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Orozco, Norma <br />From: Materia Medica < <br />Sent: Tuesday, June 04, 2019 1:16 PM <br />To: eComment <br />Subject: Tuesday, June 4, 2019 - Item#75F. Cannabis testing lab <br />75F. PUBLIC HEARING - ORDINANCE AMENDMENT NO. 2019-01 TO ADD TO AND AMEND <br />CERTAIN SECTIONS OF CHAPTER 21 OF THE SANTA ANA MUNICIPAL CODE TO ALLOW <br />VERTICAL AND HORIZONTAL INTEGRATION OF CANNABIS BUSINESSES; UPDATING <br />PROCEDURAL STANDARDS AND REQUIREMENTS RELATING TO OWNERSHIP TRANSFERS, <br />SECURITY DEPOSITS, AND VARIOUS ADMINISTRATIVE PROCESSES; AND REDUCING <br />CANNABIS TESTING TAXES TO TWO PERCENT OF GROSS RECEIPTS {STRATEGIC PLAN NOS. 3, <br />2; 3, 3; 3, 5; 4, 3) - Finance and Management Services Agency; and Planning and Building Agency - Legal <br />Notice published in the Orange County Reporter May 24, 2019 and May 31, 2019. <br />To whom it may concern, <br />I am writing in support of item#75F of today's meeting topics, specifically regarding reducing cannabis testing <br />taxes to two percent of gross receipts. It is well known that testing labs require high capital invest due to <br />equipment costs and qualified chemist salaries. At the same time, testing labs are under significant pressure to <br />keep their invoices low, which means it could be years before a lab sees a return on their initial investment. <br />Lowering taxes on labs at least gives growing laboratories a chance to retain needed funds for continued <br />operation, capital investment, and loan repayment. <br />It is no secret that potency results are an important factor for retailers/distributors to consider due to consumer <br />preferences. This problem has been partially addressed at the state level by barring businesses from "shopping <br />around" testing laboratories to maximize their potency figures on regulatory compliance batches. Again, this <br />scenario assumes all retail cannabis falls under BCC regulation when that is clearly not the case, since black- <br />market sales are still a big problem in California. Cannabis labs are uniquely positioned as potential bottleneck <br />for the market yet smaller labs continue to face many challenges to survive in the industry when it is easy <br />enough to turn to serve other industries —the longer this remains an issue there will be greater problems for the <br />industry in the future. We applaud the City for considering alleviating at least some of those pressures on testing <br />labs. <br />Respectfully, <br />Victoria <br />Lab Manager <br />Materia Medica Laboratories, Inc. <br />Located in Santa Ana, CA <br /> <br /> <br />