HomeMy WebLinkAbout22 - NB-6 - Formation of Ad Hoc Committee of - 12/17/20191
LOCK, CONNOR
From:Michael Moussalli <michael@se7enleaf.com>
Sent:Wednesday, December 4, 2019 7:49 PM
To:FOLEY, KATRINA; STEPHENS, JOHN; CHAVEZ, MANUEL; GENIS, SANDRA; MANSOOR,
ALLAN; MARR, ANDREA; REYNOLDS, ARLIS; CONSTITUENT SERVICES; CURTIS, BARRY C.;
LE, JENNIFER; PREZIOSI, TARQUIN; Kimberly Hall Barlow - City Attorney; FARRELL
HARRISON, LORI ANN; TELFORD, KELLY; GREEN, BRENDA
Subject:Recent Updates from the Cannabis Industry
Attachments:Cannabis Operators Letter to City Council and Staff 11112019.pdf
Dear City Council and Staff,
Hope you all had a nice holiday.
I wanted share a couple of recent updates with you.
The first update is that the State of California (specifically the CDTFA) recently decided to raise the already
excessive taxes on the struggling cannabis industry, cutting margins even further for current wholesale
operators and driving more consumers towards the illicit market. Despite tax revenues falling short of
projections and data showing that a tax increase could be detrimental to the stability of the legal marketplace,
the CDTFA decided to proceed with the increase, which as been met with total shock and disappointmet by the
cannabis industry as a whole in California. The financial burden this tax increase will put on businesses is now
another challenge that operators will have to figure out how to endure and overcome.
You can read more about the tax increase here:
https://www.forbes.com/sites/sarabrittanysomerset/2019/11/22/california-is-raising-its-taxes-on-cannabis-
again/#706e073c74eb
The second update is that yesterday evening the City of Long Beach voted to reduce their gross receipts tax
on all non-retail cannabis businesses from 6% down to 1%, in order to encourage more cannabis businesses
to open within the City.
You can read more about it here:
https://lbpost.com/news/long-beach-to-reduce-some-cannabis-taxes-to-spur-industry-investment
As City Council and Staff are currently discussing a reduction in the gross receipts tax for the cannabis
businesses here in Costa Mesa, I thought it prudent to share this recent information with you, as Long Beach is a
neighboring City with operators that are experiencing the same economic challenges that operators here in
Costa Mesa are facing. The tax reduction in Long Beach to 1% across the board for all wholesale businesses is
the lifeline that many operators need to survive in this challenging marketplace.
Additionally, Los Angeles is at a 2% tax rate on manufacturing businesses and a 1% tax rate on distribution
businesses. The concern here is that both LA and now Long Beach are in a strong position to sway new
Attachment 2
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cannabis operators to settle in their cities and the cost of doing business for current operators in those cities is
much less than it is for operators in Costa Mesa. Simply put, this means operators in LA and Long Beach are in
a position to win deals and earn business that we here in Costa Mesa are not.
The cannabis community in Costa Mesa looks forward to continuing an open dialogue with City Council and
City Staff in order to work together closley to get the industry in Costa Mesa back on track as soon as possible.
Thank you all for your continued help and support.
Best,
Michael Moussalli
Se7enLeaf
Co-Founder and Partner
Cell: (949) 400-4110
Office: (877) 464-6652
www.se7enleaf.com
Begin forwarded message:
From: Michael Moussalli <michael@se7enleaf.com>
Subject: The Local Cannabis Industry Requests Your Help
Date: November 11, 2019 at 3:49:35 PM PST
To: katrina.foley@costamesaca.gov, john.stephens@costamesaca.gov,
Manuel.Chavez@costamesaca.gov, sandra.genis@costamesaca.gov,
allan.mansoor@costamesaca.gov, Andrea.Marr@costamesaca.gov,
Arlis.Reynolds@costamesaca.gov, constituentservices@costamesaca.gov,
byron.dearakal@costamesaca.gov, barry.curtis@costamesaca.gov, jennifer.le@costamesaca.gov,
tarquin.preziosi@costamesaca.gov, khb@jones-mayer.com, LORI ANN FARRELL
HARRISON <LoriAnn@costamesaca.gov>, Kelly Telford <kelly.telford@costamesaca.gov>,
brenda.green@costamesaca.gov
To:
Madam Mayor Foley
Mayor Pro Tem Stephens
City Council Members
City Manager
City Staff
3
City Attorney
City Clerk
Chairman of the Planning Commission
Hope this email finds you all well.
The local Cannabis Industry formally requests a reduction in the tax on our businesses (from 6%
to 2% on all current uses), as well as we request that Home Delivery business (with a proposed
tax of 5%) be allowed within the City limits.
Please find a letter attached to this email from the industry, which outlines the reasoning for
these resets and the benefits that can be obtained for both operators and the City by acting
swiftly.
Members from the Industry will be in attendance tomorrow at the City’s Study Session and
several will be elaborating a bit further on our requests during opening comments.
We hope to stimulate dialogue with all of you and formulate a plan to take swift action on these
requests, as the local Cannabis Industry really needs your help.
Please let me know if you have any questions, we look forward to speaking with you in greater
details.
Thank you
Best,
Michael Moussalli
Se7enLeaf
Co-Founder and Partner
Cell: (949) 400-4110
Office: (877) 464-6652
www.se7enleaf.com
CONFIDENTIALITY NOTICE:
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contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the
intended recipient of this message or their agent, or if this message has been addressed to you in error, please
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its attachments is strictly prohibited. Thank you.
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CITY COUNCIL AGENDA REPORT
MEETING DATE: DECEMBER 17, 2019 ITEM NUMBER: NB-6
SUBJECT: FORMATION OF AD HOC COMMITTEE OF THE COUNCIL TO
EVALUATE CANNABIS TAX RATES AND REGULATIONS
DATE: DECEMBER 11, 2019
FROM: LORI ANN FARRELL HARRISON, CITY MANAGER
PRESENTATION BY: CONNOR A. LOCK, CHIEF OF STAFF
ALMA REYES, SENIOR MANAGEMENT ANALYST
FOR FURTHER INFORMATION CONTACT: CONNOR LOCK (714) 754-5192
ALMA REYES (714) 754-5090
RECOMMENDATION:
Mayor Foley requests that the City Council form, by nomination and confirmation, a three-
member Cannabis Ad Hoc Committee to consist of the Mayor, the Mayor Pro Tem, and
one additional Council Member, to review and discuss the City’s cannabis tax rate and
other requests from local operators within the City’s boundaries, and whether any
changes may be warranted.
BACKGROUND:
The City Council has received a letter from several of the City’s cannabis operators,
writing as the Cannabis Industry (Attachments 1 and 2). This letter, among other
comments, emails, and public testimony at City Council meetings, details changes that
operators within the City would like the Council to consider for the regulatory framework
for cannabis businesses in Costa Mesa. The requests made in the letter, and the data
used to justify them, will be reviewed by City staff to the greatest extent possible to help
develop recommendations for the City Council to consider. The formation of an Ad Hoc
Committee would assist in the review and analysis of the cannabis industry’s proposals
and recommendations to the City Council for final approval and action.
ANALYSIS:
Individual City Council members and staff have met with cannabis operators currently
situated within the City’s “Green Zone” established by Measure X. The proposed
Cannabis Ad Hoc Committee could take the lead in reviewing the operators’ requests,
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reviewing City staff analysis, and drawing up recommendations to the City Council for
action at a public meeting.
The Ad Hoc Committee would be comprised of three members of the City Council. The Ad
Hoc Committee would be solely advisory in nature, of limited duration and would hold
informal meetings on an as needed basis.
The City’s FY 2018-2019 budget included an expectation for approximately $1.5 million
in tax revenues from cannabis business operations. The actual receipts are pacing
significantly below expectations, leading staff to discuss with operators the various
reasons for lower-than-expected tax receipts and overall lower-than-expected revenue.
As described above, operators in the City have several requests that they have asserted
could potentially increase business activity and subsequent revenues to the City.
The Ad Hoc Committee would be responsible for reporting to the full City Council at public
meetings their findings and recommendations, as well as to provide time for questions
and answers from the entire City Council and comments from the public. Forming this Ad
Hoc committee would enable staff to receive questions for further research and analysis
more efficiently during preliminary conversations and meetings with stakeholders.
ALTERNATIVES CONSIDERED:
The City Council may choose to not create an Ad Hoc Committee.
FISCAL REVIEW:
No additional resources are anticipated to be required at this time.
LEGAL REVIEW:
The City Attorney’s Office has reviewed and approved this report as to form. Under the
Ralph M. Brown Act, the term "legislative body" excludes less-than-a-quorum advisory
committees composed solely of members of the legislative body, provided they are not
standing committees that have continuing subject matter jurisdiction or a meeting
schedule fixed by charter, ordinance, resolution, or formal action of a legislative body.
See Government Code § 54952(b).
COUNCIL GOALS AND PRIORITIES:
Goal 3 – Keep the City Fiscally Sustainable
CONCLUSION:
Mayor Foley requests that the City Council form a three-member Cannabis Ad Hoc
Committee to consist of the Mayor, the Mayor Pro Tem, and one additional Council
Member, to work diligently with staff in reviewing the City’s cannabis regulations and tax
rates, and make a recommendation to the City Council as to whether any changes may
be warranted.
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______________________ _______________________
KELLY A. TELFORD, CPA KIMBERLY HALL BARLOW
Finance Director City Attorney
_______________________
LORI ANN FARRELL HARRISON
City Manager
ATTACHMENTS: 1
2
November 11, 2019 Cannabis Industry Letter to the City of
Costa Mesa
Emails from Michael Moussalli relating to November 11 Letter
Cannabis Industry Letter to The City of Costa Mesa
November 11, 2019 1 | Page
Dear City Council and Staff Members,
The Cannabis Industry formally requests that the City of Costa Mesa reduce the gross receipts tax on
cannabis manufacturing, distribution and testing businesses to 2% and allow for home delivery
cannabis businesses at a gross receipts tax of 5%. The Cannabis Industry also requests that all
taxation occur upon exit of product from the City, in order to avoid multi-layered taxation and to
encourage/stimulate inter-city business between multiple cannabis operators.
As you may recall about a year ago, members of the local cannabis community started making rounds
at City Hall and to multiple City Council members to offer an explanation as to why the 6% gross
receipts tax was a heavy burden placed on operators and rendered Costa Mesa a non-competitive
home for businesses within the cannabis space. In the letter below, we would like to take the
opportunity to address some of the challenges we are facing in greater depth with you, as well as
provide solutions that will help us overcome these challenging times:
TAX ON MANUFACTURING, DISTRIBUTION AND TESTING BUSINESSES:
One the first dual-licensed business to become operational in Costa Mesa openly shared the company’s
P&L on the Distribution side of the business with City Staff and multiple Council Members in an effort
to further illustrate just how detrimental a 6% gross receipts tax really is. This business has now been
forced to close their Distribution-to-Retail side because customers were going with Distributors located
in other municipalities with much more favorable tax rates, where the cost of business is significantly
less. The last tax payment from this operator to the City reflected a significant decrease in revenue
and this trend will surely continue unless local cannabis operators are provided with significant tax
relief.
As the legal cannabis industry continues to evolve, it is important to understand why revenues of new,
legal cannabis businesses are generally declining. In short, there are many new challenges that have
arisen for current cannabis business operators. Firstly, there are not enough legal retail outlets
throughout the state, which is causing a bottle neck of product at the retail front and discouraging
consumers from shopping at convenient, legal, safe outlets. This means that consumption of legal
cannabis products has gone down, while consumption of illegal cannabis market products has
increased.
Furthermore, since there is a bottle neck of too much legal product trying to make it onto too few
legal retail shelves, the rest of the supply chain (distributors, manufacturers and cultivators) have
seen wholesale margins drastically reduce as prices of raw material and final form goods have fallen
dramatically over the last few months because of the shaky market conditions and the flourishing
black market.
Therefore, the Cannabis Industry is finding that a 6% gross receipts tax on manufacturing, distribution
and testing businesses is excessive and, in many cases, unsustainable. Cannabis operators in Costa
Mesa are losing deals to Cities with lower taxes and with lower costs of doing business.
To date, the City has collected only $259,000 in tax revenue- this amount is $1.4 million below budget
projections and will not help fix the City's structural budget deficit. We as the local cannabis
community want to help you get these numbers up, but we also need your immediate help to make
that happen.
There are several operators in Costa Mesa with multiple licenses across multiple cities, who are
choosing to avoid moving cannabis business through Costa Mesa because of the harrowing gross
receipts tax, despite Costa Mesa being an ideal logistical spot to manufacture and distribute cannabis
products. This is a shame, as Costa Mesa was on the forefront of creating a cannabis community with
Measure X and allowing cannabis businesses to operate within the City well before another other local
municipalities.
Another key indicator that the gross receipts tax is far too excessive is the availability of properties
currently located in the Green Zone. For the first few months after Costa Mesa announced the
parameters of the Green Zone, there were many competing offers on properties and it was hard to
Attachment 1
Cannabis Industry Letter to The City of Costa Mesa
November 11, 2019 2 | Page
secure a property- in many cases operators were forced into paying extremely excessive rent,
sometimes even having to agree to give up an additional gross receipts percentage to landlords,
simply to be able to secure a property to apply and open a cannabis business within the City.
Today, the landscape has dramatically changed as there is wide availability of properties with no
current offers on them – this is because of the way the cannabis industry has evolved and additionally,
the general impression of the cannabis industry outside of the local community is that it is extremely
challenging to get a cannabis business up and running in a timely manner in Costa Mesa and even
more challenging to sustain a profitable cannabis business within the City.
We are formally requesting an immediate reduction in the gross receipts tax to 2% on manufacturing,
distribution and testing businesses, in order for these businesses to A) simply survive in many cases,
and B) generate increasing, stable revenue over time to help support the budget deficit for the City of
Costa Mesa.
At a 2% gross receipts tax on these businesses, Costa Mesa will become a competitive, financially
sound location to run a cannabis business and fall in line with other cities such where cannabis
businesses are successfully thriving. Successfully thriving…. these are important words because while
many other cities have similar tax structures to Costa Mesa, they are experiencing the same
significant gap in tax projections and operators in those cities are in a similar position to local
operators here in Costa Mesa – they are trying to work with their cities to reduce taxes to a
sustainable amount in order to kick start the local industry again.
It is imperative that a tax reduction to 2% for manufacturing, distribution and testing cannabis
businesses is rendered quickly – an escalating tax bracket tier over time simply will not work. To start
at a low tax percentage that is associated with limited revenue and then to see that tax percentage
increase as revenue increases, still places Costa Mesa in a non-competitive state. Local businesses
with licenses and operations in more favorable tax havens elsewhere would be forced to limit their
production in Costa Mesa as to fall within the minimum tax bracket and continue increasing their
production in the other municipalities where taxes are a sustainable, flat number across the board.
Furthermore, an escalating tax bracket will not change the message to the greater cannabis industry
that Costa Mesa is a cannabis business friendly city. The City will only see small operations that may
or may not survive over time, as larger, multi-city operators will seek to maximize on the lower tax
bracket revenue limits and move the balance to other cities with more favorable tax structures. Only a
reduction to a 2% gross receipts tax on the above-mentioned business types would prevent this, as
even a reduction to only 5%, 4% or 3% would still encourage operators to shift revenue to a city with
1% or 2% taxes because they will still see a significant profit benefit.
INTRODUCTION AND TAXATION OF HOME DELIVERY TO COSTA MESA:
There is an opportunity for the City to place a higher gross receipts tax on home delivery businesses
of 5%, which is a percentage that is also sustainable for operators in Costa Mesa. As mentioned
earlier, one of the challenges operators are facing right now is that there are too few, legal retail
outlets for products throughout the state. Essentially this means that retail outlets, particularly
dispensaries, hold all of the buying and negotiating power within the supply chain – there is way more
legal product trying to come to market than the current store shelves can hold, which means
wholesale margins have been decimated and many manufacturers and distributors are simply trying to
find ways to stay alive at this point.
The introduction of home delivery in Costa Mesa solves a few other challenges. The first benefit of
having home delivery in Costa Mesa is that manufacturers and distributors will no longer need to go
through the “gatekeeper” dispensaries in order to get their products on the shelves for consumers to
purchase – they will have the ability to directly sell to the consumer. This means that not only will
manufacturer/distributors have the opportunity to be in full control of their own sales channels, it also
means that margins will be significantly higher, as product will no longer be sold at wholesale pricing
but rather it will be sold direct-to-consumer at retail prices.
Another major benefit of home delivery is it will provide direct access to patients who need cannabis
to help cope with their medical issues, patients who otherwise in many cases have no way to obtain it.
Cannabis Industry Letter to The City of Costa Mesa
November 11, 2019 3 | Page
There are many residents of Costa Mesa (as well as the rest of Orange County) who would like to
obtain legal cannabis to help with various ailments, however they are either A) unable to physically
get to a dispensary because of health reasons, or B) may not be comfortable shopping in a dispensary
but would still like to partake in the medical benefits of cannabis. Home delivery would provide safe,
legal access to patients on a much greater scale than a single retail dispensary ever could.
Additionally, it is important to note that since Measure X was written and enacted upon, the State of
California has determined that cannabis delivery is fully legal throughout the entire state, meaning
that operators running home delivery businesses in Costa Mesa will have the opportunity to deliver to
consumers throughout California and Costa Mesa would be able to collect 5% gross receipts tax on all
of those sales. Furthermore, if there are any concerns that a reduction in gross receipts tax to 2% on
manufacturing, distribution and testing businesses may hinder overall tax revenue for the City, the
5% gross receipts tax on home delivery would more than offset that difference as manufacturers and
distributors would have access to the entire consumer base in California.
Another point that should be mentioned is that home delivery is already taking place in the City of
Costa Mesa. Unfortunately, there are many illegal delivery services (and a couple legal ones) in
Orange County that are still supplying residents of Costa Mesa with product and the City is not able to
regulate this product or these deliveries, nor is the City able to currently benefit from any taxation on
these deliveries. By allowing home delivery businesses in Costa Mesa, the City would be able to lean
on cannabis businesses within the city limits to increase the flow of clean, safe regulated product
being delivered to local consumers and they would also be able to take advantage of the 5% gross
receipts tax on all deliveries made throughout the state.
Lastly, it should be noted that the state already has detailed regulations in place to ensure that home
delivery businesses are run in a safe, compliant and responsible manner, however Costa Mesa would
have the opportunity to work with current operators to impose additional regulations if the City were
to deem it necessary. Essentially the home delivery model is VERY similar to the Distribution model,
the difference being that product would be delivered direct to consumers rather than retail
dispensaries. Deliveries are required by law to be done on a pre-designated route in unmarked, yet
secured vehicles, a there are limitations on how much product any driver can carry at any given time.
Furthermore, product cannot simply be left at a consumer’s door – the individual ordering the product
needs to be present, show full identification and then take direct possession of the product. The
Cannabis Community is happy to share with additional regulations with you and how this business
model would work safely, discreetly and effectively in Costa Mesa.
In summary, we have been asking the City for a year to take action, and now we absolutely
need your help as the legal cannabis market has presented operators with many new,
unexpected and unforeseen challenges that are threatening the sustainability of our
businesses. We want to succeed here in Costa Mesa, and we want the City to benefit from
our success, but the only way this can happen is that we have to work together, and we
need you to please act and to help us.
We ask that you support our requests and swiftly take action. Many local cannabis
businesses that are either currently operational or are in mid-process with the City for
licensure are currently consulting with their investors, who seek to sell off operations in
Costa Mesa or abandon the licensure process and continue licensure/operations in Cities
with significantly more favorable taxes. This could result in a mass exodus of cannabis
businesses from Costa Mesa which would be detrimental Costa Mesa and to budget
projections.
Any and all members of the Costa Mesa Cannabis Community are available for discussion and are
happy to expound on our requests in greater detail.
Thank you for your consideration, we await to hear what actions will be taken.
Sincerely,
Cannabis Industry Letter to The City of Costa Mesa
November 11, 2019 4 | Page
The following Costa Mesa Cannabis Industry Executives/Owners:
Michael Moussalli Jim Fitzpatrick
Se7enLeaf Solutioneers
Krystal Kitahara Chris Boudreau
Yummi Karma Cannabis Chamber of Commerce
Eric Spitz Steve Hellings
C4 Distro SW Ventures
Blake Terreri Jeff Droege
JoshD Sol Distro
Chris Sheppard Matt Longo
Oil Haus Mellow Extracts
William Waldrop Nick Rohan
EVIO Labs Expando Products
Paul Jacobsen Perry Srey
Aureus Leaf Concepts
Daniel Abrahami Peter Ishak
TEVE Distillate Co
Mehran Moghaddam Clay Tanner
Nature’s Market California Leaf Company
Kandice Hawes Nic Deangelo
OC NORML Property Owner 18k sf
Wes Eder
Shelflife Distributing
This initiative and the above requests are also supported by the Cannabis Chamber of Commerce:
Cannabis Industry Letter to The City of Costa Mesa
November 11, 2019 5 | Page
Measure X: November 2016 – People voted 54%
“You cannot Manage what you do not Measure” – Peter Drucker
TOTAL : $259,046.38
Source: Multiple Public Records Requests