FY 2021-22 budget, including all expenditures related to cannabis specific FTEs. Cannabis operational expenditures are estimated at $5.5 million annually. The remaining $2.0 million in expenditures is attributed to general City operational expenditures required to serve Cannabis businesses and employees.

Average-Cost Expenditures
General City operational expenditures are estimated using a per persons served or per capita expenditure multiplier. Convention and Cultural Services and Citywide and Community Support expenditures are estimated using a per capita average cost multiplier because this service generally is demanded by residential development only. As the Fiscal Analysis estimates the impact of nonresidential uses, no annual expenditures are estimated for these cost categories.

Expenditures that are affected by residents and employees are projected using a per- persons-served average cost multiplier. These expenditures include General Government, Police, Fire, Community Development, and Public Works expenditures, net of direct cannabis expenditures.

An adjustment factor can be applied to the average-cost multipliers for expenditure categories to reflect the percentage of expenditures subject to increase due to development within the City, considering fixed costs. This analysis assumes adjustment Appendix A
Economic & Planning Systems, Inc. (EPS) A-7
factors consistent with those used for recent fiscal completed for various projects in the City. Expenditure factors range from 50 to 90 percent for all expenditure categories, except for police and fire services, which do not include an adjustment factor. As shown on Table A-10, general City operational are estimated at approximately $593 per person served.

Police and Fire Expenditures
Based on conversations with the City police and fire departments, cannabis operations have not been shown to be overly taxing on their respective public safety departments beyond the impacts associated with typical industrial and commercial uses. As such, this Fiscal Analysis estimates police and fire expenditures using a per persons served multiplier method for all expenditures beyond those directly attributed to Cannabis employment.

Cannabis Operations Expenditures
Based on the approved FY 2021-22 City budget and supplemental information provided by City staff, approximately $5.5 million in annual City General Fund expenditures are attributable directly to cannabis related employment. These expenditures include funding for the Office of Cannabis Management and all other cannabis related City employment FTEs. Consistent with the allocation of business operating taxes between business groups, direct cannabis operational expenditures are attributed to each business group based on the proportional share of economic activity generated by each business group, as shown on Table A-10.

Economic Impact Analysis: Detailed Findings and Assumptions The following section provides the detailed results of the economic impact analysis, as well as the assumptions used to calculate each impact.

Economic Impacts of Annual Cannabis Operations
To estimate the economic activity resulting from the cannabis operations, this Analysis estimates the ongoing economic impacts occurring annually as a result of cannabis operations in the local economy, defined as Sacramento County for the economic impact analysis. Ongoing economic impacts capture the direct, indirect, and induced impacts generated by cannabis activity, including direct operational expenditures, employee wages, and employee household spending. While the local economy for the economic impact analysis is defined as Sacramento County, due to the location of cannabis businesses in the City, it can be assumed that all direct impacts occur within the City and the majority of indirect and induced impacts would similarly occur in the City.

Impacts associated with these economic activities are estimated for each of the major business groups, including cultivation, manufacturing, distribution, retail, and delivery, based on employment estimates for each group. As shown on Table A-2 employment
levels are estimated based on an assumed square foot per employee assumption applied Appendix A
A-8 Economic & Planning Systems, Inc. (EPS)
to the total square footage of cannabis businesses for each business group. As described previously, the total square footage of cannabis businesses included in the study is based on the building square footages included on business permit applications for cannabis businesses. To arrive at a full time equivalent employee estimate for cannabis businesses, a building square foot per employee assumption was developed based on preliminary data provided by the City pertaining to a survey of cannabis business, adjusted based on EPS knowledge of data pertaining to similar land uses within the greater Sacramento region. The City data provided an estimate of full and part time employees for assorted cannabis businesses. To estimate the full time equivalent employees, this study assumes all part time employees are one half of a full time employee. As shown, cannabis operations are estimated to support approximately 8,000 full time equivalent employees in the City.

A detailed summary of the estimated economic impacts of each business groups are described below and summarized in Tables A-13 through A-18 of this appendix Economic Impacts of A ll Cannabis Business
Groups
Table A-13 summarizes the total combined estimated annual impacts associated with all cannabis business group operations. The resulting impacts are described below:
 Annual Output. Cannabis operations are estimated to generate approximately $1.5 billion in direct industry output annually. Local business to business expenditures result in approximately $437.4 million in indirect industry output impacts and employee household spending results in $308.8 million in induced impacts annually for a total industry output impact of $2.2 billion on an annual basis.  Employee Compensation. Of the $1.5 billion in direct industry output reported above, approximately $357.1 million is received by employees in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $249.2 million for a total annual employee compensation impact of approximately $606.3 million.
 Annual Employment. Cannabis operations are estimated to employ approximately 8,000 direct FTEs and support 2,600 indirect jobs, and 1,800 induced jobs annually for a total employment impact of approximately 12,400 jobs on an annual basis.

Economic Impacts of Cu ltivation Activities
Table A-14 summarizes the total estimated annual impacts associated with cultivation operations. The resulting impacts are described below:
 Annual Output. Cultivation operations are estimated to generate approximately $1.1 billion in direct industry output annually. Local business to business expenditures result in approximately $254.0 million in indirect industry output impacts and Appendix A
Economic & Planning Systems, Inc. (EPS) A-9
employee household spending results in $200.1 million in induced impacts annually for a total industry output impact of $1.6 billion on an annual basis.  Employee Compensation. Of the $1.1 billion in direct industry output reported above, approximately $238.2 million is received by employees employed by cultivation operations in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $152.4 million for a total annual employee compensation impact of approximately $390.6 million.  Annual Employment. Cultivation operations are estimated to employ approximately 4,200 direct FTEs and support 1,600 indirect jobs, and 1,200 induced jobs annually for a total employment impact of approximately 7,000 jobs on an annual basis.

Economic Impacts of Manufacturing
Activities
Table A-15 summarizes the total estimated annual impacts associated with manufacturing operations. The resulting impacts are described below:
 Annual Output. Manufacturing operations are estimated to generate approximately $159.1 million in direct industry output annually. Local business to business expenditures result in approximately $59.1 million in indirect industry output impacts and employee household spending results in $20.2 million in induced impacts annually for a total industry output impact of $238.3 million on an annual basis.  Employee Compensation. Of the $159.1 million in direct industry output reported above, approximately $12.0 million is received by employees employed by manufacturing operations in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $28.7 million for a total annual employee compensation impact of approximately $40.7 million.  Annual Employment. Manufacturing operations are estimated to employ approximately 500 direct FTEs and support 300 indirect jobs, and 100 induced jobs annually for a total employment impact of approximately 900 jobs on an annual basis.

Economic Impacts of Di stribution Activities
Table A-16 summarizes the total estimated annual impacts associated with distribution operations. The resulting impacts are described below:
 Annual Output. Distribution operations are estimated to generate approximately $114.2 million in direct industry output annually. Local business to business expenditures result in approximately $75.0 million in indirect industry output impacts and employee household spending results in $40.6 million in induced impacts annually for a total industry output impact of $229.8 million on an annual basis.

Appendix A
A-10 Economic & Planning Systems, Inc. (EPS)
 Employee Compensation. Of the $114.2 million in direct industry output reported above, approximately $46.5 million is received by employees employed by distribution operations in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $36.8 million for a total annual employee compensation impact of approximately $229.8 million.  Annual Employment. Distribution operations are estimated to employ approximately 1,400 direct FTEs and support 400 indirect jobs, and 200 induced jobs annually for a total employment impact of approximately 2,000 jobs on an annual basis.

Economic Impacts of Retail Activities
Table A-17 summarizes the total estimated annual impacts associated with retail operations. The resulting impacts are described below:
 Annual Output. Retail operations are estimated to generate approximately $43.7 million in direct industry output annually. Local business to business expenditures result in approximately $18.1 million in indirect industry output impacts and employee household spending results in $17.4 million in induced impacts annually for a total industry output impact of $79.2 million on an annual basis.  Employee Compensation. Of the $43.7 million in direct industry output reported above, approximately $22.2 million is received by employees employed by retail operations in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $11.5 million for a total annual employee compensation impact of approximately $33.8 million.
 Annual Employment. Retail operations are estimated to employ approximately 700 direct FTEs and support 100 indirect jobs, and 100 induced jobs annually for a total employment impact of approximately 900 jobs on an annual basis.

Economic Impacts of Delivery Activities
Table A-18 summarizes the total estimated annual impacts associated with delivery operations. The resulting impacts are described below:
 Annual Output. Delivery operations are estimated to generate approximately $74.9 million in direct industry output annually. Local business to business expenditures result in approximately $31.1 million in indirect industry output impacts and employee household spending results in $29.8 million in induced impacts annually for a total industry output impact of $135.8 million on an annual basis  Employee Compensation. Of the $74.9 million in direct industry output reported above, approximately $38.1 million is received by employees employed by delivery operations in the form of salary, wages, and benefits. Indirect and induced employee Appendix A
Economic & Planning Systems, Inc. (EPS) A-11
compensation impacts total approximately $19.8 million for a total annual employee compensation impact of approximately $57.9 million.
 Annual Employment. Delivery operations are estimated to employ approximately 1,200direct FTEs and support 200 indirect jobs, and 200 induced jobs annually for a total employment impact of approximately 1,600 jobs on an annual basis.

Table A-1
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
General Assumptions
Item Assumption
General Assumptions
Base Fiscal Year [1] FY 2021-22
General Demographic Characteristics
City of Sacramento
Population [2] 515,673
Employees [3] 367,400
Persons Served [4] 699,373
gen assumps
[1] This Fiscal Impact Analysis is based on the City of Sacramento's FY 2019-20 Approved Budget. [2] California Department of Finance estimate for January 1, 2019. [4] "Persons Served" is defined as City of Sacramento's population plus 50% of employees. [3] US Census Onthemap.ces.census.gov estimated a total of 318,363 jobs in Sacramento, CA in 2017.

California EDD reports an annual average growth rate of 4.91% since 2017 for the Sacramento MSA. EPS esc
alated 2017 employment figure to arrive at 2020 employment estimate, adjusted by an additional 10% to account for self-employed workers, and rounded to the nearest hundred employees.

Source: California Department of Finance; US Census Bureau, OnTheMap, and LEHD Origin Destination Employment Statistics; California EDD; EPS.

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A-12
Table A-2
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Cannabis Business Group Estimated Square Footage and Employment Item Cultivation Manufacturing Distribution Retail Delivery Total Building Square Footages
Active Cannibis Business Licenses 70 39 99 29 58 295
Building Square Footage 1,583,999 205,793 204,440 106,394 121,607 2,222,233 Employment Estimates
Square Feet per Full Time Employee (FTE) [1] 375 450 150 150 100 Estimated Employee FTE's 4,224 457 1,363 709 1,216 7,970 Source: City of Sacramento; EPS.

Total Cannabis Land Uses and Employment by Business Group [1] Square feet per employee assumptions are based on intial data provided by the Office of Cannabis Research pertaining to a survey of local cannabis businesses within the City.

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Table A-3
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Project Assumptions
Land Use Category Cultivation Manufacturing Distribution Retail Delivery Square Feet per Employment FTE [1] 375 450 150 150 100
Property Turnover Rate 5% 5% 5% 5% 5%
Assessed Value per Square Foot
Secured Value [2] $150 $150 $150 $250 $250
Unsecured Value [2] $50 $50 $0 $0 $0
Total Value per Square Foot $200 $200 $150 $250 $250
Assumps
Source: City of Sacramento; EPS.
[2] Assessed value assumptions are based on industry standard average valuations for similar uses in the City and surrounding region.

Land Use Assumptions
[1] Square feet per employee assumptions are based on intial data averages provided by the Office of Cannabis research pertaining to a survey of local cannabis businesses within the City, rounded.

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Table A-4
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Revenue-Estimating Procedures (2021$)
City of Sacramento Adjusted
Estimating Reference Approved FY 2021-22 Offsetting Net FY 2021-22 Service Revenue Item Procedure Table [1] Revenues (Rounded) Revenues [2] Revenues Population Multiplier Annual General Fund Revenues
Taxes
Property Tax Case Study Table A-6 $137,699,000 $0 $137,699,000 33.5% 0.0% NA NA Property Tax in lieu of VLF [4] Case Study Table A-6 $53,363,000 $0 $53,363,000 13.0% 0.0% NA NA Real Property Transfer Tax Case Study Table A-7 $12,659,000 $0 $12,659,000 3.1% 0.0% NA NA Sales Tax Case Study Table A-8 $96,411,000 $0 $96,411,000 23.5% 0.0% NA NA Sales Tax - Prop. 172 (Public Safety) Case Study Table A-8 $5,640,000 $0 $5,640,000 1.4% 0.0% NA NA Transient Occupancy Tax (TOT) Per Person Served Table B-6 $3,743,000 $0 $3,743,000 0.9% 50.0% 688,422 $2.72 Utility Taxes Per Person Served Table A-5 $61,594,000 $0 $61,594,000 15.0% 50.0% 699,373 $44.04 Business Operations Tax - Cannabis Case Study [5] Table A-9 $20,651,000 $0 $20,651,000 5.0% 0.0% NA NA Business Operations Tax - Other Per Employee Table A-5 $7,509,000 $0 $7,509,000 1.8% 50.0% 367,400 $10.22 Residential Development Property Tax [6] NA $368,000 $0 $368,000 0.1% 0.0% NA NA Subtotal Taxes $399,637,000 $0 $399,637,000 97.2%
Licenses and Permits
Franchise Fees Per Person Served Table A-5 $4,331,000 $0 $4,331,000 1.1% 50.0% 699,373 $3.10 Cannabis Related Business Permit Fees [5] Table A-5 $3,178,000 $0 Other Licenses & Permits Per Person Served Table A-5 $27,488,000 $27,488,000 $0 0.0% 50.0% 699,373 $0.00 Subtotal Licenses and Permits $34,997,000 $27,488,000 $4,331,000 1.1% Fines and Forfeitures Per Person Served Table A-5 $7,029,000 $0 $7,029,000 1.7% 0.0% 699,373 $10.05 Use of Money (Interest, Rents, and Concessions) [7] NA $2,854,000 $2,854,000 $0 0.0% 0.0% NA NA Intergovernmental Revenue [7] NA $14,205,000 $14,205,000 $0 0.0% 0.0% NA NA Charges for Services [7] NA $59,935,000 $59,935,000 $0 0.0% 0.0% NA NA Miscellaneous Revenues [7] NA $780,000 $780,000 $0 0.0% 0.0% NA NA Contributions From Other Funds
Enterprise Funds/General Tax [7] NA $31,303,000 $31,303,000 $0 0.0% 0.0% NA NA In-lieu Franchise Fee [7] NA $2,154,000 $2,154,000 $0 0.0% 0.0% NA NA In-lieu Property Tax [7] NA $700,000 $700,000 $0 0.0% 0.0% NA NA Investment Fees [7] NA $2,850,000 $2,850,000 $0 0.0% 0.0% NA NA Subtotal Contributions From Other Funds $37,007,000 $37,007,000 $0 0.0% Total Annual General Fund Revenues [8] $556,444,000 $142,269,000 $410,997,000 100.0% rev pro
Source: City of Sacramento FY 2019-20 Approved Budget; California Office of the Controller; California Department of Finance; EPS. [1] Refers to table with detailed revenue calculations. [3] Adjustment factor accounts for the unpredictable ebbs and flows of this revenue source. As a conservative approach to prevent potentially overestimating revenues, this analysis discounts revenues by 50%. [4] Property Tax in lieu of Motor Vehicle License Fees is authorized by SB 1096 as amended by AB 2115. [5] The entirety of revenues from this revenue item is attributable to cannabis operations. [6] This revenue source is not expected to be directly affected by cannabis operations and therefore is not evaluated in this analysis. [7] This revenue source is based on cost recovery or transfers from another fund and is therefore not evaluated in this analysis (see footnote [2] above). [8] Excludes funding for General Fund Capital Improvement expenditures. [2] Revenues are adjusted by user fees and cost recovery amounts shown in the City's FY 2021-22 Budget. These deductions from ongoing revenues also are deducted from ongoing costs, as shown in Table C-1. If Offsetting Revenues exceeds Revenues then Adjusted Net Revenues equal $0. % of
Total
Adjustment
Factor [3]
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Table A-5
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Project Revenues (2021$)
% of Total
Revenues Cultivation Manufacturing Distribution Retail Delivery Total at Buildout Annual General Fund Revenues
Taxes
Property Tax Table A-6 $715,968 $93,018 $69,305 $60,112 $68,708 $1,007,112 3.1% Property Tax in lieu of VLF Table A-6 $332,965 $43,259 $32,231 $27,956 $31,953 $468,363 1.5% Real Property Transfer Tax Table A-7 $43,560 $5,659 $4,217 $3,657 $4,180 $61,273 0.2% Sales Tax Table A-8 $76,032 $8,232 $24,533 $2,082,372 $662,920 $2,854,088 8.9% Sales Tax - Measure U Table A-8 $76,032 $8,232 $24,533 $2,082,372 $662,920 $2,854,088 8.9% Sales Tax - Prop. 172 (Public Safety) Table A-8 $4,448 $482 $1,435 $121,818 $38,781 $166,963 0.5% Transient Occupancy Tax (TOT) Table A-4 $5,742 $622 $1,853 $964 $1,653 $10,833 0.0% Utility Taxes Table A-4 $93,002 $10,069 $30,009 $15,617 $26,775 $175,472 0.5% Business Operations Tax - Cannabis Table A-9 $3,617,272 $813,865 $4,845,932 $8,703,268 $2,670,662 $20,651,000 64.3% Business Operations Tax - Other Table A-4 $43,165 $4,673 $13,928 $7,248 $12,427 $81,442 0.3% Residential Development Property Tax NA $0 $0 $0 $0 $0 $0 0.0% Subtotal Taxes $5,008,186 $988,111 $5,047,975 $13,105,384 $4,180,979 $28,330,634 88.3% Licenses and Permits
Franchise Fees Table A-4 $6,539 $708 $2,110 $1,098 $1,883 $12,338 0.0% Cannabis Related Business Permit Fees Table A-4 $1,434,444 $250,749 $723,730 $714,114 $589,963 $3,713,000 Subtotal Licenses and Permits $1,440,983 $251,457 $725,840 $715,212 $591,845 $3,725,338 11.6% Fines and Forfetitures Table A-4 $21,227 $2,298 $6,849 $3,564 $6,111 $40,049 Total Annual Gen. Fund Revenues (rounded) $6,470,000 $1,242,000 $5,781,000 $13,824,000 $4,779,000 $32,096,000 100.0% Neighborhood Responsibility Plan Fee Table A-9 $904,318 $203,466 $1,211,483 $2,175,817 $667,666 $5,162,750 revenues
Source: EPS.

Reference
Table
Annual Net Revenues
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Table A-6
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Property Tax Revenues (2021$)
Item Formula Cultivation Manufacturing Distribution Retail Delivery Total Property Tax Revenue (1% of Assessed Value)
Assessed Valuation [1] Table A-12 a $316,799,871 $41,158,519 $30,666,065 $26,598,405 $30,401,750 $445,624,609 Property Tax Revenue (1% of Assessed Value) 1.00% b = a * 1.00% $3,167,999 $411,585 $306,661 $265,984 $304,018 $4,456,246 Estimated Property Tax Allocation
City General Fund [2] 22.60% c = b * 22.60% $715,968 $93,018 $69,305 $60,112 $68,708 $1,007,112 Other Agencies/ERAF 77.40% f = b * 77.40% $2,452,031 $318,567 $237,355 $205,872 $235,310 $3,449,134 Property Tax In-Lieu of Motor Vehicle In-Lieu Fee Revenue (VLF) Total Citywide Assessed Value [3] $50,772,282,921 h
Total Assessed Value of Project i $316,799,871 $41,158,519 $30,666,065 $26,598,405 $30,401,750 $445,624,609 Percentage of Citywide AV j = i / h 0.62% 0.08% 0.06% 0.05% 0.06% 0.88% Property Tax In-Lieu of VLF [4] $53,363,000 k = j * $53,363,000 $332,965 $43,259 $32,231 $27,956 $31,953 $468,363 prop tax
Source: Sacramento County Office of the Assessor; City of Sacramento Finance Department; EPS. [1]
[2]
[3] Reflects Final FY 2021-22 Assessed Valuation. Includes Citywide secured, unsecured, homeowner exemption, and public utility roll. [4] Property tax in-lieu of VLF amount of $53.4 million taken from FY 2021-22 Approved City Budget. See Table B-1.

Estimated Annual Property Tax Revenues
The allocation of the 1% property tax rate apportioned to the City of Sacramento is an estimated citywide average allocation and includes a shift to the Educational Revenue Augmentation Fund.

Assumption/
Source
Refer to Table A-12 for details.

Property Tax
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Table A-7
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Real Property Transfer Tax (2021$)
Assumptions/
Item Sources Cultivation Manufacturing Distribution Retail Delivery Total Rate per $1,000 of AV [1] $2.75
Property Turnover Rate [2] Table A-3 5% 5% 5% 5% 5%
Assessed Value [3] Table A-12 $316,799,871 $41,158,519 $30,666,065 $26,598,405 $30,401,750 $445,624,609 Total Annual Transfer Tax Revenue $43,560 $5,659 $4,217 $3,657 $4,180 $61,273 transfer
Source: Sacramento County Recorder-Clerk; EPS.
[1]
[2] Property is anticipated to turn over once every 20 years. [3]
Real Property
Transfer Tax Revenue
The rate of $2.75 per $1,000 of AV is for the City of Sacramento only and excludes the County of Sacramento rate of $0.55 per $1,000 of AV.

Annual Property Transfer Tax Revenues
Property transfer tax is estimated based on the total assessed value and assumes any unsecured property will transfer with the sale of the building. Refer to Table A-12 for details.

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Table A-8
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Taxable Sales and Use Tax Revenue (2021$) Item Formula Cultivation Manufacturing Distribution Retail Delivery Total Estimated Annual Taxable Sales
Annual Taxable Sales from Employee Spending a Table A-8A $7,603,197 $823,170 $2,453,285 $1,276,723 $2,188,926 $14,345,302 Taxable Sales from Retail Activity [1] b Table A-8B $0 $0 $0 $206,960,469 $64,103,066 $271,063,535 Total Annual Taxable Sales c = a + b $7,603,197 $823,170 $2,453,285 $208,237,192 $66,291,992 $285,408,836 Annual Sales Tax Revenue to City
Bradley Burns Sales Tax Rate [2] d = c * 1.000% 1.0000% $76,032 $8,232 $24,533 $2,082,372 $662,920 $2,854,088 Measure U Citywide Transaction Tax Rate [3] e = c * 1.000% 1.0000% $76,032 $8,232 $24,533 $2,082,372 $662,920 $2,854,088 Total Sales Tax Rate g 2.0000%
Annual Sales Tax from Employee Spending h = a * (d + e) $152,064 $16,463 $49,066 $25,534 $43,779 $286,906 Annual Sales Tax from Retail Activity i = b * h $0 $0 $0 $4,139,209 $1,282,061 $5,421,271 Total j = h + i $152,064 $16,463 $49,066 $4,164,744 $1,325,840 $5,708,177 Gross Prop 172 Public Safety Sales Tax Revenue [4] k = c * 0.0585% 0.0585% $4,448 $482 $1,435 $121,818 $38,781 $166,963 sales tax
Source: California State Board of Equalization; City of Sacramento Finance Department; EPS. [1] Includes retail activity from both store and home delivery activity. [2] The City of Sacramento is allocated a full 1.0000% of the Uniform Local Sales Tax. [3]
[4]
Sales Tax
Revenue
The City of Sacramento receives approximately $.000627 for every $1 generated by the Public Safety Sales Tax authorized by Proposition 172. This is estimated by taking the 2020-21 Budget amount for Prop. 172 divided by the total Sales Tax from Table A-4.

In 2012, Measure U was approved by voters as a temporary, supplemental, half-cent transaction and use tax rate. In November 2018, Sacramento voters approved a new version of Measure U, extending the tax rate in perpetuity and raising it from a half-cent to a full-cent rate, effective April 1, 2019. This analysis estimates revenues and Measure U-funded expenditures generated by the full one cent tax rate.

Estimated Sales Tax RevenueSource/
Assumptions
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Table A-8A
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Taxable Sales from New Employees (2021$) Item Cultivation Manufacturing Distribution Retail Delivery Total Annual Taxable Sales from New Employees
New Employees
Average Daily Taxable Sales per Employee $10.00
Work Days per Year 240
Total Project Employees at Buildout Table A-2 4,224 457 1,363 709 1,216 7,970 Total Taxable Sales from New Employees $10,137,596 $1,097,560 $3,271,047 $1,702,298 $2,918,568 $19,127,069 Estimated Citywide Capture from New Employees [1] 75% $7,603,197 $823,170 $2,453,285 $1,276,723 $2,188,926 $14,345,302 employee spend
[1] Capture rate estimated by EPS.

Assumptions /
Source
Source: U.S. Department of Labor, Bureau of Labor Statistics; City of Sacramento; EPS.

Taxable Sales from Employee Spending
Sales Tax
Revenue
- Market Support
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Table A-8B
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Taxable Sales from Retail Activity (2021$) Item Assumption
Annual Taxable Sales
FY 2020-21 Business Operating Tax for Retail Sales [1]
Adult Use Revenue $10,842,541
Medical Use Revenue $791,673
Total FY 2020-21 Business Operating Tax for Retail Sales $11,634,215 City Business Operating Tax Rate 4%
Estimated Retail Sales
Adult Use Revenue $271,063,535
Medical Use Revenue $19,791,833
Total Estimated Retail Sales $290,855,368
Estimated Taxable Retail Sales
Adult Use Revenue $271,063,535
Medical Use Revenue [2] $0
Total Estimated Taxable Retail Sales $271,063,535
Percentage Storefront and Delivery (Adult Use Sales)
Storefront Retail Taxable Sales 76% $206,960,469
Delivery Taxable Sales 24% $64,103,066
Total Estimated Taxable Retail Sales $271,063,535
retail sales
Sales Tax
Revenue
- Retail Sales
Annual
Taxable Sales from
Retail Activity
Source: City of Sacramento; EPS.
[1] Reflect FY 2020-21 business operating taxes paid by cannabis business related to retail sale of cannabis for adult use and medical use as provided by the City of Sac
ramento. Includes storefront and delivery sales. This analysis assumes Fiscal Year 2021-22 sales will be consistent with receipts from the previous year. [2] Medical use sales are required to be considered in estimating business operation taxes paid to the City, but are not eligible for sales tax.

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Table A-9
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Cannabis Business Operations Tax (2021$)
Item Cultivation Manufacturing Distribution Retail Delivery Total Fiscal Year 2020/21 Business Operations Tax
Annual Revenues [1] $4,244,347 $954,954 $5,686,002 $10,212,029 $3,133,637 $24,230,969 Percent of Total 18% 4% 23% 42% 13% 100%
Fiscal Year 2021/22 Business Operations Tax [2] $3,617,272 $813,865 $4,845,932 $8,703,268 $2,670,662 $20,651,000 Neighborhood Responsibility Plan Fee [3] $904,318 $203,466 $1,211,483 $2,175,817 $667,666 $5,162,750 transfer
Source: Sacramento County Recorder-Clerk; EPS.
[1]
[2]
[3]
Annual Business Operations Tax
Business operating tax revenues generated by business groups provided by the City of Sacramento. Taxes attributable to microbusinesses have been allocated to other uses proprtional to the size of each business group in the City.

Fiscal year 2021-22 tax revenue estimate based on the approved Fiscal Year 2021-22 Approved Budget for cannabis business operations taxes allocated based on the proportional share of revenues from each business group in the previous year.

Business Operations Tax -
Cannabis
The neighborhood responsibility fee is a 1 percent fee applied to all cannabis activity agreed to as a condition of conditional use permitting. The neighborhood responsibility fee is collected outside of the City General Fund. This analysis estimates the local neighborhood responsibility fee based by applying the 1 percent rate to the all activity generated in each business group. While not commonly enacted, this tax can be paid through in kind activities. This analysis does not assume any in lieu activity is completed.

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Table A-10
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Expenditure-Estimating Procedures (2021$)
City of Sacramento
Approved FY 2021-22 Adjusted
Estimating Reference Expenditures Offsetting Net FY 2021-22 Service FY 2021-22 Adjustment Cost Category Procedure Table [1] (Rounded) Revenues [2] Expenditures Population Avg. Cost Factor [3] Multiplier Formula a b c = a - b d e = c / d f g = e * f
Annual General Fund Expenditures
General Government
Mayor/Council Per Person Served Table A-11 $4,930,917 $0 $4,930,917 0.9% City Manager - General Operations Per Person Served Table A-11 $5,808,464 $0 $5,808,464 1.1% City Attorney Per Person Served Table A-11 $8,088,179 $52,000 $8,036,179 1.5% City Auditor Per Person Served Table A-11 $1,006,603 $0 $1,006,603 0.2% City Clerk Per Person Served Table A-11 $2,224,706 $52,000 $2,172,706 0.4% City Treasurer Per Person Served Table A-11 $1,999,862 $3,496,000 $0 0.0% Finance Per Person Served Table A-11 $8,209,262 $820,000 $7,389,262 1.4% Information Technology Per Person Served Table A-11 $15,516,190 $0 $15,516,190 2.9% Human Resources Per Person Served Table A-11 $4,341,932 $0 $4,341,932 0.8% Subtotal General Government $52,126,115 $4,420,000 $49,202,253 9.2% General Government Cannabis Operations [6] [4] $3,486,200 $0 $3,486,200 0.7% NA NA NA NA Subtotal Government (Non-Cannabis Operations) Per Person Served $48,639,915 $4,420,000 $45,716,053 8.6% 699,373 $65.37 50% $32.68 Convention and Cultural Services Per Capita Table A-11 $1,309,212 $923,000 $386,212 0.1% 515,673 $0.75 50% $0.37 Utilities Per Person Served Table A-11 $122,410 $0 $122,410 0.0% 699,373 $0.18 50% $0.09 Police [7] Per Person Served Table A-11 $205,080,406 $0 $205,080,406 38.5% 699,373 $293.23 100% $293.23 Police - Cannabis Operations [4] Table A-11 $1,260,292 $0 $1,260,292 0.2% NA NA NA NA Fire [7] Per Person Served Table A-11 $158,259,697 $0 $158,259,697 29.7% 699,373 $226.29 100% $226.29 Fire - Cannabis Operations [4] Table A-11 $79,500 $0 $79,500 0.0% NA NA NA NA Youth, Parks, and Community Enrichment [5] NA $1,562,715 $5,018,000 $0 0.0% NA NA NA NA Debt Service [5] NA $16,431,090 $0 $16,431,090 3.1% NA NA NA NA Citywide and Community Support Per Capita Table A-11 $60,358,871 $40,525,000 $19,833,871 3.7% 515,673 $38.46 90% $34.62 Community Development [7] Per Person Served Table A-11 $31,529,203 $0 $31,529,203 5.9% 699,373 $45.08 90% $40.57 Community Development - Cannabis Operations [4] Table A-11 $669,100 $0 $669,100 0.1% NA NA NA NA Public Works Per Person Served Table A-11 $22,224,170 $23,124,000 $0 0.0% 699,373 $0.00 90% $0.00 Total Annual General Fund Expenditures [8] $551,012,781 $74,010,000 $482,854,034 100.0% Total General Operations Expenditure Multipliers
Per Person Served Table A-11 $440,707,769 91.3% 699,373 $630.15 94% $592.87 Per Capita Table A-11 $20,220,083 4.2% 515,673 $39.21 89% $34.99 Total Cannabis Operations $5,495,092 1.1% NA NA NA NA
exp pro
Source: City of Sacramento FY 2021-22 Approved Budget; EPS. [1] Refers to table with expenditure category calculation. [2] Revenues are adjusted by user fees and cost recovery amounts shown in the City's FY 2020-21 Budget. These deductions in ongoing expenditures also are deducted from ongoing revenues, as shown in Table B-1.

If Offsetting Revenues (b) exceeds Expenditures (a) then Adjusted Net Expenditures (c) equals $0. [5] Th
is expenditure category is not expected to be affected by cannabis operations and is not evaluated in this analysis. [6] General government cannabis operations allocation includes expenditures related to cannabis management, city attorney, finance, auditor, and community outreach and education. [8] Excludes General Fund Capital Improvement expenditures. % of Total
[3] Adjustment factors account for fixed costs and expenditures that do not grow and change as new development occurs within the City. [4] This expenditure category is fully attributable to cannabis operations and allocated to business groups on Table A-9. [7] Reflects the portion of departmental expenditures not directly attributable to cannabis operations.

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Table A-11
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Annual Project Expenditures (2020$)
% of Total
Expense Category Cultivation Manufacturing Distribution Retail Delivery Total at Buildout Cannabis Operations Assumptions by Business Group
Total Employees Table A-2 4,224 457 1,363 709 1,216 7,970 Total Persons Served Table A-11 2,112 229 681 355 608 3,985 Share of Business Activity [1] Table A-9 18% 4% 23% 42% 13% 100% Annual General Fund Expenditures
General City Operations [2] Table A-10 $592.87 $1,252,136 $135,564 $404,020 $210,258 $360,484 $2,001,978 26.7% Cannabis Operations
Cannabis Management Table A-10 $247,889 $55,774 $332,089 $596,429 $183,019 $1,415,200 18.9% City Attorney Table A-10 $184,621 $41,539 $247,330 $444,203 $136,307 $1,054,000 14.1% Community Development Table A-10 $117,201 $26,370 $157,010 $281,989 $86,530 $669,100 8.9% Finance Table A-10 $17,674 $3,977 $23,677 $42,524 $13,049 $100,900 1.3% Fire Table A-10 $13,925 $3,133 $18,655 $33,505 $10,281 $79,500 1.1% Police Table A-10 $220,755 $49,669 $295,738 $531,144 $162,986 $1,260,292 16.8% Auditor Table A-10 $29,094 $6,546 $38,977 $70,002 $21,481 $166,100 2.2% Community Outreach and Education Table A-10 $131,372 $29,558 $175,994 $316,084 $96,993 $750,000 10.0% Total Cannabis Operations Expenditures $962,532 $216,564 $1,289,470 $2,315,881 $710,645 $5,495,092 73.3% Total Annual General Fund Expenditures $549,711 $123,682 $736,429 $1,322,622 $405,856 $7,497,070 100.0% expenditures
Source: EPS.
[1] Share of business activity based on the estmated proportional share of annual revenues for each business group as shown on Table A-9. [2] Represents all City General Fund operations assumed to be impacted by cannabis business operations in excess of City operations dedicated specifically to cannabis operations. Refer to Table A-10 for details.

Reference
Table
Annual Net ExpendituresPer Person
Served
Multiplier
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A-24
Table A-12
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Estimated Assessed Value of Cannabis Businesses within the City Item Cultivation Manufacturing Distribution Retail Delivery Total Building Square Footage 1,583,999 205,793 204,440 106,394 121,607 2,222,233 Estimated Assessed Value of Cannabis Uses
Assessed Value per Square Foot
Secured Value $150 $150 $150 $250 $250
Unsecured Value $50 $50 $0 $0 $0
Total Value per Square Foot $200 $200 $150 $250 $250
Estimated Assessed Value
Secured Value $237,599,903 $30,868,889 $30,666,065 $26,598,405 $30,401,750 $356,135,012 Unsecured Value $79,199,968 $10,289,630 $0 $0 $0 $89,489,597 Total Assessed Value $316,799,871 $41,158,519 $30,666,065 $26,598,405 $30,401,750 $445,624,609 av
Source: City of Sacramento; EPS.

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Table A-13
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Summary of Annual Economic Impacts of All Cannabis Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 7,970 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $1,130,140,000 $291,110,000 $205,900,000 $1,627,150,000 Income [2] $357,060,000 $146,280,000 $102,940,000 $606,280,000 Total Sacramento County Output $1,487,200,000 $437,390,000 $308,840,000 $2,233,430,000 Sacramento County Employment
(Annual Average) [3] 7,969 2,608 1,841 12,418
all eia
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

All Activity
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Table A-14
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Annual Economic Impacts of the Cultivation Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 4,224 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $857,210,000 $168,620,000 $133,910,000 $1,159,740,000 Income [2] $238,180,000 $85,420,000 $66,970,000 $390,570,000 Total Sacramento County Output $1,095,390,000 $254,040,000 $200,880,000 $1,550,310,000 Sacramento County Employment
(Annual Average) [3] 4,224 1,583 1,198 7,005
cultivation
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Cultivation
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Table A-15
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Annual Economic Impacts of Manufacturing Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 457 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $147,050,000 $37,130,000 $13,450,000 $197,630,000 Income [2] $12,040,000 $21,960,000 $6,710,000 $40,710,000 Total Sacramento County Output $159,090,000 $59,090,000 $20,160,000 $238,340,000 Sacramento County Employment
(Annual Average) [3] 457 312 120 889
man
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Manufacturing
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Table A-16
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Annual Economic Impacts of Distribution Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 1,363 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $67,710,000 $51,700,000 $27,050,000 $146,460,000 Income [2] $46,460,000 $23,320,000 $13,510,000 $83,290,000 Total Sacramento County Output $114,170,000 $75,020,000 $40,560,000 $229,750,000 Sacramento County Employment
(Annual Average) [3] 1,363 443 241 2,047
distribution
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Distribution
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Table A-17
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Annual Economic Impacts of Retail Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 709 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $21,430,000 $12,400,000 $11,600,000 $45,430,000 Income [2] $22,240,000 $5,740,000 $5,800,000 $33,780,000 Total Sacramento County Output $43,670,000 $18,140,000 $17,400,000 $79,210,000 Sacramento County Employment
(Annual Average) [3] 709 99 104 912
retail
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Retail
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Table A-18
City of Sacramento Cannabis Study
Fiscal and Economic Impact Analysis
Detailed Annual Economic Impacts of Delivery Activity (Rounded 2021$) Activity/Impact Categories Source Direct Indirect Induced Key Input
Ongoing Project Full Time Equivalent (FTE) Employees Table A-2 1,216 Annual Ongoing Operating Impacts
Sacramento County Output [1]
Industry Output (excl. Income) $36,740,000 $21,260,000 $19,890,000 $77,890,000 Income [2] $38,140,000 $9,840,000 $9,950,000 $57,930,000 Total Sacramento County Output $74,880,000 $31,100,000 $29,840,000 $135,820,000 Sacramento County Employment
(Annual Average) [3] 1,216 171 178 1,565
delivery
Source: IMPLAN, 2019 Dataset; City of Sacramento; EPS.
[2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Delivery
Total
Annual
Ongoing
Impacts
Impact Type
[1] Analysis based on Sacramento County data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment. Employment includes both full-time and part-time workers.

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Appendix A
A-32 Economic & Planning Systems, Inc. (EPS)

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APPENDIX B:

Initiatives in Other States

Appendix B
Economic & Planning Systems, Inc. (EPS) B-1
Initiatives in Other States
Highlights of recent state legalization efforts that have prioritized social equity at the front end of their legalization regulation efforts regarding ownership, taxation, and spending are summarized below for New York, Illinois, and Connecticut.

New York
 Retailers, microbusinesses, and delivery licensees are allowed to deliver to consumers but cultivators are not. Only one delivery license per entity and no more than 25 full time employees.
 Sets a goal of 50% of licenses for equity applicants. Existing medical cannabis businesses can convert a maximum of three of their existing storefronts if they pay a one time fee to fund social and economic equity and incubator assistance.  Social consumption sites and delivery services are permitted.  Proposes a hybrid tax with both a potency based tax on distributors of 0.5 cents per milligram of THC flower, 0.8 cents per milligram of THC for concentrates and 3 cents per milligram of THC for edibles as well as a 9% state tax and a 4% local point of sale tax.
 Governor Kathy Hochul has pledged to create a $200 million public-private fund for social equity applicants looking to enter the adult-use cannabis marketplace in New York.
 Cities towns and villages may opt out of retail dispensaries or on-site consumption licenses by passing local laws up to nine months after the legislation.

Illinois
 Set license types to include retail dispensaries, infusers, transporters, craft growers with between 5,000 and 14,000 square feet of canopy, and cultivation centers growing up to 210,000 square feet of canopy space. Craft growers can also hold infuser and dispensary licenses in the same facility.
 Taxes include a 7% wholesale tax on cultivation centers and craft growers. Retail taxes are directly related to potency and will include a 10% tax on flower or products with less than 35% THC, 20% tax on infused and edible products, and a 25% tax on any product with a THC concentration higher than 35%. The state sales tax of 6.25% and local sales taxes of up to 3.5% also apply. The retail point of sale taxes will range from 19.55% to 34.75% not including the wholesale tax.

Appendix B
B-2 Economic & Planning Systems, Inc. (EPS)
 Tax revenues will be distributed with 2% going to public education and safety campaigns, 8% to local government funds for prevention and training of law enforcement, 25% to the Recover, Reinvest and Renew (R3) program. 3R grants will fund programs in Illinois communities that have been harmed by violence, excessive incarceration, and economic disinvestment and fund programs including civil legal aid, economic development, reentry, violence prevention, and youth development. 20% of the taxes will go to mental health services and substance abuse programs, 10% to pay unpaid bills, and 35% to the general fund.
 The social equity program provides for expungement of convictions, extra points in license applications for social equity applicants, as well as developing a $30 million cannabis business development fund to provide financial start up assistance. Local colleges will also be able to obtain licenses for training programs to help prepare residents for cannabis industry-related jobs. The Department of Agriculture and Community College board will create up to eight pilot programs to train students to work in the legal industry with at least five of the eight programs for schools in which at least 50% of the students are low income.

Connecticut
 The Department of Consumer Protection (DCP) will issue nine types of cannabis licenses: retailer, hybrid retailer (which sells both adult-use and medical cannabis), cultivator (which cultivate 15,000 square feet or more), micro-cultivator (which start between 2,000 and 10,000 square feet), product manufacturer, food and beverage manufacturer, product packager, delivery service, and transporter.  DCP must reserve 50% of the maximum number of applications that must be considered for eligible license types for social equity applicants. The vast majority of new licenses will be issued by lottery to provide an equal opportunity to all who qualify and avoid requiring large sums of money to apply.  The state will create $50 million in bonding for initial funding for start-up capital for social equity applicants, the cannabis business accelerator program, and workforce training developed by the Social Equity Council.
 Beginning on July 1, 2023, 60% to 75% of the cannabis excise tax revenue will be directed to the Social Equity and Innovation Fund. Social Equity and Innovation Fund money can be used to promote social equity in relation to access to capital for businesses, funding workforce education, and funding for community investments.  In addition to standard sales tax, the state imposes an excise tax based on potency at the point of retail sale. It exempts medical cannabis. The rate is: $0.00625 per milligram of THC in flower cannabis, $0.0275 per milligram of THC in edibles, and $0.009 per milligram of THC for other cannabis products.

Appendix B
Economic & Planning Systems, Inc. (EPS) B-3
 Until June 30, 2023, 100% of the excise tax would be directed to the General Fund.

Starting on July 1, 2023 and thereafter, 25% of the excise tax would go to the Prevention and Recovery Services Fund. From July 1, 2023 until June 30, 2026, 60% of the excise tax would go to the Social Equity and Innovation Fund. On July 1, 2026, that would increase to 65%. Beginning on July 1, 2028, it would increase again and would remain at 75%. The remainder of the tax (starting at 15%, ending at 0%) would go to the General Fund.
 The state imposes a 3% point-of-sale tax that goes to the host municipality for specific purposes, such as re-entry services, mental health or addiction services, youth services bureaus, and streetscape improvements near cannabis retailers.

Appendix B
B-4 Economic & Planning Systems, Inc. (EPS)

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APPENDIX C:

Comparison of Cannabis Land Use Regulations:

Sacramento, Oakland, Long Beach, Seattle

Sacramento Comprehensive Cannabis Study
Case Study: Land Use Regulations
City: Sacramento
Land Use Regulations
Cultivation
Distribution (Large Scale)
Manufacturing
Storefront Dispensary (Retail)
Non Storefront Delivery (Retail)
Microbusiness (Vertical Integration)
Testing Labs
Consumption lounges/alternate gathering venues Consumption lounges are currently not allowed. An illegal outdoor smoking gathering event called Club 1130 was shut down. There are a number of cannabis friendly hotels and B&Bs, but no recent evidence of private smoking clubs.

Use Permit Required, Zones C2, C4, M1, M1S, M2, M2S,
MIP, MRD, M-T.

Additional conditions: All uses are subject to Scacramento's buffer distances to sensitive receptors. No cannabis use can be permitted within 600 feet of K-12 Public and Private Schools other than Private Home Schools. Use must be approved by the planning and design commission where the production site is within 600 feet of: A park identified as a neighborhood park or community park in the city’s most recently adopted Parks and Recreation Master Plan; or a park not yet identified in the city’s most recently adopted Parks and Recreation Master Plan.

Cultivation and manufacturing uses are subject to a 1/2 mile proximity limitation the center of light rail platforms, and manufactures in certain zones are restricted to non-volitle extraction methods.

Within the area bounded by Power Inn Road to the west, Folsom Boulevard to the north, and the city limits to the east and south, there is a cap on cannabis production facilities totalling 2.5 million square feet.

Use Permit Required, Zones A, C2, C4, M1, M1S, M2, and
M2S, M-T. Class A < 5K, Class B < 10K, Class C < 22K
Use Permit Required, Zones C2, C4, M1, M1S, M2, and
M2S, MIP, MRD, M-T. Class D1- up to $5M, D2 - up to
$20M, D3 - over $20M
Use Permit Required, Zones C2, C4, M1, M1S, M2, M2S,
MIP, MRD, M-T. Class D1- up to $5M, D2 - up to $20M, D3 - over $20M
Use Permit Required, Zones C-2, C-4, M-1, M-1(S), M-2,
and M-2(S), M-T and SC
Use Permit Required, Zones C2, C4, M1, M1S, M2, and M2S Use Permit Required, Zones C2, C4, M1, M1S, M2, M2s,

MIP, MRD
Appendix C
Sacramento Comprehensive Cannabis Study
Case Study: Land Use Regulations
City: Oakland
Land Use Regulations
Cultivation
Distribution (Large Scale)
Manufacturing
Storefront Dispensary (Retail)
Non Storefront Delivery (Retail)
Microbusiness (Vertical Integration)
Testing Labs
Consumption lounges/alternate gathering venues
Dependent on what types of businesses are in the vertical integration.

Proposed cultivation, distribution, testing or transporting locations shall be in areas where "light manufacturing
industrial," "R&D," or their equivalent use, is permitted by right.

See Cultivation.

Manufacturing, packaging and infusion of cannabis products using nonvolatile solvents shall be in areas where "custom manufacturing industrial," or its equivalent use, is permitted by right.

Must be located in a commercial or industrial zone, or its equivalent as may be amended, of the City.

Must be located in a Commercial or Industrial Zone,
excluding the CN Neighborhood Center Commercial Zones
and the D-BV Broadway Valdez District Commercial Zones.

See Cultivation
Oakland allows existing dispensaries to apply for a second on-site consumption permit. Covid-19 regulations stopped all indoor smoking, and some businesses have failed. The historic Park theater has a dispensary operating and is preparing an entertainment, food and smoking venue.

Additional Conditions:

All uses are subject to Oakland's buffer distances to sensitive receptors. No cannabis use can be permitted within 600 feet of K-12 Public and Private Schools other than Private Home Schools. Cultivation, manufacturing and distribution can be associated with a dispensary provided the dispensary is located in a zone compatible with the other uses and they do not face a public retail street or impede retail activity.

There is little in the Oakland Municipal Code about additional buffers to sensitive receptors such as community centers, parks, and adult treatment centers.

Appendix C
Sacramento Comprehensive Cannabis Study
Case Study: Land Use Regulations
City: Long Beach
Land Use Regulations
Cultivation
Distribution (Large Scale)
Manufacturing
Storefront Dispensary (Retail)
Non Storefront Delivery (Retail)
Microbusiness (Vertical Integration)
Testing Labs
Consumption lounges/alternate gathering venues
Allowed in the commercial and light industrial zones and allowed with an AUP in the medium and general industrial zones.

Allowed in light and medium industrial zones, and with an administrative use permit (AUP) in general industrial areas, not allowed in residential, institutional, park, commercial and port zones.

Self-Distribution is an allowed use in the light, medium, and general industrial zones. Distribution is allowed with an AUP in the same 3 zones. Both are not allowed in all other zones.

Manufacturing is an allowed use in the light, medium, and general industrial zones. It is not allowed in all other zones.

Allowed in commercial and light industrial districts and with a conditional use permit (CUP) in the medium and light
industrial zones. They are not allowed in all other zones.

Recently approved a retail dispensary in a mixed use
building with residential in downtown. Staff is currently developing an ordinance for 8 new equity storefront
dispensaries.

Currently not allowed. Staff is developing an ordinance for non-storefront delivery based on feasibility study.

Dependent on what types of businesses in the vertical
integration.

The City of Long Beach does not allow smoking in any public venue or dispensaries.

Additional conditions: Long Beach is currently revising their instituted buffers from schools, beaches and other dispensaries (1,000 feet) as well as parks, daycares and libraries (600 feet). The City is looking to expand the green zone by reducing the school buffer to 600 feet, which is the distance required by state law, and eliminating the buffers for parks and beaches unless they have a playground.

Appendix C
Sacramento Comprehensive Cannabis Study
Case Study: Land Use Regulations
City: Seattle
Land Use Regulations
The ordinance does,however, impose a size limit on indoor agricultural operations in industrial areas, but this applies to all agricultural uses in industrial areas, not just marijuana production (§23.50.012, Table A, Note 14).

Additional conditions: In 2015, the City Council revised the State buffer requirements to include the following:

1. Any lot line of any major marijuana activity must be at least 1,000 feet from any elementary or secondary school, or playground.

2. Any lot line of any major marijuana activity including retail sales of marijuana products must be at least 500 feet from any child care, gaming arcade, library, public park, public transit station, or recreation center.

3. Any lot line of any major marijuana activity not including retail sales of marijuana products must be at least 250 feet from any child care, gaming arcade, library, public park, public transit station, or recreation center.

4. Any lot line of any major marijuana activity must be at least 350 feet from any other major marijuana activity and no more than 2 major marijuana activities can be within 1,000 feet of each other.

The Seattle Municipal Code Chapter 23.42.058 - Marijuana lays out the requirements for locating "major marijuana activity"
In 2013, the city amended its zoning ordinance to specify where larger-scale marijuana business activities could locate (§23.42.058). The specific activities include processing, selling, delivery, and the creation of marijuana-infused products and usable marijuana. While these activities are prohibited in residential, neighborhood commercial, certain downtown, and several historic preservation and other special- purpose districts, the zoning ordinance does not require a land-use permit to specifically conduct marijuana-related activities in industrial, most commercial, and a few downtown districts. For example, an applicant who wishes to open a marijuana retail store or an agricultural
application is required to get the applicable permit, but is not required to disclose that the use is marijuana related.

Appendix C

APPENDIX D:

Comparison of City of Sacramento and
State of California Cannabis Regulations

Appendix D
Comparison of Selected City of Sacramento and State of California Regulations

Definition of Reportable Ownership and Rights of Transference City of Sacramento
(5.150.050)
Cannabis business permits issued pursuant to
this chapter are not property and have no
value. Cannabis business permits may not be
transferred, sold, assigned or bequeathed
expressly or by operation by law. Any attempt
to directly or indirectly transfer a cannabis
business permit shall be unlawful and void, and
shall automatically revoke the permit. (Ord.
2017-0046 § 1)

State of California
The business may continue to operate under
the active license while the Department
reviews the qualifications of the new owner(s)
in accordance with the Act and these
regulations to determine whether the change
would constitute grounds for denial of the
license, if at least one existing owner is not
transferring his or her ownership interest and
will remain as an owner under the new
ownership structure. If all owners will be
transferring their ownership interest, the
business shall not operate under the new
ownership structure until a new license
application has been submitted to and
approved by the Department, and all
application and license fees for the new
application have been paid.

City of Sacramento
(5.150.055)
A. No person shall transfer, sell, assign, or
bequeath any ownership interest in any
storefront cannabis dispensary permittee to
another person. B. Any transfer, sale,
assignment, or bequest of any ownership
interest is unlawful and void. C. This section
remains in effect until May 11, 2022. (Ord.
2021-0028 § 1; Ord. 2020-0040 § 1; Ord.
2019-0041 § 2)

State of California
(A) A change in ownership occurs when a new
person meets the definition of owner in section
15003 of this division. (B) A change in
ownership does not occur when one or more
owners leave the business by transferring their
ownership interest to the other existing
owner(s). (2) In cases where one or more
owners leave the business by transferring
their ownership interest to the other existing
owner(s), the owner or owners that are
transferring their interest shall provide a
signed statement to the Department
confirming that they have transferred their
interest within 14 calendar days of the change.

Appendix D
Comparison of Selected City of Sacramento and State of California Regulations

Definition of Reportable Ownership and Rights of Transference (continued) City of Sacramento
(5.150.055)
A. A cannabis business shall provide the city with
names and addresses of all of the following
interested parties: 1. Person with an aggregate
ownership interest of 20% or more in the entity
engaging in the cannabis business, unless the
interest is solely a security, lien, or encumbrance.

2. The chief executive officer and the members of
the board of directors of the entity engaging in
the cannabis business. 3. The managers of the
cannabis business. 4. Person who delivers
cannabis or cannabis products for the cannabis
business. 5. Person who transports cannabis or
cannabis products for the cannabis business.

State of California
(a) An applicant for a commercial cannabis license
or a licensee shall disclose all financial interest
holders. A financial interest holder of the
commercial cannabis business includes all of
the following, except as provided in subsection (b):
(1) A person with an aggregate ownership
interest of less than 20 percent. (2) A person
providing a loan to the commercial cannabis
business. (3) A person entitled to receive 10
percent or more of the profits of the commercial
cannabis business, including: (A) An employee
who has entered into a profit share plan with the
commercial cannabis business. (B) A landlord who
has entered into a lease agreement with the
commercial cannabis business for a share of the
profits. (C) A consultant who is providing
services to the commercial cannabis business for a
share of the profits. (D) A person acting as
an agent, such as an accountant or attorney, for
the commercial cannabis business for a share of
the profits. (E) A broker who is engaging in
activities for the commercial cannabis business
for a share of the profits. (F) A salesperson who
earns a commission. (b) Financial interest
holders do not include any of the following: (1) A
bank or financial institution whose interest
constitutes a loan; (2) Persons whose only financial
interest in the commercial cannabis business is
through an interest in a diversified mutual fund,
blind trust, or similar instrument; (3) Persons
whose only financial interest is a security interest,
lien, or encumbrance on property that will be used
by the commercial cannabis business; and (4)
Persons who hold a share of stock that is less than
10 percent of the total shares in a publicly traded or
privately held company.

Appendix D
Comparison of Selected City of Sacramento and State of California Regulations

Maintaining Business Records
City of Sacramento

5.150.160
A. A cannabis business shall maintain the
following business records in printed format for
at least three years on the site and shall
produce them to the city within 24 hours after
receipt of the city’s request:

1. The name, address, and telephone numbers
of the owner and landlord of the property. 2.

The name, date of birth, address, and
telephone number of each manager and staff
of the cannabis business; the date each was
hired; and the nature of each manager’s and
staff’s participation in the cannabis business. 3.

A written accounting of all income and
expenditures of the cannabis business,
including, but not limited to, cash and in-kind
transactions. 4. A copy of the cannabis
business’ commercial general liability insurance
policy and all other insurance policies related
to the operation of the business. 5. A copy of
the cannabis business’ most recent year’s
financial statement and tax return. 6. An
inventory record documenting the dates and
amounts of cannabis received at
the site, the daily amounts of cannabis on the
site, and the daily amounts of cannabis sold,
distributed, and transported from the site. 7.

The name, address, and telephone numbers of
the owners and officers of the cannabis
business; and the nature of the ownership
interest in, and control of, the cannabis
business. B. A cannabis business shall report
any loss, damage, or destruction of these
records to the city manager within 24 hours of
the loss, damage, or destruction. (Ord. 2019-
0041 § 3; Ord. 2017-0046 § 1)

5.150.525 Delivery of cannabis.

H. A cannabis business shall maintain the
information described in subsection D for at
least three years on the site and shall produce
the information to the city upon request. (Ord.
2020-0004 § 17; Ord. 2019-0002 § 2; Ord.
2017-0002 § 2; Ord. 2017-0060 § 3)
State of California
(a) Licensees must keep and maintain records
in connection with the licensed commercial
cannabis business. Records must be kept for at
least seven years from the date of creation,
unless a shorter time is specified. Records
include, but are not limited to: (1) Financial
records including, but not limited to, bank
statements, sales invoices, receipts, tax
records, and all records required by the
California Department of Tax and Fee
Administration (formerly Board of Equalization)
under title 18, California Code of Regulations,
sections 1698 and 4901. (2) Personnel
records, including each employee’s full name,
Social Security number or individual taxpayer
identification number, date employment
begins, and date of termination of
employment, if applicable. (3 Training records
including, but not limited to, the content of the
training provided and the names of the
employees who received the training. (4)
Contracts regarding commercial cannabis
activity. (5) Permits, licenses, and
other local authorizations to conduct the
licensee’s commercial cannabis activity. (6) All
other documents prepared or executed by an
owner or their employees or assignees in
connection with the licensed commercial
cannabis business. (7) Records required by the
Act or this division. (b) Records must be kept
in a manner that allows the records to be
produced for the Department in either
hardcopy or electronic form. (c) Records must
be legible and accurate. No person may
intentionally misrepresent or falsify records.
(d) Records must be stored in a secured area
where the records are protected from debris,
moisture, contamination, hazardous waste,
and theft.

Appendix D
Comparison of Selected City of Sacramento and State of California Regulations

Limits on Delivery Vehicle Inventory
City of Sacramento

5.150.525 Delivery of cannabis.

B. No person delivering cannabis or cannabis
products shall possess more than $3,000
worth of cannabis and cannabis products at
any time.

State of California
(a) A licensed retailer’s delivery employee shall
not carry cannabis goods in the delivery
vehicle with a value in excess of $5,000 at any
time. The value of cannabis goods carried in
the delivery vehicle for which a delivery order
was not received and processed by the
licensed retailer prior to the delivery employee
departing from the licensed premises may not
exceed $3,000.

APPENDIX E:

Real Estate Market Analysis Support Figures

Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 2
Blumenfeld & Joellis Vicinity Industrial Occupancy & Rent Blumenfeld & Joellis Vicinity Flex Occupancy & Rent Blumenfeld & Joellis Vicinity Office Occupancy & Rent Blumenfeld & Joellis Vicinity Retail Occupancy & Rent 500,000 0 0 0
District 2
1750 Iris Ave Vicinity Industrial Occupancy & Rent 1750 Iris Ave Vicinity Flex Occupancy & Rent 1750 Iris Ave Vicinity Office Occupancy & Rent 1750 Iris Ave Vicinity Retail Occupancy & Rent 50,000 0 0 0
District 2
1500 El Camino Ave Vicinity Industrial Occupancy & Rent 1500 El Camino Ave Vicinity Flex Occupancy & Rent 1500 El Camino Ave Vicinity Office Occupancy & Rent 1500 El Camino Ave Vicinity Retail Occupancy & Rent 150,000 0 30,000 20,000
100%
100%
100%
100%
78%
78%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
Blumenfeld & Joellis Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
87%
92%
92%
100%
100%
97%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
500,000 SF
600,000 SF
700,000 SF
800,000 SF
900,000 SF
1,000,000 SF
1,100,000 SF
2015 2016 2017 2018 2019 2020 2021
Blumenfeld & Joellis Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
Blumenfeld & Joellis Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
Blumenfeld & Joellis Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1750 Iris Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
76%
69%
71%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
2015 2016 2017 2018 2019 2020 2021
1750 Iris Ave Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1750 Iris Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1750 Iris Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
2015 2016 2017 2018 2019 2020 2021
1500 El Camino Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
100%
96%
100%
93%
100%
96%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
300,000 SF
320,000 SF
2015 2016 2017 2018 2019 2020 2021
1500 El Camino Ave Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
45%
74%
87%
73%
92%
95%
97%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
2015 2016 2017 2018 2019 2020 2021
1500 El Camino Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
2015 2016 2017 2018 2019 2020 2021
1500 El Camino Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 2
El Monte & Colfax Vicinity Industrial Occupancy & Rent El Monte & Colfax Vicinity Flex Occupancy & Rent El Monte & Colfax Vicinity Office Occupancy & Rent El Monte & Colfax Vicinity Retail Occupancy & Rent 130,000 10,000 20,000 60,000
District 2
El Camino & Albatross Vicinity Industrial Occupancy & Rent El Camino & Albatross Vicinity Flex Occupancy & Rent El Camino & Albatross Vicinity Office Occupancy & Rent El Camino & Albatross Vicinity Retail Occupancy & Rent 110,000 0 10,000 40,000
District 2
2550 Boxwood Vicinity Industrial Occupancy & Rent 2550 Boxwood Vicinity Flex Occupancy & Rent 2550 Boxwood Vicinity Office Occupancy & Rent 2550 Boxwood Vicinity Retail Occupancy & Rent 0 0 0 40,000
100%
100%
100%
100%
86%
57%
57%
$12.00
$12.50
$13.00
$13.50
$14.00
$14.50
$15.00
$15.50
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
El Monte & Colfax Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
92%
99%
100%
98%
99%
85%
98%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
2015 2016 2017 2018 2019 2020 2021
El Monte & Colfax Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
95%
94%
94%
94%
94%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
2015 2016 2017 2018 2019 2020 2021
El Monte & Colfax Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
90%
91%
100%
99%
100%
98%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
2015 2016 2017 2018 2019 2020 2021
El Monte & Colfax Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
6,000 SF
7,000 SF
2015 2016 2017 2018 2019 2020 2021
El Camino & Albatross Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
99%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
2015 2016 2017 2018 2019 2020 2021
El Camino & Albatross Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
24%
17%
34%
100%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
2015 2016 2017 2018 2019 2020 2021
El Camino & Albatross Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
100%
91%
100%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
2015 2016 2017 2018 2019 2020 2021
El Camino & Albatross Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
0%
50%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
6,000 SF
7,000 SF
8,000 SF
9,000 SF
2015 2016 2017 2018 2019 2020 2021
2550 Boxwood Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
2015 2016 2017 2018 2019 2020 2021
2550 Boxwood Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
1%
1%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
2550 Boxwood Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
100%
95%
90%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
2015 2016 2017 2018 2019 2020 2021
2550 Boxwood Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 2
2580 Grand Ave Vicinity Industrial Occupancy & Rent 2580 Grand Ave Vicinity Flex Occupancy & Rent 2580 Grand Ave Vicinity Office Occupancy & Rent 2580 Grand Ave Vicinity Retail Occupancy & Rent 40,000 0 0 0
District 1
135 Main Vicinity Industrial Occupancy & Rent 135 Main Vicinity Flex Occupancy & Rent 135 Main Vicinity Office Occupancy & Rent 135 Main Vicinity Retail Occupancy & Rent 410,000 20,000 0 0
District 2
199 Harris Ave Vicinity Industrial Occupancy & Rent 199 Harris Ave Vicinity Flex Occupancy & Rent 199 Harris Ave Vicinity Office Occupancy & Rent 199 Harris Ave Vicinity Retail Occupancy & Rent 210,000 30,000 0 0
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2580 Grand Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
2015 2016 2017 2018 2019 2020 2021
2580 Grand Ave Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2580 Grand Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2580 Grand Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
56%
100%
100%
100%
100%
100%
100%
$8.40
$8.60
$8.80
$9.00
$9.20
$9.40
$9.60
$9.80
$10.00
$10.20
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
2015 2016 2017 2018 2019 2020 2021
135 Main Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
93%
100%
100%
94%
93%
94%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
$10.00
400,000 SF
450,000 SF
500,000 SF
550,000 SF
600,000 SF
650,000 SF
700,000 SF
750,000 SF
800,000 SF
850,000 SF
900,000 SF
2015 2016 2017 2018 2019 2020 2021
135 Main Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
135 Main Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
135 Main Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
81%
85%
90%
95%
93%
93%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
2015 2016 2017 2018 2019 2020 2021
199 Harris Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
95%
100%
94%
94%
91%
98%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
200,000 SF
250,000 SF
300,000 SF
350,000 SF
400,000 SF
450,000 SF
2015 2016 2017 2018 2019 2020 2021
199 Harris Ave Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
199 Harris Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
500 SF
1,000 SF
1,500 SF
2,000 SF
2,500 SF
3,000 SF
2015 2016 2017 2018 2019 2020 2021
199 Harris Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 4
241 N 10th St Vicinity Industrial Occupancy & Rent 241 N 10th St Vicinity Flex Occupancy & Rent 241 N 10th St Vicinity Office Occupancy & Rent 241 N 10th St Vicinity Retail Occupancy & Rent 240,000 80,000 0 0
District 2
241 Lathrop Way Vicinity Industrial Occupancy & Rent 241 Lathrop Way Vicinity Flex Occupancy & Rent 241 Lathrop Way Vicinity Office Occupancy & Rent 241 Lathrop Way Vicinity Retail Occupancy & Rent 210,000 70,000 0 0
District 2
1955 Railroad Dr Vicinity Industrial Occupancy & Rent 1955 Railroad Dr Vicinity Flex Occupancy & Rent 1955 Railroad Dr Vicinity Office Occupancy & Rent 1955 Railroad Dr Vicinity Retail Occupancy & Rent 160,000 0 0 0
93%
78%
87%
89%
90%
89%
94%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
2015 2016 2017 2018 2019 2020 2021
241 N 10th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
95%
92%
100%
100%
100%
100%
$-
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
400,000 SF
450,000 SF
500,000 SF
550,000 SF
2015 2016 2017 2018 2019 2020 2021
241 N 10th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
2015 2016 2017 2018 2019 2020 2021
241 N 10th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
95%
95%
95%
95%
95%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
500 SF
1,000 SF
1,500 SF
2,000 SF
2,500 SF
3,000 SF
3,500 SF
4,000 SF
4,500 SF
2015 2016 2017 2018 2019 2020 2021
241 N 10th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
89%
94%
95%
95%
91%
88%
97%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
2015 2016 2017 2018 2019 2020 2021
241 Lathrop Way Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
97%
99%
94%
99%
100%
83%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
400,000 SF
450,000 SF
2015 2016 2017 2018 2019 2020 2021
241 Lathrop Way Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
50%
50%
100%
50%
100%
100%
100%
$11.50
$12.00
$12.50
$13.00
$13.50
$14.00
$14.50
$15.00
$15.50
$16.00
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
2015 2016 2017 2018 2019 2020 2021
241 Lathrop Way Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
241 Lathrop Way Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1955 Railroad Dr Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
73%
73%
90%
100%
100%
74%
79%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
$18.00
$20.00
0 SF
50,000 SF
100,000 SF
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
2015 2016 2017 2018 2019 2020 2021
1955 Railroad Dr Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1955 Railroad Dr Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1955 Railroad Dr Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 2
1783 Tribute Rd Vicinity Industrial Occupancy & Rent 1783 Tribute Rd Vicinity Flex Occupancy & Rent 1783 Tribute Rd Vicinity Office Occupancy & Rent 1783 Tribute Rd Vicinity Retail Occupancy & Rent 0 80,000 120,000 10,000
District 3
2201 Northgate Bl Vicinity Industrial Occupancy & Rent 2201 Northgate Bl Vicinity Flex Occupancy & Rent 2201 Northgate Bl Vicinity Office Occupancy & Rent 2201 Northgate Bl Vicinity Retail Occupancy & Rent 0 0 0 70,000
District 4
3015 H St Vicinity Industrial Occupancy & Rent 3015 H St Vicinity Flex Occupancy & Rent 3015 H St Vicinity Office Occupancy & Rent 3015 H St Vicinity Retail Occupancy & Rent 0 0 40,000 0
80%
94%
95%
90%
84%
88%
91%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
2015 2016 2017 2018 2019 2020 2021
1783 Tribute Rd Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
1783 Tribute Rd Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
86%
85%
81%
82%
90%
93%
89%
$18.00
$18.50
$19.00
$19.50
$20.00
$20.50
$21.00
$21.50
$22.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
2015 2016 2017 2018 2019 2020 2021
1783 Tribute Rd Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
85%
92%
92%
100%
100%
96%
96%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
2015 2016 2017 2018 2019 2020 2021
1783 Tribute Rd Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2201 Northgate Bl Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2201 Northgate Bl Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2201 Northgate Bl Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
88%
90%
93%
93%
93%
93%
93%
$12.00
$12.50
$13.00
$13.50
$14.00
$14.50
$15.00
$15.50
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
160,000 SF
2015 2016 2017 2018 2019 2020 2021
2201 Northgate Bl Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3015 H St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3015 H St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
90%
94%
97%
97%
96%
92%
95%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
2015 2016 2017 2018 2019 2020 2021
3015 H St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
2015 2016 2017 2018 2019 2020 2021
3015 H St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 4
1900 19th St Vicinity Industrial Occupancy & Rent 1900 19th St Vicinity Flex Occupancy & Rent 1900 19th St Vicinity Office Occupancy & Rent 1900 19th St Vicinity Retail Occupancy & Rent 20,000 0 30,000 60,000
District 4
2100 29th St Vicinity Industrial Occupancy & Rent 2100 29th St Vicinity Flex Occupancy & Rent 2100 29th St Vicinity Office Occupancy & Rent 2100 29th St Vicinity Retail Occupancy & Rent 0 0 10,000 0
District 4
1236 C St Vicinity Industrial Occupancy & Rent 1236 C St Vicinity Flex Occupancy & Rent 1236 C St Vicinity Office Occupancy & Rent 1236 C St Vicinity Retail Occupancy & Rent 40,000 20,000 0 0
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
50,000 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
88%
89%
100%
100%
96%
61%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
99%
99%
97%
95%
96%
96%
$50.00
$51.00
$52.00
$53.00
$54.00
$55.00
$56.00
$57.00
$58.00
$59.00
$60.00
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
2015 2016 2017 2018 2019 2020 2021
1900 19th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2100 29th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
6,000 SF
2015 2016 2017 2018 2019 2020 2021
2100 29th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
2100 29th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
74%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
2015 2016 2017 2018 2019 2020 2021
2100 29th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
29%
29%
29%
29%
83%
29%
29%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
2015 2016 2017 2018 2019 2020 2021
1236 C St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
85%
100%
100%
100%
100%
85%
85%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
2015 2016 2017 2018 2019 2020 2021
1236 C St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1236 C St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
93%
83%
83%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
1236 C St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 4
1716 J St Vicinity Industrial Occupancy & Rent 1716 J St Vicinity Flex Occupancy & Rent 1716 J St Vicinity Office Occupancy & Rent 1716 J St Vicinity Retail Occupancy & Rent 10,000 0 140,000 70,000
District 4
1404 28th St Vicinity Industrial Occupancy & Rent 1404 28th St Vicinity Flex Occupancy & Rent 1404 28th St Vicinity Office Occupancy & Rent 1404 28th St Vicinity Retail Occupancy & Rent 20,000 0 40,000 10,000
District 4
1918 16th St Vicinity Industrial Occupancy & Rent 1918 16th St Vicinity Flex Occupancy & Rent 1918 16th St Vicinity Office Occupancy & Rent 1918 16th St Vicinity Retail Occupancy & Rent 0 0 90,000 20,000
100%
0%
0%
100%
100%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
2015 2016 2017 2018 2019 2020 2021
1716 J St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
2015 2016 2017 2018 2019 2020 2021
1716 J St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
95%
99%
100%
96%
93%
92%
94%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
100,000 SF
150,000 SF
200,000 SF
250,000 SF
300,000 SF
350,000 SF
2015 2016 2017 2018 2019 2020 2021
1716 J St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
160,000 SF
2015 2016 2017 2018 2019 2020 2021
1716 J St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1404 28th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
2015 2016 2017 2018 2019 2020 2021
1404 28th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
99%
98%
98%
100%
91%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
2015 2016 2017 2018 2019 2020 2021
1404 28th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
96%
100%
100%
96%
92%
96%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
1404 28th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1918 16th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1918 16th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
99%
99%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
160,000 SF
170,000 SF
180,000 SF
190,000 SF
200,000 SF
2015 2016 2017 2018 2019 2020 2021
1918 16th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
96%
100%
97%
95%
97%
97%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
50,000 SF
2015 2016 2017 2018 2019 2020 2021
1918 16th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 4
2418 17th St Vicinity Industrial Occupancy & Rent 2418 17th St Vicinity Flex Occupancy & Rent 2418 17th St Vicinity Office Occupancy & Rent 2418 17th St Vicinity Retail Occupancy & Rent 0 0 10,000 40,000
District 4
515 Broadway Vicinity Industrial Occupancy & Rent 515 Broadway Vicinity Flex Occupancy & Rent 515 Broadway Vicinity Office Occupancy & Rent 515 Broadway Vicinity Retail Occupancy & Rent 40,000 0 0 10,000
District 7
2320 Broadway Vicinity Industrial Occupancy & Rent 2320 Broadway Vicinity Flex Occupancy & Rent 2320 Broadway Vicinity Office Occupancy & Rent 2320 Broadway Vicinity Retail Occupancy & Rent 0 0 40,000 10,000
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2418 17th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2418 17th St Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
89%
96%
95%
95%
97%
97%
$15.00
$15.50
$16.00
$16.50
$17.00
$17.50
$18.00
$18.50
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
2418 17th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
95%
97%
100%
96%
96%
98%
98%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
2015 2016 2017 2018 2019 2020 2021
2418 17th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
78%
78%
60%
85%
85%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
2015 2016 2017 2018 2019 2020 2021
515 Broadway Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
2015 2016 2017 2018 2019 2020 2021
515 Broadway Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
100 SF
200 SF
300 SF
400 SF
2015 2016 2017 2018 2019 2020 2021
515 Broadway Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
86%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
2015 2016 2017 2018 2019 2020 2021515 Broadway Vicinity Retail Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2320 Broadway Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
2320 Broadway Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
19%
20%
19%
19%
19%
19%
19% $22.00
$23.00
$24.00
$25.00
$26.00
$27.00
$28.00
$29.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
2015 2016 2017 2018 2019 2020 2021
2320 Broadway Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
85%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
2015 2016 2017 2018 2019 2020 2021
2320 Broadway Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 5
3752 W Pacific Vicinity Industrial Occupancy & Rent 3752 W Pacific Vicinity Flex Occupancy & Rent 3752 W Pacific Vicinity Office Occupancy & Rent 3752 W Pacific Vicinity Retail Occupancy & Rent 50,000 0 0 10,000
District 5
4311 Attawa Vicinity Industrial Occupancy & Rent 4311 Attawa Vicinity Flex Occupancy & Rent 4311 Attawa Vicinity Office Occupancy & Rent 4311 Attawa Vicinity Retail Occupancy & Rent 70,000 0 0 0
District 5
Wilmington & Deeble Vicinity Industrial Occupancy & Rent Wilmington & Deeble Vicinity Flex Occupancy & Rent Wilmington & Deeble Vicinity Office Occupancy & Rent Wilmington & Deeble Vicinity Retail Occupancy & Rent 120,000 10,000 0 10,000
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
2015 2016 2017 2018 2019 2020 2021
3752 W Pacific Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
2015 2016 2017 2018 2019 2020 2021
3752 W Pacific Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3752 W Pacific Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
76%
77%
86%
86%
$46.50
$47.00
$47.50
$48.00
$48.50
$49.00
$49.50
$50.00
$50.50
$51.00
$51.50
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
2015 2016 2017 2018 2019 2020 2021
3752 W Pacific Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
18,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
4311 Attawa Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
100%
100%
100%
99%
100%
100%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
$10.00
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
160,000 SF
2015 2016 2017 2018 2019 2020 2021
4311 Attawa Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
4311 Attawa Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
2015 2016 2017 2018 2019 2020 2021
4311 Attawa Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
2015 2016 2017 2018 2019 2020 2021
Wilmington & Deeble Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
100%
100%
100%
100%
100%
100%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
$10.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
2015 2016 2017 2018 2019 2020 2021
Wilmington & Deeble Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
Wilmington & Deeble Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
83%
84%
90%
90%
$46.50
$47.00
$47.50
$48.00
$48.50
$49.00
$49.50
$50.00
$50.50
$51.00
$51.50
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
2015 2016 2017 2018 2019 2020 2021
Wilmington & Deeble Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 5
24th St & 23rd Ave Vicinity Industrial Occupancy & Rent 24th St & 23rd Ave Vicinity Flex Occupancy & Rent 24th St & 23rd Ave Vicinity Office Occupancy & Rent 24th St & 23rd Ave Vicinity Retail Occupancy & Rent 60,000 0 0 0
District 5
4910 Franklin Vicinity Industrial Occupancy & Rent 4910 Franklin Vicinity Flex Occupancy & Rent 4910 Franklin Vicinity Office Occupancy & Rent 4910 Franklin Vicinity Retail Occupancy & Rent 0 0 0 60,000
District 5
2831 Fruitridge Vicinity Industrial Occupancy & Rent 2831 Fruitridge Vicinity Flex Occupancy & Rent 2831 Fruitridge Vicinity Office Occupancy & Rent 2831 Fruitridge Vicinity Retail Occupancy & Rent 0 0 0 0
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
24th St & 23rd Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
99%
$-
$0.50
$1.00
$1.50
$2.00
$2.50
$3.00
$3.50
$4.00
$4.50
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
2015 2016 2017 2018 2019 2020 2021
24th St & 23rd Ave Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
24th St & 23rd Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
24th St & 23rd Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
4910 Franklin Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
86%
86%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
2015 2016 2017 2018 2019 2020 2021
4910 Franklin Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
4910 Franklin Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
98%
100%
100%
100%
100%
100%
100%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
160,000 SF
2015 2016 2017 2018 2019 2020 2021
4910 Franklin Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2831 Fruitridge Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
14,000 SF
16,000 SF
2015 2016 2017 2018 2019 2020 2021
2831 Fruitridge Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
4,000 SF
8,000 SF
12,000 SF
16,000 SF
20,000 SF
2015 2016 2017 2018 2019 2020 2021
2831 Fruitridge Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
85%
100%
96%
100%
100%
100%
100%
$-
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
$70.00
0 SF
2,000 SF
4,000 SF
6,000 SF
8,000 SF
10,000 SF
12,000 SF
2015 2016 2017 2018 2019 2020 2021
2831 Fruitridge Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 5
33rd Ave & 35th St Vicinity Industrial Occupancy & Rent 33rd Ave & 35th St Vicinity Flex Occupancy & Rent 33rd Ave & 35th St Vicinity Office Occupancy & Rent 33rd Ave & 35th St Vicinity Retail Occupancy & Rent 70,000 0 0 20,000
District 5
1421 47th Ave Vicinity Industrial Occupancy & Rent 1421 47th Ave Vicinity Flex Occupancy & Rent 1421 47th Ave Vicinity Office Occupancy & Rent 1421 47th Ave Vicinity Retail Occupancy & Rent 130,000 10,000 0 0
District 5
108 Otto Cir Vicinity Industrial Occupancy & Rent 108 Otto Cir Vicinity Flex Occupancy & Rent 108 Otto Cir Vicinity Office Occupancy & Rent 108 Otto Cir Vicinity Retail Occupancy & Rent
140,000 0 0 0
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
33rd Ave & 35th St Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
99%
99%
99%
99%
99%
99%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
60,000 SF
70,000 SF
80,000 SF
90,000 SF
100,000 SF
110,000 SF
120,000 SF
130,000 SF
140,000 SF
150,000 SF
2015 2016 2017 2018 2019 2020 2021
33rd Ave & 35th St Vicinity Industrial Occupancy & Rent Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
33rd Ave & 35th St Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
90%
90%
90%
90%
90%
90%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
2015 2016 2017 2018 2019 2020 2021
33rd Ave & 35th St Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
49%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
2015 2016 2017 2018 2019 2020 2021
1421 47th Ave Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
91%
97%
97%
98%
98%
98%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
2015 2016 2017 2018 2019 2020 2021
1421 47th Ave Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
100%
100%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
6,000 SF
2015 2016 2017 2018 2019 2020 2021
1421 47th Ave Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
1421 47th Ave Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
108 Otto Cir Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
97%
100%
100%
98%
98%
96%
100%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
300,000 SF
2015 2016 2017 2018 2019 2020 2021
108 Otto Cir Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
108 Otto Cir Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
108 Otto Cir Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 5
6955 Luther Dr Vicinity Industrial Occupancy & Rent 6955 Luther Dr Vicinity Flex Occupancy & Rent 6955 Luther Dr Vicinity Office Occupancy & Rent 6955 Luther Dr Vicinity Retail Occupancy & Rent 120,000 60,000 0 0
District 6
6720 Fruitridge Vicinity Industrial Occupancy & Rent 6720 Fruitridge Vicinity Flex Occupancy & Rent 6720 Fruitridge Vicinity Office Occupancy & Rent 6720 Fruitridge Vicinity Retail Occupancy & Rent 0 0 0 20,000
District 6
3701 Stockton Vicinity Industrial Occupancy & Rent 3701 Stockton Vicinity Flex Occupancy & Rent 3701 Stockton Vicinity Office Occupancy & Rent 3701 Stockton Vicinity Retail Occupancy & Rent 0 0 0 30,000
75%
78%
75%
78%
70%
85%
87%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
2015 2016 2017 2018 2019 2020 2021
6955 Luther Dr Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
99%
100%
100%
100%
100%
96%
84%
$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
$9.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
2015 2016 2017 2018 2019 2020 2021
6955 Luther Dr Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
6955 Luther Dr Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
6955 Luther Dr Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
6720 Fruitridge Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
0%
57%
100%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
6,000 SF
7,000 SF
2015 2016 2017 2018 2019 2020 2021
6720 Fruitridge Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
6720 Fruitridge Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
94%
97%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
2015 2016 2017 2018 2019 2020 2021
6720 Fruitridge Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3701 Stockton Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3701 Stockton Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
3701 Stockton Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
84%
87%
93%
83%
100%
94%
100%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
70,000 SF
2015 2016 2017 2018 2019 2020 2021
3701 Stockton Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-1
Cannabis Zones Commercial Real Estate Market Performance District 6
2035 Stockton Vicinity Industrial Occupancy & Rent 2035 Stockton Vicinity Flex Occupancy & Rent 2035 Stockton Vicinity Office Occupancy & Rent 2035 Stockton Vicinity Retail Occupancy & Rent 0 50,000 20,000 0
District 6
Power Inn & 14th Vicinity Industrial Occupancy & Rent Power Inn & 14th Vicinity Flex Occupancy & Rent Power Inn & 14th Vicinity Office Occupancy & Rent Power Inn & 14th Vicinity Retail Occupancy & Rent 850,000 110,000 310,000 10,000
District 6
Florin Perkins Vicinity Industrial Occupancy & Rent Florin Perkins Vicinity Flex Occupancy & Rent Florin Perkins Vicinity Office Occupancy & Rent Florin Perkins Vicinity Retail Occupancy & Rent 6,520,000 140,000 120,000 20,000
6%
6%
100%
100%
100%
0%
0% $-
$5.00
$10.00
$15.00
$20.00
$25.00
0 SF
20,000 SF
40,000 SF
60,000 SF
80,000 SF
100,000 SF
120,000 SF
140,000 SF
2015 2016 2017 2018 2019 2020 2021
2035 Stockton Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
0%
0%
0%
0%
0%
0%
0%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
0 SF
0 SF
0 SF
0 SF
1 SF
1 SF
1 SF
1 SF
1 SF
1 SF
2015 2016 2017 2018 2019 2020 2021
2035 Stockton Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
96%
100%
100%
100%
100%
68%
$15.00
$15.20
$15.40
$15.60
$15.80
$16.00
$16.20
$16.40
$16.60
$16.80
0 SF
10,000 SF
20,000 SF
30,000 SF
40,000 SF
50,000 SF
60,000 SF
2015 2016 2017 2018 2019 2020 2021
2035 Stockton Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$0.20
$0.40
$0.60
$0.80
$1.00
$1.20
0 SF
1,000 SF
2,000 SF
3,000 SF
4,000 SF
5,000 SF
2015 2016 2017 2018 2019 2020 2021
2035 Stockton Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
93%
95%
92%
97%
96%
86%
91%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
2015 2016 2017 2018 2019 2020 2021
Power Inn & 14th Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
96%
98%
96%
97%
96%
94%
98%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
1,000,000 SF
1,100,000 SF
1,200,000 SF
1,300,000 SF
1,400,000 SF
1,500,000 SF
1,600,000 SF
1,700,000 SF
1,800,000 SF
2015 2016 2017 2018 2019 2020 2021
Power Inn & 14th Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
98%
97%
97%
99%
97%
89%
$13.50
$14.00
$14.50
$15.00
$15.50
$16.00
$16.50
$17.00
$17.50
$18.00
$18.50
0 SF
100,000 SF
200,000 SF
300,000 SF
400,000 SF
500,000 SF
600,000 SF
700,000 SF
2015 2016 2017 2018 2019 2020 2021
Power Inn & 14th Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
100%
100%
100%
100%
100%
100%
100%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
2015 2016 2017 2018 2019 2020 2021
Power Inn & 14th Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
91%
91%
86%
85%
85%
100%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
100,000 SF
120,000 SF
140,000 SF
160,000 SF
180,000 SF
200,000 SF
220,000 SF
240,000 SF
260,000 SF
280,000 SF
300,000 SF
2015 2016 2017 2018 2019 2020 2021
Florin Perkins Vicinity Flex Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
95%
97%
96%
96%
89%
95%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
6,000,000 SF
7,000,000 SF
8,000,000 SF
9,000,000 SF
10,000,000 SF
11,000,000 SF
12,000,000 SF
13,000,000 SF
14,000,000 SF
2015 2016 2017 2018 2019 2020 2021
Florin Perkins Vicinity Industrial Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
94%
87%
80%
80%
79%
79%
81%
$-
$5.00
$10.00
$15.00
$20.00
$25.00
$30.00
$35.00
$40.00
$45.00
0 SF
50,000 SF
100,000 SF
150,000 SF
200,000 SF
250,000 SF
300,000 SF
2015 2016 2017 2018 2019 2020 2021
Florin Perkins Vicinity Office Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.
85%
100%
90%
100%
100%
96%
100%
$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
0 SF
5,000 SF
10,000 SF
15,000 SF
20,000 SF
25,000 SF
30,000 SF
35,000 SF
40,000 SF
45,000 SF
2015 2016 2017 2018 2019 2020 2021
Florin Perkins Vicinity Retail Occupancy & Rent
Occupied Vacant Asking Rent
Inventory
Rent (annual)
Source: Costar; EPS.

Prepared by EPS 1/16/2022 Z:\Shared\Projects\SAC\212000\212060 Sac Cannabis\Model\Real Estate Analysis 12 Appendix E-2
Maps of Cannabis Zones Identified for Costar Commercial Real Estate Market Data Extraction Maps from August 2021 (Council Districts updated January 2022) Council District 1
CD1 - 135 Main Ave 1000’
Council District 2
CD2 - 1750 Iris Ave (100’ east) 1000’
CD2 - El Monte & Colfax 1200’
CD2 - Blumenfeld Dr (200’ north of Joellis) 1200’
CD2 - El Camino & Albatross 1000’
CD2 - 1500 El Camino Ave 1000’

CD2 - 2550 Boxwood St 700’
CD2 - 2550 Boxwood St 1000’
CD2 - 2480 Grand Ave 700’
CD2 - 199 Harris Ave 1000’
CD2 - 1955 Railroad Dr 1000’
CD2 - 1783 Tribute Rd 1000’

CD2 - 241 Lathrop Way 1000’

Council District 3

CD3 - 2201 Northgate Bl 1000’

Council District 4

CD4 - 241 N 10th St 1000’

CD4 - 3015 H St 500’

CD4 - 1900 19th St 500’

CD4 - 2100 29th St 500’

CD4 - 1236 C St 500’
CD4 - 1716 J St 500’
CD4 - 1404 28th St 500’
CD4 - 1918 16th St 500’
CD4 - 2418 17th St 500’
CD4 - 515 Broadway 500’

Council District 5
CD5 - 3752 W Pacific 700’
CD5 - 4311 Attawa Ave 1000’
CD5 - Wilmington & Deeble 1200’
CD5 - 24th St & 23rd Ave 700’
CD5 - 4910 Franklin Bl 700’
CD5 - 2831 Fruitridge Rd 700’

CD5 - 33rd Ave & 35th St 700’
CD5 - 1421 47th Ave 1000’
CD5 - 108 Otto Circle 1000’
CD5 - 6955 Luther Dr 1000’
Council District 6
CD6 - 6720 Fruitridge Rd 1000’
CD6 - 3701 Stockton Bl 700’

CD6 - 2035 Stockton Bl 700’
CD6 - Power Inn & 14th Ave Zone
CD6 - Florin Perkins Zone
CD6 - Lemon Hill Zone
CD6 - 8735 Folsom 1000’
Council District 7
CD7 - 2320 Broadway 500’

275
80 80
80 80
80 5
5 99
160
5 160
50 80
80 16
99 1
5 4
7 2
3 6
8 Source: City of Sacramento, EPS, County of Sacramento, Esri, HERE, Garmin, SafeGraph, METI/NASA, USGS, Bureau of Land Management, EP A, NPS, USDA.

F
0 1.5 30.75
Miles
County of
Sacr
amento,
1/4-Mile from Production Uses
1/4-Mile to 1/2 Mile from Production Uses
City Council Districts
City Limits
Map E-3 - Areas Within 1/4-mile and 1/4-mile to 1/2-mile from Cannabis Production Uses 275
80 80
80 80
80 5
5 99
160
5 160
50 80
80 16
99 1
5 4
7 2
3 6
8 Source: City of Sacramento, EPS, County of Sacramento, Esri, HERE, Garmin, SafeGraph, METI/NASA, USGS, Bureau of Land Management, EP A, NPS, USDA.

F
0 1.5 30.75
Miles
County of
Sacr
amento,
Map E-4 - Areas Within 1/4-mile and 1/4-mile to 1/2-mile from Cannabis Dispensaries 1/4-Mile from Dispensaries
1/4-Mile to 1/2 Mile from Dispensaries
City Council Districts
City Limits
T

HIS PAGE INTENTIONALLY LEFT BLANK
APPENDIX F:

Cannabis Business Crime Data

Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
1/14/2018 2021 211 PC ROBBERY-UNSPECIFIED Robbery 58 Delivery 1/14/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 75 Cultivation 2/8/2018 2018 459 PC BURG BUSINESS-NO FORCE Burglary 40 Storefront 4/15/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 111 Storefront 5/22/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 81 Distribution 5/30/2018 2020 459 PC BURG BUSINESS-NO FORCE Burglary 49 Distribution 6/3/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 48 Storefront 7/4/2018 2020 459 PC BURG BUSINESS-FORCE Burglary 10 Cultivation 7/7/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 23 Storefront 7/29/2018 2018 459 PC Burglary 105 Unlicensed
8/2/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 109 Delivery 8/17/2018 2021 459 PC BURG BUSINESS-FORCE Burglary 79 Cultivation 8/19/2018 2021 459 PC BURG BUSINESS-FORCE Burglary 88 Cultivation 8/23/2018 2019 459 PC BURG BUSINESS-NO FORCE Burglary 91 Delivery 9/9/2018 2020 211 PC ROBBERY-UNSPECIFIED Burglary 40 Storefront 9/25/2018 2021 459 PC Burglary 42 Manufacturer
10/11/2018 2019 459 PC BURG BUSINESS-FORCE Robbery 106 Delivery 10/16/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 23 Storefront 10/25/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 103 Manufacturer 11/5/2018 2018 211 PC ROBBERY-BUSINESS Burglary 100 Delivery 11/7/2018 2021 459 PC BURG BUSINESS-FORCE Burglary 63 Manufacturer 11/14/2018 2020 459 PC BURG BUSINESS-FORCE Burglary 90 Cultivation 11/16/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 77 Delivery 11/22/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 33 Delivery 11/30/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 41 Delivery 12/4/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 30 Delivery 12/4/2018 2020 459 PC BURG BUSINESS-FORCE Burglary 48 Storefront 12/5/2018 2018 459 PC BURG BUSINESS-FORCE Burglary 87 Cultivation 12/6/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 91 Delivery 12/13/2018 2021 459 PC BURG BUSINESS-FORCE Burglary 27 Cultivation 12/14/2018 2019 459 PC BURG BUSINESS-FORCE Burglary 98 Storefront 1/8/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 70 Storefront 1/8/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 106 Cultivation 1/9/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 67 Cultivation 1/10/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 88 Cultivation 1/14/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 51 Cultivation 1/31/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 101 Storefront Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
2/9/2019 2018 459 PC BURG BUSINESS-FORCE Robbery 95 Storefront 2/16/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 37 Manufacturer 2/18/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 13 Delivery 2/20/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 36 Cultivation 2/24/2019 2019 211 PC ROBBERY-UNSPECIFIED Robbery 62 Delivery 2/27/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 96 Manufacturer 3/12/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 104 Storefront 3/18/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 83 Cultivation 3/22/2019 2019 211 PC ROBBERY-UNSPECIFIED Burglary 106 Delivery 3/25/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 9 Storefront 3/30/2019 2019 459 PC (ATTEMPT) Burglary 39 Delivery
4/1/2019 2019 211 PC ROBBERY-UNSPECIFIED Robbery 62 Delivery 4/1/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 11 Storefront 4/2/2019 2020 211 PC ROBBERY-UNSPECIFIED Burglary 91 Delivery 4/17/2019 2019 211 PC ROBBERY-UNSPECIFIED Burglary 2 Storefront 4/23/2019 2019 211 PC ROBBERY-UNSPECIFIED Burglary 3 Storefront 4/29/2019 2021 211 PC ROBBERY-UNSPECIFIED Burglary 53 Cultivation 5/20/2019 2019 211 PC ROBBERY-UNSPECIFIED Robbery 69 Delivery 5/20/2019 2018 211 PC ROBBERY-UNSPECIFIED Burglary 4 Cultivation 5/25/2019 2019 211 PC ROBBERY-UNSPECIFIED Robbery 77 Delivery 5/28/2019 2021 211 PC ROBBERY-UNSPECIFIED Robbery 58 Delivery 5/28/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 30 Delivery 5/29/2019 2020 211 PC ROBBERY-UNSPECIFIED Robbery 47 Delivery 5/29/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 26 Storefront 6/1/2019 2019 211 PC ROBBERY-UNSPECIFIED Burglary 1 Lab 6/16/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 8 Storefront 6/21/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 102 Cultivation 6/27/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 25 Cultivation 6/27/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 43 Cultivation 7/2/2019 2020 459 PC BURG BUSINESS-FORCE Robbery 30 Delivery 7/4/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 95 Lab 7/6/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 7 Cultivation 7/16/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 96 Distribution 7/17/2019 2020 459 PC BURG BUSINESS-FORCE Robbery 25 Cultivation 7/22/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 12 Manufacturer 7/27/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 17 Distribution 7/29/2019 2019 459 PC BURG BUSINESS-FORCE Robbery 88 Cultivation Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
7/30/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 35 Storefront 7/30/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 98 Storefront 8/2/2019 2021 211 PC ROBBERY-UNSPECIFIED Robbery 107 Delivery 8/2/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 88 Cultivation 8/4/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 22 Cultivation 8/5/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 68 Cultivation 8/6/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 9 Delivery 8/6/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 91 Microbusiness 8/7/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 66 Storefront 8/10/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 89 Distribution 8/13/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 98 Storefront 8/18/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 38 Cultivation 8/18/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 96 Manufacturer 8/21/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 19 Delivery 8/23/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 17 Distribution 8/24/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 63 Lab 8/24/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 96 Manufacturer 8/25/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 23 Storefront 8/25/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 73 Delivery 8/25/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 105 Unlicensed 8/26/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 60 Cultivation 8/27/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 11 Storefront 8/27/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 68 Cultivation 8/28/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 49 Delivery 8/28/2019 2021 459 PC (ATTEMPT) Burglary 68 Cultivation 8/30/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 108 Cultivation 9/1/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 27 Cultivation 9/4/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 73 Delivery 9/5/2019 2020 459 PC BURG BUSINESS-FORCE Burglary 52 Storefront 9/5/2019 2021 459 PC BURG BUSINESS-FORCE Burglary 53 Cultivation 9/5/2019 2019 459 (ATTEMPT) Burglary 70 Storefront
9/18/2019 2020 459 PC (ATTEMPT) Burglary 66 Cultivation 10/8/2019 2019 459 PC BURG BUSINESS-FORCE Robbery 10 Cultivation 10/11/2019 2021 211 PC ROBBERY-UNSPECIFIED Robbery 110 Delivery 10/27/2019 2020 459 PC (ATTEMPT) Burglary 40 Storefront 12/1/2019 2021 211 PC ROBBERY-UNSPECIFIED Robbery 80 Delivery 12/3/2019 2018 459 PC (ATTEMPT) Burglary 40 Storefront
Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
12/14/2019 2018 459 PC BURG BUSINESS-FORCE Burglary 72 Cultivation 12/18/2019 2019 459 PC BURG BUSINESS-FORCE Burglary 16 Manufacturer 12/18/2019 2021 459 PC BURG BUSINESS-FORCE Robbery 74 Cultivation 12/25/2019 2021 211 PC ROBBERY-UNSPECIFIED Burglary 15 Distribution 1/31/2020 2019 211 PC ROBBERY-UNSPECIFIED Burglary 30 Delivery 2/3/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 46 Cultivation 2/23/2020 2020 459 PC (ATTEMPT) Burglary 45 Storefront
2/24/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 30 Delivery 3/21/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 79 Cultivation 4/10/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 11 Storefront 4/24/2020 2018 459 PC BURG BUSINESS-FORCE Burglary 78 Manufacturer 5/2/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 34 Distribution 5/13/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 93 Storefront 5/13/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 93 Storefront 5/14/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 51 Storefront 5/14/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 93 Storefront 5/17/2020 2018 459 PC BURG BUSINESS-FORCE Burglary 21 Distribution 5/27/2020 2019 211 PC ROBBERY-UNSPECIFIED Robbery 84 Delivery 5/30/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 68 Cultivation 5/31/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 31 Cultivation 5/31/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 43 Cultivation 6/2/2020 2020 459 PC BURG BUSINESS-FORCE Burglary 40 Storefront 6/2/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 51 Cultivation 6/2/2020 2020 459 PC BURG BUSINESS-FORCE Burglary 94 Cultivation 6/4/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 104 Storefront 7/12/2020 2020 459 PC BURG BUSINESS-FORCE Burglary 98 Storefront 7/19/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 14 Cultivation 7/19/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 60 Cultivation 9/10/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 106 Cultivation 9/19/2020 2019 459 PC BURG BUSINESS-FORCE Burglary 65 Cultivation 11/15/2020 2020 211 PC ROBBERY-UNSPECIFIED Burglary 104 Storefront 11/18/2020 2018 211 PC ROBBERY-UNSPECIFIED Robbery 33 Storefront 12/7/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 61 Manufacturer 12/29/2020 2021 459 PC BURG BUSINESS-FORCE Burglary 51 Cultivation 1/9/2021 2020 459 PC BURG BUSINESS-FORCE Robbery 104 Storefront 1/13/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 103 Manufacturer 1/31/2021 2019 459 (ATTEMPT) Burglary 10 Cultivation
Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
2/10/2021 2021 211 PC ROBBERY-UNSPECIFIED Burglary 7 Cultivation 3/11/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 10 Cultivation 4/27/2021 2021 459 (ATTEMPT) Burglary 91 Microbusiness
5/20/2021 2020 459 (ATTEMPT) Burglary 90 Cultivation
5/21/2021 2020 211 PC ROBBERY-UNSPECIFIED Burglary 7 Cultivation 5/31/2021 2021 211 PC ROBBERY-UNSPECIFIED Burglary 6 Storefront 6/1/2021 2019 211 PC ROBBERY-UNSPECIFIED Burglary 4 Cultivation 6/2/2021 2021 211 PC ROBBERY-UNSPECIFIED Robbery 99 Delivery 6/6/2021 2019 211 PC ROBBERY-UNSPECIFIED Robbery 59 Delivery 6/6/2021 2019 211 PC ROBBERY-UNSPECIFIED Burglary 5 Cultivation 6/21/2021 2019 211 PC ROBBERY-UNSPECIFIED Burglary 82 Delivery 7/23/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 60 Cultivation 7/29/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 51 Cultivation 8/1/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 50 Delivery 8/1/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 109 Delivery 8/2/2021 2020 459 PC BURG BUSINESS-FORCE Burglary 90 Cultivation 8/3/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 92 Storefront 8/4/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 51 Cultivation 8/12/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 20 Delivery 8/13/2021 2020 459 PC BURG BUSINESS-FORCE Burglary 57 Cultivation 8/15/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 103 Manufacturer 8/18/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 38 Cultivation 8/24/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 66 Cultivation 8/25/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 56 Cultivation 8/29/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 55 Cultivation 9/4/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 111 Storefront 9/5/2021 2019 459 PC BURG BUSINESS-FORCE Robbery 49 Delivery 9/5/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 66 Cultivation 9/6/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 38 Cultivation 9/6/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 67 Cultivation 9/9/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 71 Manufacturer 9/9/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 108 Cultivation 9/10/2021 2020 459 PC BURG BUSINESS-FORCE Burglary 72 Cultivation 9/16/2021 2021 459 (ATTEMPT) Burglary 94 Cultivation
9/17/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 20 Delivery 9/17/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 86 Delivery 9/21/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 54 Storefront Table F-1
City of Sacramento Comprehensive Cannabis Study
List of Crimes At Cannabis Businesses Reported to City of Sacramento Police Department (2018 - 2021) Date [1] Year Crime [2] Crime Category
Business ID
[3]
Cannabis
Business
Type
10/2/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 71 Manufacturer 10/3/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 85 Cultivation 10/7/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 40 Storefront 10/7/2021 2020 459 PC BURG BUSINESS-FORCE Burglary 53 Cultivation 10/7/2021 2020 459 PC BURG BUSINESS-FORCE Burglary 72 Cultivation 10/7/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 76 Delivery 10/9/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 33 Distribution 10/10/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 22 Cultivation 10/10/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 28 Storefront 10/10/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 32 Microbusiness 10/10/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 98 Storefront 10/13/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 64 Cultivation 10/14/2021 2021 211 PC ROBBERY-UNSPECIFIED Robbery 97 Delivery 10/18/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 76 Delivery 10/30/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 66 Storefront 10/31/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 88 Cultivation 10/31/2021 2018 459 PC BURG BUSINESS-FORCE Burglary 88 Cultivation 11/1/2021 2021 459 PC BURG BUSINESS-FORCE Burglary 67 Cultivation 11/5/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 60 Cultivation 11/5/2021 2019 459 PC BURG BUSINESS-FORCE Burglary 93 Storefront Source: City of Sacramento Police Department, EPS.
[1] Data is current through Nov
ember 7, 2021.
[2] Burgalry
is defined in Section 459 of the California Penal Code. Robbery is defined in Section 211 of the California Penal Code. [3] Each business w
as assigned an anonymous identifier in order to prevent the publication of confidential or privileged information.

Attachment 3
Summary of Public Comments and Responses from Workshop #4

1. Jan Thurston – City should also have a program to assist small cannabis businesses that are not CORE.

Staff Response: The City has been awarded state grant funds to help cannabis businesses get their local permits and annual state licenses, and to provide rebates for certain security requirements. Both of these programs will be rolled out in FY2022-23.

2. Kevin McCarty – Supports streamlining of the ownership reporting; supports different BOT rates according to business types and progressive BOT rates according revenue bracket; NRP issue was not addressed.

Staff Response: Thank you for your comments registering your support for those recommendations. The NRP was not on the agenda and was not discussed by the Committee during the Workshop.

3. Shannon Horne – Recommendations are not impacting CORE; 25% of cannabis BOT should be allocated to CORE program; City should extend deadline for CORE storefront dispensaries to open; convert loans to grants; City should take actions consistent with the commitment to give 50% of permits to CORE; incentivize storefront dispensaries to put CORE products on the shelves.

Staff Response: CORE members, like all cannabis business applicants and permitees, will be impacted by regulatory changes. It is anticipated that additional recommendations relative to the CORE program will be forthcoming once the equity study is completed and more in-depth data around equity in the cannabis industry and the CORE program is available. These recommendations may include the items identified by the commenter. The CORE Capitol Loan Program is a zero-interest revolving loan program and the ability to make future loans is dependent on recipients’ loan repayment. Apart from taking away the ability for additional CORE members to access capital from the loan program in the future, converting the loans into grants would have severe tax consequences for the borrowers, many of whom had loan checks made out to themselves as individuals due to the inability to obtain a cannabis business banking account.

Attachment 3

4. Kevin Hooks – Social equity is not just about ownership but also other workforce opportunities; 25% of BOT should go to CORE; allow storefronts in C3; extend deadline for CORE storefronts to open; Council shouldn’t wait for equity study to finish before making decisions for CORE; Council should be more intentional in presenting solutions for CORE.

Staff Response: CORE members, like all cannabis business applicants and permitees, will be impacted by regulatory changes. Asking the Planning and Design commission to consider whether dispensaries should be an allowable use in C-3 zones is one of the L&L Committee recommendations. In-depth data and information is needed around equity in the cannabis industry and the CORE program in order to support a full package of recommendations and allow the Council to be intentional in its work around equity in cannabis.

5. Lynn Silver – Appreciates dropping onsite consumption; cannabis is leading cause of substance abuse; increase in ER visits, psychosis, other medical issues; keep dispensaries away from residential areas and limited in number; opposed to lifting of delivery cap; limit amount of THC in flavored products Staff response: The City’s goals are for a healthy, safe and regulated cannabis industry. To achieve this, the City has engaged and will continue to engage in youth cannabis education and use prevention work. However, a safe and regulated cannabis industry also means one that is integrated into the commercial districts of the City, in the way that brewpubs, bars, liquor stores, alcohol sales and distributors, and alcoholic beverage manufacturers are integrated.

6. Kimberly Cargile – Supports removing churches and parks from sensitive uses; incentivize storefronts to carry CORE products; supports flexibility in taxation Staff Response: The Committee elected to retain religious facilities and neighborhood and community parks as sensitive uses. The Council could change that direction if it wished to do so. The Committee elected to recommend flexibility in taxation up to 4%. It is anticipated that additional recommendations will be forthcoming once the equity study is completed and more in-depth data Attachment 3
around equity in the cannabis industry and the CORE program is available.

These recommendations may include the items identified by the commenter.

7. Zion Fiktre – 25% of BOT should be allocated to CORE; add more storefronts; allow onsite consumption lounges
Staff Response: It is anticipated that additional recommendations will be forthcoming once the equity study is completed and more in-depth data around equity in the cannabis industry and the CORE program is available. These recommendations may include the items identified by the commenter.

8. Joe Devlin – Opposed to layering more requirements for small businesses; replicate State policy where possible; supports creating a tax ballot measure Staff Response: None of the recommendations add regulatory requirements to businesses based upon their size. The Committee recommendations include tax measures that may need to go through the ballot process.

9. Mindy Galloway – Council should create urgency around reducing tax rates or provide tax rebates for CORE and small businesses. Provide tax credits for storefronts that carry CORE products; supports tax measure on the November ballot.

Staff response: It is anticipated that additional recommendations will be forthcoming once the equity study is completed and more in-depth data around equity in the cannabis industry and the CORE program is available. These recommendations may include the items identified by the commenter. The Committee recommendations include tax measures that may need to go through the ballot process.

10. Malaki Amen – Committee’s actions are not meeting the immediate needs of the CORE community; convert loans to grants; 25% of BOT should go to CORE; extend the deadline for storefront dispensaries to open; supports addition of C3 zone; Council should demonstrate intentionality in meeting the commitment that 50% of permits should go to CORE; incentivize storefronts to carry CORE products.

Staff Response: In-depth data and information is needed around equity in the cannabis industry and the CORE program in order to support a full package of Attachment 3
recommendations and allow the Council to be intentional in its work around equity in cannabis. The CORE Capitol Loan Program is a zero-interest revolving loan program and the ability to make future loans is dependent on members paying back their loans. Apart from taking away the ability for other CORE members to get capital from the loan program in the future, making all the loans into grants would have severe tax consequences for the borrowers, many of whom had to get loan checks made out to themselves as individuals due to the inability to obtain a cannabis business banking account. Requesting the Planning and Design commission to consider whether dispensaries should be an allowable use in C-3 zones is one of the L&L Committee recommendations.

11. Deanna Garcia – Lower taxes on all levels; CORE should not be left out when creating policy; follow State policy regarding churches/parks and ownership; incentivize businesses that support CORE
Staff Response: The Law & Legislation Committee recommendations include measures that could result in the decrease some taxes as well as requests to the Planning and Design Commission to consider whether current sensitive use buffers are still serving the purposes they were adopted for. In-depth data and information is needed around equity in the cannabis industry and the CORE program in order to support a full package of recommendations and allow the Council to be intentional in its work around equity in cannabis.

12. Barry Boyd – Suggests that ownership should be max of 25% if multiple owners come into play and max of 30% between commonly-held interests/family members; recommendations from the Auditors’ office should be addressed.

Staff Response: Council may consider additional caps on ownership as suggested when they provide further direction to staff on May 24 th.

Recommendations from the City Auditor’s office continue to be addressed.

Analysis
CORE Storefront Dispensary Survey
Storefront Dispensary RFQ Survey
Storefront Dispensary RFQ Interviews
Attachment 5

Page 2 of 9 ends

Sacramento City CouncilJanuary 23, 2024

Sacramento City Council
January 23, 2024